IR 05000327/2010301
| ML100890263 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/29/2010 |
| From: | Widmann M Division of Reactor Safety II |
| To: | Krich R Tennessee Valley Authority |
| References | |
| 50-327/10-301, 50-328/10-301 | |
| Download: ML100890263 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-8931 March 29, 2010 Mr. R. Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT: SEQUOYAH NUCLEAR PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000327/2010301 AND 05000328/2010301
Dear Mr. Krich:
During the period February 16 - 22, 2010, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate the Sequoyah 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 March 3, 2010.
Three Reactor Operator (RO) and Three Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO applicant failed the written examination. There was one post-administration comment concerning the written examination. The resolution to the licensee's comment is provided in this report as Enclosure 2. A Simulator Fidelity Report is included in this report as Enclosure 3.
In accordance with 10 CFR 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 (PARS) component of the NRC's 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) 562-4550.
Sincerely,
/RA/ Malcolm T. Widmann, Chief Operations Branch Division of Reactor Safety Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79
Enclosures:
1. Report Details 2. NRC Resolution to the Facility Comments 3. Simulator Fidelity Report
REGION II==
Docket No.: 50-327, 50-328
License No.: DPR-77, DPR-79 Report Nos.: 05000327/2010301, 05000328/2010301 Licensee: Tennessee Valley Authority (TVA)
Facility: Sequoyah Nuclear Plant, Units 1 & 2
Location: Sequoyah Access Road Soddy-Daisy, TN 37379 Dates: Operating Test - February 16 - 22, 2010 Written Examination - March 3, 2009 Examiners: Bruno Caballero, Chief Examiner, Operations Engineer Mark J. Riches, Operations Engineer Kenneth D. Schaaf, Operations Engineer Approved by: Malcolm T. Widmann, Chief Operations Branch Division of Reactor Safety Enclosure 1 SUMMARY OF FINDINGS ER 05000327/2010301, 05000328/2010301, 02/16-22/2009 & 03/3/2010; Sequoyah 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 Sequoyah Nuclear Plant training staff developed both the operating tests and the written examination.
The NRC administered the operating tests during the period February 16 - 22, 2010. Members of the Sequoyah Nuclear Plant training staff administered the written examination on March 3, 2010. Three Reactor Operator (RO) and three Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO applicant failed the written examination. Two RO applicants and two SRO applicants were issued licenses. One RO applicant received a pass letter pending results of a medical examination and one SRO applicant received a pass letter, in accordance with NUREG-1021, ES-501, Section D.3.c, until written examination appeals have been reviewed for impact on the licensing decision.
There was one post-examination comment on the written examination.
No findings of significance were identified.
Enclosure 1 REPORT DETAILS 4. OTHER ACTIVITIES 4OA5 Operator Licensing Examinations a. Inspection Scope Members of the Sequoyah Nuclear Plant 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 licensee's examination security measures while preparing and administering the examinations in order to ensure compliance with 10 CFR Part 55.49, "Integrity of examinations and tests."
The NRC examiners evaluated three Reactor Operator (RO) and four Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. The examiners administered the operating tests during the period February 16 - 22, 2010. Members of the Sequoyah Nuclear Plant training staff administered the written examination on March 3, 2010. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Sequoyah Nuclear Plant, met the requirements specified in 10 CFR Part 55, "Operators' Licenses."
b. Findings No findings of significance were identified. The NRC determined, using NUREG-1021, that the licensee's draft operating examination was outside the acceptable quality range expected by the NRC because all of the fifteen Job Performance Measures (JPM), as originally provided to the NRC, required significant rework or replacement. Some examples of the problems with the draft version of the JPMs included the following items.
