ML20294A062
| ML20294A062 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 10/19/2020 |
| From: | Eugene Guthrie NRC/RGN-II |
| To: | Kharrl C Southern Nuclear Operating Co |
| References | |
| IR 2020301 | |
| Download: ML20294A062 (19) | |
See also: IR 05000348/2020301
Text
October 19, 2020
Mr. Charles Kharrl
Southern Nuclear Operating Co., Inc.
Joseph M. Farley Nuclear Plant
7388 North State Highway 95
Columbia, AL 36319-0470
SUBJECT: JOSEPH M. FARLEY NUCLEAR PLANT - NRC OPERATOR LICENSE
EXAMINATION REPORT 05000348/2020301 and 05000364/2020301
Dear Mr. Kharrl:
Due to the national pandemic emergency, administration of the operating test and written
examination was delayed from the dates identified in the corporate notification letter
(ML19219A218). The written examination was administered by your staff on July 31, 2020.
During the period August 24 - 28, 2020, the Nuclear Regulatory Commission (NRC)
administered operating tests to employees of your company who had applied for licenses to
operate the Joseph M. Farley 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.
Seven Reactor Operator (RO) and six Senior Reactor Operator (SRO) applicants passed both
the operating test and written examination. One RO retake applicant, who was granted an
excusal from the operating test, passed the written examination. Two SRO applicants, whose
applications were subsequently withdrawn before the operating test was administered, failed the
written examination. There was one post-administration comment concerning the written
examination and three post-administration comments concerning the operating test. 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 operating test outlines and the written examination were developed by the NRC. 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.
The initial operating test, written RO examination, and written SRO examination met the quality
guidelines contained in NUREG-1021.
C. Kharrl 2
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) 997-4662
Sincerely,
/RA/
Eugene F. Guthrie, Chief
Operations Branch 2
Division of Reactor Safety
Docket Nos: 50-348 and 50-364
Enclosures:
1. Report Details
2. Facility Comments and NRC Resolution
3. Simulator Fidelity Report
cc: Distribution via Listserv
ML20294A062 SUNSI REVIEW COMPLETE FORM 665 ATTACHED
OFFICE RII:DRS/OB2 RII:DRS/OB2
NAME BCaballero EGuthrie
DATE 10/ 19 /2020 10/ 19 /2020
E-MAIL COPY? YES NO YES NO
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Examination Report
Docket No.: 05000348, 05000364
Report No.: 05000348/2020301 and 05000364/2020301
Enterprise Identifier: L-2020-OLL-0026
Licensee: Southern Nuclear Company (SNC), LLC
Facility: Joseph M. Farley Nuclear Plant
Location: Columbia, AL
Dates: Written Examination - July 31, 2020
Operating Test - August 24 - 28, 2020
Examiners: Bruno Caballero, Chief Examiner, Senior Operations Engineer
Tom Morrissey, Senior Resident Inspector
Jacob Dolecki, Resident Inspector
Joseph Viera, Operations Engineer
Kevin Kirchbaum, Operations Engineer
Jason Bundy, Operations Engineer
Travis Iskierka-Boggs, Examiner-in-training
Approved by: Eugene F. Guthrie, Chief
Operations Branch 2
Division of Reactor Safety
Enclosure 1
SUMMARY
ER 05000348/2020301, 05000364/2020301; July 31, 2020 & August 24 - 28, 2020; Joseph M.
Farley Nuclear Plant; Operator License Examinations.
Due to the national pandemic emergency, administration of the operating test and written
examination was delayed from the dates identified in the corporate notification letter
(ML19219A218).
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.
The operating test outlines were developed by the NRC and the written examination was
developed by the NRC. The initial operating test, written RO examination, and written SRO
examination met the quality guidelines contained in NUREG-1021.
Members of the Joseph M. Farley Nuclear Plant training staff administered the written
examination on July 31, 2020. The NRC administered the operating tests during the period
August 24 - 28, 2020. Seven Reactor Operator (RO) and six Senior Reactor Operator (SRO)
applicants passed both the operating test and written examination; one RO retake applicant,
who was granted an excusal from the operating test, also passed the written examination.
