IR 05000348/2015301
| ML15344A292 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/10/2015 |
| From: | Gerald Mccoy Division of Reactor Safety II |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| 50-348/15-301, 50-364/15-301 | |
| Download: ML15344A292 (12) | |
Text
December 10, 2015
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC EXAMINATION REPORT 05000348/2015301 AND 05000364/2015301
Dear Mrs. Gayheart:
During the period October 5-13, 2015, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate Joseph M. Farley Nuclear Plant. At the conclusion of the tests, the examiners discussed preliminary findings related to the operating tests and the written examination submittal with those members of your staff identified in the enclosed report. The written examination was administered by your staff on October 20, 2015.
Seven Reactor Operator (RO) and five Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO applicant failed the written examination.
There were two post-administration comments concerning the written examination. These comments, and the NRC resolution of these comments, are summarized in Enclosure 2.
A Simulator Fidelity Report is included in this report as Enclosure 3.
The initial examination submittal was within the range of acceptability expected for a proposed examination. All examination changes agreed upon between the NRC and your staff were made according to NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 10.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm.adams.html (the Public Electronic Reading Room). If you have any questions concerning this letter, please contact me at (404) 997-4551.
Sincerely,
/RA: Eugene F. Guthrie for/
Gerald J. McCoy, Chief
Operations Branch 1
Division of Reactor Safety
Docket Nos: 50-348 and 50-364 License Nos: NPF-2 and NPF-8
Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
REGION II==
Docket No.:
05000348, 05000364
License No.:
Report No.:
05000348/2015301 AND 05000364/2015301
Licensee:
Southern Nuclear Company (SNC), LLC
Facility:
Joseph M. Farley Nuclear Plant
Location:
Ashford, AL
Dates:
Operating Test - October 5-13, 2015
Written Examination - October 20, 2015
Examiners:
D. Lanyi, Chief Examiner, Senior Operations Engineer
M. Bielby, Senior Operations Engineer, Region III
L. Vick, Reactor Engineer (Examiner)
Approved by:
Gerald J. McCoy, Chief
Operations Branch 1
Division of Reactor Safety
SUMMARY
ER 05000348/2015301 and 05000364/2015301; operating test October 5-13, 2015 & written exam October 20, 2015; Joseph M. Farley Nuclear Plant; Units 1 and 2 Operator License Examinations.
Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in accordance with the guidelines in Revision 10, of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors." This examination implemented the operator licensing requirements identified in 10 CFR §55.41, §55.43, and §55.45, as applicable.
Members of the Farley Nuclear Plant staff developed both the operating tests and the written examination. The initial operating test, written Reactor Operator (RO) examination, and written Senior Reactor Operator (SRO) examination submittals met the quality guidelines contained in NUREG-1021.
The NRC administered the operating tests during the period October 5-13, 2015. Members of the Farley Nuclear Plant training staff administered the written examination on October 20, 2015. All seven RO and five of the six SRO applicants passed both the operating test and written examination. Twelve applicants were issued licenses commensurate with the level of examination administered.
There were two post-examination comments.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Operator Licensing Examinations
a. Inspection Scope
The NRC evaluated the submitted operating test by combining the scenario events and JPMs in order to determine the percentage of submitted test items that required replacement or significant modification. The NRC also evaluated the submitted written examination questions (Reactor Operator and Senior Reactor Operator questions considered separately) in order to determine the percentage of submitted questions that required replacement or significant modification, or that clearly did not conform with the intent of the approved knowledge and ability (K/A) statement. Any questions that were deleted during the grading process, or for which the answer key had to be changed, were also included in the count of unacceptable questions. The percentage of submitted test items that were unacceptable was compared to the acceptance criteria of NUREG-1021, Operator Licensing Standards for Power Reactors.
The NRC reviewed the licensees examination security measures while preparing and administering the examinations in order to ensure compliance with 10 CFR §55.49, Integrity of examinations and tests.
The NRC administered the operating tests during the period October 5-13, 2015. The NRC examiners evaluated seven Reactor Operator (RO) and six Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. Members of the Farley Nuclear Plant training staff administered the written examination on October 20, 2015. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Farley Nuclear Plant, met the requirements specified in 10 CFR Part 55, Operators Licenses.
The NRC evaluated the performance or fidelity of the simulation facility during the preparation and conduct of the operating tests.
b. Findings
No findings were identified.
The NRC developed the written examination sample plan outline. Members of the Farley Nuclear Plant training staff developed both the operating tests and the written examination. All examination material was developed in accordance with the guidelines contained in Revision 10 of NUREG-1021. The NRC examination team reviewed the proposed examination. Examination changes agreed upon between the NRC and the licensee were made per NUREG-1021 and incorporated into the final version of the examination materials.
Using NUREG-1021, the NRC determined that the licensees initial examination submittal was within the range of acceptability expected for a proposed examination.
Seven RO applicants and five SRO applicants passed both the operating test and written examination. One SRO applicant passed the operating test, but did not pass the written examination. Seven RO applicants and five SRO applicants were issued licenses.
Copies of all individual examination reports were sent to the facility Training Manager for evaluation of weaknesses and determination of appropriate remedial training.
