ML20154H564
| ML20154H564 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/03/1986 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| References | |
| NUDOCS 8603100322 | |
| Download: ML20154H564 (22) | |
Text
3 MAR 1986 Docket No. 50-29 Yankee Atomic Electric Company ATTN:
Mr. L. H. Heider Vice President of Operations 1671 Worcester Road Framingham, Massachusetts 01701
Dear Mr. Heider:
Subject:
Appeal of Yankee Licensing Examinations In response to your letter of January 17, 1986, regarding failed written examinations for seven license applicants at the Yankee Station, my staff has reviewed the detailed comments you provided as part of the appeal process.
The evaluation of this review has been documented and I am forwarding it to you for your information in advance of our meeting on Friday, March 7, 1986.
I am not making a decision at this time as to the disposition of each of the candidates appeals; nor have I declared the examination invalid, as you suggested.
I envision that the forthcoming meeting will provide th.e opportunity for candidly discussing the examination content and quality such that we can make a more informed decision as to the disposition of the results.
Sincerely, C7h 0^fY Richard W. Starostecki, Director Division of Reactor Projects
Enclosure:
As Stated cc w/ encl:
N. N. St. Laurent, Plant Superintendent J. E. Tribble, President G. J. Papanic, Jr., Senior Project Engineer - Licensing Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2) bcc w/ encl:
Region I Docket Room (with concurrences)
DRP Section Chiefe M. McBride, RI, Pilgrim W. Raymond, SRI, Vermont Yankee J.
.lifford, LPM, NRR R. RP St rostecki/grm 3/3/86 O y ck 9603100322 060303 PDR ADOCK 05000029 g
V PDR t
1 COMMENTS ON YANKEE APPEAL
GENERAL COMMENT
S 1.
Yankee commented that the exam was too long. RO exam had 45 questions, while the SRO had 44 questions. Some had several parts, mostly short answer type. Counting the number of responses may not give a true measure of the length of the exam. A rule of thumb also is that each section should be able to be completed in approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Each section had no more than 13 questions, most of which could be answered in 3 to 4 minutes.
2.
A comment was made t h at. the GRO exam included questions from the RO exam. This was hy intent, since 10CFR55.22 states that subjects for the SRO exam shall include those on the RO exam, as given in 10CFR55.21.
3.
Shutdown margin questions related to several different aspects, such as Definitions, Effects of Operation, Procedures, and Tech. Spec. Requirements.
4.
Normal, abnormal and emergency procedures are required for the written exams, as provided in 10CFR55.21 and
.22.
Questions were discussing overall understanding of precautions, limitations, and general methods of carrying out procedures, not detailed memorization. Candidates received credit for understanding, not memory.
5.
Question 4.08 related to an Emergency Procedure on Loss of 125V DC Bus, obviously a critical procedure. Immediate Actions were asked for.
6.
An understanding of reacti vi ty coef ficients is essential for an operator.
7.
Examiners must use judgement in deciding what areas to cover in the written exam. Most examiners will refrain from asking the "Old Chestnuts" which simply probe the candidate's ability to recall facts. A great effort has been made to improve the " Operational Orientation" of exams. An examiner may intentionally not ask questions on certain areas, with the intention of asking those areas on the oral exam.
8.
10CFR55.21 and.22 require the candidate to demonstrate an understanding of plant systems and equipment which may be important to safety. The Examiner Standards provide guidance on specific areas which may be asked. It appeare that the licensee either does not agree with the NRC as to what areas chould be taught, or the candidates were not properly instructed and evaluated.
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RESOLUTION OF SPECIFIC COMMENTS ON YANKEE APPEALS l
ITEM NO.
COMMENTS G-1 It appears that there is a misunderstanding or disagreement between the licensee and the NRC as to the level of detailed knowledge, required by the regulations, for RO's and SRO's. This is reflected throughout the appeal justification.
10CFR55.21 states that, "The operator written examination, to the extent applicable to the facility, will include questions on:
...(j)
Standard and emergency operating procedures for the facility and plant.
Further guidance is provided in the Examiner Standards, NUREG-1021, ES-202, as follows:
"D.4
...The candidate is not expected to have normal procedures committed to memory, but should be able to explain reasons, cautions, and limitations of normal operating procedures. In general, the candidate must demonstrate complete knowledge and understanding of the symptoms, automatic actions, and immediate action steps specified by abnormal and emergency procedures.
Administrative procedures, including operating restrictions, limitations in the facility license, and Technical Specifications, may be l
included to the extent they are applicable to an I
operator and the safe operation of the facility."
