IR 05000293/2011301
| ML111100575 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/19/2011 |
| From: | Hansell S Operations Branch I |
| To: | Rich Smith Entergy Nuclear Operations |
| Shared Package | |
| ML102210114 | List: |
| References | |
| IR-11-301 | |
| Download: ML111100575 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENOALE ROAD KING OF PRUSSlA. PA 19406-1415
+***i April L9, 207I Robert Site Vice President Entergy Nuclear Operations, lnc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 SUBJECT: PILGRIM NUCLEAR POWER STATION - NRC EXAMINATIoN REPoRT 05000293/2011301
Dear Mr. Smith:
On March 4,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an examination at the Pilgrim facility. The enclosed report documents the examination findings, which were discussed on April 7 ,2011, with Mr. David Noyes and other members of youistatf.
The examination included the evaluation of six applicants for reactor operator licenses, two applicants for instant senior operator licenses, and one applicant for an upgrade senior operator license. The written and operating examinations were developed using NUnEG-tOZt,
_Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1.
The license examiners determined that eight of the nine applicants satisfied the requirements of 10 cFR Part 55, and the appropriate licenses were issued on April r,2011.
No findings were identified during this examination.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system Agencywide Document Access and Management System (ADAMS), ADAMS is accessible from the NRC Web site at http:i/www.nrc.qov/readinq-rmiadams.html (the Public Electronic Reading Room).
Operations Branch Division of Reactor Safety Enclosure:
NRC Examination Report 05000293/201 1301 cc: Wenclosure: Distribution via ListServ
Robert
SUMMARY OF FINDINGS
ER 0500029312011301; February 21 - March 4, 2011 ; Pilgrim Nuclear Power Station; Initial
Operator Licensing Examination Report.
NRC examiners evaluated the competency of six applicants for reactor operator licenses, two applicants for instant senior operator licenses, and one applicant for an upgrade senior operator license at the Pilgrim facility. The facility licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9,
Supplement 1. The written examination was administered by the facility on March 4,2011 .
NRC examiners administered the operating tests February 21-24,2011. The license examiners determined that eight of nine applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
A. NRC-ldentifiedandSelf-RevealinqFindinqs No findings were identified.
B. Licensee-ldentified Violations None.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA5 Other Activities (lnitial Operator License Examination)
.1 License Applications
a. Scope
The examiners reviewed all nine license applications submitted by the licensee to ensure the applications reflected that each applicant satisfied relevant license eligibility requirements. The applications Were submitted on NRC Form 398, "Personal Qualification Statement," and NRC Form 396, "Certification of Medical Examination by Facility Licensee." The examiners also audited two of the license applications in detail to conlirm that they accurately reflected the subject applicant's qualifications. This audit focused on the applicant's experience and on-the-job training, including control manipulations that provided significant reactivity changes.
b. Findinos No findings were identified.
.2 Operator Knowledoe and Performance
Examination Scope On March 4, 2011, the facility licensee proctored the administration of the written examinations to all nine applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on March 10,2011.
The NRC examiners completed the final grading of the written examination on March 29,2011, and conducted a review of each missed question to determine the accuracy and validity of the examination questions. In accordance with current NRC policy the release of this written examination will be delayed for two years. The examination questions may be accessed in the ADAMS system under the accession number noted in Attachment 1.
The NRC examination team administered the various portions of the operating examination to all nine applicants February 21-24,2011. The applicants for reactor operator licenses participated in at least two dynamic simulator scenarios, in a control room and facilities walkthrough test consisting of 11 system tasks, and an administrative test consisting of four administrative tasks. The applicants seeking an instant senior operator license participated in at least three dynamic simulator scenarios, a control room and facilities walkthrough test consisting of ten system tasks, and an administrative test consisting of five administrative tasks. The applicant for an upgrade senior operator license participated in two dynamic simulator scenarios, a control room and faciiities walkthrough test consisting of five system tasks, and an administrative test consisting of five administrative tasks.
b. Findinqs All applicants passed all parts of the operating test. One instant senior operator applicant failed the senior reactor operator (SROFonly portion of the written examination. For the written examinations, the reactor operator applicants' average score was 88.66 percent and ranged from 81.33 to 92.00 percent; the senior operator applicants' average score was 89.22 percent and ranged from 87.87 to 90.90 percent.
The written examination questions may be accessed in the ADAMS system under the accession numbers noted in the attachment.
Chapter ES-403 and Form ES-403-1 of NUREG 1021 require the facility licensee to analyze the validity of any written examination questions that were missed by half or more of the applicants. The facility licensee conducted this performance analysis for four questions that met this criterion and submitted the analysis to the chief examiner.
The analysis included formal comments for two of the four questions: question #82, which Pilgrim staff believed had two correct answers, and question #90, which they believed should be deleted from the exam. The facility licensee's post-examination comments may be accessed in the Agencyvide Document Access and Management System (ADAMS). A summary of the facility's comments and the NRC responses follow.
Senior Operator Question 82 The stem of the question states that the Shutdown Transformer is "Out of Service." The facility contended that this wording is ambiguous, confused the students, and led to two correct answers.
The Shutdown transformer is a source of standby offsite power to Pilgrim during periods when the normal supply of offsite power (startup transformer) is not operable or available. lt is normally not in service supplying any power boards or loads and is therefore considered out of service during normal plant ops (similar to how core spray and Residual Heat Removal (RHR) are not normally in service but are available and operable during normal plant operations).
