IR 05000255/2012301

Er 05000255-12-301; Entergy Nuclear Operations, Inc; 10/01/2012 - 10/24/2012; Palisades Nuclear Plant, Initial License Examination Report

ML12332A142
Person / Time
Site:	Palisades
Issue date:	11/27/2012
From:	Hironori Peterson Operations Branch III
To:	Vitale A Entergy Nuclear Operations
References
ER-12-301
Download: ML12332A142 (16)

Text

ber 27, 2012

SUBJECT:

PALISADES NUCLEAR PLANT NRC INITIAL LICENSE EXAMINATION REPORT 05000255/2012301

Dear Mr. Vitale:

On October 24, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed the initial operator licensing examination process for license applicants employed at your Palisades Nuclear Plant. The enclosed report documents the results of those examinations. Preliminary observations noted during the examination process were discussed on October 11, 2012, with Mr. J. Dills and other members of your staff. An exit meeting was conducted by telephone on November 7, 2012, between Mr. B. Nixon of your staff and Mr. R. K. Walton, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation, NRC resolutions of the station=s post-examination comments, initially received by the NRC on October 24, 2012, were discussed.

The NRC examiners administered an initial license examination operating test during the weeks of October 1 and October 9, 2012. The written examination was administered by Palisades Nuclear Plant Training Department personnel on October 12, 2012. Six Senior Reactor Operator and five Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on November 15, 2012. One applicant failed one or more sections of the administered examination and was issued a proposed license denial letter.

Ten applicants passed all sections of their respective examinations and six were issued senior operator licenses and three were issued operator licenses. In accordance with NRC policy, the license for the remaining one applicant is being withheld pending the outcome of any written examination appeal that may be initiated.

The written examination will be withheld from public disclosure for 24 months per your request.

However, since an applicant received a proposed license denial letter because of a written examination grade that is less than 80 percent, the applicant will be provided a copy of the written examination. For examination security purposes, your staff should consider that written examination uncontrolled and exposed to the public. In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRC's

"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 System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Hironori Peterson, Chief Operations Branch Division of Reactor Safety Docket Nos. 50-255;72-007 License No. DPR-20

Enclosures:

1. Operator Licensing Examination Report 05000255/2012301 w/Attachment: Supplemental Information 2. Simulation Facility Report 3. Written Examination Post-Examination Comment Resolution

REGION III==

Docket No: 50-255 License No: DPR-20 Report No: 05000255/2012301 Licensee: Entergy Nuclear Operations, Inc.

Facility: Palisades Nuclear Plant Location: Covert, Michigan Dates: October 1 to October 24, 2012 Inspectors: R. K. Walton, Chief Examiner C. Moore, Examiner J. Kellum, Examiner Approved by: H. Peterson, Chief Operations Branch Division of Reactor Safety Enclosure 1

SUMMARY OF FINDINGS

ER 05000255/2012301; 10/01/2012 - 10/24/2012; Entergy Nuclear Operations, Inc.,

Palisades Nuclear Plant; Initial License Examination Report.

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

AOperator Licensing Examination Standards for Power Reactors,@ Revision 9, Supplement 1.

Examination Summary Ten of eleven applicants passed all sections of their respective examinations. Six applicants were issued senior operator licenses and four applicants were issued operator licenses.

One applicant failed one or more sections of the administered examination and was issued proposed license denial. The license(s) for the remaining applicant is being held and may be issued pending the outcome of any written examination appeal. (Section 4OA5.1)

REPORT DETAILS

4OA5 Other Activities

.1 Initial Licensing Examinations

a. Examination Scope

The NRC examiners and members of the facility licensees staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, to develop, validate, administer, and grade the written examination and operating test. Members of the facility licensees staff prepared the outline and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of September 4, 2012, with the assistance of members of the facility licensees staff. During the on-site validation week, the examiners audited three 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 (JPMs) and dynamic simulator scenarios, during the period of October 1 through October 11, 2012.

The facility licensee administered the written examination on October 12, 2012.

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 percent of the proposed examination questions were determined to be unsatisfactory and required modification or replacement.

On October 24, 2012, the licensee submitted documentation noting that there were three post-examination comments for consideration by the NRC examiners when grading the written examination. The post-examination comments and the NRC resolution for the post-examination comments are included in Enclosure 3 of this report.

