IR 05000348/2033001
| ML23227A051 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/14/2023 |
| From: | Tom Stephen Division of Reactor Safety II |
| To: | Erb D Southern Nuclear Operating Co |
| References | |
| 50-348/23-301, 50-364/23-301 50-348/OL-23, 50-364/OL-23 | |
| Download: ML23227A051 (1) | |
Text
August 14, 2023
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000348/2023301 and 05000364/2023301
Dear Mr. Erb:
During the period May 22 - 31, 2023, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate the Joseph M. Farley Nuclear Plant. At the conclusion of the operating 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 June 6, 2023.
Six Reactor Operator (RO) and ten Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO applicant passed the operating test but 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. NRC regional management considered the impacts of the post-examination comment resolution on the evaluation that the written examinations met the expected quality standards. 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 12.
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) 997-4703.
Sincerely,
/RA/
Thomas A. Stephen, Chief Operations Branch 1 Division of Reactor Safety Docket Nos.: 50-348, 50-364 License Nos.: NPF-2, NPF-8
Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
REGION II==
Examination Report Docket No.: 05000348, 05000364 License No.: NPF-2, NPF-8 Report No.: 05000348/2023301 and 05000364/2023301 Enterprise Identifier: L-2023-OLL-0027 Licensee: Southern Nuclear Company (SNC)
Facility: Joseph M. Farley Nuclear Plant Location: Columbia, AL Dates: Operating Test - May 22 - 31, 2023 Written Examination - June 6, 2023 Examiners: M. Meeks, Chief Examiner, Senior Operations Engineer D. Lanyi, Senior Operations Engineer A. Goldau, Operations Engineer S. Battenfield, Operations Engineer P. Meier, Senior Resident Inspector (examiner in training)
Approved by: Thomas A. Stephen, Chief Operations Branch 1 Division of Reactor Safety Enclosure 1
SUMMARY
ER 05000348/2023301, 05000364/2023301; May 22 - 31, 2023 & June 6, 2023; Joseph M.
Farley Nuclear Plant; Operator License Examinations.
Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in accordance with the guidelines in Revision 12, 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 Joseph M. Farley Nuclear Plant staff developed both the operating tests and the written examination. The initial operating test, written RO examination, and written SRO examination submittals met the quality guidelines contained in NUREG-1021. NRC regional management considered the impacts of the post-examination comment resolution on the evaluation that the written examinations met the expected quality standards.
The NRC administered the operating tests during the period May 22 - 31, 2023. Members of the Joseph M. Farley training staff administered the written examination on June 6, 2023. Six Reactor Operator (RO) and ten Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO applicant passed the operating test, but failed the written examination. Sixteen 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 (RO and SRO 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 performed an audit of license applications during the preparatory site visit in order to confirm that they accurately reflected the subject applicants qualifications in accordance with NUREG-1021.
The NRC administered the operating tests during the period May 22 - 31, 2023. The NRC examiners evaluated six Reactor Operator (RO) and eleven 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 June 6, 2023. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Joseph M. 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 Joseph M. Farley training staff developed both the operating tests and the written examination. All examination material was developed in accordance with the guidelines contained in Revision 12, 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.
The NRC determined, using NUREG-1021, that the licensees initial examination submittal was within the range of acceptability expected for a proposed examination.
NRC regional management considered the impacts of the post-examination comment resolution on the evaluation that the written examinations met the expected quality standards.
As a result of the post-examination comment resolution detailed in Enclosure 2 of this report, two SRO-only questions were deleted in accordance with the guidance of NUREG-1021, section ES-4.4, paragraph C.3.e. NUREG-1021 section ES-4.4, paragraph D.2 contained the following additional requirement for NRC regional management review:
If seven or more of the questions on an RO examination and/or two or more on a [sic] SRO only examination are deleted during the grading process, evaluate the remainder of the examination to ensure that it still satisfies the test outline sampling requirements in ES-4.1, Developing Written Examination Outlines. The NRC regional office must consult with the NRR operator licensing program office if the validity of the examination is in question.
In accordance with this requirement, the NRC examiners and regional management reviewed the post-examination changes against the test outline sampling requirements in ES-4.1. The review concluded that the amended SRO-only written examination and sample plan outline remained valid, and that consultation with the NRR operator licensing program office was not required.