Fourteen applicants were issued licenses commensurate with the level of examination
administered.
There were four post-examination comments.
No findings were identified.
2
REPORT DETAILS
4. OTHER ACTIVITIES
4OA5 Operator Licensing Examinations
a. Inspection Scope
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 performed an audit of license applications before the preparatory site visit in
order to confirm that they accurately reflected the subject applicants qualifications in
accordance with NUREG-1021.
Members of the Joseph M. Farley Nuclear Plant training staff administered the written
examination on July 31, 2020. The NRC administered the operating tests during the
period August 24 - 28, 2020. The NRC examiners evaluated seven Reactor Operator
(RO) and six Senior Reactor Operator (SRO) applicants using the guidelines contained
in NUREG-1021. Evaluations of applicants and reviews of associated documentation
were performed to determine if the applicants, who applied for licenses to operate the
Joseph M. Farley Nuclear Plant, 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, the operating test
outlines, and the written examination. All examination material was developed in
accordance with the guidelines contained in Revision 11, of NUREG-1021. Members of
the Joseph M. Farley Nuclear Plant training staff 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.
Seven RO applicants and six SRO applicants passed both the operating test and written
examination. One RO retake applicant, who was granted an excusal from the operating
test, passed the written examination. Two RO applicants, whose applications were
subsequently withdrawn before the operating test was administered, failed the written
examination. Eight RO applicants and six SRO applicants were issued licenses.
Several applicants demonstrated knowledge weaknesses during a job performance
measure (JPM) to recover a dropped control rod in accordance with FNP-1-AOP-19.0,
Malfunction of Rod Control System, Section 1.3, Dropped Rods in Mode 1. The JPM
was designed such that once withdrawal of the dropped rod was initiated, a second
control rod then dropped (i.e., alternate path portion of the JPM); the applicants were
then expected to initiate a reactor trip. Applicant weaknesses during administration of
3
this JPM included failure to reset the rod group step counter, failure to perform a reactor
trip, and failure to interpret plant indications associated with the second dropped rod.
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 concerning the written
examination and three post-examination comments concerning the operating test. A
copy of the final written examinations and answer keys, with all changes incorporated,
may be accessed not earlier than September 26, 2022, in the ADAMS system (ADAMS
Accession Number(s) ML20276A129 and ML20276A130). A copy of the licensees post-
examination comments may be accessed in the ADAMS system (ADAMS Accession
Number ML20276A128.
4
4OA6 Meetings, Including Exit
Exit Meeting Summary
On August 28, 2020, the NRC examination team discussed generic issues associated
with the operating test with Mr. Charles Kharrl, Site Vice President, and members of the
Joseph M. Farley Nuclear Plant staff. The examiners asked the licensee if any of the
examination material was proprietary. No proprietary information was identified.
5
KEY POINTS OF CONTACT
Licensee personnel
Charles Kharrl, Site Vice President
Delson Erb, Plant Manager
Rob Norris, Operations Director
Josh Carroll, Work Management Director
Ed Mullek, Maintenance Director
Keith Brown, Regulatory Affairs Manager
Gene Surber, Licensing Manager
Anderson Renaud, Operations Training Manager
Vince Richter, Operations Lead Instructor
Peppi Cooper, Training Support Manager
Tom Campbell, Licensing Engineer
NRC personnel
Pete Meier, NRC Resident Inspector
6
FACILITY AND APPLICANT POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS
A complete text of the facility licensee and applicant post-examination comments can be found
in ADAMS under Accession Number ML20276A128. There were four post-exam comments.
One applicant provided a post-exam comment for SRO Written Exam Item #94; other applicants
provided post-exam comments related to a scenario guide and two job performance measures
(JPMs). The facility licensee agreed with all the applicants contentions.
