ML090721095

Er 05000416-09-301; March 3-10, 2009; Grand Gulf Nuclear Station; Initial Operator Licensing Examination Report

ML090721095
Person / Time
Site:	Grand Gulf
Issue date:	03/12/2009
From:	Ryan Lantz Operations Branch IV
To:	Douet J Entergy Operations
References
ER-09-301 50-416/09-301
Download: ML090721095 (11)

See also: IR 05000416/2009301

Text

March 12, 2009

James R. Douet Vice President Operations Entergy Operations, Inc. Grand Gulf Nuclear Station P.O. Box 756

Port Gibson, MS 39150

SUBJECT: GRAND GULF NUCLEAR STATION - NRC EXAMINATION REPORT 05000416/2009301

Dear Mr. Douet:

On March 10, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an examination at Grand Gulf Nuclear Station. The enclosed report documents the examination findings, which were discussed on March 5, 2009, with yourself, Messrs. Jeremy Browning, Plant Manager, Ernest Mathes, Assistant Operations Manager for Training, Jim Caery, Training Manager, and other members of your staff.

The examination included the evaluation of two applicants for reactor operator licenses, two applicants for instant senior operator licenses, and two applicants for upgrade senior operator licenses. The written examinations and operating tests were developed using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The license examiners determined that all applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.

A licensee-identified Severity Level IV violation is listed in Section 4OA7 of this report. The NRC is treating this violation as a non-cited violation consistent with Section VI.A.1 of the NRC

Enforcement Policy because it is a Severity Level IV violation and because it is entered into your corrective action program. If you contest this non-cited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 612 East Lamar Blvd., Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Grand Gulf Nuclear Station. UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION IV612 EAST LAMAR BLVD, SUITE 400ARLINGTON, TEXAS 76011-4125

Entergy Operations, Inc. - 2 -

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 (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/ BWStapleton for Ryan E. Lantz, Chief Operations Branch Division of Reactor Safety

Docket: 50-416 License: NPF-29

Enclosure: NRC Examination Report 05000416/2009301 w/Attachment: Supplemental Information

cc w/Enclosure: Senior Vice President Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995

Senior Vice President and COO Entergy Operations, Inc. P. O. Box 31995 Jackson, MS 39286-1995

Vice President, Oversight Entergy Services, Inc. P. O. Box 31995 Jackson, MS 39286-1995

Entergy Operations, Inc. - 3 -

Chief, Energy and Transportation Branch Environmental Compliance and Enforcement Division

Mississippi Department of Environmental Quality P. O. Box 10385 Jackson, MS 39289-0385

President Claiborne County Board of Supervisors 510 Market Street Port Gibson, MS 39150

Senior Manager

Nuclear Safety & Licensing Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995

Manager, Licensing Entergy Operations, Inc. Grand Gulf Nuclear Station P. . Box 756 Port Gibson, MS 39150

Attorney General Department of Justice State of Louisiana P. O. Box 94005

Baton Rouge, LA 70804-9005

Office of the Governor State of Mississippi P.O. Box 139

Jackson, MS 39205

Attorney General Assistant Attorney General State of Mississippi P. O. Box 220 Jackson, MS 39205

Entergy Operations, Inc. - 4 -

State Health Officer State Health Board P. O. Box 1700

Jackson, MS 39215

Associate General Counsel Entergy Nuclear Operations P. O. Box 31995

Jackson, MS 39286-1995

Louisiana Dept. of Environmental Quality Radiological Emergency Planning and Response Division P. O. Box 4312 Baton Rouge, LA 70821-4312

Entergy Operations, Inc. - 5 -

Electronic distribution by RIV: Regional Administrator (Elmo.Collins@nrc.gov) Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov) DRP Deputy Director (Anton.Vegel@nrc.gov) DRS Director (Roy.Caniano@nrc.gov) DRS Deputy Director (Troy.Pruett@nrc.gov) Senior Resident Inspector Rich.Smith@nrc.gov) Resident Inspector (Andy.Barrett@nrc.gov) Branch Chief, DRP/C (Geoffrey.Miller@nrc.gov) Senior Project Engineer, DRP/C (Wayne.Walker@nrc.gov) GG Site Secretary (Nancy.Spivey@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)

ML SUNSI Rev Compl. Yes No ADAMS Yes No Reviewer Initials GWA Publicly Avail Yes No Sensitive Yes No Sens. Type Initials GWA OE:OB OE:OB SOE:OB SOE:OB C:PBC C:OB GWApger SHedger BTLarson SGarchow GMiller RELantz

/RA/ /RA/ /RA/ /RA//RA//RA/ 03/11/09 03/11/09 03/11/09 03/11/09 03/11/09 03/12/09 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

- 1 - Enclosure

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket: 50-416 Licenses: NPF-29

Report No.: 05000416/2009301

Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: Waterloo Road Port Gibson, Mississippi 39150 Dates: March 3 - 10, 2009 Inspectors: Steve Garchow (Chief Examiner) Gabriel Apger (Examiner, Chief Examiner Under Instruction) Brian Larson (Examiner) Sean Hedger (Examiner Under Instruction) Approved By: Ryan E. Lantz

- 2 - Enclosure SUMMARY OF FINDINGS

ER05000416/2009301; March 3-10, 2009; Grand Gulf Nuclear Station; Initial Operator

Licensing Examination Report.

