IR 05000440/2017301

NRC Initial License Examination Report 05000440/2017301

ML17103A591
Person / Time
Site:	Perry
Issue date:	04/13/2017
From:	Robert Orlikowski Operations Branch III
To:	Hamilton D FirstEnergy Nuclear Operating Co
References
50-440/17-01 50-440/OL-17
Download: ML17103A591 (13)

Text

UNITED STATES ril 13, 2017

SUBJECT:

PERRY NUCLEAR POWER PLANT - NRC INITIAL LICENSE EXAMINATION REPORT 05000440/2017301

Dear Mr. Hamilton:

On March 15, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed the initial operator licensing examination process for license applicants employed at your Perry Nuclear Power Plant. The enclosed report documents the results of those examinations. Preliminary observations noted during the examination process were discussed on February 10, 2017, with yourself and other members of your staff. An exit meeting was conducted by telephone on March 23, 2017, with yourself, members of your staff, and Mr. D. Reeser, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation, NRC resolution of the stations post-examination comment, initially received by the NRC on February 23, 2017, were discussed.

The NRC examiners administered an initial license examination operating test during the week of February 6, 2017. The written examination was administered by Perry Nuclear Power Plant training department personnel on February 16, 2017. Four Senior Reactor Operator (SRO) and six Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on March 23, 2017. One applicant failed one or more sections of the administered examination and was issued a proposed license denial letter. Nine applicants passed all sections of their respective examinations; one applicant was issued a senior operator license and six applicants were issued operator licenses. In accordance with NRC policy, the licenses for the remaining two SRO applicants are being withheld pending written certification that the applicants have completed the deferred portion of the six-month on-site experience required by the National Academy for Nuclear Training Guidelines for Initial Training and Qualification of Licensed Operators.

The administered written examination and operating test, as well as documents related to the development and review (outlines, review comments and resolution, etc.) of the examination will be withheld from public disclosure until April 1, 2019. However, since an applicant received a proposed license denial letter, the applicant will be provided a copy of the portion of the examination that was not successfully completed. For examination security purposes, your staff should consider that portion of examination uncontrolled and exposed to the public. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Robert J. Orlikowski, Chief Operations Branch Division of Reactor Safety Docket No. 50-440 License No. NPF-58

Enclosures:

1. OL Examination Report 05000440/2017301 2. Post-Examination Comments, Evaluation, and Resolutions 3. Simulation Facility Fidelity Report

REGION III==

Docket No: 50-440 License No: NPF-58 Report No: 05000440/2017301 Licensee: FirstEnergy Nuclear Operating Company Facility: Perry Nuclear Power Plant Location: North Perry, Ohio Dates: February 6 through March 15, 2017 Examiners: D. Reeser, Operations Engineer - Chief Examiner J. Seymour, Operations Engineer -- Examiner J. DeMarshall, Reactor Operations Engineer - Examiner Approved by: R. Orlikowski, Chief Operations Branch Division of Reactor Safety Enclosure 1

SUMMARY

Examination Report 05000440/2017301; 02/06/2017 - 03/15/2017; FirstEnergy Nuclear

Operating Company, Perry Nuclear Power Plant; Initial License Examination Report.

The announced initial operator licensing examination was conducted by regional Nuclear Regulatory Commission (NRC) examiners in accordance with the guidance of NUREG-1021,

Operator Licensing Examination Standards for Power Reactors, Revision 10.

Examination Summary Nine of ten applicants passed all sections of their respective examinations. One applicant was issued a senior operator licenses and six applicants were issued operator licenses.

One applicant failed one or more sections of the administered examination and was issued a proposed license denial. The licenses for the remaining two applicants are being withheld pending written certification that the applicants have completed the deferred portion of the six-month on-site experience required by the National Academy for Nuclear Training Guidelines for Initial Training and Qualification of Licensed Operators. (Section 4OA5.1).

REPORT DETAILS

4OA5 Other Activities

.1 Initial Licensing Examinations

a. Examination Scope

The U.S. Nuclear Regulatory Commission (NRC) examiners and members of the facility licensees staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 10, to develop, validate, administer, and grade the written examination and operating test. The written examination outlines were prepared by the NRC staff and were transmitted to the facility licensees staff. Members of the facility licensees staff prepared the operating test outlines and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of January 9, 2017, with the assistance of members of the facility licensees staff. During the on-site validation week, the examiners audited two license applications for accuracy. The NRC examiners, with the assistance of members of the facility licensees staff, administered the operating test, consisting of job performance measures and dynamic simulator scenarios, during the period of February 6 through February 10, 2017. The facility licensee administered the written examination on February 16, 2017.

b. Findings

(1) Written Examination The NRC examiners determined that the written examination, as proposed by the licensee, was within the range of acceptability expected for a proposed examination.

