ML18207A942
| ML18207A942 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 08/01/2018 |
| From: | Vincent Gaddy Operations Branch IV |
| To: | Peters K Vistra Operations Company |
| References | |
| 50-445/18-301, 50-446/18-301 | |
| Download: ML18207A942 (13) | |
See also: IR 05000445/2018301
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD
ARLINGTON, TX 76011-4511
August 1, 2018
Ken J. Peters, Senior Vice President
and Chief Nuclear Officer
Attention: Regulatory Affairs
Vistra Operations Company LLC
P.O. Box 1002
Glen Rose, TX 76043
SUBJECT: COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 - NRC
EXAMINATION REPORT 05000445/2018301; 05000446/2018301
Dear Mr. Peters:
On July 19, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator
license examination at Comanche Peak Nuclear Power Plant, Units 1 and 2. The enclosed
report documents the examination results and licensing decisions. The preliminary examination
results were discussed on June 15, 2018, with members of your staff. A telephonic exit meeting
was conducted on July 19, 2018, with Ms. Donna Christiansen, Training Director, who was
provided the NRC licensing decisions.
The examination included the evaluation of six applicants for reactor operator licenses, six
applicants for instant senior reactor operator licenses, and three applicants for upgrade senior
reactor operator licenses. The license examiners determined that fourteen of the fifteen
applicants satisfied the requirements of Title 10 of the Code of Federal Regulations (CFR)
Part 55, and the appropriate licenses have been issued. There was one post examination
comment submitted by your staff. Enclosure 1 contains details of this report and Enclosure 2
summarizes post examination comment resolution.
No violations were identified during this examination.
In accordance with 10 CFR 2.390 of the NRC's "Agency Rules of Practice and Procedure," a
copy of this letter and its enclosure will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
K. Peters 2
NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public
Electronic Reading Room).
Sincerely,
/RA/
Vincent G. Gaddy, Chief
Operations Branch
Division of Reactor Safety
Docket Nos. 50-445, 50-446
Enclosures:
1. Examination Report 05000445/2018301; 05000446/2018301
w/Attachment: Supplemental Information
2. NRC Post Examination Comment
Resolution
SUNSI Review: ADAMS: Non-Publicly Available Non-Sensitive Keyword:
By: K. Clayton Yes No Publicly Available Sensitive
OFFICE SOE:OB OE: OB SOE:OB SOE:OB C:OB C:PBA C:OB
NAME JKirkland MHayes COsterholtz KClayton VGaddy MHaire VGaddy
SIGNATURE /RA by /RA by /RA by /RA/ /RA/ /RA by /RA/
Email/ Email/ Email/ RAlexander
for MSH/
DATE 07/27/18 07/31/18 07/31/18 07/31/18 07/31/18 08/01/18 08/01/18
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-445, 50-446
Report Nos.: 05000445/2018301; 05000446/2018301
Licensee: Vistra Operations Company LLC
Facility: Comanche Peak Nuclear Power Plant, Units 1 and 2
Location: Glen Rose, Texas
Dates: June 11 - July 19, 2018
K. Clayton, Chief Examiner, Senior Operations Engineer
J. Kirkland, Senior Operations Engineer
Inspectors:
C. Osterholtz, Senior Operations Engineer
M. Hayes, Operations Engineer
Vincent G. Gaddy, Chief
Approved By: Operations Branch
Division of Reactor Safety
Enclosure
SUMMARY
ER 05000445/2018301; 05000446/2018301; June 11 - July 19, 2018; Comanche Peak Nuclear
Power Plant, Units 1 and 2; Initial Operator Licensing Examination Report.
NRC examiners evaluated the competency of six applicants for reactor operator licenses, six
applicants for instant senior reactor operator licenses and three applicants for upgrade senior
reactor operator license at Comanche Peak Nuclear Power Plant, Units 1 and 2.
The NRC developed the examinations using NUREG-1021, "Operator Licensing Examination
Standards for Power Reactors," Revision 11. The written examination was administered by the
licensee on June 20, 2018. NRC examiners administered the operating tests on
June 11 - 17, 2018.
