IR 05000440/2015301
| ML15117A634 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 04/23/2015 |
| From: | Hironori Peterson Operations Branch III |
| To: | Harkness E FirstEnergy Nuclear Operating Co |
| References | |
| 50-440/15-301 | |
| Download: ML15117A634 (12) | |
Text
April 23, 2015
SUBJECT:
PERRY NUCLEAR POWER PLANT NRC INITIAL LICENSE EXAMINATION REPORT 05000440/2015301
Dear Mr. Harkness:
On March 11, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed the initial operator licensing examination process for license applicants employed at your Perry Nuclear Power Plant. This examination was extended 3 weeks due to a personal hardship experience by one applicant during the course of taking the operating portion of the license exam where by the applicant was administered a makeup exam. The enclosed report documents the results of those examinations. Preliminary observations noted during the examination process were discussed on February 13, 2015, with Mr. E. Harkness, Site Vice President, and other members of your staff. An exit meeting was conducted by telephone on April 3, 2015, between Mr. Strohl, Operations Training Superintendent-Perry Nuclear Power Plant, and Mr. R. K. Walton, Chief Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation, NRC resolution of the stations post-examination comment, initially received by the NRC on March 4, 2015, was discussed.
The NRC examiners administered an initial license examination operating test during the weeks of February 2 and 9, 2015, and a makeup exam was administered to one Senior Reactor Operator (SRO), March 9-11, 2015. The written examination was administered by Perry Nuclear Power Plant training department personnel on February 19, 2015. Nine SROs, and four reactor operators (ROs) applicants were administered license examinations. The results of the examinations were finalized on April 3, 2015. Thirteen applicants passed all sections of their respective examinations, eight were issued senior operator licenses, and four were issued operator licenses. The license for one SRO applicant is being withheld pending completion of onsite experience requirements.
The proposed and final written examinations and answer keys will be withheld from public disclosure for 24 months per your request. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosures, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's Agencywide Documents Access and Management 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/
Hironori Peterson, Chief Operations Branch Division of Reactor Safety Docket No. 50-440 License No. NPF-58
Enclosures:
1. Operator Licensing Examination Report (ER) 05000440/2015301 w/Attachment: Supplemental Information 2. Simulation Facility Report 3. Post Exam Comments and Resolutions
REGION III==
Docket No: 50-440 License No: DPR-20 Report No: 05000440/2015301 Licensee: First Energy Nuclear Operating Company (FENOC)
Facility: Perry Nuclear Power Plant, Unit 1 Location: Perry, Ohio Dates: February 2 through March 11, 2015 Inspectors: R. K. Walton, Operations Engineer; Chief Examiner D. Reeser, Operations Engineer R. M. Morris, Senior Operations Engineer Approved by: H. Peterson, Chief Operations Branch Division of Reactor Safety Enclosure 1
SUMMARY
OF RESULTS
Examination Report 05000440/2015301; 02/02/2015-03/11/2015, First Energy Nuclear Operating Company, Perry Nuclear Power Plant, Initial License Examination Report.
The announced initial operator licensing examination was conducted by regional U.S. Nuclear Regulatory Commission examiners, in accordance with the guidance of NUREG-1021,
Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1.
Examination Summary:
All thirteen applicants passed all sections of their respective examinations. Eight applicants were issued senior operator licenses, and four applicants were issued operator licenses. The license for one senior operator applicant is being withheld pending completion of on-site experience requirements. (Section 4OA5.1).
REPORT DETAILS
4OA5 Other Activites
.1 Initial Licensing Examinations
a. Examination Scope
The U.S. Nuclear Regulatory Commission (NRC) examiners, and members of the facility licensees staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9-Supplement 1, to develop, validate, administer, and grade the written examination and operating test. Members of the facility licensees staff prepared the outlines and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of January 12, 2015, with the assistance of members of the facility licensees staff.
During the on-site validation week, the examiners audited three license applications for accuracy. The NRC examiners, with the assistance of members of the facility licensees staff, administered the operating test, consisting of job performance measures (JPMs)and dynamic simulator scenarios, during the periods of February 2-12, 2015, and a makeup exam was administered to a senior license applicant on March 10-11, 2015.
The facility licensee administered the written examination on February 19, 2015.
b. Findings
- (1) Written Examination The NRC examiners determined that the written examination, as proposed by the licensee, was within the range of acceptability expected for a proposed examination.
Less than 20 percent of the proposed examination questions were determined to be unsatisfactory, and required modification or replacement.
On March 4, 2015, the NRC received the licensees submittal documentation with one post-examination comment for consideration by the NRC examiners when grading the written examination. The post-examination comment, and the NRC resolution of the comment is included in Enclosure 3 of this report. The final as-administered written examination and answer key (ADAMS Accession Number ML15106A397), will be available in 24 months electronically in the NRC Public Document Room or from the Agencywide Documents Access and Management System (ADAMS). All changes made to the proposed written examination were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, and documented on Form ES-401-9, Written Examination Review Worksheet.