Pilgrim staff noted that throughout the exam the words "inop", "inoperable", or "inoperative" were used to describe equipment status and in most cases technical specification allowable out of service times were also given. The only other question that used the term out of service clearly stated that the equipment was danger tagged out of service.
For this question two SRO applicants interpreted out of service to mean the equipment was in its normat standbv condition (operable, available to perform its intended function but not in service until needed). This interpretation led them to conclude choice "A" would be correct because the only inoperable source of offsite power would be from the startup transformer. The third SRO applicant interpreted out of service to mean the shutdown transformer was inoperable. This interpretation led that student to conclude the correct answer was "D" because both the startup and shutdown transformers were inoperable.
the correct answer was "D" because both the startup and shutdown transformers were inoperable.
Based on the above discussion, the facility staff asserted that the inconsistent and interpretive nature of the phrase out of service made choice "A" an additional correct answer along with "D", the original correct answer.
NRC Response The comment is not accepted. Throughout Pilgrim procedures, the term out of seryice consistently means unavailable. A few of the examples which support this conclusion follow:
Procedure No. 1.5.22, RISK ASSESSMENT PROCESS Definition of Unavailable - The fraction of time in which a structure.
system, or component is not available. In the context of this Procedure ...
"unavailable or out-of-service are considered synonymous."
[The] Equipment Out of Service Monitor [is a] quantitative risk assessment tool used [to] provide output in the form of the Plant Risk lndex.
Protected Equipment - Key plant equipment or systems whose failure would substantially increase the risk of core damage or containment failure if it were to become unavailable while redundant or related equipment is out of service.
Quantitative Risk Management [is] a technique involving the use of ...
calculations to assess the risks of taking equipment out of service to perform maintenance.
Procedure No. 1.3.34, OPERATIONS ADMINISTRATIVE POLICIES AND PROCESSES Prior to granting release of equipment, a determination shall be [made for]
how long it may be released, and what functional testing of redundant systems is required prior to and during the out of service period.
For the Station Blackout Diesel Generator, any out of service time is tracked and minimized under the Maintenance Rule process.
The Pilgrim Morning Report (completed by the Shift Manager each morning) includes Sections titled "Major Equipment Out of Service" and "Other Equipment Tagged or Out-of-Service".
The Tagout Briefing Sheet includes the following question as an important consideration for discussion: Are compensatory measures needed while the equipment is out of service?
Element
- (d) of Technical Specifications 5.5, Programs and Manuals, Section 5.5.7, Configuration Risk Management Program (CRMP) is "Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action Statement."
The above examples all show that the phrase out of service means unavailable. This meaning is consistentty applied throughout Pilgrim procedures, and is neither ambiguous nor interpretive. The question is deemed valid as originally written, and therefore the correct answer remains only choice "D."
Senior Operator Question 90 The facility staff noted the stem of this question is not technically accurate. lt is not possible under any circumstances for the following stem condition to be true, " ... the digital readout for RPV "ACTUAL LEVEL" is displayed in YELLOW numbers reading
+32...". Pilgrim staff commented that number values are always displayed in white characters. Any color change occurs only on the borders surrounding the characters.
Since the question erroneously gave the numbers a color (here, YELLOW), the students concluded that significant errors were occurring with the process computer. However, no answer choice reflected problems with the computer. Therefore, Pilgrim staff proposed this question be eliminated because the technical error in the stem made the question and all the answer choices implausible.
NRC Response Comment accepted. A readout in YELLOW numbers cannot exist and so renders the question technically flawed. Therefore, this test item has been deleted from the exam.
The NRC examiners revised both the key and any affected exam scores.
.3 Initial Licensinq Examination Development
a. Examination Scope
The facility licensee developed the examinations in accordance with NUREG-1021, Revision 9, Supplement 1. All licensee facility training and operations staff involved in examination preparation and validation were listed on a security agreement. The facility licensee submitted both the written and operating examination outlines on October 23,2010. The chief examiner reviewed the outlines against the requirements of NUREG-1021, Revision 9, Supplement 1, and provided comments to the licensee.
The facility licensee submitted the draft examination package on December 2,2410.
The chief examiner reviewed the draft examination package against the requirements of NUREG-1021, Revision 9, Supplement 1, and provided comments to the licensee on the examination on December 17,2010. The NRC conducted an onsite validation of the operating examinations and provided further comments during the week of December 6,2010. The facility licensee satisfactorily completed comment resolution on January 26,2011.
b. Findinos The NRC approved the initial examination outline and advised the licensee to proceed with the operating examination development.
The examiners determined that the written and operating examinations initially submitted by the licensee were within the range of acceptability expected for a proposed examination.
No findings were identified.
.4 Simulation Facilitv Performance
a. Examination Scope
The examiners observed simulator performance with regard to plant fidelity during the examination validation and administration.
b. Findinos No findings were identified.
.5 Examination Securitv
a. Examination Scope
The examiners reviewed examination security for examination development and during both the onsite preparation week and examination administration week for compliance with NUREG-1021 requirements. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.
b. Findinos No findings were identified.
4OAG Meetinss. Includins Exit The chief examiner presented the examination results to Mr. David Noyes, Operations Manager, on April 7 ,2011. The licensee acknowledged the findings presented.
The licensee did not identify any information or materials used during the examination as proprietary.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- S. Reininghaus, Operations Training Manager
- A. Muse, Operations lnstructor
- V. Magnata, Operations Instructor
- D. Fountain, Operations lnstructor
ITEMS OPENED, CLOSED, AND DISCUSSED
NONE