ML102030206

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Er 05000259-10-301, 05000260-10-301, 05000296-10-301, 06/7-14/2010 & 06/17/2010; Browns Ferry Nuclear Plant; Operator License Examinations
ML102030206
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 07/22/2010
From: Widmann M
Division of Reactor Safety II
To: Krich R
Tennessee Valley Authority
References
Download: ML102030206 (13)


See also: IR 05000259/2010301

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200

ATLANTA, GEORGIA 30303-1257

July 22, 2010

Mr. R. M. Krich

Vice President, Nuclear Licensing

Tennessee Valley Authority

3R Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

SUBJECT: BROWNS FERRY NUCLEAR PLANT - NRC OPERATOR LICENSE

EXAMINATION REPORT 05000259/2010301, 05000260/2010301, AND

05000296/2010301

Dear Mr. Krich:

During the period June 7 - 14, 2010, the Nuclear Regulatory Commission (NRC) administered

operating tests to employees of your company who had applied for licenses to operate the

Browns Ferry Nuclear Plant. At the conclusion of the tests, the examiners discussed

preliminary findings related to the operating tests with those members of your staff identified in

the enclosed report. The written examination was administered by your staff on June 17, 2010.

Of the twelve applicants who applied for licensees, three Reactor Operator (RO) and seven

Senior Reactor Operator (SRO) applicants passed both the operating test and written

examination. One RO applicant passed a written retake exam (the operating test for this

individual has been waived.) One SRO applicant failed the written examination. There were

three 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.

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) 997-4550.

Sincerely,

/RA/

Malcolm T. Widmann, Chief

Operations Branch

Division of Reactor Safety

Docket Nos.: 50-259, 50-260, 50-296

License Nos.: DPR-33, DPR-52, DPR-68

Enclosures: 1. Report Details

2. NRC Post Examination Comment Resolution

3. Simulator Fidelity Report

cc w/encl: (See page 2)

__ G SUNSI REVIEW COMPLETE

OFFICE RII:DRS RII:DRP RII:DRS

SIGNATURE Via email EFG /RA/ MTW /RA/

NAME P CAPEHART E GUTHRIE M WIDMANN

DATE 07/22/2009 07/22/2009 07/22/2009 07/ /2009 07/ /2009

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO

TVA 2

cc w/encl: Jeff D. Morris

K. J. Polson Training Manager

Vice President Browns Ferry Nuclear Plant

Browns Ferry Nuclear Plant Tennessee Valley Authority

Tennessee Valley Authority Electronic Mail Distribution

P.O. Box 2000

Decatur, AL 35609

J.J. Randich

General Manager

Browns Ferry Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Decatur, AL 35609

F.R. Godwin

Manager, Licensing and Industry Affairs

Browns Ferry Nuclear Plant

Tennessee Valley Authority

P.O. Box 2000

Decatur, AL 35609

E. J. Vigluicci

Assistant General Counsel

Tennessee Valley Authority

6A West Tower

400 West Summit Hill Drive

Knoxville, TN 37902

State Health Officer

Alabama Dept. of Public Health

RSA Tower - Administration

Suite 1552

P.O. Box 30317

Montgomery, AL 36130-3017

Chairman

Limestone County Commission

310 West Washington Street

Athens, AL 35611

James L. McNees, CHP

Director

Office of Radiation Control

Alabama Dept. of Public Health

P. O. Box 303017

Montgomery, AL 36130-3017

TVA 4

Letter to Mr. Krich from Malcolm T. Widmann dated July 22, 2010

SUBJECT: BROWNS FERRY NUCLEAR PLANT - NRC OPERATOR LICENSE

EXAMINATION REPORT 05000259/2010301, 05000260/2010301, AND

05000296/2010301

Distribution w/encl:

C. Evans, RII

L. Slack, RII

OE Mail

RIDSNRRDIRS

PUBLIC

RidsNrrPMBrownsFerry Resource

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket No.: 50-259, 50-260, 50-296

License No.: DPR-33, DPR-52, DPR-68

Report Nos.: 05000259/2010301, 05000260/2010301, 05000296/2010301

Licensee: Tennessee Valley Authority (TVA)

Facility: Browns Ferry Nuclear Plant, Units 1, 2 & 3

Location: Corner of Shaw and Nuclear Plant Roads

Athens, AL 35611

Dates: Operating Test - June 7 - 14, 2010

Written Examination - June 17, 2010

Examiners: Phillip G. Capehart, Chief Examiner, Operations Engineer

Gerard W. Laska, Senior Operations Engineer

Kenneth D. Schaaf, Operations Engineer

Approved by: Malcolm T. Widmann, Chief

Operations Branch

Division of Reactor Safety

Enclosure 1

SUMMARY OF FINDINGS

ER 05000259/2010301, 05000260/2010301, 05000296/2010301, 06/7-14/2010 & 06/17/2010;

Browns Ferry Nuclear Plant; Operator License Examinations.

Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in

accordance with the guidelines in Revision 9, Supplement 1, 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 Browns Ferry Nuclear Plant training staff developed both the operating tests and

the written examination.

The NRC administered the operating tests during the period June 7 - 14, 2010. Members of the

Browns Ferry Nuclear Plant training staff administered the written examination on June 17,

2010. Three Reactor Operator (RO) and seven Senior Reactor Operator (SRO) applicants

passed both the operating test and written examination. One RO applicant passed a written

retake exam. One SRO applicant failed the written examination. Nine applicants were issued

licenses commensurate with the level of examination administered. Due to their written exam

scores, two applicants licenses will be held in abeyance for a minimum of 20 days to account

for any possible appeals due to the one written exam failure.

There were three post-examination comments.

No findings of significance were identified.

Enclosure 1

REPORT DETAILS

4. OTHER ACTIVITIES

4OA5 Operator Licensing Examinations

a. Inspection Scope

Members of the Browns Ferry Nuclear Plant developed both the operating tests and the

written examination. All examination material was developed in accordance with the

guidelines contained in Revision 9, Supplement 1, of NUREG-1021, "Operator Licensing

Examination Standards for Power Reactors." 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 reviewed the licensees examination security measures while preparing and

administering the examinations in order to ensure compliance with 10 CFR Part 55.49,

Integrity of examinations and tests.

The NRC examiners evaluated four Reactor Operator (RO) and eight Senior Reactor

Operator (SRO) applicants using the guidelines contained in NUREG-1021. The

examiners administered the operating tests during the period June 17 - 14, 2010.

Members of the Browns Ferry Nuclear Plant training staff administered the written

examination on June 17, 2010. Evaluations of applicants and reviews of associated

documentation were performed to determine if the applicants, who applied for licenses

to operate the Browns Ferry Nuclear Plant, met the requirements specified in 10 CFR

Part 55, Operators Licenses.

b. Findings

No findings of significance were identified. The NRC determined that the details

provided by the licensee for the written exam, walkthrough, and simulator tests were

within the range of acceptability expected for a proposed examination.

During the performance of the examination, Job Performance Measures were being

conducted in the simulator by the examination team, a security violation occurred. A

Licensed Operator Requalification Instructor, who was not on the security agreement,

ignored the examination barriers in place and entered the simulator during the

examination process. Both the licensee and the NRC examiner immediately recognized

the security violation, stopped the examination process, and addressed the individual to

be escorted out of the simulator. The licensee immediately placed the Instructor on the

security agreement and wrote a service request report (192291) to address the error and

to prevent a reoccurrence.

Enclosure 1

3

Three RO applicants and seven SRO applicants passed both the operating test and

written examination. One RO applicant passed a written retake and was waived on the

operating examination. One SRO applicant failed the written examination. Two RO

applicants and seven SRO applicants were issued licenses.

Two RO applicants passed the operating test, but passed the written examination with

overall scores between 80% and 82%. These applicants were issued letters stating that

they passed the examination and issuance of their license has been delayed pending

any written examination appeals that may impact the licensing decision for their

application.

A copy of the final as-given RO and SRO written examinations and answer keys, with

all changes incorporated, and the licensees post-examination comments, may be

accessed in the ADAMS system (ADAMS Accession Numbers ML102020489,

ML102020475, and ML102020502).

Copies of all individual examination reports were sent to the facility Training Manager for

evaluation of weaknesses and determination of appropriate remedial training.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On June 14, 2010, the NRC examination team discussed generic issues associated with

the operating test with Mr. K. Polson, Browns Ferry Nuclear Plant, Site Vice President,

and members of the Browns Ferry Nuclear Plant staff. The examiners asked the

licensee if any of the examination material was proprietary. No proprietary information

was identified.

Enclosure 1

KEY POINTS OF CONTACT

Licensee personnel

J. Davenport, Licensing Engineer

B. Carrier, Exam Developer

D. Malinowski, Operations Training Manager

D. McConnell, Initial Training Manager

J. Miller, Operations Manager

J. Morris, Training Manager

K. Polson, Site Vice President BFN

J. Randich, GMSO

M. Sweeney, Exam Team Member

D. Williamson, Licensing Manager

D. Zielinski, Exam Team Member

NRC personnel

P. Capehart, DRS

T. Ross, SRI

K. Schaaf, DRS

Enclosure 1

NRC Post Examination Comment Resolution

A complete Text of the licensees post examination comments can be found in ADAMS under

Accession Number ML102020502.

RO QUESTION # 68

LICENSEE COMMENT:

The question asks, What is the MINIMUM personnel requirement at the VFD (Variable

Frequency Drive) to perform speed control manipulations for the Reactor Recirculation Pumps

in accordance with the procedure (2-OI-68, Reactor Recirculation System)?

2-OI-68, Reactor Recirculation System, only requires communication between a licensed

operator and the Unit Operator in the control room. The correct answer, based solely on the 2-

OI-68 procedure, from the choices given, was intended to be Reactor Operator ONLY, choice

A.

