IR 05000400/2013301

Er 05000400-13-301; Operating Test September 9 - 18, 2013, & Written Exam September 25, 2013; Shearon Harris Nuclear Plant; Operator License Examinations

ML13305A222
Person / Time
Site:	Harris
Issue date:	10/30/2013
From:	Mark Franke Division of Reactor Safety II
To:	Hamrick G Carolina Power & Light Co
References
50-400/13-301
Download: ML13305A222 (14)

Text

UNITED STATES ber 30, 2013

SUBJECT:

SHEARON HARRIS NUCLEAR POWER PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000400/2013301

Dear Mr. Hamrick:

During the period September 9 - 18, 2013, the Nuclear Regulatory Commission (NRC)

administered operating tests to employees of your company who had applied for licenses to operate the Shearon Harris Nuclear Plant. At the conclusion of the tests, the examiners discussed preliminary findings related to the operating tests with those members of your staff identified in the enclosed report. The written examination was administered by your staff on September 25, 2013.

Five Reactor Operator (RO) and six Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. Two SRO applicants failed the operating test examination. There were four post-administration comments concerning the written examination. These comments, and the NRC resolution of these comments, are summarized in Enclosure 2. A Simulator Fidelity Report is included in this report as Enclosure 3.

The initial written RO/SRO examination submitted by your staff failed to meet the guidelines for quality contained in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, as described in the enclosed report.

In accordance with 10 CFR 2.390 of the NRCs 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 (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm.adams.html (the Public Electronic Reading Room).

If you have any questions concerning this letter, please contact me at (404) 997- 4436.

Sincerely,

/RA/

Mark E. Franke, Chief Operations Branch Division of Reactor Safety Docket No: 50-400 License No: NPF-63

Enclosures:

1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report

REGION II==

Docket No.: 50-400 License No.: NPF-63 Report No.: 05000400/2013301 Licensee: Carolina Power & Light Company Facility: Shearon Harris Nuclear Plant, Unit 1 Location: 5413 Shearon Harris Road New Hill, NC 27562 Dates: Operating Test - September 9 - 18, 2013 Written Examination - September 25, 2013 Examiners: Bruno Caballero, Chief Examiner, Senior Operations Engineer Dan Bacon, Operations Engineer Gerry Laska, Senior Operations Examiner Newton Lacy, Operations Engineer in Training Approved by: Mark E. Franke, Chief Operations Branch Division of Reactor Safety Enclosure 1

SUMMARY OF FINDINGS

ER 05000400/2013301; operating test September 9 - 18, 2013, & written exam September 25, 2013; Shearon Harris Nuclear Plant; Operator License Examinations.

Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in accordance with the guidelines in Revision 9, Supplement 1, of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors." This examination implemented the operator licensing requirements identified in 10 CFR §55.41, §55.43, and §55.45, as applicable.

Members of the Shearon Harris Nuclear Plant staff developed both the operating tests and the written examination. The initial written RO/SRO examination submittal did not meet the quality guidelines contained in NUREG-1021.

The NRC administered the operating tests during the period September 9 - 18, 2013. Members of the Shearon Harris Nuclear Plant training staff administered the written examination on September 25, 2013. Five Reactor Operator (RO) and six Senior Reactor Operator (SRO)applicants passed both the operating test and written examination. Eleven applicants were issued licenses commensurate with the level of examination administered.

There were four post-examination comments.

No findings were identified.

REPORT DETAILS

4OA5 Operator Licensing Examinations

a. Inspection Scope

Members of the Shearon Harris Nuclear Plant staff developed both the operating tests and the written examination. All examination material was developed in accordance with the guidelines contained in Revision 9, Supplement 1, of NUREG-1021, "Operator Licensing Examination Standards for Power Reactors." The NRC examination team reviewed the proposed examination. Examination changes agreed upon between the NRC and the licensee were made per NUREG-1021 and incorporated into the final version of the examination materials.

The NRC reviewed the licensees examination security measures while preparing and administering the examinations in order to ensure compliance with 10 CFR §55.49, Integrity of examinations and tests.

The NRC examiners evaluated five Reactor Operator (RO) and eight Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. The examiners administered the operating tests during the period September 9 - 18, 2013.

Members of the Shearon Harris Nuclear Plant training staff administered the written examination on September 25, 2013. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Shearon Harris Nuclear Plant, met the requirements specified in 10 CFR Part 55, Operators Licenses.

b. Findings

The NRC determined that the licensees written examination submittal was outside the range of acceptable quality specified by NUREG-1021 because more than 20% [17 of 75 (22%) RO questions and 11 of 25 (44%) SRO questions] of questions sampled for review contained unacceptable flaws. Individual questions were evaluated as unsatisfactory for the following reasons:

• Two questions failed to meet the K/A statement contained in the examination outline.

• Sixteen questions contained two or more implausible distractors.

• Three questions on the SRO examination were not written at the SRO license level.

• Six questions contained multiple unacceptable flaws.