The examiners determined that fourteen of the fifteen applicants satisfied the requirements
of 10 CFR Part 55, and the appropriate licenses have been issued.
A. NRC-Identified and Self-Revealing Findings
None.
B. Licensee-Identified Violations
None.
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REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA5 Other Activities (Initial Operator License Examination)
.1 License Applications
a. Scope
NRC examiners reviewed all license applications submitted to ensure each applicant
satisfied relevant license eligibility requirements. Examiners also audited three of the
license applications in detail to confirm that they accurately reflected the subject
applicants qualifications. This audit focused on the applicants experience and on-the-
job training, including control manipulations that provided significant reactivity changes.
b. Findings
No findings were identified.
.2 Examination Development
a. Scope
The NRC developed the written exam and operating tests in accordance the
requirements of NUREG-1021. The NRC examination team conducted an on-site
validation of the operating tests.
b. Findings
No findings were identified.
.3 Operator Knowledge and Performance
a. Scope
On June 20, 2018, the licensee proctored the administration of the written examinations
to all applicants. The licensee staff graded the written examinations, analyzed the
results, and presented their analysis and post examination comments to the NRC on
June 25, 2018.
The NRC examination team administered the various portions of the operating tests to
all applicants on June 11 - 17, 2018.
b. Findings
No findings were identified.
All applicants passed the written examination and fourteen of fifteen applicants passed
all portions of the operating test. The final written examinations and post examination
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analysis and comments may be accessed in the ADAMS system under the accession
numbers noted in the attachment.
The examination team noted five generic weaknesses associated with applicant
performance on the operating tests. All of the weaknesses were attributed to
knowledge weaknesses on the topic and included the following items:
1. Several crews (2/4) could not adequately determine a fuel failure event was in
progress during a scenario.
2. Several applicants (3/4) could not adequately operate the control room ventilation
system.
3. Applicants had difficulty with anti-pump features of handswitches and their
associated breakers.
4. Several crews (3/4) had difficulty diagnosing a faulted and ruptured steam
generator during a scenario.
5. Several crews struggled with proper communications during the scenarios.
The licensee identified five generic weaknesses associated with applicant performance
on the written examinations. All of the weaknesses were attributed to knowledge
weaknesses on the topic and included the following items:
1. Applicants were unfamiliar with design features of the containment sump.
2. Applicants were unfamiliar with Abnormal Procedure ABN-901, Fire Protection
System Alarms or Malfunctions.
3. Applicants had difficulty recalling safety-related battery capacities.
4. Applicants were unfamiliar with the immediate operability requirements regarding
fuel oil for the emergency diesel generators and their Technical Specification
requirements (day tank requirements).
5. Applicants had difficulty determining what system to use during emergency
procedures to lower containment hydrogen during a Loss of Coolant Accident.
Copies of all individual examination reports were sent to the facility Training Manager for
evaluation and determination of appropriate remedial training. The licensee generated
Issue Report IR-2018-004425 for resolution of all operating test and written examination
generic weaknesses.
.4 Simulation Facility Performance
a. Scope
The NRC examiners observed simulator performance with regard to plant fidelity during
examination validation and administration.
b. Findings
No findings were identified.
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.5 Examination Security
a. Scope
The NRC examiners reviewed examination security for examination development during
both the onsite preparation week and examination administration week for compliance
with 10 CFR 55.49 and NUREG-1021. Plans for simulator security and applicant control
were reviewed and discussed with licensee personnel.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The chief examiner presented the preliminary examination results to Mr. Thomas McCool, Site
Vice President, and other members of the staff on June 15, 2018. A telephonic exit was
conducted on July 19, 2018 between Mr. K. Clayton, Chief Examiner, and Ms. Donna
Christiansen, Training Director.
The licensee did not identify any information or materials used during the examination as
proprietary.