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, may be accessed not earlier than December 9, 2025, in the ADAMS system (ADAMS Accession Number(s) ML23221A322 and ML23221A326).
4OA6 Meetings, Including Exit
Exit Meeting Summary
On May 31, 2023, the NRC examination team discussed generic issues associated with the operating test with D. Cottea, Site Projects Senior Manager, and other members of the Joseph M. Farley staff. The examiners asked the licensee if any of the examination material was proprietary. The information that the licensee identified as proprietary was handled in a manner consistent with NRC and licensee guidelines for this type of information. On July 28, 2023, the NRC examination team conducted a final exit meeting with A. Renaud, Site Training Director, and other members of the Joseph M.
Farley staff to discuss the examination results and provide the licensing details KEY POINTS OF CONTACT Licensee personnel J. Angel, Maintenance Director D. Cottea, Site Projects Senior Manager T. Driggers, Operations Training Manager A. Gray, Engineering Director A. Renaud, Site Training Director W. Sorrell, Operations Support Manager M. Stanley, Operations Director D. Stiles, Training Corporate Functional Area Manager G. Surber, Licensing Manager D. Williams, Regulatory Affairs Manager NRC personnel P. Meier, Senior 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 ML23221A329.
Item
Question 89, K/A 062A2.20 (SRO only)
Applicant Comment
[N.B. The applicant began by listing the text of Question 89 and the initial keyed answer of C]
Comment:
Since there was no information given to identify the reason for the failure of 2B DG to start and
the output breaker close to automatically, an assumption must be made on the failed
component to determine whether the breaker would automatically close.
1. Per drawing D207032 (LOGIC DIAGRAM DIESEL 2B AUTO START & LOADING) if UV
relays do not sense the undervoltage condition on the 2G Bus, the 2B DG will neither
automatically start nor will the output breaker automatically close. Once the DG is
started from the EPB, the output breaker would have to be closed manually per ECP-
0.0.
2. Per drawing D207654 (ELEMENTRY DIAGRAM SEQUENCER B2G LOAD SHEDDING
CIRCUIT) and D202778 (ELEMENTARY DIAGRAM - DIESEL GEN 2B START, STOP
&SHUTDOWN) if relay 27XG failed, the start signal would not be sent to the 2B DG, but
would not affect the manual start from the EPB. Once started from the EPB per ECP-
0.0, as shown on D207032, the LOSP sequencer would then close the 2B DG output
breaker automatically.
3. Per FNP-2-ECP-0.0 Step 5.12 checks DG08 closed for unit two and if not, you go to the
RNO column of the procedure and close the breaker. The procedure is written for
situations where the breaker may not automatically close and gives guidance for the
operator to manually close the output breaker to restore power to the bus.
References:
- D207032 (LOGIC DIAGRAM DIESEL 2B AUTO START & LOADING)
- D207654 (ELEMENTRY DIAGRAM SEQUENCER B2G LOAD SHEDDING
CIRCUIT)
- D202778 (ELEMENTARY DIAGRAM - DIESEL GEN 2B START, STOP
&SHUTDOWN)
- FNP-2-ECP-0.0 LOSS OF ALL AC POWER
Recommendation: Remove question 89 from the SRO Written Exam.
Facility Licensee Position
FNP agrees with the comment and recommends that this question be removed from the exam
based on ES-4.4 C.3.e. The question does not provide the plant conditions necessary to
determine the failure mechanism that caused the diesel to not automatically start and re-
energize the B train class 1E AC bus.
NUREG-1021, ES-4.4, C.3.c, supports a post exam change when a question does not provide
all necessary information.
Post exam change in accordance with ES-4.4 is clearly justified given the fact that the stem did
not provide the necessary information to determine the failure mode of the diesel generator and
associated output breaker.
NRC Resolution
The licensees recommendation was accepted.
During written exam administration on June 6, 2023, there was one applicant question on
Question 89 that was only related to the second part of the question (procedural selection), and
a change was made to the second-part question stem which was communicated to all SRO
applicants. This change to Question 89 during exam administration had no impact on the post-
examination comment under review, and no other questions were asked related to Question 89
during exam administration.