Post-Examination Comment #1: SRO Question #94
The applicant contended that there were two correct answers for the first part of the question
because NMP-OS-007-001, Conduct of Operations Standards and Expectations, Section
4.28.5, Manual Operation of Motor-Operated Valves (MOVs) and Air-Operated Valves (AOVs),
stated that a motor-operated valve (MOV), which was manually actuated using its handwheel
operator, should be unseated and electrically stroked prior to declaring the valve operable, even
though the same administrative procedure stated that the MOV may be considered operable
when the MOV was manually actuated via the handwheel operator to its required safety
position. The applicant contended that the stem of the question did not specify the availability of
the MOVs electrical power supply, and the word should was a stronger administrative
requirement than may. Therefore, the applicant contended that the stem of the question did
not contain any conditions that would preclude electrically stroking the MOV, which was a
management expectation, even though the procedure allowed that the MOV to be considered
operable as long as the MOV was electrically stroked later.
The facility licensee agreed with the applicants contention and further contended that the past
and current operational practice was to use the motor prior to returning a valve to remote
service unless precluded by plant conditions.
Background
Question #94 was a two-part question:
Enclosure 2
The answer key indicated that Choice A was the correct answer. Neither the facility licensee
nor any of the applicants contested the second portion of the test item. One of the eight SRO
applicants who took the written exam picked Choice A as the original correct answer; four
SRO applicants picked Choice B; one SRO applicant picked Choice C; and two SRO
applicants picked Choice D. During the administration of the written exam, a different
applicant asked the proctor whether power was removed from the MOV when the System
Operator manually operated the MOV.
NRC Resolution: Applicant and facility comment accepted
The first part of the question tested Item g in NMP-OS-007-001, Conduct of Operations
Standards and Expectations, Section 4.28.5, Manual Operation of Motor-Operated Valves
(MOVs) and Air-Operated Valves (AOVs), which stated:
2
The first part of the question asked if the MOV is / is NOT operable. In accordance with
Item g (1), an MOV which was manually actuated using the hand wheel operator
SHOULD [emphasis added] be stroked prior to declaring it operable, which implied a
management expectation that was to be performed unless specific conditions precluded
the action. The stem of the question did not specify the availability of the MOV power
supply or whether an immediate discretionary decision was required; therefore, the stem
of the question did not provide information to imply Item g (2) was necessary, i.e., the
stem did not imply that an immediate discretionary decision by the SRO was required.
Item g (2) stated that an MOV which was manually actuated using the handwheel
operator MAY [emphasis added] be considered operable if the MOV was in its required
safety position, but still required electrical cycling later.
NMP-AP-003, Procedure and Work Instruction Use and Adherence, Section 2.0,
Definitions, stated:
The stem of the question did NOT ask whether NMP-OS-007-001 allowed [emphasis
added] the MOV to be considered [emphasis added] operable, and the stem did not
include any information that implied an immediate discretionary operability decision was
required; therefore, the applicants were forced to make an assumption whether
electrically stroking the valve was possible. Based on an operationally valid assumption,
there were two possible answers.
- IF an applicant assumed that the power supply was available, THEN the applicant
could select Choice B (not operable) because the management expectation was
to use the motor prior to returning a valve to remote service.
- IF an applicant assumed that the power supply was NOT available AND further
assumed that an immediate discretionary operability decision was required,
3
- THEN the applicant could select Choice A (operable) because there was no
known issue with the valve in its required safety position.
NUREG-1021, ES-403, Grading Initial Site-Specific Written Examinations, Section D.1.a
stated, in part:
The following types of errors, if identified and adequately justified by the facility
licensee or an applicant, are most likely to result in post-examination changes
agreeable to the NRC:
- a question with an unclear stem that confused the applicants or did not
provide all the necessary information.
ES-403, Section D.1.c stated, in part,
If a question is determined to have two correct answers, both answers will be
accepted as correct.
Therefore, the answer key was changed to accept both Choice A and B as correct.
Post-Examination Comment #2: Simulator Scenario 1, Event 5
One applicant contended that Form ES-D-2, Required Operator Actions, for Scenario 1 Event 5
did not align with Revision 23.0 of AOP-100, Section 1.4, Step 3. The applicant contended that
the Form ES-D-2 should be changed to say, IF desired to stabilize the plant and a ramp is in
progress, place turbine on HOLD. The facility licensee concurred with the applicants
contention.