Less than 20% of the proposed examination questions were determined to be unsatisfactory and required modification or replacement.

All changes made to the proposed written examination, were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, and documented on Form ES-401-9, Written Examination Review Worksheet.

On February 23, 2017, the licensee submitted documentation noting that there was one post-examination comment for consideration by the NRC examiners when grading the written examination. The post-examination comment and the NRC resolution for the post-examination comment is included as Enclosure 2 to the report.

The written examination outlines and worksheets, the proposed written examination, as well as the final as-administered examination and answer key (ADAMS Accession Number ML17096A744), will be available, in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS).

The NRC examiners graded the written examination on March 22, 2017, and conducted a review of each missed question to determine the accuracy and validity of the examination questions.

(2) Operating Test The NRC examiners determined that the operating test, as originally proposed by the licensee, was within the range of acceptability expected for a proposed examination.

Following the review and validation of the operating test, minor modifications were made to several Job Performance Measures (JPMs), and some minor modifications were made to the dynamic simulator scenarios.

During the administration of the operating test, one of the Senior Reactor Operator (SRO) Administrative JPMs was replaced after it was determined that the specified INITIAL CONDITIONS did not support the desired outcome. The deficiency in the JPM was not identified until after the JPM had been administered to all of the SRO applicants. A replacement JPM was selected and validated, and was then administered to all of the SRO applicants.

Changes made to the operating test, documented in a document titled, Operating Test Comments, as well as the final, as-administered, dynamic simulator scenarios and JPMs, will be available, in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS.

The NRC examiners completed operating test grading on March 23, 2017.

(3) Examination Results Four applicants at the SRO level and six applicants at the Reactor Operator (RO) level were administered written examinations and operating tests.

• Seven applicants passed all portions of their examinations and were issued their respective operating licenses on March 23, 2017.

• One applicant failed one or more sections of the administered examination and was issued a proposed license denial.

• Two applicants passed all portions of the license examination, but their licenses are being withheld pending written certification that the applicants have completed the deferred portion of the six-month on-site experience required by the National Academy for Nuclear Training Guidelines for Initial Training and Qualification of Licensed Operators.

.2 Examination Security

a. Scope

The NRC examiners reviewed and observed the licensee's implementation of examination security requirements during the examination validation and administration to assure compliance with Title10 of the Code of Federal Regulations, Section 55.49, Integrity of Examinations and Tests. The examiners used the guidelines provided in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, to determine acceptability of the licensees examination security activities.

b. Findings

None

4OA6 Management Meetings

.1 Debrief

The chief examiner presented the examination team's preliminary observations and findings on February 10, 2017, to Mr. D. Hamilton, Site Vice President, and other members of the Perry Nuclear Power Plant staff.

.2 Exit Meeting

The chief examiner conducted an exit meeting on March 23, 2017, with Mr. D. Hamilton, Site Vice President, and other members of the Perry Nuclear Power Plant staff, by telephone. The NRCs final disposition of the stations post-examination comment was disclosed and discussed with during the telephone discussion. The examiners asked the licensee whether any of the material used to develop or administer the examination should be considered proprietary. No proprietary or sensitive information was identified during the examination or debrief/exit meetings.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

R. Torres, Fleet Exam Team

T. Gaydosik, Lead Fleet Exam Team

L. Vriezen, Initial Licensed Operator Training Supervisor

M. McFarland, Superintendent, Operations Training

P. Boissoneault, Training Manager

B. Blair, Operations Manager

U.S Nuclear Regulatory Commission

R. Elliot, Senior Resident Inspector

J. Nance, Resident Inspector

D. Reeser, Chief Examiner

J. Seymour, Examiner

J. DeMarshall, Examiner

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access and Management System

CFR Code of Federal Regulations

JPM Job Performance Measures

NRC U.S. Nuclear Regulatory Commission

RO Reactor Operator

SRO Senior Reactor Operator

POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION

QUESTION No. 58

Annunciator INVERTER DB-1-A TROUBLE just alarmed on H13-P870.

A(An) (1) condition will cause an Auto Transfer to the Alternate Source.

If the condition causing the alarm clears in 10 minutes, the loads will (2) back to the

inverter.

(1) (2)

A. DC GROUND FAULT automatically transfer

B. DC GROUND FAULT need to be manually transferred

C. inverter LOW output voltage automatically transfer

D. inverter LOW output voltage need to be manually transferred

Explanation: Answer C - Low AC output is annunciated for the BOP inverter, not the ATWS

inverter. If the alarm condition clears, the Static Transfer will automatically

transfer the load back to the inverter. One condition causes the Static Transfer

Switch to latch after 15 minutes.