Also, some individual questions not initially evaluated as unsatisfactory required rework due to the potential for partially correct answers or low level of difficulty. The NRC regional office returned the entire written examination, containing 100 questions, to the licensee for rework and correction in accordance with NUREG-1021. Future examination submittals need to incorporate lessons learned.

The NRC determined that the licensees initial operating test submittal was within the range of acceptability expected for a proposed examination.

Five RO applicants and six SRO applicants passed both the operating test and written examination. Two SRO applicants passed the written examination but did not pass the operating test. Five RO applicants and six SRO applicants were issued licenses.

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

The licensee submitted four post-examination comments concerning the written examination. A copy of the final written examination and answer key, with all changes incorporated, and the licensees post-examination comments may be accessed not earlier than September 25, 2015 in the ADAMS system (ADAMS Accession Numbers ML13295A408, ML13295A416, and ML13295A412).

4OA6 Meetings, Including Exit

Exit Meeting Summary

On September 18, 2013 the NRC examination team discussed generic issues associated with the operating test with John Dufner, Plant Manager, and members of the Shearon Harris Nuclear Plant staff. The examiners asked the licensee if any of the examination material was proprietary. No proprietary information was identified.

KEY POINTS OF CONTACT Licensee personnel John Dufner, Plant Manager Donald Griffith, Training Manager Frankie Womack, Operations Manager John Caves, Regulatory Affairs Engineer Rodney Teachey, Nuclear Oversight Assessor Ron Bright, Simulator Support Engineer Simon Schwindt, Superintendent Operations Training George Pickar, Initial Training Supervisor Artie Sylvester, Supervisor, Licensed Operator Requalification Richard J.R. Horton, Senior Nuclear Operations Instructor Archie Lucky, Senior Nuclear Operations Instructor Ed Bertram, Operations Instructor Vince Parente, Rotational Operations Training Instructor NRC personnel Joe Austin, Senior Resident Inspector Patrick Lessard, Resident Inspector

FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS

A complete text of the licensees post-examination comments can be found in ADAMS under

Accession Number ML13295A412.

Item

RO Question # 26

Comment

The licensee contended that the only correct answer was Choice C; the answer key incorrectly

reflected that Choice A was the correct answer.

The licensee contended that FR-C.2, Response to Degraded Cooling Core Cooling, was a

higher priority than FR-Z.1, Response to High Containment Pressure, based on the conditions

provided in the stem. Specifically, the stem conditions also included core exit thermocouples at

740°F, RCS sub cooling less than 50°F (due to high containment pressure at 17 psig and sub

cooling monitor not available), no reactor coolant pumps running, and RVLIS Full Range Level

at 60%.

NRC Resolution

The licensees recommendation was accepted.

In accordance with EOP-Users Guide, Section 6.2, when the sub cooling monitor was not

available, the core exit thermocouples were required to be used to manually calculate sub

cooling, since this yielded a more conservative sub cooling value than the RCS cold leg

temperature. For this question, if the sub cooling value was (incorrectly) calculated using the

cold leg temperature, then Choice A (FR-Z.1, Response to High Containment Pressure) was a

higher priority than Choice C.

Although an orange path for containment integrity existed (containment pressure greater than

psig and no containment spray pumps operating), another orange path for core cooling also

existed. The EOP-Users Guide stated that the hierarchy of entering functional restoration

procedures was:

1. Subcriticality (S)

2. Core Cooling (C)

3. Heat Sink (H)

4. Integrity (P)

5. Containment (Z)

6. Inventory (I)

The stem question specifically asked which procedure was the crew required to implement at

this time. Therefore, because core cooling was a higher priority than containment, Choice C

was the only correct choice.

Item

RO Question # 52

Comment

The licensee contended that this question should be deleted from the exam because the

Recycle Evaporator Valve Gallery Radiation Monitor, RM-1RR-3600, could not reach a high

alarm condition due to reactor coolant system (RCS) activity because the Boron Recycle

System (BRS), including the recycle evaporator, was no longer used at the plant and has not

been used since 1989. Additionally, the licensee contended that the question was not

appropriate for testing, in accordance with NUREG 1021, ES-401, Preparing Initial Site-Specific

Written Examinations, Section D.1.b.

NRC Resolution

The licensees recommendation was not accepted.

The question tested the applicants knowledge of a required entry condition for AOP-032, High

RCS Activity, specifically,

Which ONE of the following identifies an RAB radiation monitor that requires entry into AOP-

2, High RCS Activity, when a valid HIGH alarm condition exists?

AOP-032, High RCS Activity, Table 1, Fuel Breach Area Radiation Monitors, listed the RM-1RR-

3600 (Recycle Evaporator Valve Gallery radiation monitor) as a required entry condition.

In accordance with the bases document for AOP-032 (AOP-32-BD), Fuel Breach Area Radiation

Monitors are sited in the reactor auxiliary building (RAB) areas to detect the presence of fission

products from a reactor coolant pressure boundary leak. The RAB areas equipped with fuel

breach area radiation monitors are those with accessible piping and/or components that carry

reactor coolant (for example, Chemical Volume Control System). The purpose of the area

radiation monitor system is to warn of uncontrolled or inadvertent movement of radioactive

material in the plant.

