IR 05000445/2014301

Er 05000445-14-301; 05000446-14-301; on June 9-16, 2014; the Comanche Peak Nuclear Power Plant, Units 1 and 2; Initial Operator Licensing Examination Report

ML14178B264
Person / Time
Site:	Comanche Peak
Issue date:	06/27/2014
From:	Vincent Gaddy Division of Reactor Safety IV
To:	Flores R Luminant Generation Co
References
50-445/14-301, 50-446/14-301
Download: ML14178B264 (12)

Text

June 27, 2014

Rafael Flores, Senior Vice President

and Chief Nuclear Officer

Attention: Regulatory Affairs Luminant Generation Company LLC Comanche Peak Nuclear Power Plant P.O. Box 1002 Glen Rose, TX 76043

SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC EXAMINATION REPORT 05000445/2014301; 05000446/2014301

Dear Mr. Flores:

On June 16, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at the Comanche Peak Nuclear Power Plant, Units 1 and 2. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on June 12, 2014, with Mr. K. Peters, Site Vice President, and other members of your staff. A telephonic exit meeting was conducted on June 26, 2014, with Mr. Garry Struble, License Examination Manager, who was provided the NRC licensing decisions.

The examination included the evaluation of four applicants for reactor operator licenses and four applicants for upgrade senior reactor operator licenses. The license examiners determined that all four applicants for upgrade senior reactor operator licenses and two of the applicants for reactor operator licenses satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued. There was one post examination comment submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2 summarizes post examination comment resolution.

No findings were identified during this 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).

Sincerely,

/RA/

Vincent G. Gaddy, Chief Operations Branch Division of Reactor Safety

Docket: 50-445; 50-446 Licenses: NPF-87; NPF-89 Enclosure:

NRC Examination Report 05000445/2014301; 05000446/2014301, w/Attachments 1. Supplemental Information 2. NRC Review of CPNPP Written Post-Examination Comments

ML14178B264 SUNSI Review By: VGG ADAMS Yes No Publicly Available Non-Publicly Available Non-Sensitive Sensitive Keyword: RGN-002 OFFICE SOE:OB C:PBA SOE:OB OE:OB OE/OB C:OB NAME COsterholtz/dch WWalker CSteely TFarina DStrickland VGaddy SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ /RA/ DATE 6/26/14 6/26/14 6/26/14 6/26/14 6/26/14 6/27/14 Letter to Rafael Flores from Vincent G. Gaddy, dated June 27, 2014

Electronic distribution by RIV

Regional Administrator (Marc.Dapas@nrc.gov) Deputy Regional Administrator (Kriss.Kennedy@nrc.gov)

Acting DRP Director (Troy.Pruett@nrc.gov)

DRP Deputy Director - Vacant DRS Director (Anton.Vegel@nrc.gov)

DRS Deputy Director (Jeff.Clark@nrc.gov) Senior Resident Inspector (John.Kramer@nrc.gov) Resident Inspector (Rayomand.Kumana@nrc.gov)

Administrative Assistant - Vacant Branch Chief, DRP/A (Wayne.Walker@nrc.gov)

Senior Project Engineer, DRP/A (Ryan.Alexander@nrc.gov)

Acting Senior Project Engineer, DRP/A (Theresa.Buchanan@nrc.gov) Project Engineer, DRP/A (Brian.Cummings@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Public Affairs Officer (Lara.Uselding@nrc.gov)

Project Manager (Balwant.Singal@nrc.gov) Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov) RITS Coordinator (Marisa.Herrera@nrc.gov)

ACES (R4Enforcement.Resource@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Technical Support Assistant (Loretta.Williams@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov) RIV/ETA: OEDO (Yen-Chu.Jen@nrc.gov)

Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Dockets: 05000445, 05000446 Licenses: NPF-87, NPF-89 Report: 05000445/2014301; 05000446/2014301 Licensee: Luminant Generation Company, LLC Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2 Location: FM-56, Glen Rose, Texas Dates: June 9 through June 16, 2014 Inspectors: C. Osterholtz, Senior Operations Engineer C. Steely, Senior Operations Engineer T. Farina, Operations Engineer D. Strickland, Operations Engineer Approved by: Vince Gaddy, Chief Operations Branch

Division of Reactor Safety

SUMMARY OF FINDINGS

ER05000445/2014301; 05000446/2014301; June 9-16, 2014; the Comanche Peak Nuclear Power Plant, Units 1 and 2; Initial Operator Licensing Examination Report.

NRC examiners evaluated the competency of four applicants for reactor operator licenses and four applicants for upgrade senior reactor operator licenses at the Comanche Peak Nuclear Power Plant, Units 1 and 2.

The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 9, Supplement 1. The written examination was administered by the licensee on June 16, 2014. NRC examiners administered the operating tests the week of June 9, 2014.

The license examiners determined that all four applicants for upgrade senior reactor operator licenses and two of the applicants for reactor operator licenses satisfied the requirements of 10 CFR Part 55 and the appropriate licenses have been issued.

A. NRC-Identified and Self-Revealing Findings

None

B. Licensee-Identified Violations

None

REPORT DETAILS

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. The examiners also audited two 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 were identified.

.2 Examination Development

a. Scope

NRC examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examination team conducted an onsite validation of the operating tests.

b. Findings

No findings were identified.

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

NRC examiners determined that the written ex aminations initially submitted by the licensee were not within the range of acceptability expected for a proposed examination.

