IR 05000397/2025301
| ML25050A124 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/20/2025 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Schuetz R Energy Northwest |
| References | |
| 50-397/25-301 50-397/OL-25 | |
| Download: ML25050A124 (1) | |
Text
February 20, 2025
SUBJECT:
COLUMBIA GENERATING STATION - NRC EXAMINATION REPORT 05000397/2025301
Dear Mr. Schuetz:
On February 18, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Columbia Generating Station. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on January 16, 2025, with Mr. G. Hettel, Chief Nuclear Officer, and other members of your staff. A telephonic exit meeting was conducted on February 18, 2025, with Mr. G. Knudson, Operations Training Manager, who was provided the NRC licensing decisions.
The examination included the evaluation of four applicants for reactor operator licenses, five applicants for instant senior reactor operator licenses, and four applicants for upgrade senior reactor operator licenses. The license examiners determined that all applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There was one post-examination comment submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post-examination comment resolution.
No findings were identified during this examination. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety Docket No. 50-397 License No. NPF-21 Enclosures:
1.
Examination Report 05000397/2025301 2.
NRC Post-Examination Comment Resolution Electronic Distribution via LISTSERV Signed by Gepford, Heather J.
on 02/20/25
ML25050A124 SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive Keyword:
By: TJF Yes No Publicly Available Sensitive NRR-079 OFFICE SOE:DORS:OB SOE:DORS:OB OE:DORS:OB OE:DORS:OB C:DORS:OB NAME TFarina NHernandez CHarrington PBreidenbach HGepford SIGNATURE
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DATE 02/19/25 02/19/25 02/19/25 02/19/25 02/20/25
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Examination Report Docket Number:
05000397 License Number:
NPF-21 Report Number:
05000397/2025301 Enterprise Identifier:
L-2025-OLL-0012 Licensee:
Energy Northwest Facility:
Columbia Generating Station Location:
Richland, Washington Inspection Dates:
January 13, 2025, to February 18, 2025 Inspectors:
T. Farina, Senior Operations Engineer (Chief Examiner)
N. Hernandez, Senior Operations Engineer C. Harrington, Operations Engineer P. Breidenbach, Operations Engineer Approved By:
Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety
SUMMARY Examination Report 05000397/2025301; January 13 - February 18, 2025; Columbia Generating Station; Initial Operator Licensing Examination Report The NRC examiners evaluated the competency of four applicants for reactor operator licenses, five applicants for instant senior reactor operator licenses and four applicants for upgrade senior reactor operator licenses at Columbia Generating Station.
The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 12. The written examination was administered by the licensee on January 23, 2025. The NRC examiners administered the operating tests on January 13-16, 2025.
The NRC examiners determined that all applicants satisfied the requirements of 10 CFR 55, and the appropriate licenses have been issued.
A.
NRC-Identified and Self-Revealing Findings None.
B.
Licensee-Identified Violations None.
REPORT DETAILS OTHER ACTIVITIES - INITIAL LICENSE EXAM
.1 License Applications a.
Scope The NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The NRC examiners also audited two of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants experience and on-the-job training, including control manipulations that provided significant reactivity changes.
b.
Findings No findings were identified.
.2 Examination Development a.
Scope The NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examiners conducted an onsite validation of the operating tests.
b.
Findings The NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.
The NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.
.3 Operator Knowledge and Performance a.
Scope On January 23, 2025, the licensee proctored the administration of the written examinations to all applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis and post-examination comments to the NRC on January 30, 2025.
The NRC examination team administered the various portions of the operating tests to all applicants from January 13-16, 2025.
b.
Findings No findings were identified.
All applicants passed the written examination and all parts of the operating test. The final examinations and post-examination analysis and comments may be accessed in the ADAMS system under the accession numbers noted in the attachment.
The examination team noted one generic weakness associated with applicant performance on the administrative job performance measure section of the operating tests. The applicants displayed a weakness generating a classification notification form during a general emergency. Post-examination analysis revealed seven generic weaknesses associated with applicant performance on the written examination. The following questions had a miss rate of greater than 50%: Questions 6, 35, 36, 37, 52, 83, and 90. These weaknesses were captured in the licensees corrective action program as condition report 466133. Copies of all individual examination reports were sent to the facility training manager for evaluation and determination of appropriate remedial training.
.4 Simulation Facility Performance a.
Scope The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.
b.
Findings No findings were identified.
.5 Examination Security a.
Scope The NRC examiners reviewed examination security for examination development during both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.
Findings No findings were identified.
