ML070820448

Interim NRC Examination Report 2007-301

ML070820448
Person / Time
Site:	Robinson
Issue date:	03/23/2007
From:	Haag R Division of Reactor Safety II
To:	Walt T Carolina Power & Light Co
References
IR-07-301
Download: ML070820448 (10)

Text

March 23, 2007 Carolina Power and Light Company ATTN: Mr. T. D. Walt Vice President H. B. Robinson Steam Electric Plant Unit 2 3581 West Entrance Road Hartsville, SC 29550

SUBJECT:

H. B. ROBINSON STEAM ELECTRIC PLANT - INTERIM NRC EXAMINATION REPORT 05000261/2007301

Dear Mr. Walts:

During the period of February 5 - 9, 2007, the Nuclear Regulatory Commission (NRC) administered operating examinations to employees of your company who had applied for licenses to operate the H. B. Robinson Steam Electric Plant. At the conclusion of the examination, the examiners discussed the examination questions and preliminary findings with those members of your staff identified in the enclosed report. The written examination was administered by your staff on February 2, 2007.

While administering the written examination, your staff discovered that the version of the written examination given to the applicants was not NRC approved. The actual as-given written examination administered on February 2, 2007, was an earlier version of the exam and did not include a number of significant changes that were made to resolve NRC pre-examination review comments. In accordance with Title 10, Section 55.40, of the Code of Federal Regulations (10 CFR 55.40), the NRC uses the criteria in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, to evaluate the written examinations prepared by facility licensees. In addition, 10 CFR 55.40 and NUREG-1021 require that facilities receive NRC approval of the proposed examinations prior to their administration. The NRC performed a comprehensive review of the as-given exam to determine whether the exam satisfied the requirements of NUREG-1021. Based on the large number of as-given exam questions that were found to be unacceptable due to not meeting the requirements of NUREG-1021, the NRC determined that the as-given exam was invalid. Consequently, the written examination administered on February 2, 2007, will not be used by the NRC in licensing decisions for those individuals who had applied for licenses. All of the applicants (two Reactor Operators (RO) and seven Senior Reactor Operators (SRO)) passed the operating test. The above information was provided to members of your staff during a telephone call on March 6, 2007. Details regarding the NRCs review of the as-given exam and factors used to determine the validity of the exam are discussed in the enclosed report.

On March 9, 2007, Mr. Greg Ludlam - Robinson Training Manager, and myself discussed your plans to develop a new written examination and administer the exam during the week of June 11, 2007. The NRC will make resources available to support the review and approval of the new exam and will be contacting you under separate correspondence to discuss the

CP&L 2 arrangements for the written examination. The examination process for these nine applicants remains open pending the results of the new written examination, which will be used with the results of the previously administered operating tests to make the final licensing decisions. A final examination report will be issued to discuss the results of the examination.

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).

Should you have any questions concerning this letter, please contact me at (404) 562-4607.

Sincerely,

\\RA\\

Robert C. Haag, Chief Operations Branch Division of Reactor Safety Docket No. 50-261 License No. DPR-23

Enclosure:

NRC Inspection Report cc w/encl: J. F. Lucas, Manager William G. Noll Support Services - Nuclear Director, Site Operations Carolina Power & Light Company Carolina Power & Light Company H. B. Robinson Steam Electric Plant H. B. Robinson Steam Electric Plant Electronic Mail Distribution Electronic Mail Distribution Henry J. Porter, Director Ernest J. Kapopoulos, Jr. Div. of Radioactive Waste Mgmt.

Plant General Manager Dept. of Health and Environmental Carolina Power & Light Company Control H. B. Robinson Steam Electric Plant Electronic Mail Distribution Electronic Mail Distribution R. Mike Gandy Paul Fulford, Manager Division of Radioactive Waste Mgmt.

Performance Evaluation and S. C. Department of Health and Regulatory Affairs PEB 5 Environmental Control Electronic Mail Distribution Electronic Mail Distribution C. T. Baucom, Supervisor Beverly Hall, Chief Radiation Licensing/Regulatory Programs Protection Section Carolina Power & Light Company N. C. Department of Environment, H. B. Robinson Steam Electric Plant Health and Natural Resources Electronic Mail Distribution Electronic Mail Distribution

CP&L 3 cc w/encl contd David T. Conley Associate General Counsel - Legal Dept.