The NRC examiners graded the written examination on March 30, 2015, and conducted a review of each missed question to determine the accuracy, and validity of the examination questions.
- (2) Operating Test The NRC examiners determined that the operating test, as originally proposed by the licensee, was within the range of acceptability expected for a proposed operating test.
Changes made to the proposed operating test, were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, and were documented in Perry 2015 Operating Test Comments, which will be available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS.
One applicant was unable to complete the operating exam due to a personal hardship.
The individual completed all simulator scenarios and three of fifteen job performance measures (JPMs). In order to preserve exam security, the remaining dozen makeup JPMs had to be either newly written or from the licensees exam bank. The licensee developed a dozen makeup JPMs that were different from the JPMs that the rest of the class had been administered, and different from the licensees audit exam. These JPMs met all quality, type code, and safety function attributes from the original operating test.
The NRC and licensee validated these makeup JPMs prior to administering these JPMs to the applicant during the week of March 9, 2015.
The final as-administered dynamic simulator scenarios and JPMs will be available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS.
The NRC examiners completed operating test grading on April 3, 2015.
- (3) Examination Results All thirteen applicants passed all sections of their respective examinations.
Eight applicants were issued SRO licenses and four applicants were issued RO licenses. The license for one senior operator applicant is being withheld pending completion of on-site experience requirements. Twelve applicants were issued their respective operating licenses on April 7, 2015.
.2 Examination Security
a. Scope
The NRC examiners reviewed and observed the licensee's implementation of examination security requirements during the examination validation and administration to assure compliance with Title 10 of the Code of Federal Regulations, Section 55.49, Integrity of Examinations and Tests. The examiners used the guidelines provided in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, to determine acceptability of the licensees examination security activities.
b. Findings
No findings were identified.
4OA6 Management Meetings
.1 Exit Meeting Summary
Debrief The chief examiner presented the examination team's preliminary observations and findings on February 13, 2015, to Mr. E. Harkness, Site Vice President, and other members of the Perry Nuclear Power Plant Operations and Training Department staff.
.2 Exit Meetings
The chief examiner conducted an exit meeting, by telephone, on April 3, 2015, with Mr. R. Strohl, Training Manager, and Mr. J. Kelly, Training Supervisor. The NRCs final disposition of the stations post-examination comments were disclosed and discussed during the telephone discussion. The examiners asked the licensee whether any of the material used to develop or administer the examination, should be considered proprietary. No proprietary or sensitive information was identified during the examination or debrief/exit meetings.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- E. Harkness, Site Vice President
- D. Hamilton, Plant General Manager
- C. Olivier, Operations Manager
- R. Strohl, Training Manager
U.S. Nuclear Regulatory Commission
- J. Nance, Resident Inspector
- R. K. Walton, Chief Examiner
- D. Reeser, Examiner
- R. M. Morris, Examiner
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed, and Discussed
None
LIST OF ACRONYMS USED
ADAMS Agency Wide Document Access and Management System
CFR Code of Federal Regulations
DRS Division of Reactor Safety
NRC U.S. Nuclear Regulatory Commission
RO Reactor Operator
SRO Senior Reactor Operator
SIMULATION FACILITY REPORT
Facility Licensee: Perry Nuclear Power Plant
Facility Docket No: 50-440
Operating Tests Validated/Administered: January 12-18 and February 2-12, 2015
Makeup Test Validated/Administered: March 9 and March 10 - 11, 2015
The following documents observations made by the NRC examination team during the initial
operator license examination. These observations do not constitute audit or inspection
findings and are not, without further verification and review, indicative of non-compliance with
CFR 55.45(b). These observations do not affect NRC certification or approval of the
simulation facility other than to provide information which may be used in future evaluations.
No licensee action is required in response to these observations.
During the conduct of the on-site validation and simulator portion of the operating tests,
the following items were observed:
ITEM DESCRIPTION
Relief Valve During on-site validation week, a relief valve tailpipe temperature
Tailpipe recorder continued to trend up in temperature even though the relief
Temperature valve was closed. The licensee identified an error in the algorithm
Recorder needed to compute the parameter. The licensee corrected the
problem at the conclusion of the exam.
Rosemont Analog During Scenario #3, an applicant noted a difference between the
Trip Units analog trip units used in the plant vs. the analog trip units used in the
simulator. Specifically, DW/HPCS pressure analog trip units, in the
simulator, were scaled in units of %, whereas in the control room,
these units were scaled in psig. This minor detail did not affect exam
administration.