A - Incorrect - Plausible since DC GROUND FAULT is an alarm condition for the TSC-UPS

inverter.

B - Incorrect - Plausible since DC GROUND FAULT is an alarm condition for the TSC-UPS

inverter. For the BOP inverter, if the alarm condition clears, the Static Transfer

will automatically transfer the load back to the inverter.

D - Incorrect - If the alarm condition clears, the Static Transfer will automatically transfer the

load back to the inverter.

Technical Reference(s):

ARI-H13-P870-01 [INVERTER DB-1-A TROUBLE]; Rev 15 [16]

System Description Manual - Uninterruptable Power Supplies (R14&15); Rev. 2

POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION

QUESTION No. 58 (page 2 of 3)

APPLICANT COMMENT/CONTENTION

The applicant contends that answer choice C is not a correct answer and that answer D is the

correct answer.

1. The second part of the question asks if the static switch will automatically re-transfer

back to the inverter if the signal (low output voltage) clears after 10 minutes.

2. The Answer Key incorrectly states "Answer C" is correct, and that the static switch will

automatically transfer back to the inverter.

3. Per plant drawings 208-0202-0011, 0012 and 0013, along with data from the vendor

manual and discussions with the Responsible System Engineer and a representative

from the vendor, the static switch WILL NOT automatically transfer back to the inverter

for the listed failure.

4. The signal generated by "inverter LOW output voltage" has the same input to the

transfer logic as if an operator had manually transferred the load to the Alternate

Source by depressing S202. (see drawing 208-0202-0013)

5. Amend the Answer Key to list "Answer D" as the only correct answer.

Recommended revision to Justification for Answers

A. lncorrect answer - DC GROUND FAULT is an alarm condition for the TSC-UPS inverter'

B. lncorrect answer - DC GROUND FAULT is an alarm condition for the TSC-UPS inverter.

C. lncorrect answer - the Static Transfer Switch will NOT automatically transfer the load

back to the inverter after a LOW output voltage condition.

D. Correct answer - the Static Transfer Switch WILL require manual action to transfer the

load back to the inverter. The signal generated by the low voltage condition does not

allow for an automatic retransfer back to the inverter.

Recommendation:

Amend the Answer Key to list "Answer D" as the correct answer

FACILITY RESPONSE AND PROPOSED RESOLUTION

The station agrees with the above candidate comments, justifications and

recommendations.

POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION

QUESTION No. 58 (page 3 of 3)

NRC EVALUATION/RESOLUTION

Given the technical information provided by the Applicant/Facility, the NRC agrees that answer

choice D is a correct answer, but only if the examinee assumes that the second part of the

question relates ONLY to the answer of the first part.

As indicated in the reference information provided, the output will automatically retransfer back

to the inverter under certain conditions (loss of inverter square wave (control) signal or

momentary over current condition).

The first sentence is not needed to complete the first fill in the blank statement since the

statement specifically requires the examinee to select, from the two conditions provided in the

answer choices, the condition that will cause the inverter to auto-transfer to the Alternate

Source. The stem implies, but does not specifically state, that the condition causing the auto-

transfer was also responsible for the alarm.

The second fill in the blank statement is linked to the first sentence, and can be completed

independently from the first fill in the blank statement, if one knows specifically what caused

the alarm condition.

Since the question, as written, does not specifically link the first fill in the blank statement to

the alarm condition, there is not enough information provided in the stem to specifically identify

the cause of the alarm condition; the examinee must make an assumption - not fully supported

by the information provided in the stem - that the answer to the first part is also the condition

that generated the alarm condition. If one makes that assumption, then as stated above the

correct answer would be

D.

However, examinees are instructed not to make assumptions, unless that assumption is

supported by the information contained within the stem of the question. If no assumptions are

made regarding the cause of the alarm, then there is no correct answer choice. Either answer

choice C OR D could be the correct answer, depending on the specific condition that caused

the referenced alarm, but not both since they are mutually exclusive.

CONCLUSION

Based the information provided and a review of the applicable references, the NRC concludes

that there is no correct answer to the question and the question will be deleted from the exam.

SIMULATION FACILITY FIDELITY REPORT

Facility Licensee: Perry Nuclear Power Plant

Facility Docket No: 50-440

Operating Tests Administered: February 6 through 10, 2017

The following documents observations made by the NRC examination team during the initial

operator license examination. These observations do not constitute audit or inspection findings

and are not, without further verification and review, indicative of non-compliance with Title 10 of

the Code of Federal Regulations 55.45(b). These observations do not affect NRC certification

or approval of the simulation facility other than to provide information which may be used in

future evaluations. No licensee action is required in response to these observations.

During the conduct of the simulator portion of the operating tests, the following items were

observed:

ITEM DESCRIPTION

None

3