The final as-administered examination and answer key (ADAMS Accession Numbers ML12324A288 and ML12324A291) will be available in 24 months electronically in the NRC Public Document Room or from the Agencywide Documents Access and Management System (ADAMS). 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.

The NRC examiners graded the written examination on November 7, 2012, 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.

Changes made to the operating test, documented in a document titled, AOperating Test Comments,@ as well as the final as-administered dynamic simulator scenarios and JPMs are available electronically in the NRC Public Document Room or from ADAMS.

The NRC examiners completed operating test grading on November 7, 2012.

(3) Examination Results Six applicants at the Senior Reactor Operator (SRO) level and five applicants at the Reactor Operator (RO) level were administered written examinations and operating tests. Nine applicants passed all portions of their examinations and were issued their respective operating licenses. One applicant failed the written section of the administered examination and was issued a proposed license denial. One applicant passed all portions of the license examination, but received a written test grade of 82 percent. In accordance with NRC policy, the applicant=s license will be withheld until any written examination appeal possibilities by other applicants have been resolved.

If the applicant=s grade is still equal to or greater than 80 percent after any appeal resolution, the applicant will be issued an operating license. If the applicant=s grade has declined below 80 percent, the applicant will be issued a proposed license denial letter and offered the opportunity to appeal any questions the applicant feels were graded incorrectly.

.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 Title 10 of the Code of Federal Regulations, Section 55.49, AIntegrity 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 licensee=s examination security activities.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Debrief

The chief examiner presented the examination team's preliminary observations and findings on October 11, 2012, to Mr. J. Dills, Operations, and other members of the Palisades Nuclear Plant Operations and Training Department staff.

.2 Exit Meeting

The chief examiner conducted an exit meeting on November 7, 2012, with Mr. B. Nixon, Training Manager, by telephone. The NRC=s final disposition of the Palisades Nuclear Plant's post-examination comments were disclosed and discussed with Mr. Nixon and his staff during the telephone exit meeting. 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

Enclosure 1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

J. Dills, Operations Manager

B. Nixon, Training Manager

T. Mulford, Assistant Operations Manager

D. Corbin, Assistant Operations Manager

J. Iliff, Operations Training Superintendent

NRC

T. Taylor, Senior Resident Inspector

R. K. Walton, Chief Examiner

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed

None

LIST OF ACRONYMS USED

ADAMS Agencywide Document Access and Management System

CFR Code of Federal Regulations

ER Examination Report

JPM Job Performance Measure

NRC U.S. Nuclear Regulatory Commission

PARS Publicly Available Records System

PCP Primary Coolant Pump

PCS Primary Coolant System

PZR Pressurizer

RO Reactor Operator

SRO Senior Reactor Operator

SIMULATION FACILITY REPORT

Facility Licensee: Palisades Nuclear Plant

Facility Docket No: 50-255

Operating Tests Administered: October 1 - 11, 2012

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 10 CFR 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

Annunciator Bell Alarm would come in, but bell would not sound. Bell fixture repaired

between Job Performance Measures (JPMs).

Turbine Operator Plant Process Computer would produce output to Turbine Operator

Computer Computer, but computer locked up. Computer was replaced between

JPMs.

RVLIS OPERATE The bulb illuminating the RVLIS OPERATE light failed. The broken bulb

PB light out. was identified after the crew took the watch for a scenario, but could not

be repaired until after scenarios were completed for the day. This issue

had no effect to exam administration.

Enclosure 2

WRITTEN EXAMINATION POST-EXAMINATION COMMENT RESOLUTION

RO Question 4:

Which one of the following correctly completes the statement below?

Per EOP-4.0, Loss of Coolant Accident Recovery, the indication that the Control Room team

uses to determine when to trip the last two Primary Coolant Pumps (PCPs) is (1) and

the reason for tripping all PCPs under these conditions is to (2) .

a. (1) Primary Coolant System (PCS) subcooling less than 25°F

(2) prevent damaging a PCP

b. (1) PCS subcooling less than 25°F

(2) minimize PCS inventory loss

c. (1) Pressurizer (PZR) pressure less than minimum for PCP operation

(2) prevent damaging a PCP

d. (1) PZR pressure less than minimum for PCP operation

(2) minimize PCS inventory loss

ANSWER: B

Applicant's Contention:

Question #4 is not valid. There is not enough information in the stem to correctly answer the

question. The student needs to know the value of Primary Coolant System temperature and

they must have a copy of EOP Supplement 1, Pressure Temperature Limit Curves, to

determine the correct criteria for securing the last two PCPs.