Progress Energy Service Company, LLC Electronic Mail Distribution John H. O'Neill, Jr.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128 Chairman of the North Carolina Utilities Commission c/o Sam Watson, Staff Attorney Electronic Mail Distribution Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326 Public Service Commission State of South Carolina P. O. Box 11649 Columbia, SC 29211 Mr. Gregg Ludlam, Training Manager H. B. Robinson Steam Electric Plant Unit 2 Progress Energy Carolinas, Inc.

3581 West Entrance Road Hartsville, SC 29550

______ML#070820448___________________

OFFICE RII:DRS RII:DRS RII:DRP SIGNATURE RSB2 RCH RXM1 NAME RBaldwin BHaag RMusser DATE 3/23/2007 3/23/2007 3/23/2007 3/ /2007 3/ /2007 3/ /2007 3/ /2007 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 50-261 License No.: DPR-23 Report No.: 05000261/2007301 Licensee: Carolina Power & Light (CP&L)

Facility: H. B. Robinson Steam Electric Plant Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: Operating Test - February 5 - 9, 2007 Written Examination - February 2, 2007 Examiners: R. Baldwin, Chief, Senior Operations Examiner G. Laska, Senior Operations Engineer F. Ehrhardt, Senior Operations Engineer B. Caballero, Operations Engineer (In-Training)

Approved by: Robert C. Haag, Chief Operations Branch Division of Reactor Safety Enclosure

SUMMARY

OF FINDINGS ER 05000261/2007301, 02/02/2007, 02/05-09/2007, H. B. Robinson Steam Electric Plant; Licensed Operator Examinations.

The NRC examiners conducted operator licensing initial examinations in accordance with the guidance in NUREG-1021, Revision 9, Operator Licensing Examination Standards for Power Reactors. This examination implemented the operator licensing requirements of 10 CFR

§55.41, §55.43, and §55.45.

The NRC administered the operating tests during the period of February 5 - 9, 2007. Members of the Robinson training staff administered the written examination on February 2, 2007. The entire written examination and the operating test were developed by the Robinson training staff.

Due to an error by the licensee, the written examination administered to the applicants on February 2, 2007, was not the version that had been approved by the NRC. This unapproved/

as-given version of the exam was subsequently reviewed by the NRC in detail and was determined to be invalid. To support the examination process for the nine applicants who applied for licenses, Robinson plans to develop a new written examination that will be administered during the week of June 11, 2007. All of the applicants (two Reactor Operators (RO) and seven Senior Reactor Operators (SRO)) passed the operating test. The examination process for these nine applicants remains open pending the results of the new written examination, which will be used with the results of the previously administered operating tests to make the final licensing decisions. A final examination report will be issued to discuss the results of the examination.

While there were no post examination comments, the licensee issued a letter (Serial: RNP-RA/07-0024; ADAMS Accession Number ML070820133) dated March 1, 2007, that provided the results of their evaluation of the unapproved written examination. Information provided in this letter was factored into the NRCs overall review and determination that the as-given written examination was invalid.

Enclosure

Report Details

4. OTHER ACTIVITIES 4OA5 Operator Licensing Initial Examinations

a. Inspection Scope The examiners evaluated two RO and seven SRO applicants who were being assessed under the guidelines specified in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9. The examiners administered the operating tests during the period of February 5 - 9, 2007. Members of the Robinson training staff administered the written examination on February 2, 2007. The evaluations of the applicants and review of documentation were performed to determine if the applicants, who applied for licenses to operate the Robinson plant, met the requirements specified in 10 CFR 55, Operators Licenses.

The examiners reviewed the circumstances surrounding the administration of an earlier unapproved version of the written examination on February 2, 2007, and assessed how this affected the examination process.

The examiners reviewed the licensees examination security measures while preparing and administering the examinations to assess whether examination security and integrity complied with 10 CFR 55.49, Integrity of examinations and tests.

b. Findings During the administration of the written examination on February 2, 2007, the licensee identified that an earlier unapproved version of the examination was inadvertently given to the applicants. The licensee informed the NRC chief examiner of the error and it was decided to continue with the examination process since the applicants were in the process of taking the exam and at that time, the differences between the as-given exam and the NRC approved exam were unknown. All nine applicants successfully passed the operating test that was administered during the period of February 5 - 9, 2007.

