IR 05000250/2019301

NRC Operator License Examination Report 05000250/2019301 and 05000251/2019301

ML19084A106
Person / Time
Site:	Turkey Point
Issue date:	03/25/2019
From:	Gerald Mccoy Division of Reactor Safety II
To:	Nazar M Florida Power & Light Co
References
EPID I-2018-OLL-0024 50-250/19-301, 50-251/19-301
Download: ML19084A106 (11)

Text

UNITED STATES March 25, 2019

SUBJECT:

TURKEY POINT NUCLEAR PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000250/2019301 AND 05000251/2019301

Dear Mr. Nazar:

During the period January 7 - 18, 2019 the Nuclear Regulatory Commission (NRC)

administered operating tests to employees of your company who had applied for licenses to operate the Turkey Point 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 January 23, 2019.

Five Reactor Operator (RO) and nine Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One SRO applicant failed the operating test and passed the written examination. There were two 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 examination submittal was within the range of acceptability expected for a proposed examination. All examination changes agreed upon between the NRC and your staff were made according to NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 11.

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) 997-4551.

Sincerely,

/RA/

Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Docket Nos: 50-250, 50-251 License Nos: DPR-31, DPR-41 Enclosures:

1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report cc: Distribution via Listserv

ML19084A106 _ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII/ DRS/OL1 RII/ DRS/OL1 RII/ DRS/OL1 RII/ DRS/OL1 RII/ DRS/OL1 RII/ DRS/OL1 SIGNATURE DRL2 JBB5 DED MGD1 AXG1 GJM1 NAME D. Lanyi J. Baptist D. Dumbacher M. Donithan A. Goldau G. McCoy DATE 3/ 19 /20193/ 3/ 11 2019 3/ 11 2019 3/ 14 2019 3/ 14/ 2019 3/ 25 2019 E-MAIL COPY? YES/2019 NO YES NO YES NO YES NO YES NO YES NO

U.S. NUCLEAR REGULATORY COMMISSION Examination Report Docket No.: 50-250, 50-251 License No.: DPR-31, DPR-41 Report No.: 05000250/2019301, 05000251/2019301 EPID No.: I-2018-OLL-0024 Licensee: Florida Power & Light Company (FP&L)

Facility: Turkey Point Nuclear Plant, Units 3 and 4 Location: 9762 S. W. 344th Street Florida City, FL 33035 Dates: Operating Test - January 7 - 18, 2019 Written Examination - January 23, 2019 Examiners: D. Lanyi, Chief Examiner, Senior Operations Engineer J. Baptist, Senior Operations Engineer D. Dumbacher, Senior Operations Engineer M. Donithan, Operations Engineer A. Goldau, Operations Engineer Approved by: Gerald J. McCoy, Chief Operations Branch 1 Division of Reactor Safety Enclosure 1

SUMMARY

ER 05000250/2019301,05000251/2019301; January 7 - 18, 2019 & January 23, 2019; Turkey

Point Nuclear Plant; Operator License Examinations.

Nuclear Regulatory Commission (NRC) examiners conducted an initial examination in accordance with the guidelines in Revision 11, 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 Turkey Point Nuclear Plant staff developed both the operating tests and the written examination. The initial operating test, written RO examination, and written SRO examination submittals met the quality guidelines contained in NUREG-1021.

The NRC administered the operating tests during the period January 7 - 18, 2019. Members of the Turkey Point training staff administered the written examination on January 23, 2019. All five Reactor Operator (RO) and nine of ten 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. Issuance of licenses for three SRO applicants have been delayed pending receipt of additional information. Details concerning the need for additional information has been sent to the individual applicants and the facility licensee.

There were two post-examination comments pertaining to the written examination.

No findings were identified.

REPORT DETAILS

4OA5 Operator Licensing Examinations

a. Inspection Scope

The NRC evaluated the submitted operating test by combining the scenario events and Job Performance Measures (JPMs) in order to determine the percentage of submitted test items that required replacement or significant modification. The NRC also evaluated the submitted written examination questions (RO and SRO questions considered separately) in order to determine the percentage of submitted questions that required replacement or significant modification, or that clearly did not conform with the intent of the approved knowledge and ability (K/A) statement. Any questions that were deleted during the grading process, or for which the answer key had to be changed, were also included in the count of unacceptable questions. The percentage of submitted test items that were unacceptable was compared to the acceptance criteria of NUREG-1021, Operator Licensing Standards for Power Reactors.

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 administered the operating tests during the period January 7 - 18, 2019. The NRC examiners evaluated five Reactor Operator (RO) and ten Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. Members of the Turkey Point training staff administered the written examination on January 23, 2019. A review of associated documentation was performed to determine if the applicants met the requirements specified in 10 CFR Part 55, Operators Licenses.

The NRC evaluated the performance or fidelity of the simulation facility during the preparation and conduct of the operating tests.

b. Findings

No findings were identified.

The NRC developed the written examination sample plan outline. Members of the Turkey Point training staff developed both the operating tests and the written examination. All examination material was developed in accordance with the guidelines contained in Revision 11 of NUREG-1021. 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 determined using NUREG-1021 that the licensees initial examination submittal was within the range of acceptability expected for a proposed examination.