- Incorrect simulator setup
- Incorrect valve and/or component numbers
- Poorly defined standards (i.e., the "answer key" for successful procedure step completion) due to inadequate pass/fail criteria for critical steps
- Initial conditions were missing important details, poorly defined, or included cues
- Initiating cue statements were not defined to ensure the applicants understanding of the entire task and included initial conditions information or cues
- JPM Steps either inappropriately designated as "critical" or should have been designated as "critical" 4 Enclosure 1
- Procedures and/or data packages provided for the JPMs were incomplete and/or not marked up according to plant protocols for place keeping
- Excessive typographical errors that were misleading to the examiners Three RO applicants and three SRO applicants passed both the operating test and written examination. One SRO applicant passed the operating test but did not pass the written examination. Two RO applicants and two SRO applicants were issued licenses.
One RO applicant passed the operating test and the written examination but was not issued a license until a medical examination is completed. One SRO applicant passed the operating test, but passed the SRO-only portion of the written examination with a score between 70% and 74%. Each of these applicants was issued a letter stating that they passed the examination and issuance of their license has been delayed pending the completion of the medical examination (for the RO applicant) and any written examination appeals that may impact the licensing decision for their application (for the SRO applicant).
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 one post-examination comment. A copy of the final RO and SRO written examinations, handouts and answer keys, with all changes incorporated may be accessed in the ADAMS system (ADAMS Accession Numbers ML100830628 and ML100830639).
4OA6 Meetings, Including Exit Exit Meeting Summary On February 22, 2010, the NRC examination team discussed generic issues associated with the operating test with Mr. Chris Church, Sequoyah Nuclear Plant Site Vice President, and members of the Sequoyah Nuclear Plant staff. The examiners asked the licensee if any of the examination material was proprietary. No proprietary information was identified.
Enclosure 1 KEY POINTS OF CONTACT Licensee personnel M. Buckner, Exam Author C. Church, Site Vice President V. Ford, Operations Shift Manager J. Klaus, Acting Training Director K. Langdon, Plant Manager R. Milner, General Manager, Nuclear Training R. Proffitt, Licensing Engineer P. Simmons, Operations Manager S. Smith, Operations Training Manager M. Stephens, Initial License Training Supervisor T. Vander Warf, Corporate Operations Training Manager B. Wetzel, Director Safety & Licensing K. Wilkes, Operations Superintendent
NRC personnel M. Speck, RI
Enclosure 2 NRC Resolution to the Facility Comments
SRO QUESTION # 81 LICENSEE COMMENT:
In summary, the licensee requested that this question be deleted. The original post exam comments submitted by the licensee can be viewed in ADAMS as ML100830633.
The licensee contended that Note 6 (in Revision 131 of GOI-6, Section AA, Actions For Condition Red or Yellow Offsite Power Sources) provided conservative direction to immediately declare both offsite power sources inoperable after the Transmission Operator had notified the control room that the grid was in an unanalyzed condition. Consequently, the licensee contended that SRO Question #81 be deleted since the two answer choices were mutually exclusive, i.e., offsite power cannot be both operable and inoperable at the same time.
NRC DISCUSSION:
The question asked for the applicant to identify 1) the required procedure after the Transmission Operator had notified the control room that the grid was in an unanalyzed condition and 2) the current operability status of the offsite power source.
The governing plant procedure was GOI-6, Rev 131, Apparatus Operations, and Step 3.0 [1] [d] stated the following:
[1] IF notified by Transmission Operator the grid/offsite power conditions are in a red condition OR are unanalyzed, THEN PERFORM the following:
NOTE 5 IF grid frequency and/or voltage is outside acceptable limits, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowance to determine operability does NOT apply.
[d] START a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> clock for an operability determination to be done.
The stem of the question stated that the Transmission Operator had notified the control room that the grid was in an unanalyzed condition due to excessive load. The conditions provided in the stem stated that grid frequency was 60 hertz and and Capacitor Yard Bus Voltages were 164.3 KV, 164.2 KV, and 164.3 KV. Because these voltage values were acceptable, i.e., above the minimum required voltage and above the low voltage annunciator alarm setpoint, and because the frequency was normal, the applicant was required to start a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> clock in order for an operability determination to be performed.
Furthermore, Step 3.0 [1] [e], stated the following:
NOTE 6 Entry into LCOs 3.8.1.1 and 3.8.1.2, is a conservative action at this point.
