IR 05000250/2011302
| ML12059A361 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 02/28/2012 |
| From: | Mark Franke Division of Reactor Safety II |
| To: | Nazar M Florida Power & Light Co |
| References | |
| ER-11-302 | |
| Download: ML12059A361 (17) | |
Text
February 28, 2012
SUBJECT:
TURKEY POINT NUCLEAR POWER PLANT - NRC OPERATOR LICENSE EXAMINATION REPORT 05000250/2011302 AND 05000251/2011302
Dear Mr. Nazar:
During the period December 6 - 8, 2011, the Nuclear Regulatory Commission (NRC)
administered operating tests to employees of your company who had applied for licenses to operate the Turkey Point Nuclear Power Plant. At the conclusion of the tests, the examiners discussed preliminary findings related to the operating tests and the written examination submittal with those members of your staff identified in the enclosed report. The written examination was administered by your staff on December 14, 2011.
Three Reactor Operator (RO) and two Senior Reactor Operator (SRO) applicants passed both the operating test and written examination. One RO applicant failed the written examination.
There were six post-administration comments concerning the written examination. The post examination comments were identified in letters dated December 23, 2011, and January 10, 2012. 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 written SRO examination submitted by your staff failed to meet the guidelines for quality contained in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 9, Supplement 1, as described in the enclosed report. All other parts of 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 9, Supplement 1.
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) 997-4436.
Sincerely,
/RA/
Mark E. Franke, Chief
Operations Branch 2
Division of Reactor Safety
Docket Nos. 50-250 and 50-251 License Nos. DPR-31 and DPR-41
Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
If you have any questions concerning this letter, please contact me at (404) 997-4436.
Sincerely,
/RA/
Mark E. Franke, Chief
Operations Branch 2
Division of Reactor Safety
Docket Nos. 50-250 and 50-251 License Nos. DPR-31 and DPR-41
Enclosures:
1. Report Details 2. Facility Comments and NRC Resolution 3. Simulator Fidelity Report
XG PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE XG NON-SENSITIVE ADAMS: XG Yes ACCESSION NUMBER:__ml12059A361________________
XG SUNSI REVIEW COMPLETE G FORM 665 ATTACHED OFFICE RII:DRS RII:DRS RII:DRP RII:DRP RII:DRS RII:DRS
NAME ELEA DBACON CKONTZ DRICH MFRANKE BCABALLERO
DATE 2/27/2012 2/23/12 2/27/2012 2/27/2012 2/28/2012 2/28/2012
E-MAIL COPY?
YES NO YES NO YES NO YES NO YES NO YES NO YES NO OFFICIAL RECORD COPY DOCUMENT NAME:
G:\\DRSII\\OBII\\SITES\\TURKEY POINT\\GENERAL CORRESPONDENCE\\TP 2011 302 EXAM REPORT.DOCX
REGION II==
Docket No.:
50-250, 50-251
License No.:
Report No.:
05000250/2011302, 05000251/2011302
Licensee:
Florida Power & Light Company (FP&L)
Facility:
Turkey Point Nuclear Plant, Units 3 & 4
Location:
9762 S. W. 344th Street
Florida City, FL 33035
Dates:
Operating Test - December 6 - 8, 2011
Written Examination - December 14, 2011
Examiners:
Edwin Lea, Chief Examiner, Senior Operations Examiner
Craig Kontz, Senior Project Engineer Dan Bacon, Operations Engineer Andreas Goldau, Operations Engineer (Training)
Amanda Toth, Operations Engineer (Training)
Approved by:
Mark E. Franke, Chief
Operations Branch
Division of Reactor Safety
Enclosure 1
SUMMARY OF FINDINGS
ER 05000250/2011302, 05000251/2011302, 12/6 - 8/ 2011; Turkey Point Nuclear Station;
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 the Turkey Point Nuclear Plant staff developed both the operating tests and the written examination. The initial senior reactor operator (SRO) written examination submittal did not meet the quality guidelines contained in NUREG-1021.
The NRC administered the operating tests during the period December 6 - 8, 2011. Members of the Turkey Point Nuclear Station training staff administered the written examination on December 14, 2011. Three Reactor Operator (RO) and two SRO applicants passed both the operating test and written examination. Two RO applicants and two SRO applicants were issued licenses commensurate with the level of examination administered. One RO applicant passed the operating test, but passed the written examination with an overall score between 80% and 82%. The one RO applicant was issued a letter stating that they passed the examination and issuance of their license has been delayed pending any written examination appeals that may impact the licensing decision for their application. One RO applicant passed the operating test, but failed the written examination.