The licensee determined that the as-given version of the exam was essentially the original version of the exam that had been revised slightly to address some of the NRCs review comments. The licensee performed a post-examination review to assess the validity of the as-given exam. The results of that review were documented in a March 1, 2007, letter (Serial: RNP-RA/07-0024) to the NRC. The licensees review effort concluded that nine questions were invalid or unapproved, but that the remaining 91 questions provided an acceptable basis upon which the applicants could be evaluated for issuance of NRC operating licenses.

To assess the validity of the as-given exam, the NRC performed a comprehensive review of the exam and assessed the differences between the as-given exam and the approved exam. The as-given version of the exam required numerous changes to correct questions that the NRCs review had initially identified as unacceptable. These Enclosure

2 changes were made as part of the normal examination review and revision process.

The final version of the exam was approved by the NRC on January 31, 2007.

Two NRC chief examiners performed independent reviews of the as-given exam.

Individual exam questions were reviewed to determine whether they satisfied the requirements of NUREG-1021. The results of the two independent reviews were compared and a final determination on question acceptability was made based on the following criteria: 1) both chief examiners agreed that the question was unacceptable; 2) two or more of the four multiple choice answers were non-plausible; 3) there were multiple correct answers; 4) there were no correct answers; and 5) the as-given question was changed during the review process and differed from the approved version of the question. Using these criteria it was determined that 27 of the as-given questions were unacceptable. To gain further insights on question acceptability, the NRC reviewed the scores for these 27 questions. All applicants correctly answered 26 of these questions and seven of the nine applicants correctly answered the remaining question. With an overall average score of 99.15%, the 27 unacceptable questions were determined to be an inadequate discriminatory tool in which to judge applicant knowledge level.

Given the large number of unacceptable questions, the ability of the remaining acceptable questions to adequately test the knowledge, skills, and abilities of the applicants was assessed. While only a few of the examination areas required by NUREG-1021 were not covered by the remaining questions, a more important consideration was the limited coverage these remaining questions provided on operator knowledge, skills, and abilities that are needed to perform licensed duties. Based on these factors, the NRC determined that the as-given exam was not valid and could not be used as a basis for making licensing decisions.

To support the examination process for the nine applicants who applied for licenses, Robinson plans to develop a new written examination that will be administered during the week of June 11, 2007. The examination process for these nine applicants remains open pending the results of the new written examination, which will be used along with the results of the previously administered operating tests to make the final licensing decisions. A final examination report will be issued to discuss the results of the examination.

NUREG-1021, ES-201, Paragraph C.3.j states that the region will not allow the written examination and operating test dates to diverge by more than 30 days without obtaining concurrence from the NRR operator licensing program office. Since the new written examination in June 2007 will be more than 30 days apart from the operating test that was administered in February 2007, Region 2 personnel discussed this situation with NRR. On March 13, 2007, NRR provided concurrence on the planned time frame for the new written examination.

The licensees administration of an unapproved written examination was reviewed for possible noncompliance with 10 CRF 55.49, Integrity of Examinations and Tests.

Additional NRC review and consideration is needed to determine whether a violation of Enclosure

3 this regulatory requirement occurred. Therefore, this item is identified as an unresolved item (URI)05000261/2007301-01, Administering an Unapproved Written Examination, and is unresolved pending additional NRC review of the circumstances and information regarding this occurrence.

4OA6 Meetings Exit Meeting Summary On February 9, 2007, the examination team discussed generic examination issues with Mr. William Noll and members of his staff. The examiners asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

PARTIAL LIST OF PERSONS CONTACTED Licensee personnel W. Farmer, Manager - Engineering C. Baucom, Supervisor of Licensing and Regulatory Programs B. Clark, Manager - Nuclear Assessment Section D. Foster, Manager - Shift Operations G. Ludlam, Manager - Training B. Noll, Director of Site Operations C. Church, Manager - Operations G. Sanders, Licensing Engineer C. Moon, Supervisor - Technical Training S. Wheeler, Supervisor - Emergency Preparedness K. Jones, Supervisor - Plant Support Group J. Huegel, Manager - Maintenance D. Blakeney, Manager - Outages and Scheduling A. Musselwhite, Assessor - Nuclear Assessment Section J. Long, Assessor - Performance Evaluation & Regulatory Affairs NRC personnel D. Jones, Resident Inspector ITEMS OPENED, CLOSED, AND DISCUSSED Opened 05000261/2007301-01 URI Administering an Unapproved Written Examination (Section 4OA5)

Enclosure