IR 05000416/2012301

Er 05000416-12-301; December 10, 2012 - February 27, 2013; Grand Gulf Nuclear Station; Initial Operator Licensing Examination Report

ML13087A708
Person / Time
Site:	Grand Gulf
Issue date:	03/28/2013
From:	Vincent Gaddy Division of Reactor Safety IV
To:	Kevin Mulligan Entergy Operations
References
ER-12-301
Download: ML13087A708 (14)

Text

UNITE D S TATE S NUC LEAR RE GULATOR Y C OMMI S SI ON rch 28, 2013

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC EXAMINATION REPORT 05000416/2012301

Dear Mr. Mulligan:

On December 17, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at Grand Gulf Nuclear Station. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on December 17, 2012, with Mr. M. Rasch, Superintendent, Operations Training, and other members of your staff. A telephonic meeting was conducted on January 29, 2013, with Mr. M. Rasch, Superintendent, Operations Training, who was provided the NRC licensing decisions. A final telephonic exit meeting was conducted on February 27, 2013, with Mr. M.

Richey, Director, Special Projects, who was provided the decisions on the NRC identified violations.

The examination included the evaluation of six applicants for reactor operator licenses, five applicants for instant senior reactor operator licenses, and two applicants for upgrade senior reactor operator licenses. The license examiners determined that ten of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There were no post examination comments submitted by your staff. The Enclosure contains details of this report.

Additionally, a NRC-identified Severity Level IV violation is listed in Section 4OA5 of this report.

The NRC is treating this violation as a non-cited violation consistent with Section 6.4 of the NRC Enforcement Policy because it is a Severity Level IV violation and because it is entered into your corrective action program. The NRC has also identified an issue that was evaluated under the risk significance determination process as having very low safety significance (Green) and is listed in Section 4OA5 of this report. The NRC has determined that this issue is a violation.

However, because of the very low safety significance and because it was entered into your corrective action program as well, the NRC is treating this finding as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the violations or the significance of the non-cited violations, 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, 1600 E. Lamar Blvd, Arlington, Texas, 76011-4125; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001; and the NRC Resident Inspector at the facility. In addition, if you disagree with the crosscutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region IV, and the NRC Resident Inspector at the facility.

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 NRCs 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: 50-416 License: NPF-29

Enclosure:

NRC Examination Report 05000416/2012301

REGION IV==

Docket: 50-416 License: NPF-29 Report: 05000416/2012301 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Waterloo Road Location:

Port Gibson, Mississippi 39150 Dates: December 10, 2012 - February 27, 2013 Inspectors: C. Steely, Chief Examiner, Operations Engineer B. Larson, Senior Operations Engineer T. Farina, Operations Engineer D. Strickland, Operations Engineer Approved By: Vincent Gaddy, Chief Operations Branch Division of Reactor Safety-1- Enclosure

SUMMARY OF FINDINGS

ER 05000416/2012301; December 10, 2012 - February 27, 2013; Grand Gulf Nuclear Station;

Initial Operator Licensing Examination Report.

NRC examiners evaluated the competency of six applicants for reactor operator licenses, five applicants for instant senior reactor operator licenses, and two applicants for upgrade senior reactor 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 examination was administered by the licensee on December 17, 2012. NRC examiners administered the operating tests on December 10 through 15, 2012.

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

Cornerstone: Mitigating Systems

Green.

The team identified a Green non-cited violation (NCV) of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. Specifically, the licensees procedures for aligning portable nitrogen bottles to the Instrument Air system for backup operation of Automatic Depressurization System (ADS) valves do not include a step to direct the pressure regulator outlet isolation valves to be opened. If these valves are left closed, the nitrogen bottles will remain isolated from the Instrument Air system.

The failure to include a procedural step to open the nitrogen regulator outlet isolation valves when aligning nitrogen to the ADS valve instrument air lines is a performance deficiency. The performance deficiency is more than minor and is therefore a finding because it is associated with the procedure quality attribute of the mitigating systems cornerstone and affects the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This deficiency could have significantly affected the operators ability to perform the activity affecting quality, in this case, aligning nitrogen as a backup to ADS valve instrument air. Using Inspection Manual Chapter 0609,

Attachment 4, Initial Screening and Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, a Phase 1 screening was performed and determined that the finding required a detailed risk evaluation because the finding would have resulted in a loss of system safety function had the procedure been called upon.