There were six post-examination comments.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES
4OA5 Operator Licensing Examinations
a. Inspection Scope
Members of the Turkey Point staff 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 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 examiners evaluated four Reactor Operator (RO) and two Senior Reactor Operator (SRO) applicants using the guidelines contained in NUREG-1021. The examiners administered the operating tests during the period December 6 - 8, 2011.
Members of the Turkey Point Nuclear Power Plant training staff administered the written examination on December 14, 2011. Evaluations of applicants and reviews of associated documentation were performed to determine if the applicants, who applied for licenses to operate the Turkey Point Nuclear Power Plant, met the requirements specified in 10 CFR Part 55, Operators Licenses.
b. Findings
The NRC determined that the licensees written SRO examination submittal was outside the range of acceptable quality specified by NUREG-1021. The initial written SRO examination submittal was outside the range of acceptable quality because more than 20% [10 out of 25] of the questions contained unacceptable flaws. Individual questions were evaluated as unsatisfactory for the following reasons:
- One question failed to meet the K/A statement contained in the examination outline.
- Four questions contained two or more implausible distractors.
- One question did not provide any discriminatory value, i.e., level of difficulty equal to 1.
The NRC determined that the licensees initial operating test submittal was within the range of acceptability expected for a proposed examination.
Three RO applicants and two SRO applicants passed both the operating test and written examination. One RO 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, but passed the written examination with an overall score between 80 percent and 82 percent. The one RO applicant was issued a letter stating that they passed the examination and issuance of their license has been delayed pending any written examination appeals that may impact the licensing decision for their application.
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 six 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 January 7, 2014, in the ADAMS system (ADAMS Accession Numbers ML120090385, ML120090388, and ML120090369).
4OA6 Meetings, Including Exit
Exit Meeting Summary
On December 9, 2011, the NRC examination team discussed generic issues associated with the operating test with Mr. Mark Jones, Operations 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
M. Jones, Operations Manager N. Constance, Training Manager B. Heidecker, Training Instructor S. Mihalakea, Licensing M. Similey, Initial Training Supervisor B. Stamp-Operations Training Supervisor M. Wilson, Training Instructor
NRC personnel
M. Junge, Branch Chief (Acting)
FACILITY POST-EXAMINATION COMMENTS AND NRC RESOLUTIONS
A complete text of the licensee's post examination comments can be found in ADAMS under
Accession Number ML120093609.
RO QUESTION # 3
Comment: The licensee requested that this question be deleted from the exam. The licensee
contended that the word controlled, which was used in the stem of the question, was
ambiguous because it implied that RCS subcooling was required to be maintained within a
specific band. During the administration of the exam, one applicant asked the proctor if the
word controlled meant the same thing as monitored and ensured or minimized. The proctor
response, as agreed to by the NRC, was to answer the question with the information provided.
Additionally, the licensee contended that the question was beyond the normal knowledge and
abilities for a reactor operator.
NRC Resolution: Recommendation not accepted. Question #3 tested the applicants
knowledge of the reason for controlling subcooling during the RCS depressurization in ES-1.2,
Post-LOCA Cooldown and Depressurization. The high-level statement of Step 26 was:
When reducing RCS pressure, the crew is required to maintain a safe buffer of RCS
subcooling margin, i.e., control subcooling above 40 °F. After the safety injection (SI)
reduction sequence had been completed, the RCS can be depressurized until RCS subcooling
approaches a minimum value. The wording of the high-level statement at Step 26 is slightly
different from the Westinghouse Owners Group (WOG) Emergency Response Guideline
Background Information, Step 14, which is Depressurize RCS to Minimize Subcooling. The
purpose statement for this step, as listed in the WOG background document, is PURPOSE: To
minimize break flow by reducing subcooling. Therefore, the word controlled was not
ambiguous and Choice B was the correct choice.
Choice A (to ensure continued RCP operation) was incorrect because the stem provided
information that normal spray was in service (RCP was running), Safety Injection pumps had
been manually overridden off, and that the crew was cooling down and depressurizing the
RCS; therefore, the applicant was expected to discern that the plant status was already beyond
Step 11.
At Turkey Point, normal spray is obtained from either of the RCS loop B or C cold legs when an
RCP is operating. Therefore, the applicant was expected to discern that the plant status
matched the major action category associated with depressurizing the RCS to minimize RCS
leakage, NOT starting an RCP. Choices C and D were incorrect because they both
contained the word challenge, which implied either a red or orange path. The stem of the
question indicated that the crew had purposely stopped the Safety Injection (SI) Pumps to cool
down the plant and depressurize the RC
crew had more than adequate cooling flow based on the fact that the SI pumps were manually
overridden off. Choices C and D could not be correct unless the applicant made
assumptions well beyond those provided in the stem. Therefore, the only reason for controlling
subcooling during the major action category of Depressurize RCS to Minimize RCS Leakage
was to minimize RCS Leakage.
