ML18142B454

NRC Operator License Examination Report 5200025/2018302

ML18142B454
Person / Time
Site:	Vogtle
Issue date:	05/22/2018
From:	Eugene Guthrie NRC/RGN-II/DRS/EB2
To:	Yox M Southern Nuclear Operating Co
References
ER 2018302
Download: ML18142B454 (14)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 May 22, 2018 Mr. Michael Yox Regulatory Affairs Director Southern Nuclear Operating Company 7835 River Road, Bldg. 140, Vogtle 3&4 Waynesboro, GA 30830

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT UNIT 3 - NRC OPERATOR LICENSE EXAMINATION REPORT 5200025/2018302

Dear Mr. Yox:

During the period March 5 -14, 2018, the Nuclear Regulatory Commission (NRC) administered operating tests to employees of your company who had applied for licenses to operate the Vogtle Electric Generating Plant Unit 3. 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 21, 2018.

All applicants passed both the operating test and written examination. There were three post-examination comments and a summary of their dispositions is included in Enclosure 2. A Simulator Fidelity Report is included in this report as Enclosure 3.

The initial examination submittal met the guidelines for quality contained in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 11, following review by the NRC, and changes that were mutually agreed upon between the NRC and your staff.

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).

M. Yox 2 If you have any questions concerning this letter, please contact me at (404) 997-4662.

Sincerely,

/RA/

Eugene F. Guthrie, Chief Operations Branch 2 Division of Reactor Safety Docket No: 5200025 License No: NPF-91

Enclosures:

1. Report Details

2. Facility Post Examination Comments and NRC Resolutions

3. Simulator Fidelity Report cc: See page 3

M. Yox 3 cc:

Resident Manager Mr. Reece McAlister Oglethorpe Power Corporation Executive Secretary Alvin W. Vogtle Nuclear Plant Georgia Public Service Commission 7821 River Road Atlanta, GA 30334 Waynesboro, GA 30830 Resident Inspector Office of the Attorney General Plant Vogtle 3&4 40 Capitol Square, SW 7825 River Road Atlanta, GA 30334 Waynesboro, GA 30830 Southern Nuclear Op. Co. Mr. Barty Simonton Document Control Coordinator Environmental Radiation Program Manager 42 Inverness Center parkway Environmental Protection Division Attn: B236 Georgia Dept. of Natural Resources Birmingham, AL 35242 4224 International Pkwy. Suite 120 Atlanta, GA 30354-3906 Anne F. Appleby Oglethorpe Power Corporation Gene Stilp 2100 East Exchange Place 1550 Fishing Creek Valley Road Tucker, GA 30084 Harrisburg, PA 17112 Mr. Robert E. Sweeney County Commissioner IBEX ESI Office of the County Commissioner 4641 Montgomery Avenue Burke County Commission Suite 350 Waynesboro, GA 30830 Bethesda, MD 20814 Mr. Wayne Guilfoyle George B. Taylor, Jr.

Commissioner District 8 2100 East Exchange PL Augusta-Richmond County Commission Atlanta, GA 30084-5336 4940 Windsor Spring Rd Hephzibah, GA 30815 Brian H. Whitley 42 Inverness Center Parkway Gwendolyn Jackson BIN B237 Burke County Library Birmingham, AL 35242 130 Highway 24 South Waynesboro, GA 30830

M. Yox 4 Email agahghtm@southernco.com (Amy Aughtman) annacom@westinghouse.com (Michael J. Annacone) awc@nei.org (Anne W. Cottingham)

Bartley.Higgins@hq.doe.gov (Bartley Higgins) becky@georgiawand.org (Becky Rafter) bhwhitle@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) bjadams@southernco.com (Brad Adams) burrouno@westinghouse.com (Nicholle Burroughs) bwwaites@southernco.com (Brandon Waites) castelca@westinghouse.com (Curtis Castell) comerj@westinghouse.com (James Comer) couturgf@westinghouse.com (Gerald Couture) crenshjw@westinghouse.com (John Crenshaw) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dgbost@southernco.com (Danny Bost) dlfulton@southernco.com (Dale Fulton) drculver@southernco.com (Randy Culver) durhamdc@westinghouse.com (David Durham) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed Davis) erg-xl@cox.net (Eddie R. Grant) fdhundle@southernco.com (Forrest Hundley)

G2NDRMDC@southernco.com (SNC Document Control) graysw@westinhgouse.com (Scott W. Gray) james1.beard@ge.com (James Beard) jannina.blanco@pillsburylaw.com (Jannina Blanco) jantol1dj@westinghouse.com (David Jantosik) jbtomase@southernco.com (Janice Tomasello) jenmorri@southernco.com (Jennifer Buettner) jim@ncwarn.org (Jim Warren)