The senior reactor analyst performed a detailed risk evaluation using the Grand Gulf Standardized Plant Analysis Risk model Version 8.22, and the SPAR-H human reliability analysis method. This method resulted in an incremental conditional core damage probability of 7.0 x 10-6. However, the analyst noted that, given the specific performance deficiency, this method provided a bounding analysis. Therefore, the finding was assessed using

Inspection Manual Chapter 0609, Appendix M, Significance Determination Process using Qualitative Criteria. The analyst noted that licensee calculations and surveillance of the accumulators and associated check valves indicated that accumulator pressure would remain available for much longer than the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> suggested in the model. Additionally, the failure of the 21 safety-relief valves under this condition would not occur simultaneously, but would be staggered as a result of the depressurization of individual accumulators. This would provide additional indication, cues, and time for operators to identify and correct the valve alignment error. Finally, the SPAR model does not consider the potential for recovery of the instrument air system. Based on this additional qualitative information, the analyst determined that the additional cues and time provided to the operators combined with the straight-forward diagnosis for this specific finding would reduce the overall risk of this performance deficiency by more than an order of magnitude. Therefore, using a bounding quantitative evaluation combined with qualitative factors, this finding was determined to be of very low safety significance (Green).

The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a corrective action program with a low threshold for identifying issues by missing multiple opportunities to identify the procedural discrepancy when it was developing and validating the exam material for submission to the NRC P.1(a).

Severity Level IV. The examination team identified a Severity Level IV, non-cited Violation (NCV), of Title 10 CFR Part 55.49, Integrity of Examination and Tests.

Specifically, the licensee failed to follow procedure EN-TQ-217, Revision 2,

Examination Security, Attachment XI, Simulator Security Checklist Pre-Evaluation. This resulted in the failure to remove a telephone from the simulator classroom that is adjacent to the simulator as required by the examination security checklist. The telephone is used by the licensee to communicate with simulator personnel to facilitate crew briefings and coordinating rotations during simulator evolutions. The examination compromise existed because the telephone could be used by someone not on the examination security agreement to communicate with simulator personnel, and thereby gain prior knowledge of initial license examination materials, whether during initial license examination validation or administration.

The failure to follow procedure EN-TQ-217, Revision 2, Examination Security,

Attachment XI, Simulator Security Checklist Pre-Evaluation, resulted in the failure to remove a telephone from the simulator classroom as required by the examination security checklist. Failure to follow approved examination security procedures is a performance deficiency. The performance deficiency is more than minor and is therefore a violation because it could have impacted the regulatory process if licensing decisions were made with applicants having prior knowledge of examination materials. This is a violation of 10 CFR 55.49,

Integrity of Examination and Tests. Since the simulator classroom was locked to non-examination personnel and the only other entrance to this room was via the simulator, where the NRC examination team was stationed, no actual affect of the examination security compromise occurred. Therefore a Severity Level IV non-cited violation (NCV) is assigned per the NRC Enforcement Policy,

Section 6.4, Licensed Reactor Operators, example d.1., a non-willful compromise of 10 CFR 55.49 that did not contribute to the NRC making an incorrect regulatory decision. There are no cross-cutting aspects assigned to traditional enforcement violations.

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. Examiners also audited four of the license applications in detail to confirm that they accurately reflected the subject applicants qualifications. This audit focused on the applicants 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

The NRC developed the written exam outline and reviewed all other 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.

1. Inadequate Procedure for Aligning Nitrogen Backup to Automatic

Depressurization System The team identified a finding of very low safety significance (Green) involving a non-cited violation of title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.

Introduction.

The team identified a Green non-cited violation (NCV) of Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. Specifically, the licensees procedures for aligning portable nitrogen bottles to the Instrument Air system for backup operation of Automatic Depressurization System (ADS) valves do not include a step to direct the pressure regulator outlet isolation valves to be opened. If these valves are left closed, the nitrogen bottles will remain isolated from the Instrument Air system.

Description.

On December 10, 2012, the team was administering Job Performance Measures (JPMs) inside the plant as part of the Initial Licensing Exam. One particular JPM required the applicants to simulate aligning a temporary nitrogen bottle to the ADS air supply per step 2.4.2 of EOP 05-S-01-EP-1, Attachment 7, Rev 27, Defeating Containment and Drywell Instrument Air Isolation Interlocks.

This is a backup means of supplying pressurized gas to the eight ADS valve air lines and one non-ADS Safety Relief Valve (SRV B21-F051D) in the event of an extended loss of instrument air (the normal supply). The setup of the temporary nitrogen supply consists of four gas cylinders in parallel, each with its own pressure regulator, all connected to a common manifold which can be connected to the Instrument Air system. Each individual nitrogen supply has two isolation valves: one on the bottle itself and one on the outlet of the pressure regulator. During the performance of the JPM, the team noticed that step 2.4.2 of the referenced procedure directed the valve on the bottle to be opened, but it did not direct the regulator outlet isolation valve to be opened. If this valve is left closed, there is no path from the nitrogen bottle to the Instrument Air system. The issue was brought to the attention of the licensees exam staff, who acknowledged that the guidance was deficient and further noted that the four regulator outlet isolation valves in question are not labeled with identifying valve numbers, nor does there appear to be valve numbers assigned for them. This same procedural deficiency was also identified in Off-Normal Event Procedure 05-1-02-V-9 Rev 41, Loss of Instrument Air, which contains identical guidance for aligning nitrogen backup to ADS. The licensee entered this issue into their corrective action program as Condition Report 2012-13015.