The licensee further contended that the question was beyond the knowledge required for a
reactor operator; however, the Turkey Point Post LOCA Cooldown and Depressurization lesson
plan (6902329) contained the following reactor operator learning objective:
Obj #4: EXPLAIN the major action categories of ES-1.2
Section 3.3 (Major Action Categories) of the lesson plan listed the following six major action
categories:
Prepare for and initiate RCS Cooldown
Depress RCS to Refill PZR
Start One RCP/Stop All But One RCP
Reduce SI Flow
Depress RCS to Minimize RCS Leakage
Perform Other Long Term Recovery Actions
The ES-1.2 major action categories were the overall mitigative strategy of ES-1.2; therefore, this
was reactor operator knowledge level.
RO QUESTION # 17
Comment: The licensee requested that two answers be accepted for this question.
The licensee contended that two procedures provided guidance for a controlled cooldown of the
RCS using Residual Heat Removal (RHR); therefore, the licensee recommended accepting
Choices B and D as correct answers.
NRC Resolution: Recommendation not accepted. The Foldout Page in ONOP-13, Loss of
Instrument Air, provided the following guidance in the Response Not Obtained (RNO) column of
Step 13:
The licensee contended that Choice D was also correct because Step 4.8.7 in 3-OP-050,
Residual Heat Removal System, provided the following guidance:
The guidance listed in 3-OP-050, Step 4.8.7 applied during a situation when the Component
Cooling Water (CCW) was required to be throttled to limit a cooldown. The stem of the question
required that applicants to complete the fill-in-the-blank statements in accordance with ONOP-
013, which provided guidance for controlling the RHR side of the heat exchanger. Choice D is
incorrect because the stem of the question specified ONOP-013 to control the RHR side of the
heat exchanger. Choice B is the only correct answer.
RO QUESTION # 53
Comment: The licensee requested that this question be deleted from the exam because it
tests knowledge beyond the normal knowledge and abilities for a reactor operator.
The licensees contention was that the licensed operators at Turkey Point are not required to
memorize all alarm setpoints for control room annunciators.
NRC Resolution: Recommendation not accepted. The Component Cooling Water (CCW)
System Lesson Plan (6902140) listed the following reactor operator learning objective:
Objective 7.c: EVALUATE the setpoints, coincidence and operational significance of
alarms associated with the CCW System, including:
a. CCW System Load Low Flow Alarms (H-7/5)
The Containment Spray System Lesson Plan (6902125) listed the following reactor operator
learning objective:
Objective 7.d: DESCRIBE the interrelations between the Containment Spray System
and the following:
b. Component Cooling Water
Section 2.0 of the Containment Spray System lesson plan listed the following information:
D. Mechanical Seals
d. CONTAINMENT SPRAY PUMPS COOLING WATER LOW FLOW alarm
1) 7.7 gpm decreasing
2) H-7/5
Section 3.6 (System Interrelationships) of the Containment Spray lesson plan listed the
following information:
Component cooling water cools the CSP mechanical seal heat exchanger. Loop A of
the component cooling water system supplies CS pump A while loop B supplies CS
pump B. A component cooling water low flow condition to the CS pumps seal water heat
exchanger is indicated by a common alarm.
The Containment Spray System operating procedure (3/4-NOP-068) provided the following
Caution:
Throttle valves are preset to establish design basis flow rates and should NOT be
operated. Repositioning of the throttle valves may affect CCW System operability and
should NOT be performed without System Engineer evaluation.
The CCW operating procedure (3/4-NOP-030), Precaution and Limitation (P&L) 2.2.1.8, listed
the maximum allowed CCW flow rate to a Containment Spray Pump Seal Water heat
exchanger. Additionally, Attachment 4, Component Cooling Water Flow Rates, listed the flow
adjustment valves and the normal operating CCW flow rates (gpm) for the containment spray
pump seal water heat exchangers.
Question # 53 was reviewed, validated, and approved by Operations and Training Management
for the NRC to make a licensing decision by virtue of their final written exam submittal package
to the NR
- C. NUREG 1021, Revision 9, Supplement 1, ES-403, Section D.1.b states:
Given that both the NRC and the facility licensee agreed that the examination met NUREG-
21 prior to the examination administration, the following types of question errors, identified
after examination administration, are less likely to result in examination changes:
a question for which references would be needed to provide the correct answer, even
though the facility licensee and the NRC previously agreed that the question should be
closed-reference.
