IR 05000395/2015301

Er 05000395/2015301; May 4-8, 2015 & May 20, 2015; Virgil C. Summer Nuclear Station; Operator License Examinations

ML15175A414
Person / Time
Site:	Summer
Issue date:	06/23/2015
From:	Gerald Mccoy Division of Reactor Safety II
To:	Gatlin T South Carolina Electric & Gas Co
References
50-395/15-301 50-395/15-301
Download: ML15175A414 (12)

Text

UNITED STATES une 23, 2015

SUBJECT:

VIRGIL C. SUMMER NUCLEAR STATION - NRC OPERATOR LICENSE EXAMINATION REPORT 05000395/2015301

Dear Mr. Gatlin:

During the period May 4 - 8, 2015, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate the V. C. Summer Nuclear Station. 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 May 20, 2015.

All applicants passed both the operating test and written examination. There was one post-administration comment concerning the operating test, and two post-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.

The initial examination submittal was within the range of acceptability expected for a proposed examination. All examination changes agreed upon between the NRC and your staff were made according to NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1.

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) 997-4551.

Sincerely,

/RA/

Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Docket Nos: 50-395 License Nos: NPF-12

Enclosures:

1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report

REGION II==

Docket No.: 05000395 License No.: NPF-12 Report No.: 05000395/2015301 Licensee: South Carolina Electric and Gas Facility: Virgil C. Summer Nuclear Station, Unit 1 Location: Jenkinsville, South Carolina Dates: Operating Test - May 4-8, 2015 Written Examination - May 20, 2015 Examiners: M. Meeks, Chief Examiner, Senior Operations Engineer T. Hedigan, Operations Engineer (Region I)

L. Vick, Reactor Engineer (NRR)

Approved by: Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Enclosure 1

SUMMARY

ER 05000395/2015301; May 4-8, 2015 & May 20, 2015; Virgil C. Summer Nuclear Station;

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.

The operating tests were developed by members of the Virgil C. Summer (VCS) Nuclear Station staff and the written examination was developed by the NRC. The initial operating test, written Reactor Operator (RO) examination, and written Senior Reactor Operator (SRO) examination submittals met the quality guidelines contained in NUREG-1021.

The NRC administered the operating tests during the period May 4-8, 2015. Members of the VCS training staff administered the written examination on May 20, 2015. All applicants (5 ROs and 3 SROs) passed both the operating test and written examination. All applicants were issued licenses commensurate with the level of examination administered.

There were three post-examination comments.

No findings were identified.

REPORT DETAILS

4OA5 Operator Licensing Examinations

a. Inspection Scope

The NRC evaluated the submitted operating test by combining the scenario events and JPMs in order to determine the percentage of submitted test items that required replacement or significant modification. The percentage of submitted test items that were unacceptable was compared to the acceptance criteria of NUREG-1021, Operator Licensing Standards for Power Reactors.

The NRC reviewed the licensees examination security measures while preparing and administering the examinations in order to ensure compliance with 10 CFR §55.49, Integrity of examinations and tests.

The NRC administered the operating tests during the period May 4-8, 2015. The NRC examiners evaluated five RO and three SRO applicants using the guidelines contained in NUREG-1021. Members of the Virgil C. Summer (VCS) Nuclear Station training staff administered the written examination on May 20, 2015. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the VCS nuclear station, met the requirements specified in 10 CFR Part 55, Operators Licenses.

The NRC evaluated the performance or fidelity of the simulation facility during the preparation and conduct of the operating tests.

b. Findings

No findings were identified.

The NRC developed the written examination sample plan outline and the written examination. Members of the VCS training staff developed the operating test. All examination material was developed in accordance with the guidelines contained in Revision 9, Supplement 1, of NUREG-1021. 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 determined, using NUREG-1021 that the licensees initial examination submittal was within the range of acceptability expected for a proposed examination.

All applicants passed both the operating test and written examination and were issued licenses.

Copies of all individual examination reports were sent to the facility Training Manager for evaluation of weaknesses and determination of appropriate remedial training.

Various minor issues identified by the NRC during exam development and administration were entered into the licensees corrective action program as CR-15-02373. The licensee submitted one post-examination comment concerning the operating test and two comments concerning the written examination. A copy of the final written examination and answer key, with all changes incorporated, may be accessed not earlier than June 20, 2017, in the ADAMS system (ADAMS Accession Number(s) ML15173A438 and ML15173A439. A complete text of the licensees post-examination comments can be found in ADAMS under Accession Number ML15173A440.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On May 20, 2015, the NRC examination team discussed generic issues associated with the operating test with Mr. G. Lippard, General Manager Nuclear Plant Operations, and members of the VCS staff. The examiners asked the licensee if any of the examination material was proprietary. No proprietary information was identified.