[e] IF analysis is NOT complete within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, THEN COMPLETE the following:
1. ENTER LCO 3.8.1.1 or 3.8.1.2 2. PERFORM Diesel testing.
2 Enclosure 2 The licensee's contention was that Note 6 applied throughout the implementation of Step 3.0 [1], i.e., it was acceptable to conservatively declare both offsite power sources inoperable at any time after the Transmission Operator had notified the control room that the grid was in an unanalyzed condition. However, the procedure writer's guide WG-1.3-001, Special Messages, Rev 0, Section 2.0, Placement of Special Messages, states the following:
Place notes before and on the same page as the related step(s) or section and any step or section notations (for example, critical step, performer, etc.).
Because Note 6 was specifically placed on the same page (i.e., only preceding Step 3.0 [1] [e]), the Note only applied to Step 3.0 [1] [e]. Therefore, the conservative entry to Tech Spec 3.8.1.1 was only directed if the operability analysis could not be completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Declaring the offsite power source immediately inoperable solely because the Transmission Operator stated that the grid was in an unanalyzed condition was incorrect because 1) the procedure stated that the operability determination was required to be coordinated through Sequoyah Site Engineering and the Transmission Operator and 2) the procedure directed entering Tech Spec 3.8.1.1 as a conservative measure only after it had been determined that the operability analysis could not be completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Consequently, the "current" status of the offsite power source was operable.
NRC RESOLUTION
There is only one correct answer for Question #81 and that answer is "A".
Enclosure 3 SIMULATOR FIDELITY REPORT Facility Licensee: Sequoyah Nuclear Plant Facility Docket No.: 05000327, & 05000328
Operating Test Administered: February 16 - 22, 2010 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.
1. During the NRC administration of one scenario, the simulator model stopped operating because of a longstanding, intermittent problem with the "RELAP" reactor coolant system temperature model. Based on interviews with the licensee's simulator staff, a non-repeatable spike in a temperature in one of the core thermo hydraulic nodes had occurred a few seconds following the reactor trip. This simulator "lock up" also occurred four times in 2009. The simulator staff stated that they had corrected several problems associated with the "RELAP" model since it was installed on the simulator in 2003; however, there was no longer any vendor support available. Consequently, when this simulator lockup occurs, the Operations Training Staff has been instructed to stop the scenario in progress, backtrack the simulator for approximately 2 minutes, and then resume the scenario. This could impact the quality of training and/or examinations in progress to the licensed operators and caused a delay during the NRC administration of the operating exam. [Simulator Problem Report # 5036]
2. While the simulator staff was resetting the simulator for a job performance measure (JPM), the Shutdown Bank A, Group 1 rod step counters incorrectly reset to a "00" value. According to the simulator staff, the reason that this occurred was that the booth operator's command to "fast forward" the recorders caused a voltage spike. According to the simulator staff, a modification had been previously installed on the simulator which prevented the "clicking" sound of the rod step counters during a simulator reset; however, the voltage relay adjustment was set to a critical level that responded to the "fast forward" command for the recorders. This caused a delay during the NRC administration of the operating exam because the issue had to be investigated before the next applicant's JPM was administered. [Simulator Problem Report #5037]
3. Based on the NRC Chief Examiner's request during the January prep week, the licensee changed a Tcold instrument malfunction (RX11A) in one scenario to "ramp" to its failed upscale condition instead of instantaneously failing upscale. This change was supposed to result in gradual control rod movement as soon as the malfunction was inserted; however, during one scenario, the auto rod movement was delayed. (During other scenarios, the malfunction worked correctly.) According to the simulator staff, there were two reasons why the auto rod movement was delayed: 1) the initial value of malfunction RX11A did not track the current value of the parameter and 2) the booth operator had inserted the RX11A malfunction prior to the simulator being taken out of freeze. The delay in auto rod movement did not impact administration of the scenario. [Simulator Problem Report #5021]