1. Technical Assessment:
The NRC agreed that the proposed/as-given question stem did not provide enough necessary
information to determine or elicit the correct answer without having to make unwarranted
assumptions that were not supported by any other information provided for the question.
In accordance with the intent of this question, the applicant was presented with a failure of the
2B DG to automatically start and load as designed. This plant condition was implied by the fact
that the question stem stated that a loss of all AC power has occurred on Unit 2; that is, a
station blackout condition and entry into procedure ECP-0.0, Loss of All AC Power. The
applicant is then given the information that at a time of 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> (10:00 AM), operators were
able to start the 2B DG from the EPB and restore power to the 2G, 2L, and 2J electrical
buses. Given this sequence of events, the first part of the question, which was the only part of
this question involved in the post-examination comment, then asked the applicant to determine
if the 2B DG output breaker would have closed automatically at time 1000, or if the 2B DG
output breaker would have to be manually closed. Because the question stated that power was
restored to the electrical buses, it was a logical true condition for this question that the 2B DG
output breaker was closed.
During question development and validation, the examination team assumed that the failure of
the 2B DG to automatically start and load as designed was caused by an (admittedly
unstated/unspecified) failure of the 2B DG automatic start logic or component therein. For
example, as stated by the applicant contention, if relay 27XG failed, the start signal would
not be sent to the 2B DG, but would not affect the manual start from the EPB. Once started
from the EPB per ECP-0.0, as shown on D207032, the LOSP sequencer would then close the 2B
DG output breaker automatically. The NRC agreed with the applicants statement; if this relay
had been the cause of the 2B DG failure, it would be technically correct that the 2B DG output
breaker would have automatically closed given the plant conditions listed in the Question 89 stem.
Other hypothetical failure modes where this condition (breaker automatically closed) was
technically correct could be postulated as well.
However, it is also technically accurate to state that if there was a different cause of the 2B DG
failure to automatically start, the breaker would have to be closed by manual operator actions.
For example, as stated by the applicant contention, if UV relays do not sense the undervoltage
condition on the 2G Bus, the 2B DG will neither automatically start nor will the output breaker
automatically close. Once the DG is started from the EPB, the output breaker would have to be
closed manually per ECP-0.0. The NRC also agreed with this applicant statement; specifically,
there are other causes or modes of failure that would prevent the 2B DG output breaker from
automatically closing, once the 2B DG had been manually started, and therefore manual action
would be required to close the output breaker. Other hypothetical failure modes where this
condition (breaker manually closed) was technically correct could be postulated as well.
The NRC agreed that the question could have been improved by providing the specific failure
mechanism in the question stem during examination development and reviews.
Therefore, the NRC assessment concluded that there were technically correct and valid reasons
for the output breaker to have automatically closed, and there were also technically correct and
valid reasons for the output breaker to have to be closed via manual operator action.
2. Regulatory Assessment:
NUREG-1021, revision 12, section ES-4.4, paragraph C.3.c, stated the following requirements for
the types of errors that may result in changes to the examinations:
c. Despite the extensive reviews performed by both the NRC and the facility
licensee before examination administration, it is possible that errors may be
discovered only after an examination has been administered. The NRC will
consider examination changes for the following types of errors, if identified and
adequately justified by the facility licensee or an applicant:
-a question with an unclear stem that confused the applicants or did not provide
all the necessary information (to assist in determining whether an unclear stem
confused the applicants, closely evaluate any applicant questions asked during
the examination; also evaluate the question stem to determine whether the
information provided could reasonably result in the applicant misunderstanding
the intent of the question or the validity of the answer choices)
-unintended typographical errors in a question or on the answer key
-newly discovered technical information that supports a change in the answer
key -testing the wrong license level (RO versus SRO) or not linked to job
requirements.
Based on the above requirements, the NRC determined that SRO Question 89 provided
applicants with an unclear stem that did not provide all the necessary information to
determine one and only one correct answer. Therefore, the regulatory guidance supported a
further assessment as to how to correct the identified errors in Question 89.