There were 36 questions categorized as unsatisfactory per NUREG-1021 requirements, with the two most common issues being knowledge/ability mismatch or two or more distractors that were not credible. This is of particular concern, as it is a repeat observation from the last initial examination administered in 2013. Additionally, there were 32 questions that needed editorial changes, and 32 questions that were

satisfactory as originally submitted. Consistent with the corporate notification letter sent to licensees at the start of examination development for each examination, future unsatisfactory examination submittals may cause the examinations to be rescheduled or cancelled. The licensee wrote Condition Report CR-2014-007297 to address these exam development issues.

.3 Operator Knowledge and Performance

a. Scope

On June 16, 2014, the licensee proctored the administration of the written examination for all eight applicants, analyzed the results, and presented their analysis and post examination comments to the NRC on June 20, 2014.

The NRC examination team administered the various portions of the operating tests to all eight applicants the week of June 9, 2014.

b. Findings

No findings were identified.

All four applicants for upgrade senior reactor operator licenses and two of the applicants for reactor operator licenses passed the written examination and all eight passed all parts of the operating test. The final written examinations, final operating test, and post-examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment with supplemental information, which includes one post-examination comment. The post-examination comment was accepted and the answer key was changed accordingly. See Enclosure 2 for a brief synopsis of the question, the comments, and the NRC resolution of these comments. The complete submittal with detailed information on each question can be found in the ADAMS system using accession number ML14174B412.

The examination team noted the following generic weaknesses:

There were fifteen questions missed by 50 percent or more of the applicants, with each question analyzed by the licensee as required by NUREG-1021. All fifteen question weaknesses were determined to be knowledge weaknesses. Condition Report CR-2014-007485 was written to address the written exam weaknesses.

During performance of the simulator scenarios, the applicants were inconsistent in the use of annunciator response procedures. On some occasions, the annunciator response procedures were referenced late, and in some cases they were not referenced at all. The licensee generated Condition Report CR 2014-007287 to address this issue.

.4 Simulation Facility Performance

a. Scope

The NRC examiners observed simulator performanc e with regard to plant fidelity during examination validation and administration.

b. Findings

No findings were identified.

.5 Examination Security

a. Scope

The NRC examiners reviewed examination security 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

No findings were identified.

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Mr. Ken Peters, Site Vice President, and other members of the staff on June 12, 2014. A telephonic exit was conducted on June 26, 2014, between Messrs. Clyde Osterholtz, Chief Examiner, and Garry Struble, License Examination Manager.

The licensee identified administrative JPM's SA2 and RA2 as containing proprietary information. JPMs SA2 and RA2 will be withheld from public disclosure. The licensee did not identify any other information or materials used during the examination as proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Cox, Initial License Class Instructor

J. Dreyfuss, Organizational Effectiveness Director

B. Moore, Nuclear Training Director

C. Rice, Initial Licensed Operator Training Supervisor

E. Skelton, Operations Training Manager

R. Slough, Regulatory Affairs

M. Smith, Operations Director

M. Stakes, Shift Operations Manager

G. Struble, License Examination Manager

D. Whitsitt, Initial License Class Instructor

NRC Personnel

J. Kramer, Senior Resident Inspector

ADAMS DOCUMENTS REFERENCED

Accession No. ML14174B412 - FINAL WRITTEN EXAMINATION Accession No. ML14174B414 - FINAL OPERATING TEST

Accession No. ML14174B418 - POST EXAMINATION ANALYSIS AND COMMENTS

NRC Review of CPNPP Written Post-Examination Comments Note:

A complete text of the licensee's post examination analysis and comments can be found in ADAMS under Accession Number ML 14174B418.

Question 66

In the final written exam submittal the stem of the question reads:

Which of the following describes the MINIMUM clothing and flash protection boundary requirements when racking a 480 V Switchgear load breaker in accordance with

STA-124, Electrical Safe Work Practices?

Based on NUREG 1021 Appendix B, Attachment 1; Question Development Checklist

item number 5:

Does the question provide all necessary information, stipulations, and assumptions needed for a correct response?

Does the stem include as much information as possible?

The applicants are left to assume that either the MINIMUM prior to clothing applies to clothing and flash protection boundary or that the MINIMUM prior to clothing only applies to the clothing.

Therefore, not all the necessary information is available in the stem to ensure the original intent of the question and the correct answer are selected based on the MINIMUM applying to both the clothing and the flash protection boundary.

If the MINIMUM is assumed to only apply to the clothing then the 20 foot boundary in distractor D becomes inclusive of the 10 foot boundary in correct answer C.

That is if 10 feet is the minimum required then 20 feet includes the 10 foot

boundary.

Based on the above information and the applicant feedback on Question 66 both answer C and distractor D should be accepted as correct answers to the question. For future use a separate

MINIMUM will be inserted prior to flash protection boundary prior to placing the question in the exam bank.

NRC Resolution of Question 66:

The NRC agrees with the licensee's assessment of this question.

Consequently, the NRC changed the key and re-graded the written examinations with the correct answer as C or D for question 66 as recommended.

- 2 -

ES-501 Simulator Fidelity Report Attachment 2

Facility Licensee: Comanche Peak Nuclear Power Plant

Facility Docket No.: 50-445; 50-446

Operating Test Administered on: Week of June 9, 2014

This form is to be used only to report observations.

These observations do not constitute audit or inspection findings and, without further verification and review in accordance with

IP 71111.11, are not indicative of noncompliance with 10

CFR 55.46.

No licensee action is required in response to these observations.

While conducting the simulator portion of the operating tests, examiners observed the following items:

Item Description Spurious Alarm

During the simulator scenarios the reactor makeup water header pressure low alarm, 1-ALB-1, window 2.5 would spuriously come in and clear.

The licensee generated Condition Report

CR 2014-007285 to address the deficiency.