Joseph_Hegner@dom.com (Joseph Hegner) jpredd@southernco.com (Jason R. Redd) jranalli@meagpower.org (Jerry Ranalli) jtgasser@southernco.com (Jeff Gasser) karen.patterson@ttnus.com (Karen Patterson) karlg@att.net (Karl Gross) kdfili@southernco.com (Karen Fili) kim.haynes@opc.com (Kim Haynes) kmseiber@southernco.com (Kristin Seibert) kmstacy@southernco.com (Kara Stacy)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) lchandler@morganlewis.com (Lawrence J. Chandler) markus.popa@hq.doe.gov (Markus Popa)

(Vogtle Units 3 & 4 Mailing List contd - See page 5)

M. Yox 5 (Vogtle Units 3 & 4 Mailing List contd) mcintyba@westinghouse.com (Brian McIntyre) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith)

Michael.Kca@hq.doe.gov (Michael Kuca) mike.price@opc.com (M.W. Price) mlgraves@southernco.com (Michelle Graves)

MSF@nei.org (Marvin Fertel) myox@southernco.com (Mike Yox) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple) patriciaL.campbell@ge.com (Patricia L. Campbell)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) r.joshi15@comcast.net (Ravi Joshi) randall@nexusamllc.com (Randall Li) rjarrett@southernco.com (Robyn Jarrett)

RJB@nei.org (Russell Bell)

Ronald.Jones@scana.com (Ronald Jones) russpa@westinghouse.com (Paul Russ) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sara@cleanenergy.org (Sara Barczak) sblanton@balch.com (Stanford Blanton) sfrantz@morganlewis.com (Stephen P. Frantz)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) skauffman@mpr.com (Storm Kauffman) sroetger@psc.state.ga.us (Steve Roetger) stephan.moen@ge.com (Stephan Moen) taterrel@southernco.com (Todd Terrell) tom.miller@hq.doe.gov (Tom Miller)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn)

Wanda.K.Marshall@dom.com (Wanda K. Marshall) wasparkm@southernco.com (Wesley A. Sparkman) wayne.marquino@ge.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver) x2gabeck@southernco.com (Gary Becker)

_________________ SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS RII:DRS SIGNATURE Via email Via email Via email Via email Via email Via email NAME D.LANYI B.CABALLERO M.KENNARD P.CAPEHART J.VIERA N.LACY DATE 5/ 11 2018 5/ 14 2018 5/22/2018 5/16/2018 5/ 14 / 2018 5/ 14 /2018 E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO OFFICE RII:DRS RII:DRS SIGNATURE Via email EFG NAME A.GOLDAU E.GUTHRIE DATE 5/ 13 /2018 5/22 2018 E-MAIL COPY? YES NO YES NO

U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 5200025 License No.: NPF-91 Report No.: 05200025/2018302 Licensee: Southern Nuclear Operating Company, Inc.

Facility: Vogtle Unit 3 Location: Waynesboro, GA Dates: Operating Test - March 5 - 14, 2018 Written Examination - March 21, 2018 Examiners: David Lanyi, Chief Examiner, Senior Operations Engineer Bruno Caballero, Senior Operations Engineer Philip Capehart, Senior Operations Engineer Andreas Goldau, Operations Engineer Michael Kennard, Operations Engineer Newton Lacy, Operations Engineer Joseph Viera, Operations Engineer Approved by: Eugene F. Guthrie, Chief Operations Branch 2 Division of Reactor Safety Enclosure 1

SUMMARY

ER 05200025/2018302; operating test March 5 - 14, 2018 & written exam March 21, 2018; Vogtle Unit 3; 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 Vogtle Units 3 & 4 plant staff developed both the operating tests and the written examination. The NRC developed the written examination outlines. 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 March 5 - 14, 2018. Members of the Vogtle Units 3 & 4 training staff administered the written examination on March 21, 2018. All applicants passed both the operating test and written examination. None of the applicants were issued licenses; licensing action has been delayed pending receipt of additional information.

There were three post-examination comments.

No findings were identified.

REPORT DETAILS

4. OTHER ACTIVITIES 4OA5 Operator Licensing Examinations

a. Inspection Scope The NRC evaluated the submitted operating test by combining the scenario events and 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 March 5-14, 2018. The NRC examiners evaluated six Reactor Operator (RO) and fourteen Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. Members of the Vogtle Units 3 & 4 training staff administered the written examination on March 21, 2018. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Vogtle Electric Generating Plant Unit 3, met the requirements specified in 10 CFR Part 55, Operators Licenses.

The NRC evaluated the performance and 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 Vogtle Units 3 & 4 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.