NUREG-1021 revision 12, section ES-4.4, paragraph C.3.e provided additional guidance on how
to evaluate question errors that were identified post-examination administration as follows:
If a question is determined to have two correct answers, the NRC will accept
both answer options as correct. However, there cannot be two correct answers
if both answer options contain conflicting information. Conflicting information is
present when two answer options contain plant information that cannot be true
or exist at the same time. For example, if a part of an answer option states that
operators are required to insert a manual reactor scram and a part of another
answer states that a manual scram is not required, then the NRC will not
accept both answers as correct because a facility cannot have a manual scram
be both required and not required at the same time. The question will be
deleted.
For Question 89, it was a logical true condition that the 2B output breaker was closed; this was
implied by the statement in the stem that [electrical] power has been restored to the 2G, 2L,
and 2J Busses. The output breaker could only have been closed automatically, or closed
manually. Therefore, the question distractors could have been re-written to state closed
automatically and NOT closed automatically; and the logical psychometrics of the question
would not have been affected; conversely, the question distractors could have been re-written to
state was manually closed and was NOT manually closed, also without affecting the logical
psychometrics of the question. Therefore, the NRC concluded that the distractor choices
contained conflicting information; that is, using the above language from NUREG-1021, it was not
technically possible that the 2B DG output breaker was both closed automatically and was
manually closed at the same time.
Therefore, in accordance with the NUREG-1021 revision 12 guidance cited herein, the final NRC
assessment was that Question 89 was required to be deleted from the SRO only written
examination because there were two potentially correct answer options that contain[ed] plant
information that cannot be true or exist at the same time.
All SRO applicants were therefore graded on the SRO only portion of the written examination with
Questions 89 and 91 deleted.
Item
Question 91, K/A 076AA2.09 (SRO Only)
Applicant Comment
[N.B. The applicant began by listing the text of Question 91 and the initial keyed answer of C]
The EAL Basis states that SU3 is applicable in Mode 3 which is the mode you are in for the
question above per NMP-EP-141-001, Farley Emergency Action Level and Basis.
Per NMP-EP-141-001, it defines applicable as when the EAL applies for a given mode, which
is represented in the MODE APPLICABILITY MATRIX on page 8 of NMP-EP-141-001
The dictionary definition of applicable per (Webster New Collegiate Dictionary Copyright 1977
by G. & C. Merriam Co.) IS capable of or suitable for being applied. Capable of or suitable
for being applied also supports the challenge that SU3 is applicable, and Choice B is correct
vice Choice D.
NMP-EP-141-001 Section 4.2 states:
If an EAL has been met or exceeded, the IC is met and the associated ECL (Emergency
Classification level) is declared in accordance with plant procedures.
Based on the question asking if SU3 is applicable versus asking if you met or exceeded the
EAL threshold for classification, answer B is the correct answer since it is applicable in Modes
1-4. Answer choice D is not correct since SU3 is applicable in the current mode of operation. If
the question was intended to ask if a EAL threshold is met it should have stated:
Per NMP-EP-141-001-F01, Farley - Hot Initiating Condition Matrix, SU3 threshold
criteria__(has)(has not)__ been exceeded.
Recommendation: Change the key for the SRO written exam for question 91. The key should
be changed to reflect that B is correct based on the question asking if SU3 is applicable versus
asking if you met or exceeded the EAL threshold for classification. If the question was intended
to ask if a EAL threshold is met it should have stated:
Per NMP-EP-141-001-F01, Farley - Hot Initiating Condition Matrix, SU3 threshold criteria
(has) or (has not) been exceeded.
Facility Licensee Position
Based on the question asking Per NMP-EP-141-001-F01, Farley - Hot Initiating Condition
Matrix, SU3 __(is) or (is not)__ applicable, the correct answer should be B. The word
applicable as outlined in NMP-EP-141-001 pertains to when a specific EAL applies for a given
plant mode. From the stem of the question, on May 2 at 22:00 the plant is in Mode 3 and EAL
SU3 is applicable in modes 1-4; therefore, the correct answer should be B instead of
- D.
NUREG-1021, ES-4.4, C.3.c, supports a post exam change when a questions answer is
incorrect based on the stem of the question.