"E.2 Memorization of symptoms and automatic and operator actions of all procedures that require immediate action is necessary for the examination."
These policies have been followed by the NRC in conducting licensing exam for many years, at Yankee and other facilities.
2 G-2 The quality and completeness of the training material, provided to the candidates during training, and to the NRC in preparation for the examinations, has a direct bearing on the quality and technical content of the exam. The quality and completeness of the i
training material for Yankee has been a long-standing concern of the NRC Operator Licensing staff. On many occasions, examiners have expressed dissatisfaction with the completeness or currency of training material provided by the licensee. For example:
System descriptions were not provided for Main Steam System Fire Protection System Reactor Vessel and Internals Waste Disposal Systems Vapor Container Fuel Handling Emergency Diesel Generator In some cases, these systems are discussed, briefly in other training material.
Changes made to major systems are not reflected in training material. For example:
Reactor vessel and pressuri=er vents, which were installed in early 1985, are not mentioned in the System Descriptions, or MCS Operating Procedures.
J.,
3 Lesson Plans are extremely sparse, relying compl etel y on the knowledge and experience of the instructor to impart the necessary information. A typical Lesson Plan, on the Main Steam System, consisting of 2 pages, for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of lectures, consists of the following:
Location of training 20 Objectives List of activities, such as:
"Use overheads of the main steam system to illustrate various components, their location and function."
" Discuss Tech. Specs. associated with this system."
Materials needed Equipment needed Evaluation (Duiz, 70% minimum)
References There is no list of key topics for the lesson, detailed areas to discuss,'or other instructor guidance.
G-3 Answer key was corrected, based on post-exam review by the training staff, and candidate's exam graded using corrected key.
G-4 Cuestion comes under reference 10CFR55 section.
G-5 Question comes under reference Examiner Standard section.
G-6 Answer key does not require information in parenthesis. This is used for grader's inf ormati on onl y.
4 SPECIFIC COMMENTG ON YANKEE RO APPEALS CATECORY I: CONFUSING OUESTIONS QUESTION RESOLUTION COMMENTS 1.02 Disagree Dased on the answers given, the candidates understood the question. 2 of 4 candidates missed part b.
All other answers were correct.
1.03 Disagree Question and solution taken from the Reactor Operator Training Manual (ROTM), 3-176.
1.06 Disagree Question taken from ROTM, 3-252, where a similar problem 1s discussed.
1.07 Disagree Candidates who stated assumptions were given p
credit based on those assumptions.
1.08 Disagree Question stated the assumption that the thermocouple was located in the leakage stream.
1.10 Disagree Question was taken verbatim from the ROTM review questions, 2-62, Question #9.
2.05B Disagree Suujective comment. Question asked:
" Describe the pressure interlock associated with the SDC isolation valves. Include the purpose of the interlock."
Answer key required 2 parts:
Valves won't open unless PRZR < 375 psig and Purpose is to prevent overpressurization of SDC system.
3.01 Agree Designation was taken from the Systems Training Manual (STM), 21-0, where only val.ve numbers are used, without description.
All the candidates understood the valve number in their answers.
3.02 Disagree Subjective comment. Question asked:
" Describe how a loss of control air pressure will affect the #1 and #3 charging pump."
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Loss of control air to the charging pumps in discussed in detail in STM 15-24.
3.05C Disagree Subjective comment. Question asked:
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"At what point during an MCS cooldown is the NRV auto close blocked?"
i Answer required "1800 psig", as given in ROTM 6-05,
-93, -94.
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3.09 Disagree Subjective comment. Question asked:
"After a trip condition has cleared, in what modu-i (auto or manual) should MS-PCV-402 be j
shifted to recover the valve?"
Answer required an understanding that valve should not be returned to auto, so that valve would not introduce a transient by popping open.
4 3.10 Disagree Question taken from ROTM, 9-1-7, which states that
" decreasing the field current by lowering the generator voltage will shed inductive load and improve the generator Power Factor."
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b CATEGORY.II: INAPPROPRIATE QUESTIONS 1.07 Disagree Re'f 110CFR55.21.te) and ES-202.D.1 Candidate should understand principles of core thermodynamics such that undetected AFW flow would result in core power being higher that
, indicated power after adjusting the power range channels.
4 1.09 Disagree Reft f0CFR55.21.(e) and ES-202.D.1 2.06 Disagree Ref: 10CFR55. 21. (g) and ES-202.D.2 s 2.09D Disagree G-6'comhent above 3
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q-Those who gave direction of change were given full credit for that part on grading.