The licensee, in their post examination comment, challenges this question and request that two

correct answers (choice A Reactor Operator ONLY and choice C Reactor Operator AND

Senior Reactor Operator for oversight) be accepted. The licensee states that there are two

higher ranking procedures that state a Unit Supervisor shall be present or provide direct

oversight when reactivity manipulations are performed:

OPDP-1, Conduct of Operations, Rev 16, page 13, step 3.6.B.2, states that the Unit Supervisor

is responsible for all manipulations that affect reactivity and is charged to personally oversee all

reactivity changes or assign another SRO to oversee the reactivity change if unable to give

his/her undivided attention.

SSP-10.4, Reactivity Management Program, Rev. 8, page 12, step 3.2.6.J, states that the Unit

Supervisor shall provide direct oversight (line of sight within normal conversation level distance)

for all reactivity manipulation (may be performed by a dedicated SRO for major reactivity

evolutions such as reactor startup).

NRC RESOLUTION:

Based on the above discussion, the licensees recommendation was not accepted. Both

answer choices A and C are not correct. Based on the two higher tier procedures, an SRO

should always be present for reactivity manipulations. This does not contradict but adds

additional requirements to 2-OI-68 that always applies. Therefore, both A and C cannot be

correct. The only correct answer is choice C. The answer key has been changed to reflect this

change.

Enclosure 2

2

SRO QUESTION # 77

LICENSEE COMMENT:

The question concerns itself with the requirement for the highest level of EAL classification if the

backup control panel cannot be manned within 20 minutes following a control room evacuation.

The licensee contends that the basis document of EPIP-1, 6.2-S, gives a possible justification

for NOT classifying the event as a Site Area Emergency based on certain key parameters being

controlled by automatic functions. HPCI initiation and automatic operation is specifically given

as one of these instances. With no other evidence of uncontrolled key parameters in the

question stem, the event could also be classified as an Alert and therefore there are two correct

answers.

The licensee contends that there are two correct answers for this question: Choice A (1) Alert

and Choice C (1) Site Area Emergency.

NRC RESOLUTION:

After reviewing the licensees contention and supporting information, the recommendation is not

accepted. The criteria to establish plant control from the backup control panel is not based on

just one parameter (i.e. HPCI control), but on several critical parameters. The operator is forced

to evacuate the control room and is not aware of the status of these other critical parameters

within the time limit of 20 minutes and therefore has no other option but to declare a Site Area

Emergency.

Based on the above discussion, the recommendation to accept two answers was not accepted;

only answer choice C will be considered as a correct answer. No answer key change was

required.

Enclosure 2

3

Simulator JPM b Place a 2nd/3rd RFPT in service

LICENSEE COMMENT:

The JPM cue statement states The Unit Supervisor directs you to place RFPT 3A in service

and in automatic level control per 3-OI-3, Reactor Feedwater System, section 5.7. The task

standard is to Place the 2nd/3rd RFPT in service.

For this JPM, Unit 3 was less than 70% Reactor Power with the B and C Reactor Feedwater

Pumps in service. Placing RFP 3A MIN FLOW VALVE, 3-HS-3-20, in the OPEN position will

lock it open, preventing minimum flow valve oscillations at low flow. Although it is desired to

minimize valve oscillations, such oscillations at given conditions are well within the capability of

the Feedwater Level Control System to respond to and will not result in a significant plant

transient or significant diminished margin to safety.

The licensee contends that step [3] of the procedure: VERIFY RFP 3A MIN FLOW VALVE, 3-

HS-3-20 in OPEN position, is not a critical step. The task standard for this JPM is to place RFPT

3A in service and in automatic level control per 3-01-3 Reactor Feedwater System section 5.7.

Failure to perform this step will not prevent successful completion of the task standard.

Therefore, the licensee recommends that the performance of the step be changed to Not

Critical.

NRC RESOLUTION:

After reviewing the licensees contention and supporting information, the recommendation is

accepted. JPM step [3] to VERIFY RFP 3A MIN FLOW VALVE, 3-HS-3-20 OPEN does not

require the operator to place the switch from AUTO to OPEN and therefore it is not critical.

Enclosure 2

SIMULATOR FIDELITY REPORT

Facility Licensee: Browns Ferry Nuclear Plant

Facility Docket No.: 05000259, 05000260, 05000296

Operating Test Administered: June 7 - 14, 2010

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.

The following simulator fidelity or configuration issues were identified:

During a simulator scenario examination the simulator stopped responding and the examination

process had to be halted. The simulator support staff identified that the problem originated from

the digital feedwater computer. The crew under examination was escorted from the simulator

so that a simulator download and upload could be performed. This was required to restore the

simulator to proper operation. After approximately 15 minutes, the simulator was restored and

verified to be operational. The simulator examination crew was reintegrated to the scenario

from the point at which the simulator stopped responding and the exam was recommenced.

The delay in the scenario evaluation process did not impact administration of the scenario.

[Simulator Problem Report # 5048]

Enclosure 3