Facility Position:

The facility agrees with the applicant's contention. Question #4 is not valid and has no correct

answer because there is not enough information in the stem for the applicant to correctly

answer the question. EOP-4.0, Loss of Coolant Accident Recovery, steps 6 and 8 require

Primary Coolant Pumps (PCPs) be monitored and secured during a LOCA if any of the following

three conditions are met: (1) Pressurizer Pressure lowers to less than 1300 psia (first two PCPs

only), (2) PCS subcooling lowers to less than 25°F and (3) PCP operating limits are not met with

per EOP Supplement 1, Pressure and Temperature Limit Curves. With PCS temperature

above 500°F, the 25°F subcooling criteria applies. If PCS temperature is less than 500°F, the

minimum pressure for PCP operating criteria applies. Furthermore, even if PCS temperature

was supplied in the stem, the student would need the curve supplied from EOP Supplement 1

as a reference to determine the correct criteria to apply because knowing the point at which

minimum pressure for pump operation becomes more limiting (500°F) is not required

knowledge. Based on these issues, the facility recommends that Question #4 be removed from

the exam.

Enclosure 3

WRITTEN EXAMINATION POST-EXAMINATION COMMENT RESOLUTION

References:

EOP-4.0, Loss of Coolant Accident Recovery, Rev. 21.

EOP Supplement 1, Rev. 5.

NRC Resolution:

The K/A for this question was to test the applicants knowledge of the reasons for tripping PCPs

during a Large Break LOC

A. During such an event, PCS pressure would drop quickly and

eventually result in a temperature/pressure condition that would require tripping the PCPs,

either upon exceeding the 25°F subcooling line or exceeding the minimum pressure for PCP

operation. EOP Supplement 1, Pressure Temperature Limit Curves, revealed an inflection

point at 500°F for both of these curves. Above this point, PCPs must be tripped due to

exceeding the 25°F subcooling line to minimize PCS inventory loss. Below 500°F, PCPs must

be tripped for pump protection (exceeding minimum pressure for PCP operation). The question

stem did not provide temperature/pressure conditions so the applicant would not know what

curve would be crossed first.

The applicants did not need any references to know that there are only two reasons for tripping

the last two PCPs. Independent of PCS temperature or pressure conditions, EOP-4.0, Loss of

Coolant Accident Recovery, recognized only two reasons for tripping the last two PCPs. Step 6

has the operators trip the last two PCPs due to subcooling issues, and Step 8 has the operators

trip the last two PCPs due to not satisfying the PCP operating limits.

Since there were no PCS pressure/temperature conditions provided in the stem of the question,

there was no one correct answer. Without references, Distracter B would be considered

correct for EOP -4.0, Step 6. Distracter C would be considered correct for EOP-4.0, Step 8.

In accordance with NUREG-1021, ES 403, step D.1.c, the NRC will accept two correct answers.

Both distracters B and C were determined to be correct answers to Q4.

Enclosure 3

WRITTEN EXAMINATION POST-EXAMINATION COMMENT RESOLUTION

RO Question 14:

Given the following with the Plant at full power:

• A manual Reactor trip occurs in response to a Steam Line Break inside Containment

• During the transient, Y40, Preferred AC Bus, de-energizes

• Pressurizer pressure is 1725 psia and lowering slowly

• Containment pressure is 4.2 psig and rising

• The following alarms annunciate:

o EK-1126, CIS INITIATED

o EK-1342, SAFETY INJ INITIATED

Which one of the following describes the action(s) required, if any, based on the above

conditions for the Right Channel of Containment Spray and Safety Injection?

a. Containment Spray and Safety Injection must be manually initiated.

b. Containment Spray must be manually initiated only.

c. Safety Injection must be manually initiated only.

d. No actions required; Containment Spray and Safety Injection will automatically initiate.

ANSWER: A

Applicant's Contention:

Question #14 is not valid. There is no correct answer because there is information in the stem

that conflicts with all correct answers. If Preferred AC Bus, Y40, is de-energized, it is not

possible for EK1342 to be alarming.

