IR 05000397/2005301
| ML051930389 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 07/12/2005 |
| From: | Gody A Operations Branch IV |
| To: | Parrish J Energy Northwest |
| References | |
| ER-05-301 | |
| Download: ML051930389 (10) | |
Text
July 12, 2005
SUBJECT:
COLUMBIA GENERATING STATION - NRC RETAKE EXAMINATION REPORT 05000397/2005301
Dear Mr. Parrish:
On June 13, 2005, the U. S. Nuclear Regulatory Commission (NRC) written examination retake was completed at Columbia Generating Station. The enclosed report documents the examination findings, which were discussed on June 27, 2005, with Mr. Greg Knudson and other members of your staff.
The examination included the evaluation of two applicants for instant senior operator licenses.
The written examination was developed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9. The license examiner determined that both of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
During the examination development, the NRC identified one finding that was evaluated as having very low safety significance (Green). The NRC has also determined that a violation is associated with the finding. Consistent with Section VI.A of the Enforcement Policy, the violation is being treated as a non-cited violation because it has been entered into your corrective action program. The violation is described in the subject examination report. If you contest the violation or its significance, you should provide a response within 30 days of the date of this examination report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Columbia Generating Station facility.
Energy Northwest-2-In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Anthony T. Gody, Chief Operations Branch Division of Reactor Safety Docket: 50-397 License: NPF-21
Enclosure:
NRC Examination Report 05000397/2005301
REGION IV==
Docket:
50-397 License:
NPF-21 Report :
05000397/2005-301 Licensee:
Energy Northwest Facility:
Columbia Generating Station Location:
Richland, WA Dates:
June 13, 2005 Inspector:
M. S. Haire, Chief Examiner, Operations Branch Approved By:
Anthony T. Gody, Chief Operations Branch Division of Reactor Safety
-2-Enclosure
SUMMARY OF FINDINGS
ER 05000397/2005-301; 06/13/05; Columbia Generating Station; Retake Operator Licensing
Examination Report.
The NRC examiner evaluated the competency of two applicants for instant senior operator licenses at Columbia Generating Station. The facility licensee developed the examination using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9.
The written examination was administered by the facility to all applicants on June 13, 2005.
The examiner determined that both of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. One Green non-cited violation was identified. The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
Cornerstone: Not Applicable
- Green.
The NRC examiner identified a noncited violation of 10 CFR 55.49, for engaging in activities that, but for detection, would have affected the equitable and consistent administration of the examination. The licensee assigned its license examination author to also author training examinations for the license candidates. Such interactions between license examination developers and license candidates are prohibited by NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9. The licensee has documented this issue in Condition Report 2-05-01123.
The finding is more than minor because it could have compromised the integrity and discriminatory validity of the license examination. If the practice had gone undetected, it could have produced such overlap between the training examinations and the license examination that the ability of the license examination to adequately discriminate between applicants with acceptable overall plant knowledge and those with unacceptable overall plant knowledge would have been unacceptably reduced. The finding is of very low safety significance since it was detected before license examination administration and the license examination was modified to eliminate overlap with the training examination, thereby, ensuring that the license examination had discriminatory validity to support a licensing decision.(Section 4OA5)
Licensee-Identified Violations
None.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA5 Other Activities (Initial Operator License Examination)
1. Operator Knowledge and Performance
b. Examination Scope
This examination was a retake of the written examination from the September 2004 examination where both applicants passed the original operating examination, and, therefore, no portions of an operating examination were administered during this retake examination.
On June 13, 2005, the licensee administered the examination to both applicants. The licensee staff graded the examinations, analyzed the results, and presented their analysis to the NRC on June 15, 2005.
b. Findings
Both of the applicants passed the examination with a score of 82 percent.
Chapter ES-403 and Form ES-403-1 of NUREG 1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, require the licensee to analyze the validity of all written examination questions that were missed by half or more of the applicants.
The licensee conducted this analysis for 29 questions that met this criteria and submitted the analysis to the chief examiner on June 15, 2005. The analysis concluded that all 29 of the questions represented knowledge weaknesses and none warranted changes to the examination or its answer key.
2. Initial Licensing Examination Development
a. Examination Scope
The licensee developed the examination in accordance with NUREG-1021, Revision 9.