3.06 Disagree Ref: 10CFR55. 2t. (g) s Answer key required " higher than actual" to show understanding of response.
. s 3.08 Disagree Ref: 10CFR55.21.(d)
'G-6--comment above 3.10ALB Disagree Ref: 10CFR55.21.(d) & (e) 4.01D Disagree Full credit was given without numerical value.
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4.10 Disagree Ref: 10CFR55.21. (j) and ES-202.B.4 x
OP-2151, Precautions #4 4.12A Disagree Ref: 10CFR55.21.(e) and ES-202.D.4 Question did not ask for memorization, but for limits, giv n in OP-2100
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7 CATEGORY III: QUESTIONS REQUIRING TOO MUCH DETAIL QUESTION RESOLUTION COMMENTS 2.02 Disagree Candidates did not lose points for not giving numerical value. Thrust of question was to determine whether candidates understood rate protection feature of aux. governor.
2.05 Disagree G-6 comment above 2.06A Disagree Ref: 10CFR55.21.(d) & (g) 2.00D&C Disagree Question asked :
" List the Condensate Pump automatic trips" Ref: 10CFR55.21.(d) & (e) 3.01C Disagree Ref: 10CFR55. 21. ( J ) and ES-202.B.4 3.04A&B Disagree Ref: 10CFR55.21.(d) & (g)
Credit was given for i ntent without exact wording in procedure.
3.05C Disagree Ref: 10CFR55.21.(g) i Candidate should know enough about plant procedures to be able to state prerequisites for steps I
such as blocking important valve operation 3.07 Disagree Ref: 10CFR55.21(g)
Question asked for knowledge of the 4 functions of the LTOP system key interlock.
3.10A&B Disagree Ref: 10CFR55.21.(d) & (e) and ES-202.D.3 4.01D Disagree Ref: 10CFR55. 21. ( J ) and ES-202.D.4 Question asked "Why must water treatment 4
system be restarted as soon as practical?"
3
> a 4.03 Agree Question has been deleted from the exam as a result of the appeal. Actions required after 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> would not be considered immediate.
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B 4.04
. Disagree Credit was given for giving intent of procedure (not drawing in smoke from outside)
Immediate Action in OP-3111 4.07 Disagree Ref: 10CFR55.21. (j ) and ES-202.E.2 Note is part of Immediate Action in OP-3115 4.08 Disagree Ref t 10CFR55. 21. (J ) and ES-202.E.2 Immediate Action in OP-3257 4.10 Disagree Ref 10CFR55.21. (J ) and ES-202.D.4 Precautions in OP-2151
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9 CATEGORY IV: QUESTIONS WHICH DO NOT SOLICIT RESPONSES IN THE ANSWER KEY CUESTION RESOLUTION COMMENTS 1.04A Agree G-3 comment above 1.04C Disagree Ref: 10CFR55.21.(c) and (d) 1.04D Agree Burnable poison rods discussed in ROTM, 3-208 (first core only). Did not affect original grading.
1.09 Disagree Question was taken from ROTM 2-43.
1.10 Agree G-3 comment above 1.12 Agree Credit was given in original grading if candidate understood that power decreased without actual level.
2.01A Agree Alternate answers were allowed during original grading.
Disagree OP-3203 and ROTM contain n'o indication that SIT can be used to provide water supply to the EBFP's (SI pumps through blowdown lines but not from SIT) 2.02 Disagree Thrust of question was the rate protection feature. Points were taken off if candidate did not provide that purpose of the system.
2.02B Disagree ROTM 6-41 states that closure of all control valves (by aux. govnr) will scram reactor (i f "at power scrams" are not blocked) causing reactor trip.
2.03B Disagree ROTM 9-3-1 states "59-1 Voltage Relay allows auto closure of EG-1 when generator voltage is >=
460 volts" 2.06D Agree G-3 comment above 2.07 Disagree Training material (STM 17-h1, OP-2167) contain no mention of electric heater, only steam heater.
Disagree Ref: 10CFR55.21.(j).
RO is responsible to perform operations in the field as well as in the control room.
10 2.07C Agree See G-3 comment above 2.08 Disagree STM,3-19 states:
"The purpose of this valve is to provide adequate flow though the air ejector and 91and steam condenser following a reactor scram to maintain a condenser vacuum after a plant trip."
2.08D Agree Candidate given +.2 from appeal 3.01 Disagree STM Figure 21-8 shows GD cooler is on SDC pump discharge. STM, 21-8 also states that controller senses pump suction temperature.
3.02B Agree Candidates given full credit during original grading for local / manual operation.