A post exam change in accordance with ES-4.4 is clearly justified given the question asked in
the stem whether a specific EAL was applicable instead of whether a specific EAL was met or
exceeded. It is clear that based on the stem of the question, answer B is correct.
NRC Resolution
The licensees recommendation was partially accepted.
During written exam administration on June 6, 2023, for question 91 (the applicant mis-labeled it
as question 90 on the provided applicant question sheet) one applicant asked, By applicable
given current conditions is this asking if mode 3 is one of the modes of applicability? At the
time, the Farley examination team and NRC examiners discussed this question via phone and
the parties agreed that the question was clear enough as written that the applicant should have
been able to determine that the question was not asking for modes of applicability. The single
applicant who asked this question was provided with a directing cue to answer the question
with the information provided; and this particular applicant query and response was not
provided to any other SRO applicant. No other SRO applicant asked any additional questions
concerning SRO #91 during the exam administration. The applicant who submitted the question
during the exam administration was not the same applicant who submitted this post-examination
comment.
1. Technical Assessment:
The contention essentially becomes an exercise in determining the technically correct usage of
the word applicable as it pertains to the Farley Nuclear Plant Emergency Plan/Emergency
Action Level (EAL) program, as implemented for this class of applicants. The applicant and
facility position cited herein essentially state that when used for an EAL declaration, the word
applicable means as related to the mode of applicability defined in Farley procedure NMP-
EP-141-001, Farley Emergency Action Levels and Basis, and was ONLY used to define mode
of applicability for the various EAL conditions listed in the Matrix. The NRC agreed that mode
of applicability is one way that the Farley Nuclear Plant used the term applicable as related to
EALs.
However, note that this examination question was proposed and developed by the facility
licensee. During question development, the facility licensee examination team asserted that the
term applicable as used in Question 91 could be used in the sense of listed conditions met or
exceeded such that EAL declaration was required. During the exam review process, Question
was validated by multiple currently-licensed Farley Nuclear Plant SROs. If the common
usage at Farley for the word applicable for EALs was to only mean as related to the mode of
applicability, the validators would have insisted on changing the answer key and identifying the
difference in usage. During exam administration, the facility representatives and the NRC
examiners believed that the usage of the term applicable was clear enough, such that a
change to the question stem during exam administration was not warranted.
Furthermore, note that the as-given question stem and provided references made any
determination of whether or not the SU3 EAL was in the mode of applicability trivial. That is,
the question stem explicitly stated that the plant was in MODE 3, and the provided SU3 EAL
box from the EAL Matrix procedure explicitly listed MODES 1, 2, 3, and 4 as the modes of
applicability above the listed SU3 conditions. In other words, if one believed that applicable
referred to mode of applicability, it would be a direct look-up/mental level-of-difficulty less than
one to relate the question stem statement of MODE 3 with the MODE 3 box above the SU3
condition. Therefore, if the applicant contention was widely held, one would expect that every
SRO applicant who took this question would answer that that the SU3 EAL is applicable, or
choose answer distractors A or
- B. However, this is not the case; in fact, five of the eleven
(45%) applicants chose answer distractors C or D (asserting SU3 is NOT applicable), which
shows that it was not universally held that applicable was only defined as as related to the
mode of applicability with the applicants who took the examination.
All that being said, the above NRC analysis is only of secondary value; it is more important to
establish how the official plant reference documents related to the Emergency Plan/EALs use
the term applicable. The NRC assessed this question as summarized in the following
discussions.
First, as stated above, the NRC agreed with the applicant and facility that Farley procedures
support the definition of applicable as meaning as related to mode of applicability. However,
the same procedure (NMP-EP-141-001) also supported a usage of applicable that has other
meanings. For example, section 4.1 of NMP-EP-141-001 stated the following:
For ICs and EALs that have a stipulated time duration, the emergency
director will not wait until the applicable time has elapsed, but will declare the
event as soon as it is determined that the condition has exceeded, or will
likely exceed, the applicable time. [emphasis added] If an ongoing
radiological release is detected and the release start time is unknown, it will
be assumed that the release duration specified in the IC/EAL has been
exceeded, absent data to the contrary.