All licensee facility training and operations staff involved in examination preparation and validation were on a security agreement. The facility licensee submitted the written examination outline on February 1, 2005. The chief examiner reviewed the outline against the requirements of NUREG-1021, Revision 9, and provided comments to the licensee. The facility licensee submitted the draft examination on March 18, 2005. The chief examiner reviewed the draft examination against the requirements of NUREG-1021, Revision 9, and provided comments to the licensee on the examination on April 18, 2005. The licensee satisfactorily completed comment resolution on May 16, 2005.
b. Findings
The NRC approved the initial examination outline and advised the licensee to proceed with examination development.
The examiner determined that the examination initially submitted by the licensee was within the range of acceptability expected for a proposed examination.
No findings of significance were identified.
3. Examination Security
a. Examination Scope
The examiner reviewed examination security for compliance with 10 CFR 55.40, 10 CFR 55.49, and NUREG-1021, Revision 9, requirements.
b. Findings
Introduction.
A green noncited violation of 10 CFR 55.49 was identified by the examiner for engaging in activities that, but for detection, would have affected the equitable and consistent administration of the examination.
Description.
On March 1, 2005, license candidates were administered a training examination that was developed by the same licensee personnel who were developing the NRC license examination. The licensee had tasked the license examination development personnel to write the weekly training examinations for the license candidates, and the March 1, 2005, examination was the first of these. The examination development personnel questioned the practice of using the same personnel to develop both training examinations and NRC license examinations for the license candidates, but they did not consult NUREG-1021, Revision 9, which prohibits such a practice as being contrary to maintaining required examination security. Licensee personnel discussed this practice with the chief examiner on March 2, 2005 and were directed to Section ES-201.D.2. of NUREG-1021, Revision 9, which prohibits the practice. The licensee immediately discontinued the practice and documented the issue in Condition Report 2-05-01123.
Analysis.
The finding is a performance deficiency, in that, the licensee allowed its license examination development personnel to engage in additional training activities prohibited by 10 CFR 55.40, 10 CFR 55.49, and NUREG-1021, Revision 9. The finding is more than minor because it could have compromised the integrity and discriminatory validity of the license examination. The examiner identified two questions on the draft license examination that had been compromised after the first and only training examination had been administered. If the practice had gone undetected, applicants could have been exposed to many training examinations containing material overlapping with the license examination, thereby, effectively reducing the ability of the license examination to adequately discriminate between applicants with acceptable overall plant knowledge and those with knowledge limited to the material specifically covered in the
training examinations. The finding is of very low safety significance since it was detected before examination administration and the license examination was modified to eliminate overlap with the March 1 training examination, thereby, ensuring that the license examination had discriminatory validity to support a licensing decision.
Enforcement.
10 CFR 55.40(b) states, in part, that power reactor facility licensees may prepare, proctor, and grade the written examinations required by 55.41 and 55.43...,
subject to the following conditions:
- (1) Power reactor facility licensees shall prepare the required examinations and tests in accordance with the criteria in NUREG-1021...;
- (2) Pursuant to 55.49, power reactor facility licensees shall establish, implement, and maintain procedures to control examination security and integrity; 10 CFR 55.49, examination security and integrity is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Section ES-201.D.2.b of NUREG-1021, Revision 9, requires personnel with detailed knowledge of any portion of the NRC licensing examination to read and sign Form ES-201-3, Examination Security Agreement. This section also prohibits personnel who have signed the ES-201-3 from preparation, review, grading, and evaluation of periodic quizzes [and] examinations in order to ensure examination security and integrity.
Contrary to the above, the licensees NRC licensing examination developers developed a training examination for the license candidates that was administered to the candidates on March 1, 2005. The finding is not suitable for SDP evaluation, but has been reviewed by NRC management and is determined to be a green finding of very low safety significance. This violation is being treated as a noncited violation (05000397/2005-301-01) in accordance with Section VI.A of the NRC Enforcement Policy. The licensee entered this issue into their corrective action program as Condition Report 2-05-01123.
4OA6 Meetings, Including Exit
The chief examiner presented the examination results to Mr. Greg Knudson, Acting Training Manager, and other members of the licensee's staff on June 27, 2005. The licensee acknowledged the findings presented.
The licensee did not identify any information or materials used during the examination as proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- G. Knudson, Acting Training Manager
- R. Hayden, Training Specialist
- S. Hutchison, Training Specialist
NRC Personnel
- Z. Dunham, Senior Resident Inspector
ITEMS OPENED AND CLOSED
Opened and Closed
Compromise of license examination security during
development (4OA5)