KEY POINTS OF CONTACT Licensee personnel A. Barbee, Director Nuclear Training S. Billingsley, Operations Supervisor (Training)

N. Constance, Manager Nuclear Training D. Edwards, Operations Supervisor R. Goldstein, Exam Writer R. Johnston, Lead Exam Developer R. Justice, Operations Manager J. Lawter, Supervisor Simulator Engineering G. Lippard, General Manager Nuclear Plant Operations F. Lucas, Supervisor Operations Training G. McEntyre, Supervisor Initial Training S. Richardson, Exam Writer T. Stewart, Nuclear Licensing Engineer B. Thompson, Manager Nuclear Licensing NRC personnel E. Coffman, Resident Inspector

FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS

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

Accession Number ML15173A440.

Item

Job Performance Measure G - Restore Spent Fuel Pool Level During Refueling.

Comment

The licensee recommends that an additional comment be inserted for JPM step 6 to clarify the

critical elements of this step, per the below discussion.

JPM 2015 NRC Sim g, NJPS-084 required candidates to respond to a decreasing level in the

spent fuel pool in accordance with AOP-123.1, DECREASING LEVEL IN THE SPENT FUEL

POOL OR REFUELING CAVITY DURING REFUELING .

This JPM was discussed during the exam week between V.C. Summer staff and the NRC

examiners; specifically, there was a discussion as to whether it was appropriate to have step 6

indicated as a critical step. Step 6 of the JPM evaluates the performance of step 10.f of AOP-

23.1, which directs the operators to Adjust FCV-605A(B), A(B) BYP, as necessary to establish

the desired refueling water level.

The simulator was set up for this JPM with FCV-605A in a position that did not require

adjustment to allow flow from the RHR train to the RCS, therefore no adjustment was necessary

to complete the JP

M.

V.C. Summer requests that the evaluator note for NRC JPM Sim g, NJPS-084, step 6 be

revised as follows:

Evaluator note: FCV-605A must remain open in order to assure a discharge flow path from the

RHR pump to the refueling cavity/spent fuel pool. Adjustment of FCV-605A is not required;

however, it is critical that FCV-605A be left in a position that provides flow that is sufficient to

raise spent fuel level. This is evaluated in step 10 of this JPM.

NRC Resolution

The licensees recommendation was accepted.

Within the context of the JPM design, the critical element of this step is to establish an adequate

amount of makeup flow to the spent fuel pool, such that pool level is noted to be rising

(increasing). During validation, FCV-605A was adjusted and was apparently a critical step in

the JPM that needed to be performed in order to ensure adequate flow rates to the spent fuel

pool. However, during exam administration it was noted that the applicants were able to

establish rising spent fuel pool level without having to adjust the bypass valve.

The NRC agrees with the addition of the note to the examiner that more clearly specifies the

critical element that is the basis for this step, and notes the fundamentally conditional nature of

the procedural requirementAdjust FCV-605A(B), as necessary [emphasis added]. The

NRC agrees that as long as spent fuel pool levels were determined to be rising, adjustment of

FCV-605A was not a critical step in the JPM.

Item

Question 96, K/A G2.2.23

Comment

The licensee recommends that the question be deleted from the exam, per the below

discussion.

Question 96 requires the candidate to recall information contained in procedure SAP-205,

STATUS CONTROL AND REMOVAL AND RESTORATION (R&R). Section 6.10.5 in SAP-205

states that an evaluation is not required for Outage R&Rs that have been in effect for 30 days.

Since the component that is being tagged, as posed in question 96, has an LCO that is only

applicable in Modes 1 through 4, this is an Outage R&R. The approved answer D is based on

this information.

A conflicting statement, however, was identified during the examination review. The following

statement also exists in SAP-205:

5.3 Operations Administrative Clerical Support shall complete Attachment

IX for any R&R which has been in effect for greater than 30 days and

forward to the Operations Supervisor for review.

Thus, since the wording of section 5.3 specifies a review using Attachment IX for any R&R,

answer C could be construed as the correct answer.

NRC Resolution

The licensees recommendation was accepted. The applicants did not ask any questions on

this item during the written exam administration.