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SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
T. McCool, Site Vice President
D. Christiansen, Training Director
J. Lloyd, Operations Support Manager
J. Ruby, Exam Developer
NRC Personnel
J. Josey, Senior Resident Inspector
ADAMS DOCUMENTS REFERENCED
Accession No. ML18204A263 - FINAL WRITTEN EXAMS (DELAYED Release until 6/27/2020)
Accession No. ML18204A262 - FINAL OPERATING TEST (DELAYED Release until 6/27/2020)
Accession No. ML18204A264 - POST EXAM ANALYSIS-COMMENTS
Attachment
NRC Resolution to the Comanche Peak Post Examination Comments
A complete text of the licensee's post examination analysis and comments can be found in
ADAMS under Accession Number ML18204A264.
The chief examiner discussed the requested change to the key for one question (Q15) with the
licensee prior to post examination comment submittal in accordance with NUREG-1021 and
agreed that the requested change seemed reasonable pending formal documents to support the
request. The final disposition of this comment is documented below.
Question 15
Unit 1 has a reactor trip from 100% power with the following conditions:
- four control rods failed to insert
- The US has entered EOP-0.0A, Reactor Trip or Safety Injection, and ABN-107,
Emergency Boration.
Step 1 of ABN-107 states:
Check RWST TO CHRG PMP SUCT VLVs, 1/1-LCV-112D AND 1/1-LCV-112E - CLOSED.
For some unknown reason the RWST TO CHRG PMP SUCT VLV, 1/1-LCV-112D is OPEN
and WILL NOT CLOSE.
The Response Not Obtained (RNO) column of ABN-107 directs the operator to emergency
borate _________ because it is the preferred method for these plant conditions.
A. from the RWST via 1/1-LCV-112D OR 1/1-LCV-112E using Attachment 4
B. through emergency borate valve 1-8104 using Attachment 1
C. through manual emergency borate valve 1CS-8439 using Attachment 3
D. through normal boration valves 1-FCV-0110A and 1/u-FCV-0110B using Attachment 2
Answer: A
Explanation:
A is correct because according to ABN-107, step 1 if 1/1-LCV-112D and 1/1-LCV-112E are
not closed, the RNO directs you to step 7 which states that Attachment 4 is the preferred
method to emergency borate from the RWST. If it is open (LCV-112D) and wont close, the
interlock to allow the other valves to open and borate through other normally preferred
methods is not available so this is the preferred method.
B is incorrect because according to ABN-107, Attachment 1 is the preferred method if 1/1-
LCV-112D and 1/1-LCV-112E are closed, and at least one Boric Acid pump is available.
C is incorrect because according to ABN-107, Attachment 3 is another method if 1/1-LCV-
112D and 1/1-LCV-112E are closed, and at least one Boric Acid pump is available.
D is incorrect because according to ABN-107, Attachment 3 is another method if 1/1-LCV-
112D and 1/1-LCV-112E are closed, and at least one Boric Acid pump is available.
Enclosure 2
Technical References:
ABN-107, Emergency Boration, Rev. 9, pages 4-5
Licensee Comments for Question 15
Recommend accepting two correct answers A and B
During written examination review of the CPNPP 2018 NRC exam it was identified that
Question 15 has two correct answers.
Reason
- The question exhibits a normal reactor trip with NO Safety Injection, 4 Control Rods
failing to insert into the core, and 1/1-LCV-112D open for some unknown reason.
- The US then enters EOP-0.0A, Reactor Trip or Safety Injection AND ABN-107,
Emergency Boration.
- When the Reactor Operator notes all rods failed to insert, there is no RNO action to
be performed in EOP-0.0A and the crew proceeds to step 2. After the completion
and verbalization of the Immediate Operator Actions (Steps 1-4) of EOP-0.0A, the
Reactor Operator will Emergency Borate for the stuck rods per the Fold Out Page
guidance contained in EOP-0.0A, Attachment 1A, Foldout For EOP-0.0A Reactor
Trip Or Safety Injection.
- The action to perform Emergency Boration is performed independently of US
direction as a Foldout Page action. The US will not direct the action, only ensure that
it takes place and verify its initiation.