Disagree Ouestion asked " Describe how each of the three charging pumps can be used..."
3.04A Agree 10 second time delay not required during grading.
3.04D Disagree Question did not ask for T.S limit. Asked "What interlock must be satisfied for loop stop valve to open?" Answer contained in STM.13-20,
-21.
3.05B Agree Candidates given credit for correct answers on appeal.
3.06 Agree Candidates given credit for correct answer on appeal.
3.07 Disagree Ref: 10CFR55. 21. (c)
STM,14-20 states that detector receives signal from loop #1 hot leg of MCS.
3.09 Disagree EDC 83-03 states that valve was installed.
Training material is silent on use of the valve.
3.11A Disagree OP-3100 lists bleed line and the AARM.
3.11C Disagree OP-3100 gives methods to reduce the radiological effects as given in the answer Ley. Candidates received credit for intent of procedure without exact words.
11 4.03 Agree Question deleted on appeal.
4.08 Agree G-3 comment above 4.10B Disagree Ref 10CFR55. 21. ( j ) and ES-202.B.4 OP-2151 provides limits of 1000 psig and >=330 F m-.
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CATEGORY V.t PROBLEMS WITH GRADING TECHNIQUES QUESTION RESOLUTION COMMENTS 1.07 Disagree Candidate explained HOW but not WHY as asked for in question.
1.08 Disagree Math error was adding 50 degrees instead of subtracting to determine subcooling. Did not understand principles of subcooling.
i 1.11 Disagree Candidate stated effect on DND but could not relate that to change in DNBR.
1.12 Agree Candidate given.25 on appeal.
2.01 Agree Candidate given.50 on appeal.
2.03 Agree Candidate given.25 on appeal.
2.04 Disagree Tech. Spec. limit given as 473 psig +-
10 psi. Answer given demonstrated a lack of i
detailed knowledge. (Other candidates gave 473 psig) 2.04C Disagree STM 19-54 states that 100 psig Nitrogen i s used to open trip valves. Opening a valve is not the same as keeping the valve closed.
2.05 Agree
.5 deducted from two candidates. Did not give purpose, gave description only.
2.07 Agree Two candidates given.50 on appeal.
2.09 Disagree STM 13-10 gives requirements (250 psig or 200 psi above saturation). Candidates did not answer the question.
3.03 Disagree STM,34-15 lists 3 causes of " rods in motien" signal, as given in answer key.
3.09 Disagree Candidate did not demonstrate understanding of purpose of procedure (Valve should be operated in manual so it would not pop open.)
3.11 Agree Candidates given.75 and.5 on appeal.
4.04 Agree See G-3 comment above i
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13 4.05 Disagree Answers given, while possibly true, did not provido correct as "GO/NO-GO" decisions for diagnostics.
4.07 Disagree Candidate lost.25 of 1.5 for inaccuracy.
4.09 Disagree 3 of 4 candidates followed instructions in the exam. One listed emergencies backwards, for which he received 50% credit.
4.10 Disagree Candidate did not answer second part of question as to when each path is used.
4.12 Disagree OP-2100 lists 2 requirements (500 psi NDT margin, and dedicated operator)
e 14 SPECIFIC COMMENTS ON YANKEE SRO APPEALS CATEGORY I: CONFUSING OUCSTIONS QUESTION RESOLUTION COMMENTS 5.01 Disagree See comment on RO:I 1.00 above 5.04 Agree All candidates received credit on regrade in the Region before denial.
5.10B Agree Candidates did not lose points because rods do not move out in auto.
- 6.05 Disagree See comment on RO:I 3.02 6.07 Disagree See ccmment on RO I 3.05 6.09 Disagree See comment on RO I 3.09
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1G CATEGORY II: INAPPROPRIATE OUESTIONS OUESTION RESOLUTION COMMENTS 5.02 Agree Question deleted on appeal.
5.13 Disagree Ref: 10CFR55.22.(e) and ES-402.A.1 6.04 Agree Candidates received ful) credit f or showing direction of change and why.
7.03 Disagree Ref: 10CFR55.21.(j) and ES-402.A.3 7.04 Disagree Ref: 10CFR55. 21. ( J ) and ES-402.A.3 7.06 Disagree Ref: 10CFR55.21.(j) and ES-402.A.3 7.07 Disagree See comment on RO II:4.12 7.09 Disagree Ref: 10CFR55.21.(g)
Question did not ask for memory recall. SRO should know where to go for alternate indication of critical par'ameters.