4 All applicants passed both the operating test and written examination. Issuance of licenses to all applicants has 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 three post-examination comments and the final written examination. All were proprietary; a redacted version of the final RO/SRO examination, with an answer key, and the post-exam comments may be accessed not earlier than March 21, 2020, in the ADAMS system (ADAMS Accession Numbers ML18108A155 and ML18108166, respectively). The non-redacted versions can be found at ML18108A151 and ML18108A152 respectively, but will not be publically available.

4OA6 Meetings, Including Exit On March 8, 2018, the NRC examination team discussed generic issues associated with the operating test with Joseph Klecha, Site Vice President, and members of the Vogtle Units 3 & 4 staff. The examiners asked the licensee if any of the examination material was proprietary. The information that the licensee identified as proprietary was handled in a manner consistent with NRC and licensee guidelines for this type of information.

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel Joseph Klecha, Vice President Nuclear Plant Site Jay Miller, Operations Director John Austin, Training Director S. Mitch Crosby, Maintenance Director Jeffrey Todd, Site Integration Director James Williams, Work Management Director Michael Yox, Regulatory Affairs Director Douglas Cluney, Chemistry Manager Michael McCue, Nuclear Operations Training Manager Stephen Trickett, Radiation Protection Manager Brian Zeik, Site Design Manager Thomas Joseph, Shift Manager John Umphlett, Nuclear Operations Plant Instructor, Lead John Howard, Nuclear Operations Plant Instructor, Lead Eric Thompson, Nuclear Operations Plant Instructor, Lead Jason Cearley, Nuclear Operations Plant Instructor Ben Denlinger, Nuclear Operations Plant Instructor James Dugas, Nuclear Operations Plant Instructor Andrew Nichols, Nuclear Operations Plant Instructor Ralph Pritchard, Shift Support Supervisor, Training

FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS A complete text of the licensees post-examination comments can be found in ADAMS under Accession Number ML ML18108A152 (non-public).

Item RO QUESTION #20: K/A A-328 2.1.24, Malfunction of Feedwater Heaters and Extraction Steam, Knowledge of system purpose and/or function Comment:

The licensee contended that answers A and C are both correct.

The licensee contended that the first part of the question did not provide clear guidance as to whether it should be answered with procedural direction from AOP-206 or based upon the expectations provided in the Conduct of Operations procedure.

NRC Resolution The licensees recommendation was rejected.

Since the stem of the question stated that the crew had entered AOP-206, it would be expected that the applicant would answer the question based upon that procedure unless stated plant conditions would require a more restrictive power level. Since the Conduct of Operations was less restrictive than the active procedure, using the value prescribed by the Conduct of Operations would be incorrect The answer key has not been changed.

Item RO QUESTION #51: K/A CNS K5.02, Knowledge of the operational implications or cause and effect relationships of the following as they apply to the Containment System; Automatic Depressurization System (ADS) Operation Comment:

The licensee contended that only answer D is correct.

The licensee contended that since the stem did not identify that the second question was independent from the first, the question did not provide the applicants with adequate information to answer the question as expected. Instead, it was more logical to assume that the second question should be answered assuming that the first condition existed. Therefore with the conditions presented the correct answer would be D.

Enclosure 2

2 NRC Resolution The licensees recommendation was partially accepted.

The NRC agreed that the answer to the question could change depending on how you interpret the independence of the two questions. If the applicant read the second question as being independent from the first question, the originally proposed answer would be correct. If the applicant read the question as dependent on the first question, then answer D would be correct. Therefore, the NRC agreed that inadequate information was provided to the applicants to answer the question.

Normally, when a question has two correct answers, both answers would be accepted.

However, if those two answers have conflicting information, the question would be deleted.

Since these answers directly conflict the question was deleted from the examination.

The answer key has been changed to identify Question 51 as being deleted.

Item RO QUESTION #59: K/A VFS A1.01 Ability to predict and/or monitor changes in parameters associated with the operation of the Containment Air Filtration System including: Secondary building ambient pressure differential Comment:

The licensee contended that only answer B is correct.

Based upon conditions stated in the stem, the question asked what the status of the Containment Air Filtration System would be.

The licensee contended that the answer stated in the key was technically incorrect. Following the exam, the licensee identified that there is a previously unidentified 30 second time delay which would trip the fans in question if they were running with low flow. Since these fans would trip before the time delay associated with a high differential pressure was complete, the circuit being tested would never be completed. Therefore, the correct answer should have been B.

NRC Resolution The licensees recommendation was accepted.

The NRC agreed that for the conditions given the circuit would operate as described by the licensee.

The answer key has been changed to identify B as the correct answer.

SIMULATOR FIDELITY REPORT Facility Licensee: Vogtle Unit 3 Facility Docket No.: 5200025 Operating Test Administered: March 5-14, 2018 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 new simulator fidelity or configuration issues were identified that had not been previously identified.

Enclosure 3