In the above quotation, the word applicable does not refer to mode of applicability, but to a
time duration that may be specified in the EAL conditions. Furthermore, the basis description of
EAL RA3 in NMP-EP-141-001 included the following:
This IC addresses elevated radiation levels in certain plant rooms or areas
sufficient to preclude or impede personnel from performing actions necessary
to maintain normal plant operation, or to perform a normal plant cooldown
and shutdown. As such, it represents an actual or potential substantial
degradation of the level of plant safety. The emergency director should
consider the cause of the increased radiation levels and determine if another
IC may be applicable. [emphasis added]
For this quotation, the word applicable refers to increased radiation levels, a provided
condition of the EAL in question, and not the mode of applicability of the particular EAL. NMP-
EP-141-001 provided another example of applicable referring to conditions in its discussion of
EAL RU2. For RU2, the initiating condition is listed as UNPLANNED loss of water level above
irradiated fuel, and the basis description included the following:
The effects of planned evolutions will be considered. For example, a refueling
bridge area radiation monitor reading may increase due to planned evolutions
such as lifting of the reactor vessel head or movement of a fuel assembly. Note
that this EAL is applicable only in cases where the elevated reading is due to
an UNPLANNED loss of water level. [emphasis added]
Again, for this example EAL, the term applicable is being used to describe the EAL
conditions, and was not related to mode of applicability. In another example, for EAL CA3,
procedure NMP-EP-141-001 contained a NOTE that stated: If an RCS heat removal system is
in operation within this time frame and RCS temperature is being reduced, the EAL is not
applicable. This NOTE provided another example where the term applicable is being used in
reference to given conditions that must be evaluated in order to declare, or not declare, the
individual EALand not in any way related to the mode of applicability of the individual EAL. To
provide a final example, when discussing the basis of the RCS Barrier Thresholds, procedure
NMP-EP-141-001 stated the following:
This threshold is based on an UNISOLABLE RCS leak of sufficient size to
require an automatic or manual actuation of the Emergency Core Cooling
System (ECCS). This condition clearly represents a loss of the RCS Barrier.
This threshold is applicable to unidentified and pressure boundary leakage,
as well as identified leakage. It is also applicable to UNISOLABLE RCS
leakage through an interfacing system. The mass loss may be into any
location - inside containment, to the secondary-side (i.e., steam generator
tube leakage) or outside of containment. [emphasis added]
As before, the discussion of the RCS barrier is a discussion of conditions as stated in the EAL
description block(s), and not a discussion of the modes of applicability of the EALs. Aside from
the actual procedure of record (NMP-EP-141-001), the NRC also determined that the usage of
the word applicable was also not consistent in the training materials provided to the applicants.
Specifically, the Farley training document NMP-TR-209-F02, Southern Nuclear Company
LESSON PLAN Student Text for Emergency Declaration/Classification and Dose Assessment,
version 1.1, stated the following:
When evaluating an event for emergency declaration or upgrade in
classification, NMP-EP-141 requires determination of initiating plant mode. If
the initiating plant mode was 5, 6, or defueled, then go to the COLD IC/EAL
Matrix Evaluation Chart directly instead of Fission Product Barrier Matrix. If
the initiating plant condition was Modes 1-4, go to Fission Product Barrier
Matrix to determine which, if any, Fission Product Barriers are Lost or
potentially lost. Then, determine if FG1, FS1, FA1, or FU1 is the highest
applicable fission product barrier initiating condition (IC). [] There may be
more than one IC TV [threshold value] exceeded, but classify based on the
first TV met. This method ensures that the highest level of emergency
classification that applies is declared, and no unnecessary time is spent
evaluating ICs which are lower in priority to the highest applicable IC & TV.
[emphasis added]
This quotation from the training handout showed that the use of applicable could be used as to
refer to initiating conditions, not just Modes, as also shown above in the text of the actual plant
procedure NMP-EP-141-001. Consider, when the above text directed the operator to
determine if FG1, FS1, FA1, or FU1 is the highest applicable fission product barrier initiating
condition (IC), if highest applicable referred to the mode of applicability, then if the plant is in
MODE 1-4 you would be required to always declare FG1 (a General Emergency) because it is
applicable in MODEs 1-4.