The licensee submitted two post-examination comments concerning the written examination. A copy of the final written examination and answer key, with all changes incorporated, and the licensees post-examination comments may be accessed not earlier than October 15, 2017, in the ADAMS system (ADAMS Accession Number(s)
ML15316A129, ML15316A134, and ML15316A144.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On October 12, 2015 the NRC examination team discussed generic issues associated with the operating test with Cheryl Gayheart, Site Vice-President, and members of the Farley Nuclear Plant staff. The examiners asked the licensee if any of the examination material was proprietary, or if any of the examination material received should be withheld from public disclosure. No proprietary information was identified. No information was identified that required withholding from public disclosure.
KEY POINTS OF CONTACT
Licensee personnel
C. Gayheart Site Vice-President J. Hutto
Plant Manager S. Henry
Operations Director B. Reed
Training Director B. Taylor
Regulatory Affairs Manager D. McKinney Corporate Regulatory Affairs Manager G. Ohmstead Corporate Training D. Reed
Engineering Programs Manager R. Godwin
Training R. Odom
Training D. Williams
Training B. Thornton Training G. Bell
Licensing Supervisor J. McLean
Licensing Engineer J. Collier
Licensing Engineer
NRC personnel
P. Niebaum Senior Resident Inspector K. Miller
Resident Inspector
FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS
A complete text of the licensees post-examination comments can be found in ADAMS under
Accession Number ML15316A144.
Item
Question 79, K/A 007EA2.03
Comment
The second part of the question asked what the bases was for maintaining the P-4 interlock
operable. Multiple applicants contended that both answers A and C could be correct. Damage
to the Main Steam lines and Safety valves due to steam generator (SG) overfill is not
specifically called out in the BASES summary for P-4, but P-4 is mentioned as performing a seal
in function for P-14 in the BASES for P-14. The P-14 BASES clearly states that it helps to
prevent damage to Main Steam Lines and Safety valves due to SG overfill.
The licensee disagreed. They stated that P-4 seals in P-14 to prevent inadvertent addition of
feed water to a faulted SG to prevent excessive cooldown and excessive Containment
Pressure. This supports the P-4 BASES. The P-4 BASES has no discussion of P-4 being
OPERABLE to prevent damage to Main Steam Lines and Safeties due to SG overfill.
NRC Resolution
The licensees recommendation was accepted
According to the basis document, P-4 exists to avert or reduce continued cooldown of the
Reactor Coolant System (RCS) following a reactor trip. Excessive cooldown of the RCS
following a reactor trip would cause insertion of positive reactivity with a subsequent increase in
generated power. Addition of feedwater to a steam generator associated with a steam line or
feedline break could result in excessive containment building pressure. The P-4 bases does not
discuss steam generator overfill at all. Additionally, P-4 is not required to be operable in order
for P-14 to perform its function.
The applicants recommendation was rejected. No changes have been made to the answer
key.
Item
Question 92, K/A G2.2.13
Comment
The question asked who had the authority to release a tagout if the Work Document Holder was
not on site and was unable to be contacted.
Several applicants stated that there was no correct answer since all conditions for signing off
the Work Document Holder were not met. They contended that no one can sign off the Work
Document Holder based on the conditions in the stem.
The Facility agreed. They stated that the question appeared faulted based on the student
feedback.
The exam team developed and validated this question with the intent that the question
ask which individual has the authority to sign off a Work Document Holder from a
tagout when he is offsite and unavailable. Based on validator feedback and efforts to
clarify the question this was the final product:
A tagout is required to be cleared during night shift and the Work
Document Holder is not on site and cannot be contacted to gain their
approval.
Per NMP-AD-003, Equipment Clearance and Tagging, which one of
the following can sign off the Work Document Holder?
A. Shift Manager
B. Operations Director
C. Maintenance Director
D. Maintenance Manager
Answer choice A, the Shift Manager was selected as the correct answer.
During post exam feedback, some applicants stated that based on the question asked, there is
no correct answer. Since all the requirements of NMP-AD-003 were not met, no one could sign
off the Work Document Holder. NMP-AD-003 has 3 requirements for the Shift Manager to be
able to sign off the Work Document Holder, and only 2 of the requirements were listed in the
stem. It was not stated in the stem that A knowledgeable individual (department supervisor)
has conducted a check of the job and determined the release will not be detrimental to the plant
or personnel. This knowledgeable individual would normally be someone from the
maintenance department who had in depth knowledge of the work in progress that required the
tagout. The Maintenance Director answer choice was chosen once, and the Maintenance
Manager was chosen once.
Although the intent of the question was to ask which individual has the authority to sign off a
Work Document Holder from a tagout when he is offsite and unavailable, the question is asking
which one of the following can sign off the Work Document Holder. For the conditions given,
no one can sign off the Work Document Holder since all the requirements are not met.
NUREG-1021, Appendix B page 4 of 26, c. states: State the question unambiguously, precisely,
and as concisely as possible, but provide all necessary information. The question lacks
adequate Stem Focus. All of the necessary information was not provided in the stem of the
question to answer the question.