Background
Scenario 1, Event 5 was 1A Steam Generator Feed Pump (SGFP) Controller failure. The
operating test Form ES-D-2 for Scenario 1 included the following Step 3 from 1-AOP-100,
Instrument Malfunction, Section 1.4, SGFP Speed Control:
However, version 23.0 of 1-AOP-100, Section 1.4, included the following Step 3:
4
NRC Resolution: Applicant and facility comment accepted
Version 23.0 of 1-AOP-100 was issued on February 12, 2020; the facility licensee froze the
initial exam procedures on February 28, 2020 following their internal validation of the operating
test. However, the new version 23.0 was not incorporated into the ES-D-2 for the scenario.
Therefore, evaluation of the applicants performance during Scenario 1, Event 5 was completed
in accordance with ES-303, Documenting and Grading Initial Operating Tests, using the
corrected marked-up version of Form ES-D-2 for Scenario 1 Event 5 that reflected Revision
23.0 of AOP-100, Section 1.4, Step 3. In accordance with NUREG-1021, Rev. 11, ES-501,
Section F.1, the marked-up version of Form ES-D-2 will be added to ADAMS.
Post-Examination Comment #3: JPM D, Place Letdown in service after Spurious SI
One applicant contended that the task standard for JPM Step 6 did not align with ESP-1.1, SI
Termination, Step 14.1.4. Specifically, the applicant contended that the phrase Open letdown
orifice isolation valve(s) should be added to the standard. The applicant contended that Step
14.1.4 allowed any one orifice isolation valve to be opened since the word valve(s) meant that
the singular form of only opening any one orifice isolation valve was permitted.
The facility licensee agreed with the applicants contention and further contended that the intent
of Step 14.1.4, according to the ESP-1.1 basis document, was to establish a controlled bleed
path from the RCS to allow lowering and controlling pressurizer level. The facility licensee
contended that ANY one of the letdown orifices provided adequate flow to reestablish a RCS
bleed path, with charging and seal injection in service, to lower and control pressurizer level.
The facility licensee contended that the intent of the AND / OR connectors in Step 14.1.4 was
to preclude two 60 gpm orifices from being placed in service because 120 gpm could exceed
the allowed flow through the CVCS demineralizers. The facility licensee stated that a procedure
change request was subsequently initiated via the corrective action program to enhance Step
14.1.4.
Background
The initial conditions for JPM D were:
JPM Step 6 (Procedure Step 14.1.4) and its performance standard was:
5
ESP-1.1, Step 14.1.4 Action/Expected Response (A/ER) and Response NOT Obtained (RNO)
columns were:
NRC Resolution: Applicant and Facility Comment NOT accepted
In Step 14.1.4, the word valve(s) allowed two options to be performed.
Option 1: Plural valves: Open the 45 gpm (8149A) AND the 60 gpm (8149B) orifice isolation
valves (plural) to achieve 105 gpm.
Option 2: Singular valve: Open ONLY the 60 gpm (8149C) orifice isolation valve (singular) to
achieve 60 gpm.
Step 14.1.4 did not allow ONLY the 45 gpm (8149A) orifice to be opened because of the AND
connection to the 60 gpm (8149B) orifice, and also did not allow both 60 gpm orifice isolation
valves (8149B and 8149C) to be opened.
The basis for establishing letdown, in accordance with FNP-0-ESB-1.1, Specific Background
Document for 1/2 ESP-1.1 SI Termination, was to establish a controlled bleed path from the
RCS, and stated, in part:
6
Normal letdown provided a controlled mechanism for offsetting volume additions
through the charging system. If normal letdown cannot be established, excess
letdown is established to balance seal injection flow. Charging may have to be reduced
after excess letdown is established due to the limited capacity of excess letdown.
The applicant and facility licensee contended that opening any ONE of the letdown orifices met
the intent of Step 14.1.4 because sufficient RCS bleed path flow would be established such that
charging and seal injection flow would be maintained. The JPM initial conditions stated that
pressurizer level was 44% and rising. The letdown flow with only the 8149A (45 gpm) orifice
was ~ 49 gpm; the total seal injection flow was ~ 24 gpm (8 gpm per pump); and the #1 Seal
Leakoff flow was ~ 7.5 gpm (2.5 gpm per pump).