POST EXAM COMMENTS AND RESOLUTIONS
There was one Candidate comment regarding the 2015 NRC Written Exam. The comment is
for SRO Question No. 5.
QUESTION SRO 5:
The Plant is in a refueling outage.
A contract worker performing an inspection of a twice burnt fuel bundle in the fuel
inspection machine received an unexpected exposure of 5105 mrem TEDE when the upper
stop failed on the fuel inspection machine.
Not including Events Of Potential Public Interest, what notification to the NRC is required?
A An Immediate Notification
B A 4 Hour Notification
C A 24 Hour Notification
D A Thirty Day Notification
The correct answer was previously determined to be C.
Candidate Comments:
1. The question asks what NRC notification is required based on an unexpected
radiological exposure exceeding 5 rem.
2. Per NOBP-OP-1015, Revision 02, Attachment 19, O1.12, News Release or Notification
to Other Government Agency, The licensee shall notify the NRC as soon as practical
and in all cases, within four hours of the occurrence of any event or situation, related
to the health and safety of the public or onsite personnel, or protection of the
environment, for which a news release is planned to notification to other government
agencies has been or will be made.
3. The licensee is required to notify the Director of Ohio Department of Health in
accordance with NOBP-OP-1015, Attachment 45, RP.1 Radiation Exposure of
Radioactive Material Release - PY, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> requirement is valid.
4. Each licensee shall, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery of the event, report any event involving
loss of control of licensed material possessed by the licensee that may have caused, or
threatens to cause any of the following conditions:
(1) An individual to receive, in a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -
(i) A total effective dose equivalent exceeding 5 rems
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement is valid.
5. Amend the answer key to list B and C as correct answers.
Candidate Justification for answers:
A. Incorrect answer - an exposure to >25 rem is immediately reportable.
- B. Correct answer - Per 10 CFR 50.72(b)(2)(xi), the licensee shall notify the NRC as soon
as practical and in all cases, within four hours of the occurrence of any event or
situation, related to the health and safety of the public or onsite personnel, or protection
of the environment, for which a news release is planned or notification to other
government agencies has been or will be made. Such an event may include an onsite
fatality or inadvertent release of radioactively contaminated materials.
A 4-hour NRC notification is required due to notification of the Ohio Department of
Health per Ohio Administrative Code 370-1:1-38-21.
- C. Correct answer - Per 10 CFR 20.2202(b), each licensee shall, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of
discovery of the event, report any event involving loss of control of licensed material
possessed by the licensee that may have caused, or threatens to cause, any of the following
conditions:
(1) An individual to receive, in a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> -
(i) A total effective dose equivalent exceeding 5 rems
D. Incorrect answer - This is a requirement for lost or stolen SNM.
Recommendation: Amend the Answer Key to list answer B as a correct answer in addition to
answer
- C.
References: NOBP-OP-1015, Event Notifications, Attachments 19, 34, and 45.
Station Proposed Resolution: The station agrees with the above candidate Comments,
Justifications and Recommendation since we have provided newly discovered technical
information that supports a change in the answer key.
NRC Response: The question as originally written, required the applicants to have knowledge
of NRC reporting requirements for an over exposure event. References were provided to the
applicants during the written exam since this information was not required to be known from
memory. The applicants were expected to recognize that over exposure (5 rem TEDE) was a
hour reportable event IAW 10 CFR 20.2202(b). As such, distractor C was considered the
correct answer.
However, unknown to either the author or reviewers of this question, some of the applicants
identified a 24-hour required notification to the State of Ohio for an exposure exceeding 5 rem
(TEDE) (required by Ohio Administrative code 3701:1-38-21), and a subsequent 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />
notification to the NRC IAW 10 CFR 50.72(b)(2)(xi). This additional requirement, notification
to other government agencies... made for a second correct answer.
Upon further NRC review, the third distractor, a 30-day notification, was required by
CFR 20.2203(a), and also would be considered a possible correct answer since this too was
a notification - a written notification. In hind sight, SRO Question 6 had three possible correct
answers.
As allowed by NUREG-1021, Rev 9, Section 403, D.1.c, SRO Question 5 will be deleted from
the exam.
E. Harkness -2-
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its
enclosures, and your response (if any) will be available electronically for public inspection in the NRCs
Public Document Room or from the Publicly Available Records (PARS) component of the NRC's
Agencywide Documents Access and Management 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/
Hironori Peterson, Chief
Operations Branch
Division of Reactor Safety
Docket No. 50-440
License No. NPF-58
Enclosures:
1. Operator Licensing Examination
Report (ER) 05000440/2015301
w/Attachment: Supplemental Information
2. Simulation Facility Report
3. Post Exam Comments and Resolutions
cc w/encls: Distribution via LISTSERV
- R. Strohl, Training Manager