NRC examiners evaluated the competency of two applicants for reactor operator licenses, two applicants for instant senior operator licenses, and two applicants for upgrade senior operator licenses at Grand Gulf Nuclear Station.

The licensee developed the examinations using NUREG-1021, "Operator Licensing

Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examinations were administered by the licensee on March 9, 2009. NRC examiners administered the operating tests on March 3 - 5, 2009.

The examiners determined that all applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Violations

A licensee identified Severity Level IV non-cited violation has been reviewed by the examiners. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and its corrective action tracking numbers are listed in Section 4OA7 of this report.

- 3 - Enclosure REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA5 Other Activities (Initial Operator License Examination)

.1 License Applications

a. Scope NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. Examiners also audited three of the license applications in detail to confirm 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. Findings

No findings of significance were identified.

.2 Examination Development

a. Scope NRC examiners developed the outlines, written examinations and portions of the operating tests. The NRC staff submitted the operating test outlines and test material to the licensee to validate and finalize for submittal as draft operating tests. NRC

examiners reviewed the draft operating tests submitted by the licensee against the requirements in NUREG-1021.

b. Findings

NRC examiners provided draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.

NRC examiners determined that the draft operating tests submitted by the licensee did

not meet the requirements of NUREG-1021. Specifically, the simulator scenario "Applicant's Actions" portion of the Form ES-D-2 did not contain sufficient detail. Errors in identifying malfunctions were found. The job performance measures were not validated, and they contained numerous technical, formatting and grammatical errors. A contributing factor is the licensee replaced the operating test developer two weeks before on-site validation, and had no process in place to ensure the developer effectively implemented the requirements of NUREG-1021.

- 4 - Enclosure .3 Operator Knowledge and Performance

a. Scope On March 9, 2009, the licensee proctored the administration of the written examinations

to all six applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on March 10, 2009.

The NRC examination team administered the various portions of the operating tests to all applicants on March 3 - 5, 2009.

b. Findings

No findings of significance were identified.

All applicants passed the written examination and all parts of the operating test. The final written examinations, operating tests and post-examination analysis can be

accessed in the ADAMS system under the accession numbers noted in the attachment. There were no post-examination comments as indicated in a letter received from the licensee, dated March 9, 2009.

.4 Simulation Facility Performance

a. Scope The NRC examiners observed simulator performance with regard to plant fidelity during examination validation and administration.

b. Findings

No findings of significance were identified.

.5 Examination Security

a. Scope The NRC examiners reviewed examination security for examination development during

both the onsite preparation week and examination administration week for compliance with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.

b. Findings

A compromise of the simulator scenario portion of the operating test occurred during

examination development that resulted in the licensee-identified non-cited violation documented in section 4OA7 of this report. The finding is being treated under traditional enforcement because the violation, if not found or corrected, had the potential to impede the NRC's regulatory function. Specifically, licensing decisions could have been made based on an invalid and compromised examination. To ensure a valid examination, the

following changes were made to the simulator scenario portion of the operating test:

- 5 - Enclosure

• All four scenarios were removed from the examination, and

• Two new scenarios were developed by the NRC and the facility during the onsite validation week. There was no overlap with any of the removed scenarios.

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Mr. James R.

Douet and members of his staff on March 5, 2009. A telephonic exit was conducted on March 11, 2009 between Messrs. Gabriel Apger, Examiner, and Bruce Bryant, Operations Training Superintendant, Initial.

The licensee did not identify any information or materials used during the examination

as proprietary.

4OA7 Licensee Identified Violations

The following Severity Level IV violation was identified by the licensee and is a violation of NRC requirements that meets the criteria of Section VI of the Enforcement Policy, NUREG 1600, for being dispositioned as a Non-Cited Violation.

• 10CFR55.49 states in part: "Applicants, licensees, and facility licensees shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination." Contrary to the above, during scenario development in

December of 2008, the facility licensee left unsecured examination scenario paperwork on the simulator printer. The paperwork for one of the four scenarios was discovered by a facility licensee contractor on January 27, 2009 during onsite validation with the NRC examination team. The facility licensee immediately reported this to the NRC chief examiner and entered this into their

corrective action program under CR-CGN-2009-00388. Because the paperwork was left on the printer for approximately one month; the facility licensee could not definitively determine that the other three scenarios had not been printed; and applicants were inside the simulator within eyesight of the printer, the NRC Chief Examiner determined that the integrity of the simulator scenario portion of

the examination had been compromised. This is a Severity Level IV violation because it was a unintentional compromise of the examination, it was discovered and reported by the licensee, and the compromised portion of the examination was replaced prior to making licensing decisions.

ATTACHMENT: SUPPLEMENTAL INFORMATION

A-1 Attachment SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

Randy Douet, Site Vice President

Jeremy Browning, Plant Manager Jim Caery, Training Manager Ernest Mathes, Assistant Operations Manager, Training Charles Roberts, Operations Training Superintendant, Requalification Bruce Bryant, Operations Training Superintendant, Initial

Rita Jackson, Licensing Will Ryder, Exam Team Kyle Grillis, Exam Team

NRC Personnel

Richard Smith, Senior Resident Inspector

ADAMS DOCUMENTS REFERENCED

Accession No. ML090700248 - FINAL WRITTEN EXAMS Accession No. ML090700228 - FINAL OP TEST Accession No. ML090700256 - POST EXAM COMMENTS-ANALYSIS