Analysis.

The failure to include a procedural step to open the nitrogen regulator outlet isolation valves when aligning nitrogen to the ADS valve instrument air lines is a performance deficiency. The performance deficiency is more than minor and is therefore a finding because it is associated with the procedure quality attribute of the mitigating systems cornerstone and affects the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences.

This deficiency could have significantly affected the operators ability to perform the activity affecting quality, in this case, aligning nitrogen as a backup to ADS valve instrument air. Using Inspection Manual Chapter 0609, Attachment 4, Initial Screening and Characterization of Findings, and Appendix A, The Significance Determination Process (SDP) for Findings At-Power, a Phase 1 screening was performed and determined that the finding required a detailed risk evaluation because the finding would have resulted in a loss of system safety function had the procedure been called upon.

The senior reactor analyst performed a detailed risk evaluation using the Grand Gulf Standardized Plant Analysis Risk model Version 8.22, and the SPAR-H human reliability analysis method. This method resulted in an incremental conditional core damage probability of 7.0 x 10-6. However, the analyst noted that, given the specific performance deficiency, this method provided a bounding analysis. Therefore, the finding was assessed using Inspection Manual Chapter 0609, Appendix M, Significance Determination Process using Qualitative Criteria. The analyst noted that licensee calculations and surveillance of the accumulators and associated check valves indicated that accumulator pressure would remain available for much longer than the 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> suggested in the model. Additionally, the failure of the 21 safety-relief valves under this condition would not occur simultaneously, but would be staggered as a result of the depressurization of individual accumulators. This would provide additional indication, cues, and time for operators to identify and correct the valve alignment error. Finally, the SPAR model does not consider the potential for recovery of the instrument air system. Based on this additional qualitative information, the analyst determined that the additional cues and time

provided to the operators combined with the straight-forward diagnosis for this specific finding would reduce the overall risk of this performance deficiency by more than an order of magnitude. Therefore, using a bounding quantitative evaluation combined with qualitative factors, this finding was determined to be of very low safety significance (Green).

The finding has a cross-cutting aspect in the area of problem identification and resolution associated with the corrective action program component because the licensee did not implement a corrective action program with a low threshold for identifying issues by missing multiple opportunities to identify the procedural discrepancy when it was developing and validating the exam material for submission to the NRC P.1(a).

Enforcement.

Title 10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, prior to December 10, 2012, the licensee failed to ensure that an activity affecting quality was prescribed by a procedure that was appropriate to the circumstances.

Specifically, the licensee failed to include a procedural step to open the nitrogen regulator outlet isolation valve when aligning nitrogen as a backup to ADS valve instrument air, per Procedures EOP 05-S-01-EP-Rev 27, Defeating Containment and Drywell Instrument Air Isolation Interlocks and Off-Normal Event Procedure 05-1-02-V-9, Rev 41, Loss of Instrument Air. Because this violation is of very low safety significance and has been entered into the licensees corrective action program as Condition Report 2012-13015, this violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the NRC Enforcement Policy:

NCV 05000416/2012301-01, Inadequate Procedure for Aligning Nitrogen Backup to Automatic Depressurization System.

Exam Acceptability NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination

.3 Operator Knowledge and Performance

a. Scope

On December 17, 2012, the licensee proctored the administration of the written examinations to all thirteen applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on December 19, 2012.

The NRC examination team administered the various portions of the operating tests to all applicants on December 10-15, 2012.

b. Findings

No findings were identified.

All applicants passed the written examination and ten applicants passed all parts of the operating tests. The final written examinations and post examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment.

There were no post examination comments as indicated in the licensee submittal.

The examination team noted the following generic weaknesses during the operating test administration:

(1) All four crews mis-identified Intermediate Range Monitor (IRM) channel G as channel C.

(2) Two out of four crews failed the critical task of transferring High Pressure Core Spray (HPCS) suction from the Condensate Storage Tank (CST) to the Suppression Pool.

(3) Poor performance on Administrative JPMs. Fourteen failures out of fifty-nine administered. Specifically, Senior Reactor Operator (SRO) performance on tag-out approval. This is a same generic weakness from the Grand Gulf 2011 exam.

Copies of all individual examination reports were sent to the facility Training Manager for evaluation and determination of appropriate remedial training.

.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 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.