Facility Position:

The facility agrees with the applicant's contention. Question #14 has no correct answer

because of conflicting information given in the stem of the question. EK-1342, SAFETY INJ

INITIATED alarm and a loss of Y40, Preferred AC Bus, cannot exist at the same time. EK-

1342 actuates when both trains of Safety Injection actuate via SIS Relays SIS-1 and SIS-6.

If Y40 is de-energized, then SIS-6 relay will not actuate because relay 5P-8 does not have

power. If SIS-6 relay does not actuate, EK1342 will not alarm because both trains must receive

an actuation signal. If the applicant sees that EK-1342 is alarming in the stem, he/she would

believe that the Safety Injection Equipment actuated and B would be the correct answer.

Therefore, the presence of EK-1342 in the stem makes this question operationally invalid and

no answers are correct. The facility proposes that Question #14 be removed from the exam.

References:

ARP-7, Window 42, Rev. 71.

E-Prints E-17, Sheet 3 (Rev. 18), and Sheet 4 (Rev. 17).

Enclosure 3

WRITTEN EXAMINATION POST-EXAMINATION COMMENT RESOLUTION

NRC Resolution:

The applicant argued that a loss of AC Bus Y40 cannot coexist with EK-1342 being in alarm.

Specifically, EK-1342 cannot alarm since the AC Bus Y40 provided power to one of the two

inputs of the alarm circuit and the logic required both inputs to cause the alarm condition to

occur. The question does not provide any specific information as to the sequence of events for

the given conditions. Regarding the loss of AC Bus Y40, the question only stated, a loss of Bus

Y40 occurred during the transient. There was no timeline relating the loss of Bus Y40 to the

annunciator alarms. NUREG-1021, Operator Licensing Examination Standards for Power

Reactors, does not have any convention on how to read bulleted conditions in the context of

time sequencing. There were, however, precedences for time sequencing events during exams

by adding relative times to events (e.g., t = 0 reactor trip; t = +10 seconds, bus de-energized) or

connecting related events to one another, (e.g., the loss of the bus occurred at the time of the

reactor trip). Neither of these methods for time sequencing were employed for this question.

The applicants did not ask any questions during the written exam for Q14 indicating there was

no confusion with the conditions given, including the apparent conflict between a loss of power

to one of EK-1342 inputs with the loss of AC Bus Y40. The applicants chose Distracters A or

B indicating that they recognized that the loss of Y40 would require a manual start of Right

Channel safety equipment. This also indicated that the applicants evidently answered the

question not knowing the relationship between EK-1342 and AC Bus Y40.

Condition 1: If the applicants read the question as written, and assumed that all the

conditions in the stem of the question were true, then the applicants must have assumed

that the annunciators alarmed before the loss of AC Bus Y40. This condition would

result in a successful actuation of safety train equipment with distracter D being the

correct answer. However, none of the applicants chose distracter

D.

Condition 2: Independent of the annunciators, and with a failure of Y40, the applicants

should know that with containment pressure at 4.2 psig and rising, containment spray

must be manually initiated. Then B distracter would be correct.

Since both conditions 1 and 2 above are logical explanations for the conditions given in the

question and since both answers are opposite from each other (B distracter - manually actuate

equipment and D distracter - successful automatic actuation of equipment occurred - take no

manual actions), then there are two conflicting answers. As such, in accordance with

NUREG-1021, ES-403, D.1.c, Q14 is deleted from the exam.

Enclosure 3

WRITTEN EXAMINATION POST-EXAMINATION COMMENT RESOLUTION

RO Question 33:

Which one of the following correctly completes the statement below describing the minimum

required level and source of makeup water for T-73, Quench Tank?

The Quench Tank is maintained at a minimum water level of (1) by adding makeup water

using (2) .

a. (1) 70%

(2) P-90A or P-90B, Primary Makeup Tank Pumps

b. (1) 70%

(2) P-79A or P-79B, Primary System Makeup Transfer Pumps

c. (1) 40%

(2) P-90A or P-90B

d. (1) 40%

(2) P-79A or P-79B

ANSWER: A

Applicant's Contention:

Question #33 has two correct answers. Choices A and B are both correct because the

Quench Tank makeup supply can be lined up from P-79A/B Primary System Makeup Transfer

Pumps, per procedure RWSO-1, Transfer of Water from Primary Makeup Storage Tank (T-81)

for T-90 Loads.