As noted in the licensee discussion above, the question was developed using an apparently

clear requirement listed in section 6.10 of SAP-205. However, a conflicting requirement

between section 6.10 of SAP-205 and section 5.3 of SAP-205 was also identified, as stated

above.

The NRC notes that section 5.3 clearly denotes a shall requirement, not a should or

conditional recommendation ( shall complete Attachment IX for any R&R which has been in

effect for greater than 30 days [emphasis added]), and agrees with the licensee that the

SAP-205 procedure apparently provides equally applicable, yet contradictory guidance. The

licensee has included this procedural issue into its corrective action program as part of CR-15-

2373.

NUREG 1021 ES-403 section D.1.c states, in part, that If, however, both answers contain

conflicting information, the question will likely be deleted. This is the case for question 96,

which provides as answer choices that a status evaluation will or will not be required.

Therefore, in accordance with NUREG-1021 ES-403, Question 96 is deleted from the

examination.

Item

Question 98, K/A G2.3.6

Comment

The licensee recommends that answer D also be accepted as a correct answer along with

original correct answer C, per the below discussion.

Question 98 requires the candidate to recall that the release using Reactor Building Purge must

begin within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of sampling.

HPP-0709, SAMPLING AND RELEASE OF RADIOACTIVE GASEOUS EFFLUENTS, section

5.1.2.B reads as follows:

B. A full set of grab samples (Gas, Particulate, Iodine, and Tritium) are

required to initiate a Main Plant Vent or Reactor Building Purge

(Attachment VI) permit.

Thus, the release permit is initiated after samples are taken. Further actions are as follows:

• Results are analyzed and Radiation Monitor setpoints are calculated in follow on steps.

• Data is recorded and then pre-release approval by the HP organization is entered on

the release permit per section 5.1.2.K.

• The permit is forwarded to the control room in step 5.1.2.L.3.

• When the shift is ready to begin the actual release, the permit will be approved in

section II. Of the release permit entitled ACTUAL RELEASE DATA (Operations).

Since the sequence prior to beginning of the release requires sampling first, with approval for

release by the Shift Supervisor after, then D can be construed as an additional correct answer.

Additionally, Section 5.1.2.L.8 states the following:

8. COMMENCE releases from the Reactor Building within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from

time of sample.

In accordance with the conditions posed in question 98, the following items are true:

• Operations approval of the Release Permit occurred after samples were taken.

• 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and 30 minutes have passed since the Operations Approval of the permit.

• The release had not been previously begun and interrupted.

It can be logically assumed that if more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since approval of the permit,

then more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since sampling occurred; therefore, a release is

prohibited.

NRC Resolution

The licensees recommendation was rejected. The applicants did not ask any questions on this

item during the written exam administration.

As noted above, the clear procedural requirement is that Reactor Building releases must be

started within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from the time of sample.

For Question 98, answer choice C reads: The release can not be started because more than

hours have passed since the containment air sample. Answer choice D reads: The

release can not be started because more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since approval of the

release permit. For both answer choices, the key word to analyze is because.

Websters Ninth New Collegiate Dictionary defines the word because as 1: for the reason that

SINCE . Using this definition, distractor C could be re-written as The reason that the

release can not be started is more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since the containment air

sample. In accordance with the procedural requirement, this re-write of distractor C is a true

statement. Now, using the same definition, distractor D could be re-written as The reason

that the release can not be started is more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have passed since approval of the

release permit. In accordance with the procedural requirement, this re-write of distractor D is

not true, in that it does not express the correct reason why the release may not be commenced.

Based on this discussion, answer choice C will be retained as the only technically correct

answer to Question 98, and the answer key will not be modified.

SIMULATOR FIDELITY REPORT

Facility Licensee: Virgil C. Summer Nuclear Station

Facility Docket No.: 05000395

Operating Test Administered: May 4-8, 2015

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.

While conducting the simulator portion of the operating test, examiners observed the following:

Item Description

SDR #556 During exam development and validation of simulator JPMs, NRC

examiners questioned whether Diesel Generator (D/G) automatic

protective trips were correctly modeled on the simulator.

SDR #555 During exam administration of one simulator scenario, the A

Service Water Booster Pump (SWBP) did not automatically start

upon receipt of a Safety Injection signal, as expected. This failure

to automatically start was not part of the scenario design.

However, the A SWBP did correctly auto-start during the other

two instances that this scenario was administered.

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