The licensees contention was that a valid high alarm condition on RM-1RR-3600 was not

operationally possible (due to RCS activity) because the BRS was in a long term shutdown

status. However, any piping system that carried reactor coolant in the vicinity of the evaporator

valve gallery could potentially leak, thereby causing a high alarm condition on this area radiation

monitor. If a significant fuel element failure occurred, sufficient activity could be transported to

one or more RAB areas to significantly raise area radiation levels. The stem question specified

that a valid high alarm condition existed, which encompassed any situation involving an

uncontrolled or inadvertent movement of radioactive material in the plant.

The licensees post exam comment related to NUREG 1021, ES-401, Section D.1.b was

presumed to pertain to the following excerpt:

The knowledge/ability (K/A) statement for question 52 was:

073 Process Radiation Monitoring (PRM) System

073 A4.02 Ability to manually operate and/or monitor in the control room:

Radiation monitoring system control panel (CFR: 41.7 / 45.5 to 45.8)

The required K/A statement pertained to systems that contained radiation monitors, that is,

process radiation monitors. The RM-1RR-3600 is NOT a process radiation monitor; therefore,

the question did not exactly match the K/A statement. However, in accordance with ES-403,

Grading Initial Site Specific Written Examinations, Section D.1.b, given that both the NRC and

the facility licensee agreed that the examination met NUREG-1021 prior to examination

administration, errors, identified after examination administration, are less likely to result in

examination changes. Specifically, a question which does not exactly match its referenced K/A

statement does not warrant a change to the examination because the K/A was still relevant

since the RM-1RR-3600 area radiation monitor is currently installed and operational at the plant.

Therefore, the only correct answer to the question was Choice A.

Item

RO Question # 69

Comment

The licensee contended that Choice D was also a correct answer even though the answer key

identified Choice B as the only correct answer. Specifically, the licensee contended that

temporary M&TE test point/jack connections could also be classified as extended M&TE

connections when these connections were installed for greater than one shift, and, therefore;

could be considered as an acceptable example of a troubleshooting activity.

NRC Resolution

The licensees recommendation was accepted.

The question tested the applicants ability to recognize an acceptable example of a

troubleshooting activity listed in accordance with AP-929, Troubleshooting Guide. The four

choices were:

A. Installing gags on valves

B. Pulling an annunciator card (correct)

C. Replacing failed components on circuit boards

D. Temporary M&TE Test point /jack connections

AP-929, Section 3.0, Item 2 listed the following specific examples:

AP-929, Section 5.3.2, Extended Troubleshooting, M&TE, Jumpers, Lifted Leads, Test Gauges,

stated that temporary M&TE Test point/jack connections were NOT considered to be extended

troubleshooting unless these connections were installed for more than one shift. The stem of

the question did not specify whether Choice D was applicable for one shift or greater than one

shift. Therefore, Choices B and D are both correct.

Item

RO Question # 85

Comment

The licensee contended that Choice D was the only correct answer even though the answer

key identified Choice C as the only correct answer. Specifically, the licensee contended that

because of clarifying information that was provided to the applicants during the administration of

the written exam, the only correct answer is Choice D.

NRC Resolution

The licensees recommendation was accepted.

Given a situation involving door seal failures on the personnel air lock (PAL) and equipment air

lock (EAL) containment doors, the question tested the applicants ability to apply Tech Spec 3.6.1.3, Containment Air Locks. Specifically, given a copy of Tech Spec 3.6.1.3 (no bases), the

two-part question tested the applicants ability to determine 1) the latest day/time that either of

the air locks could be used for entry/exit under administrative controls, and 2) whether the use

of the air lock to perform a non-Tec Spec required activity or a repair on non-vital plant

equipment was allowed. The licensees contention involved the second portion of the two-part

question.

The bases for Tech Spec 3.6.1.3 only allowed use of the airlocks for non-Tech Spec required

activities or repairs on non-vital plant equipment IF an allowed activity required the use of the

air lock door.

During the administration of the written exam, two applicants asked the proctor for clarification

of the following second portion of the question:

Specifically, the two applicants asked whether an allowed activity that required use of the

airlock door was also in progress. The proctor, with concurrence from the NRC Chief Examiner,

added the word ONLY to the fill-in-the-blank statement, and provided this to the entire class,

such that the affected portion of the fill-in-the-blank was changed to:

This change caused the correct answer to be Choice D (not allowed). Therefore, the only

correct answer to question 85 is Choice D.

SIMULATOR FIDELITY REPORT

Facility Licensee: Shearon Harris Nuclear Plant

Facility Docket No.: 50-400

Operating Test Administered: September 9 - 18, 2013

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 Inspection

Procedure 71111.11 are not indicative of noncompliance with 10 CFR 55.46. No licensee

action is required in response to these observations.

No simulator fidelity or configuration issues were identified.

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