8.01 Disagree Ref: 10CFR55.22.(a) and ES-402.A.8 8.04 Disagree Ref: 10CFR55.22.(a) and ES-402.A.B 8.05 Agree Question deleted on appeal 8.08 Disagree Ouestion relates to action required to save lives of injured in a radiation field.
Comment borders on an unacceptable safety attitude by the licensee.
8.10 Disagree Ref: 10CFR55.22.(a) and ES-402.A.4
16 CATEGORY III:OUESTIONS REOUIRINO TOO MUCil DETAIL OUESTION RESOLUTION COMMENTS 5.04 Agree Credit given for either answer during Regional review prior to denial.
5.07 Disagree Ref: 10CFR55.22(e) and ES-402.A.1 5.09 Disagree Comment does not relate to question or answer. Question taken from ROTM 3-97.
6.01 Disagree Numerical answer not required. Candidate received full credit if he gave purpose.
6.06 Disagree See comment on RO IV:3.04 6.07 Disagree See comment on RO III:3.05 6.00 Disagree Ref 10CFR55.21.(g) 6.10 Disagree See comment on RO IV 3.11 7.02A&B Agree Ouestion deleted on appeal 7.04 Disagree See comment on RO II:4.10 7.05 Disagree Ref: 10CFR55. 21. ( j )
Question asked for precautions not memory recall.
7.06 Disagree Ref: 10CFR55. 21. ( j )
7.07 Disagree Ref: 10CFR55.22.(a) 7.09 Disagree See comment on SRO II:7.09 0.09 Disagree Ref: 10CFR55.22.(J) 8.10 Disagree Ref: 10CFR55.22.(a)
17 CATEGORY IV: QUESTIONS WHICH DO NOT SOLICIT RESPONSES IN THE ANSWER KEY OUESTION RESOLUTION COMMENTS 5.OC6]A Agree Both answers accepted. One car.didate received.3 on appeal 5.Ot6]B Disagree Comment does not relate to question or answer.
5.06 Do not understand comment 5.07B Agree Candidates given
.5 for correct answer on appeal.
One candidate lost
.5 for incorrect answer on appeal.
Answer key and grading corrected in Region prior to denial on Part 3.
5.11 Agree Comment did not affect grading or credit given 5.12 Comment not relevant to question or answer 5.13 Comment not relevant to question or answer 6.01A Aaree One candidate given
.5 on appeal 6.01D Agree Full credit given #or answer in comment on original grading.
6.03 Agree Training material does not reflect the addition of an electric heater.
6.03C Agree Question deleted prior to grading 6.05D Di sagree See comment on RO IV:3.02B 6.06 Disagree See comment on RO IV:3.04 6.07 Disagree See comment on RO'III:3.05 6.09 Disagree EDC 83-03 contained reason and precaution 6.10 Disagree See comment on RO IV:3.11 7.04 Disagree Ref: 10CFR55.21.(J) and ES-402.A.4 7.04C Disagree Comment not relevant to question or answer
18 7.10 Disagree Ref: 10CFR55. 21. ( j )
Key had 2 required answers, as given in OP-3254 8.03 Agree Question deleted prior to grading i
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s 19 CATEGORY /r PROBLEMS WITH GRADING TECHNIQUES QUESTION RESOLUTION COMMENTS 5.12 Agree Candicate given.25 on appeal 6.01A Disagree Candidate did not show understanding of rate protection feature (STM,6-41) 6.01B Disagree STM 6-41 states that reactor and turbine will trip 6.02 Disagree See comment on RO IV 2.03B One candidate lost
.5 on appeal for incorrect original grading (gave 460 v) 6.04 Disagree STM 13-10 provides limits.
6.05 Agree One candidate given 2.0 on appeal. Other stated motor still runs.
6.10 Disagree See comment on RO IV:3.11 Agree Grader's comment was inappropriate Agree Grader's comment " ASAP" was incorrect.
Candidato did not lose credit for not saying " ASAP" Disagree Ref: 10CFR55.21.(j)
Question related to important casualty and should not be deleted.
7.02 Agree Question deleted on appeal 7.04 Disagree See comment on RO II:4.10 7.12 Disagree Question asks candidates to provide classification criteria for major accidents.
1 candidate gave correct criteria. Other 2 gave either incorrect or incomplete answers. Verbatim nords were not required for full credit.
0.07 Disagree OP-3321 states " Plant stable and not likely to worsen."
Candidate gave "When EAL 's are met. for next lower level." These are not the same.
20 8.00 Disagree See comment on SRO II:8.OO O.09 Disagree Procedure requires the 15 minutes to start from recoonition that event warrants classification.
Candidate said time started when the accident is classified. These are not the same.
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