EXIT MEETINGS AND DEBRIEFS Exit Meeting Summary The chief examiner presented the preliminary examination results to Mr. G. Hettel, Chief Nuclear Officer, and other members of the staff on January 16, 2025. A telephonic exit was conducted on February 18, 2025, between Mr. T. Farina, chief examiner, and Mr. G. Knudson, Operations Training Manager. The licensee did not identify any information or materials used during the examination as proprietary or requiring special controls.
ADAMS DOCUMENTS REFERENCED Accession No. ML25050A101 - FINAL WRITTEN EXAMS Accession No. ML25050A102 - FINAL OPERATING TEST Accession No. ML25050A113 - POST-EXAMINATION ANALYSIS-COMMENTS
Enclosure 2 NRC Resolution to the Columbia Generating Station Post-Examination Comment A complete text of the licensee's post-examination analysis and comments can be found in ADAMS under Accession Number ML25050A113.
SRO QUESTION # 83
LICENSEE COMMENT: Question SRO-83 as-given correct answer is D. Following analysis, correct answer is C.
Analysis: SRO-83 requires applicants to utilize knowledge of ABN-BACKPRESSURE. This includes automatic actions and immediate actions which applicants need to have memorized as well as general awareness of paths that will be taken in subsequent actions. Per the stem of the question, reactor power is 56% and main turbine output is 680MWe, and condenser backpressure is 3.5 in Hg and up 0.5 in Hg per minute. The main turbine trip setpoint at 680MWe is roughly 6.5 in Hg, meaning the turbine trip would occur in six minutes without any operator action.
The keyed answer D states the CRS should direct a power reduction in accordance with PPM 3.2.4 Fast Power Reduction. This is in accordance with step 4.3 of ABN-BACKPRESSURE. However, this action would be adverse for several reason[s]. First, reducing reactor power would reduce turbine loading and cause a change to the turbine trip setpoint associated with backpressure. At 560MWe, the turbine trip setpoint reaches its lowest value of 5.5 in Hg, meaning the time to a turbine trip could quickly be reduced to four minutes. Second, at an initial reactor power of 56%, the power reduction would not constitute a relatively fast and easy flow back in recirculation flow. Control rod movement would need to be evaluated and rods would be inserted to help with the power reduction. This task takes more time than the operating crew would have available to them before the automatic turbine trip would occur.
Distractor C gives the applicant the option to scram the reactor and trip the main turbine. This would be the prudent action and is found in ABN-BACKPRESSURE step 3.1. This step directs these actions when reactor power is GT 25% and a condenser backpressure trip is imminent.
The applicant is faced with deciding if they can correct the issue within a limited time frame or take the actions associated with taking the plant offline. In this case, without a way to correct the rising backpressure and a main turbine trip only six minutes away, taking this action described in distractor C is the correct response and C should be selected by the applicant, not D.
NRC RESOLUTION: The NRC disagrees with the licensee's recommendation to change the correct answer from D to C for Question #83, and will instead delete this question from the exam.
The licensee argued that, contrary to the original justification, attempting a fast power reduction would be more complicated than simply reducing recirc flow to reduce reactor power. At 56%
power, the fast power reduction would require control rod insertion as part of the power maneuver, an evolution that would take longer than a recirculation flow reduction only. The reduced turbine load would additionally lower the turbine trip setpoint on high backpressure to 5.5 inches Hg, further shortening the time until a trip. The licensee argued that the crew should consider that a main condenser backpressure trip is imminent, and manually scram the reactor and trip the main turbine per step 3.1 of ABN-BACKPRESSURE, rather than attempting a fast power reduction.
The NRC believes that the decision between scramming the reactor or attempting a fast power reduction could reasonably be viewed as a judgement call. The stem of the question does not provide specificity about the condition of the core beyond power level, such as core flow or rod line, factors which would influence how quickly the crew could conduct a fast power reduction.
It would not be unreasonable that, given the scale of condenser vacuum loss and the time required to downpower, a crew would assess a turbine trip as imminent and find it prudent to scram the reactor. Likewise, if a crew in its judgement determined that it should first try to
reduce power to stabilize condenser backpressure before directing a scram, that would not be unreasonable. Lacking additional detail, either choice C or D could be viewed as a prudent action.
NUREG 1021 ES-4.4 states, 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.
The above example describes the conflict in question SRO-83 almost exactly - a manual scram cannot be both required and not required at the same time. Therefore, given that both C and D could be viewed as reasonable answers under the conditions given, but both answers cannot exist simultaneously, question SRO-83 will be deleted from the exam.