Although the 8149A (45 gpm) orifice could [emphasis added] potentially meet the intent
[emphasis added] of Step 14.1.4 with additional charging flow adjustments, Step 14.1.4 did not
allow only the 8149A (45 gpm) orifice to be placed in service.
NUREG-1021, Appendix C, Job Performance Measure Guidelines, Section B.3 stated, in part,:
Every procedural step that the examinee must perform correctly (i.e., accurately, in the
proper sequence, and at the proper time) to accomplish the task standard shall be
identified as a critical step and shall have an associated performance standard.
Therefore, the task standard for JPM Step 6 was retained because procedure Step 14.1.4 did
not allow only the 8149A (45 gpm) orifice to be placed in service.
Post-Examination Comment #4: SRO Admin JPM, Determine LHRA Access Controls and
Evaluate Administrative Dose Limit Requirements
Two applicants contended that the task standard for JPM Step 2 should be revised to also
permit the use of a flashing light and barrier as a compensatory action to preclude unauthorized
individuals access into the locked high radiation area (LHRA); the applicants contended that the
task standard for JPM Step 2 only allowed an access control guard even though the flashing
light and barrier was permitted.
The facility licensee agreed with the applicants and contended that NMP-HP-302, Restricted
Area Classification, Postings, and Access Control, allowed the use of a flashing red light and
barrier, in lieu of an access control guard, and has been utilized by the facility licensee in the
past, although not on a routine basis.
Background
The administrative JPM involved entering the Letdown Heat Exchanger Room when it was
posted as a LHRA and one element of the JPM was for the applicants to identify the required
compensatory action(s) to ensure only authorized individuals gained access into the LHRA
while a system operator entered the room to manually close a valve. The initial conditions of
the JPM specified that the Letdown Heat Exchanger Room did not have a way to be re-locked
while the system operator was performing the work in the room.
7
JPM Step 2 and its performance standard was:
NMP-HP-302, defined the following boundary requirements for LHRAs:
The standard for JPM Step 2 (access control guard) was based on the 6th bullet, i.e., an Access
Control Guard may be used while an area is being routinely accessed or additional time is
required to establish controlled boundaries. Attachment 4, LHRA Access Guard
Responsibilities Checklist, provided requirements for an individual performing the function of an
Access Guard to a LHRA.
Precaution and Limitation 24 stated:
8
The standard for JPM Step 2 did not include all the options available for compensatory actions
that precluded unauthorized individuals from entering the Letdown Heat Exchanger Room while
the work was being performed, i.e., the standard for JPM Step 2 only identified one option,
which was the access control guard, even though NMP-HP-302 also allowed a flashing light and
barrier with RP Manager approval.
NUREG-1021, Appendix C, Job Performance Measure Guidelines, Section B.3 stated, in part,:
Every procedural step that the examinee must perform correctly (i.e., accurately, in the
proper sequence, and at the proper time) to accomplish the task standard shall be
identified as a critical step and shall have an associated performance standard.
Therefore, the performance standard for JPM Step 2 was revised to include both options, i.e.,
an access control guard or a flashing light and barrier with RP Manager approval. In
accordance with NUREG-1021, Rev. 11, ES-501, Section F.1, the marked-up version of this
SRO administrative JPM will be added to ADAMS.
9
SIMULATOR FIDELITY REPORT
Facility Licensee: Joseph M. Farley Nuclear Plant
Facility Docket No.: 05000348, 05000364
Operating Test Administered: August 24 - 28, 2020
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.
For the simulator portion of the operating test, examiners observed the following:
Item Description
1. R-70B, N16 Primary-to-Secondary Leak Rad Monitor (Mirion
R70) did not allow changing the setpoint at the Remote Display.
Simulator Maintenance DR # 0025004
2. Simulator A main computer was required to be re-booted and its
initial conditions (IC) reset function did not occur, potentially due to
compatibility issues with the exam room desktop simulator and/or
Simulator B.
Simulator Maintenance DR# 0024985, # 0024904, and #0025003
Enclosure 3