Facility Position:

The facility agrees with the applicant that Q#33 has two correct answers. The Quench Tanks is

normally supplied makeup water from P-90A/B, Primary Makeup Tank Pumps, but is capable of

being supplied by P-79A/B, Primary System Makeup Transfer Pumps, per procedure RWSO-1,

Transfer of Water from Primary Makeup Storage Tank (T-81) for T-90 Loads. This procedure

has been performed recently (August 2011) while the P-90A/B pumps were out of service. Both

P-90A/B have been cautioned tagged OFF since June 2010 due to a leaking boric acid flow

path to the SIRW Tank (WO #228532). The pumps were left off until required to be used for

makeup. Also, P-90A was out of service from May 2012 until September 2012 due to a failed

seal. Based on the combination of the problems the plant has experienced with P-90A/B pumps

and the fact that P79A/B is capable of, and routinely is, used to supply P-90A/B loads, it is easy

to understand why 3 of 11 applicants selected B as the correct answer.

References:

RWSO-1, Transfer of Water from Primary Makeup Storage Tank (T-81) for T-90 Loads.

WO 228532, MV-CV2157 valve Leaks by, Replace valve (Weld)

P&ID M-220, Makeup Domestic Water & Chemical Injection Systems, Rev. 94.

P&ID M-652, Primary System Make-up Water Utility Water & Oil Waste System, Rev. 70.

Enclosure 3

WRITTEN EXAMINATION POST-EXAMINATION COMMENT RESOLUTION

NRC Resolution:

The Primary System Make-Up Water Pumps, P-90A/B, are normally aligned with one pump

continuously running to provide water to various primary plant components including the

pressurizer quench tank and to the chemical volume control system. However, the plant has

had problems with these pumps including pump seal leakage and leakage past a valve seat.

As previously mentioned, both P-90A/B pumps were out of service for a time requiring the

licensee to install a spool piece and use water from an alternate source, the Primary System

Makeup Transfer Pumps P-79A/B, to supply the loads that would normally be serviced by

P-90A/

B. A licensee procedure, RWSO-1, allowed the use of the P-79A/B pumps to supply

these loads. This condition existed in August 2011, a time when the applicants were collecting

in-plant experience. It would be reasonable to assume that some of the applicants believed that

the P-79A/B pumps were the normal method for supply water to the pressurizer quench tank.

But this would be incorrect, since the P-90A/B pumps were the normal method for supplying

water to the pressurizer quench tank. Pumps P-79A/B were an alternate flow path to fill the

quench tank, via a normally removed spoolpiece.

NUREG-1021, Appendix E, Policies and Guidelines for Taking NRC Examinations, stated in

Part B7, When answering a question, do not make assumptions regarding conditions that are

not specified in the question unless they occur as a consequence of other conditions that are

stated in the question. There were no other conditions stated in the question that would lead

the applicants to believe that the normal P-90A/B pumps were unavailable, nor was there any

statement about the status of a spool-piece that tied the alternate source to the normal source

of water to the quench tank. If the applicants had any concerns about the initial conditions of

the question, they should have asked a clarifying question during the exam. However, no

questions were asked by the applicants during the exam for Q33.

The alternate method was in use during a period when the applicants were on shift, however,

the applicants should still have known that the normal source of fill to the quench tank was

P-90A/B and they should have known that the use of the P79A/B pumps was an abnormal,

temporary condition. Therefore, distracter B was considered an incorrect answer.

Distracter A was considered the only correct answer for Q33.

Enclosure 3

A. Vitale -2-

In accordance with Title 10 of the Code of Federal Regulations, Section 2.390 of the NRC's "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 System (PARS) component of

NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from

the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Hironori Peterson, Chief

Operations Branch

Division of Reactor Safety

Docket Nos. 50-255;72-007

License No. DPR-20

Enclosures:

1. Operator Licensing Examination Report 05000255/2012301

w/Attachment: Supplemental Information

2. Simulation Facility Report

3. Written Examination Post-Examination Comment Resolution

cc w/encl: Distribution via ListServ'

DISTRIBUTION w/encl:

Cayetano Santos Christine Lipa

RidsNrrPMPalisades Resource Carole Ariano

RidsNrrDorlLpl3-1 Resource Linda Linn

RidsNrrDirsIrib Resource DRPIII

Chuck Casto DRSIII

Cynthia Pederson Tammy Tomczak

Steven Orth John McHale, NRR

Jared Heck Janet Kweiser, DRS

Allan Barker

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DATE 11/21/12 11/27/12

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