NUREG-1021, Appendix E, page 2 of 6, step 7 states: When answering a question, do not
make assumptions regarding conditions that are not specified in the question unless they occur
as a consequence of other conditions that are stated in the question. Similarly, you should
assume that no operator actions have been taken, unless the stem of the question or the
answer choices specifically state otherwise.
The third requirement of NMP-AD-003 was not stated in the stem and could not be assumed to
be met, therefore no correct answer exists.
NRC Resolution
The licensees recommendation was rejected
The question specifically asked per NMP-AD-003, who could sign off the Work Document
Holder. Normally, only the Work Document Holder is authorized to sign himself or herself off of
a tagout. Therefore, the stem of the question was written to ensure that it was clear that that
person was not available in order to test the section on alternate release authorization, not to
contain an all-inclusive list of conditions. Appendix E of NUREG-1021 (B.7) states that the
applicants should not make assumptions regarding questions that are not specified in the
question unless they occur as a consequence of other conditions that are stated in the question.
In this case, if the utility needed to remove this tagout at night and the Work Document Holder
was not available, then the consequence of that condition would be to complete whatever
actions would be required to perform that task within procedural allowances. The staff would be
capable of contacting an appropriate supervisor to conduct a job check to determine that the
release would not be detrimental to the plant. Therefore this requirement, even though not
stated, could be assumed to be a consequence of the condition.
The procedure clearly stated that only one person, besides the Work Document Holder, could
be authorized to release a tagout. That is the Shift Manager. One of the applicants chose the
Maintenance Director and the other chose the Maintenance Manager, clearly indicating that
they thought this authority resided in the Maintenance Department. Since the authority to
release the tagout rests with only the Shift Manager under the conditions given, adding the third
condition to the stem of the question would not have added any information that would have
driven the applicants to answer any differently.
Additionally, no questions about the initial conditions of this question were asked during the
exam. Therefore, it is apparent that there was no confusion among the applicants as to what
the question was asking. Nor was any applicant confused due to there being no correct
answers.
The licensees recommendation was rejected. No changes have been made to the answer key.
SIMULATOR FIDELITY REPORT
Facility Licensee: Joseph M. Farley Nuclear Plant
Facility Docket No.: 05000348, 05000364
Operating Test Administered: October 5-13, 2015
This form is to be used only to report observations. These observations do not constitute audit
or inspection findings and, without further verification and review in accordance with Inspection
Procedure 71111.11 are not indicative of noncompliance with 10 CFR 55.46. Further follow-up
of these observations will be performed during the biennial Inspection Procedure 71111.11 for
appropriate disposition. No licensee action is required in response to these observations.
While conducting the simulator portion of the operating test, examiners observed the following:
Item
Description
1.
Currently, the Farley Unit 1 plant-referenced simulator has
installed Unit 2 turbine controls (DEH) and instrumentation on the
panel console instead of Unit 1 turbine controls (Ovation). The
licensee maintains plug in controls to mimic the Unit 1 Ovation
control system. When used to simulate Unit 1, a separate
keyboard is installed over the DEH keyboard, and two indicators
are masked. This reproduces the functionality of the current Unit
Control Room layout, however it does not precisely mimic the
Unit 1 Control Room panel.
Farley is committed to ANSI/ANS-3.5-1985, Nuclear Power Plant
Simulators for Use in Operator Training which is accepted and
endorsed by NRCs Regulatory Guide 1.149, Revision 1, Nuclear
Power Plant Simulation Facilities for Use in Operator License
Examinations with exceptions/clarifications.
RG 1.149, Rev 1, Section C, Regulatory Position, discusses,
among other things, minimum performance and configuration
criteria for a simulator, for comparing a simulator to its reference
plant, and for upgrading simulators to reflect changes to reference
plant response or control room configuration. Item 4 discusses
standard Section 5.2, Simulator Update Design Data,
requirements and time constraints
ANSI/ANS-3.5-1985, Section 3.2, Simulator Environment,
discusses the requirements pertaining to the degree of panel
simulation, control on panels, and control room
environment...The controls on panels and consoles that are
simulated shall be designed to duplicate the size, shape, color,
and configuration of the functionally simulated hardware of the
reference plantAll functionally simulated and visually simulated
hardware shall replicate that in the reference plant control room.
Section 5.3, Simulator Modifications states The simulator
shall be modified as required within 12 months following the
annual establishment of the simulator update design data
referenced in 5.2 (Simulator Update Design Data).
CFR 55.46 (c)(2)(ii) requires that simulator fidelity has been
demonstrated so that significant control manipulations are
completed without procedural exceptions, simulator performance
exceptions, or deviation from the approved training scenario
sequence. Based upon observation of the operating exam, it
appears that this temporary simulator design can accomplish this.
Furthermore, 10 CFR55.59 (c)(3)(v) states: a simulator may be
used in meeting the requirements of paragraphs (c)(3)(i) and (3)(ii)
of this section, if it reproduces the general operating
characteristics of the facility involved and the arrangement of the
instrumentation and controls of the simulator is similar to that of
the facility involved.