1. Failure to Maintain Initial Operator Licensing Examination Integrity

A compromise of a portion of the simulator Job Performance Measure (JPM) test occurred during the examination development that resulted in the NRC-identified non-cited violation documented in this section. The finding is being treated under traditional enforcement because the violation, if not found or corrected, had the potential to impede the NRCs regulatory function. Specifically, licensing decisions could have been made based on an invalid and compromised examination.

Introduction.

The examination team identified a Severity Level IV, non-cited violation (NCV), of Title 10 CFR Part 55.49, Integrity of Examination and Tests. Specifically, the licensee failed to follow procedure EN-TQ-217, Revision 2, Examination Security, XI, Simulator Security Checklist Pre-Evaluation. This resulted in the failure to remove a telephone from the simulator classroom that is adjacent to the simulator as required by the examination security checklist. The telephone is used by the licensee to communicate with simulator personnel to facilitate crew briefings and coordinating rotations during simulator evolutions. The examination compromise existed because the telephone could be used by someone not on the examination security agreement to communicate with simulator personnel, and thereby gain prior knowledge of initial license examination materials, whether during initial license examination validation or administration.

Description.

On October 25, 2012, the examination team was validating Job Performance Measures (JPMs) as part of the initial licensing examination that was scheduled to begin the week of December 10, 2012. An integral part of the validation process was auditing the facilities security procedures/checklists to verify no examination compromise had or could have occurred via connections to remote computer stations or telephones and that proper measures were taken to ensure only the required personnel per the examination security agreement had access to the simulator during examination development and administration. The physical setup of the simulator area consisted of the simulator room and an adjacent room, called the simulator classroom, where access was granted to/from the simulator to allow for crew briefings and the coordination of simulator activities such as licensed operator requalification training, just-in-time training and initial operator licensing class evolutions.

During the performance of the simulator examination security audit using licensee Procedure EN-TQ-217, Revision 2, Examination Security, the NRC identified that the telephone in the simulator classroom had not been removed as required per Attachment XI, Simulator Security Checklist Pre-Evaluation. The facility immediately disconnected the telephone and notified other members of the examination development team. When questioned as to why the telephone had not been removed, the licensee replied that they had neglected to perform the checklist that morning although they had performed it on previous days of the validation. The licensee entered this issue into their corrective action program as CR-GGN-2012-11839.

Analysis.

The failure to follow procedure EN-TQ-217, Revision 2, Examination Security, Attachment XI, Simulator Security Checklist Pre-Evaluation, resulted in the failure to remove a telephone from the simulator classroom as required by the examination security checklist. Failure to follow approved examination security

procedures is a performance deficiency. The performance deficiency is more than minor and is therefore a violation because it could have impacted the regulatory process if licensing decisions were made with applicants having prior knowledge of examination materials. This is a violation of 10 CFR 55.49, Integrity of Examination and Tests.

Since the simulator classroom was locked to non-examination personnel and the only other entrance to this room was via the simulator, where the NRC examination team was stationed, no actual effect of the examination security compromise occurred. Therefore a Severity Level IV non-cited violation (NCV) is assigned per the NRC Enforcement Policy, section 6.4, Licensed Reactor Operators, example d.1., a non-willful compromise of 10 CFR 55.49 that did not contribute to the NRC making an incorrect regulatory decision. There are no cross-cutting aspects assigned to traditional enforcement violations.

Enforcement.

Title 10 CFR Part 55.49, Integrity of Examination and Tests, states, in part, Applicants, licensees, and facility licensees shall not engage in any activity that compromises the integrity of any application, tests, 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 examination. Contrary to the above, during JPM validation, the licensee failed to ensure the integrity of the initial licensing examination process. Specifically, the licensee failed to conduct the required simulator pre-evaluation checklist as required procedure EN-TQ-217, Examination Security, and thus neglected to remove a telephone from the simulator classroom. If not for detection, this could have affected the equitable and consistent administration of the test or examination. This violation is being treated as an NCV, consistent with Section 6.4, Licensed Reactor Operators, of the NRC Enforcement Policy and is designated as Severity Level IV, NCV 05000416/2012301-02, Failure to Maintain Initial Licensing Examination Integrity. The performance deficiency was entered into the licensees corrective action program as CR-GGN-2012-11839.

4OA6 Meetings, Including Exit

The chief examiner presented the preliminary examination results to Mr. M. Rasch, Superintendent, Operations Training, and other members of the staff on December 17, 2012.

A telephonic exit was conducted on February 27, 2013, between Mr. C. Steely, Chief Examiner, and Mr. M. Richey, Director, Special Projects.

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

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Giles, Manager, Training & Development

M. Rasch, Superintendent, Operations Training

M. Pait, Senior Operations Instructor - Exam Developer

S. Reeves, Senior Operations instructor - Exam Developer

NRC Personnel

R. Smith, Senior Resident Inspector