- EOP-0.0A Foldout Page states to Emergency Borate, per ABN-107, if two or more
control rods are NOT fully inserted (1800 gallons of 7000 ppm boric acid for each
control rod not fully inserted)
- ABN-107 contains a NOTE prior to Step 1 stating: Attachment 1 and Attachment 4
have been developed into Operator Aids for use during emergency boration and may
be entered independently of this procedure.
- This NOTE is what allows the Reactor Operator to initiate Emergency Boration per
the Operator Aid independently of ABN-107. The operator will execute either
page 1 or page 2 of the operator aid by diagnosing the current plant conditions and
determining if a Safety Injection has occurred or not. In this case there is no Safety
Injection present, therefore Emergency Boration will be conducted per
Attachment 1 (Page 2 of the Operator Aid)
- The Operator Aid (PLR# 2013-0023-S) is contained at the Main Control Board (MCB)
Panel CB-06
- The first page of the operator aid is an exact replica of ABN-107, Attachment 4,
Transfer of Charging Pump Suction to the RWST, Page 1 ONLY. This page of the
operator aid would be used to initiate Emergency Boration anytime a Safety Injection
HAS occurred
- The second page of the operator aid is an exact replica of ABN-107, Attachment 1,
2
Emergency Boration Through Emergency Borate Valve u-8104. This page of the
operator aid would be used to initiate Emergency Boration anytime a Safety Injection
has NOT occurred and there are no known issues with either u-8104 or the Boric
Acid Transfer Pumps.
- The Reactor Operator may either Emergency Borate per the second page of the
operator aid that is a replica of Attachment 1 of the ABN or the first page of the
operator aid that is a replica of page 1 of Attachment 4 of the ABN.
- Based on the information provided above CPNPP has determined both selections A
and B are correct.
- Answer choices C and D are incorrect because these attachments CANNOT be
entered independently of ABN-107 and are NOT directed by the procedure based on
the given conditions.
- The original correct answer as approved on the worksheet and the answer key is A
- See attached figure of the Operator Aid marked as PLR# 2013-0023-S.
- See attached figure of ABN-107 NOTE prior to Step 1.
NRC Resolution of Question 15
Licensee (CPNPP) requests that both answers A and B be accepted for Q15. Their analysis is
included as item 6 in the post exam package. The Chief Examiner agrees and the key is
changed to accept both A and B as correct answers for Q15.
The Chief Examiner reviewed the challenge, the applicant answer selections, and questions
asked both during administration of the exam and during review of the exam with the applicant
class and licensee training staff. Relevant information from this is the following:
1. The entire class either picked correct answer as originally keyed, A or the proposed
second correct answer, B.
2. Two of the applicants asked direct questions regarding the reasons why distracter B
could be considered correct.
The Chief Examiner agrees with the licensee that distracter B could be argued as correct
because the NOTE on page 4 of the Abnormal Procedure ABN-107, prior to step 1, states that
Attachment 1 and Attachment 4 have been developed into Operator Aids for use during
emergency boration and may be entered independently of this procedure. Also, the note
occurs prior to the RNO step that is called out in the stem of the question. The licensee
indicated in their submittal that operators (applicants) are trained to use the job aid for
emergency boration activities from the Emergency Operating Procedures and these aids are
entered independently of the ABN-107 procedure via the foldout page.
Additionally, the word preferred is a word that the NUREG-1021 discourages using in the stem
of questions because it can be ambiguous or confusing. The word preferred is used in the
stem of this question and also in the Abnormal Procedure ABN-107. Furthermore, the use of
preferred in this procedure is confusing because it is mentioned several times and has several
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steps in the procedure that use it for different attachments. For example, just below step 2.3.3 it
states that Attachment 1 is the preferred source of emergency boration, which leads the Chief
Examiner to believe that the procedure needs modification to clarify the actual preferred source
for a given set of conditions with proper RNO steps for each Attachment as necessary. This
would allow an operator to make the correct decision for completing foldout page actions or
immediate operator actions for an abnormal event in a timely and successful manner.
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