Based on the above analysis, the NRC agreed with the applicant and facility licensee, and
determined that it was technically correct that the use of the word applicable could be used to
define as related to the mode of applicability. However, the NRC also determined that it was
technically correct that the word applicable was used for other definitions than mode of
applicability; including that applicable could be used in the sense of listed conditions met or
exceeded such that EAL declaration was required.
The NRC agreed that the question could have been improved by using a different set of words
instead of applicable that may have been a more precise way to specify the intent of the
question writers, such as whether or not the EAL conditions or threshold criteria were met or
exceeded.
However, during exam administration, the as-given question 91 stem, references, and
distractors did not provide the applicants with the additional information that would be needed to
determine if applicable should be used in the sense of mode of applicability, or if the word
applicable should be applied in the sense of listed conditions met or exceeded such that EAL
declaration was required, or some other undefined definition.
Therefore, the NRC assessment was that there were technically correct and valid reasons for
an applicant to determine that EAL SU3 IS applicable, and there were also technically correct
and valid reasons for the applicant to determine that EAL SU3 is NOT applicable.
2. Regulatory Assessment:
NUREG-1021, revision 12, section ES-4.4, paragraph C.3.c, stated the following requirements
for the types of errors that may result in changes to the examinations:
c. Despite the extensive reviews performed by both the NRC and the facility
licensee before examination administration, it is possible that errors may be
discovered only after an examination has been administered. The NRC will
consider examination changes for the following types of errors, if identified
and adequately justified by the facility licensee or an applicant:
-a question with an unclear stem that confused the applicants or did not
provide all the necessary information (to assist in determining whether an
unclear stem confused the applicants, closely evaluate any applicant
questions asked during the examination; also evaluate the question stem to
determine whether the information provided could reasonably result in the
applicant misunderstanding the intent of the question or the validity of the
answer choices)
-unintended typographical errors in a question or on the answer key
-newly discovered technical information that supports a change in the answer
key
-testing the wrong license level (RO versus SRO) or not linked to job
requirements
Based on the above requirements, the NRC determined that SRO Question 91 provided
applicants with an unclear stem that did not provide all the necessary information to
determine one and only one correct answer. Furthermore, at least one applicant was confused
about the usage of applicable during exam administration and asked a question to the proctors
and examination staff. Therefore, the regulatory guidance in effect supported a further
assessment as to how to correct the identified errors in Question 91.
NUREG-1021 revision 12, section ES-4.4, paragraph C.3.e provided additional guidance on
how to evaluate question errors that were identified post-examination administration as follows:
If a question is determined to have two correct answers, the NRC will accept
both answer options as correct. However, there cannot be two correct
answers if both answer options contain conflicting information. Conflicting
information is present when two answer options contain plant information that
cannot be true or exist at the same time. For example, if a part of an answer
option states that operators are required to insert a manual reactor scram and
a part of another answer states that a manual scram is not required, then the
NRC will not accept both answers as correct because a facility cannot have a
manual scram be both required and not required at the same time. The
question will be deleted.
For Question 91, if an applicant believed that applicable referred to mode of applicability,
then it was technically correct that EAL SU3 was applicable (answer choices A and B). On
the other hand, if an applicant believed that applicable referred to listed conditions met or
exceeded such that EAL declaration was required, then it was technically correct that EAL SU3
was not applicable. Therefore, the NRC concluded that the distractor choices contained
conflicting information; that is, using the above language from NUREG-1021, it was not
technically possible that EAL SU3 was both applicable, and not applicable, at the same time.
Therefore, in accordance with the NUREG-1021 revision 12 guidance cited herein, the final
NRC assessment was that Question 91 was required to be deleted from the SRO only written
examination, because there were two potentially correct answer options that contain[ed] plant
information that cannot be true or exist at the same time.
All SRO applicants were therefore graded on the SRO only portion of the written examination
with Questions 89 and 91 deleted.
SIMULATOR FIDELITY REPORT
Facility Licensee: Joseph M. Farley Nuclear Plant
Facility Docket No.: 05000348, 05000364
Operating Test Administered: May 22 - 31, 2023
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. No licensee
action is required in response to these observations.
No simulator fidelity or configuration issues were identified.
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