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

Issuance of licenses for three SRO applicants have been delayed pending receipt of additional information. Details concerning the need for additional information has been sent to the individual applicants and the facility licensee.

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 two 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 February 25, 2021, in the ADAMS system (ADAMS Accession Number ML19072A225).

4OA6 Meetings, Including Exit

Exit Meeting Summary

On January 18, 2019 the NRC examination team discussed generic issues associated with the operating test with Mr. Brian Stamp, Plant General Manager, and members of the Turkey Point 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 B. Stamp, Plant General Manager E. Neville, Assistant Operation Manager C. Cashwell, Training Manager R. J. Hess, Licensing Supervisor C. Trent, Shift Manager M. Murphy, Shift Manager S. Cousino, LOIT Supervisor V. Miklausich, Exam Project Manager NRC personnel D. Orr, Senior 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 ML19072A250. The licensees post-examination comments were both

associated with the written examination.

SRO Written Exam Question 82

The question consisted of two parts, the first part of the question provided the applicants data

from an ongoing event. They were asked to determine if the event was an uncontrolled rod

withdrawal. There were no comments on this part of the question. The second part asked

whether the RPS trip for this casualty was designed to 1) maintain the Departure from Nucleate

Boiling Ratio (DNBR) below the analysis limit OR 2) prevent the Axial Flux Distribution (AFD)

from exceeding design limits.

The answer was based upon information identified in the facilitys UFSAR, Section 14.1.2,

Uncontrolled RCCA Withdrawal at Power. The FSAR states, in part:

An uncontrolled RCCA withdrawal at power results in an increase in core heat

flux. Since the heat extraction from the steam generator lags behind the core

power generation until the steam generator pressure reaches the relief or safety

valve setpoint, there is a net increase in reactor coolant temperature. Unless

terminated by manual or automatic action, this power mismatch and resultant

coolant temperature rise would eventually result in DN

B. Therefore, to avert

damage to fuel cladding, the Reactor Protection System is designed to

terminate any such transient before the DNBR falls below the safety analysis

limit value or the fuel rod linear heat generation rate (kW/ft) limit is exceeded.

The question was meant to focus on the fact that the uncontrolled power excursion would result

in a DNB situation.

Comment

The licensee contends that the review of the question did not look deeply enough in the fuel rod

linear heat (kW/ft) generation limit aspect. The licensee pointed out that part of the description

of the protective scheme for an uncontrolled rod withdrawal is the Overpower T trip. This

variable trip protects from cladding damage by ensuring that the allowable heat generation

(kW/ft) rate is not exceeded. Additionally, linear heat generation rates are maintained below

safe limits by operating the unit such that the heat flux hot channel factor (Fq ) is maintained

within limits. They also noted that FSAR Section 3.2.1, Nuclear Design and Evaluation, stated

Limits placed on axial flux difference are designed to assure that the heat flux hot channel

factor Fq is maintained within acceptable limits.

The licensee reasoned that since controlling Fq maintains the linear heat generation below limits

and AFD maintains Fq within limits, it is logical that AFD is also designed to terminate an

uncontrolled rod withdrawal casualty before exceeding its safety analysis limit.

NRC Resolution

The licensees recommendation was accepted.

The NRC agrees that the FSAR does state that the AFD limits are in place to ensure that Fq is

maintained. The NRC also agrees that Fq protects the cladding from excessive linear heat

generation. Therefore, it could be argued that AFD protects the cladding from excessive linear

heat generation. Therefore, the licensees contention that both answers are correct is accepted.

The key was changed to accept either answer A or B.

SRO Written Exam Question 97

The question placed the unit in MODE 3 performing a reactor startup when a Technical

Specification (TS) required piece of equipment failed. The first part asked if the startup could

continue. The second part asked how long the equipment could remain out of service prior until

a shutdown was required. The intent of the first part of the question was to test the applicants

understanding of TS 3.0.4.

Comment

The licensee contends that there was inadequate information provided in the stem. The

applicants were confused by the term preparing for a reactor startup. One applicant inquired if

the question was asked if the question was asking if a Mode change could occur. He was told

that the intent was to get to full power. During the post-exam review, another applicant claimed

that he had the same question and answered it as if the question was asking whether the

General Operating Procedure to startup could continue.

The licensee contends that either answer could be correct depending on the assumptions made

by the applicant. Therefore, the question should be deleted

NRC Resolution

The licensees recommendation was accepted.

Since at least one applicant was confused enough about the stem to ask a question during the

exam, it is possible that the wording was confusing to other applicants. Therefore, the premise

that the stem was flawed was accepted and that the first part of the question had two correct

answers. However, these answers contained conflicting information. ES-403 section D.1.c of

NUREG-1021 states that if the correct answers contain conflicting information, the question

shall be deleted.

The question was deleted and the answer key was amended to reflect this.

SIMULATOR FIDELITY REPORT

Facility Licensee: Turkey Point Nuclear Plant Units 3 and 4

Facility Docket No.: 05000250, 05000251

Operating Test Administered: January 7 - 18, 2019

This form is 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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