10CFR55.41, Written Examination: Operators, Items (7) requires testing operator applicant
knowledge of design, components, and functions of control and safety systems, including
instrumentation, signals, interlocks, failure modes, and automatic and manual features. The
Containment Spray System is safety system used to spray cool water into the containment
atmosphere when appropriate in the event of a loss-of-coolant accident. The containment spray
pump (CSP) has mechanical seals which are cooled by CCW. The CCW cooling is critical to
eliminate seal leakage, which would be radioactive during the recirculation phase of an
accident.
The question required the applicants to recognize 1) a pre-adjusted component cooling water
(CCW) flow rate and 2) low CCW flow annunciator setpoint for a containment spray pumps
(CSP) seal water heat exchanger. Cooling water to safety related equipment, including the
instrumentation (annunciators), signals, interlocks, and failure modes is the design of the safety
system, and is required to be tested in accordance with 10CFR55.41.
RO QUESTION # 60
Comment: The licensee requested that this question be deleted from the exam because there
was no absolutely correct answer. The licensees comment was that if the Steam Dump Mode
Selector Switch was placed in the Manual position, then the steam dumps would arm; therefore,
Choice A (Steam Dumps are reset and can ONLY be armed by a turbine trip) was not
absolutely correct.
NRC Resolution: Recommendation accepted. The question tested the applicants knowledge
of the status of the condenser steam dumps after Turbine First Stage Pressure Transmitter 3-
PT-447 had failed low, and all applicable actions in 3-ONOP-049.1, Deviation of Failure of
Safety Related or Reactor Protection Channels, had been completed. The following choices
were provided:
A. Steam Dumps are reset and can ONLY be armed by a turbine trip.
B. Steam Dumps are reset and can ONLY be armed by a load reject.
C. Steam Dumps are armed and will actuate if Tave exceeds Tref by 9.5 °F
- D. Steam Dumps are armed and, if actuated, will close when Tave is within 5 °F of Tref.
Any of the following signals will arm the steam dumps:
Load rejection signal derived from PT-447
Steam Dump Mode Selector Switch in the MANUAL position.
Turbine trip signal derived from either auto stop oil pressure switches or turbine stop
valves.
In the case of Question #60, PT-447 had failed low and the required operator action in
accordance with 3-ONOP-049.1, was listed in Step 5.14:
Once the Steam Dump to Condenser Mode Selector switch had been placed to the RESET
position, the steam dumps were no longer armed and could no longer be armed from a load
rejection signal. However, the steam dumps could still be MANUALLY armed if the operator
placed the Mode Selector Switch to the MANUAL position. The wording of Choice A did not
sufficiently distinguish between automatically arming vs manually arming. Therefore, Question
- 60 was deleted from the exam.
RO QUESTION # 61
Comment: The licensee requested that this question be graded with two correct answers. The
licensees comment was that the stem of the question did not specify which S/G level indication
was being tested, that is, indicated S/G level did not specifically refer to the Narrow Range S/G
level or Wide Range S/G level. The licensee contends that the Narrow Range S/G level
indication initially lowered after the respective MSIV had closed whereas the Wide Range S/G
level indication initially rose. The licensee substantiated these level indication differences on
the plant referenced simulator.
NRC Resolution: Recommendation accepted. The two-part question asked for the initial effect
of closing 4A Main Steam Isolation valve on the 4A S/G indicated level, and the initial effect on
4B and 4C Feedwater Regulating Valve Position. The position of the reference leg tap for
Narrow Range level indicators was near the feedwater nozzles, which resulted in the level
indication phenomena commonly known as shrink and swell. The position of the reference leg
tap for Wide range levels at the bottom of the S/G did not produce this shrink and swell
phenomenon. Therefore, the initial response to a sudden change in steam flow from the closure
of a MSIV had an opposite effect on the indicated level readings on Narrow Range versus Wide
Range. Since the question stem did not specify whether the level indication referred to was
Narrow Range or Wide Range level indication, the applicant could assume either; therefore,
both answers A and D were correct.
SRO QUESTION # 80
Comment: The licensee requested that the answer key be changed to reflect A as the correct
answer (instead of C). The licensee contended that the original answer key (C) was
incorrect because the correct answer for second part of the question, based on EOP procedure
routing with Subcooling less than 50 degrees, was A.
NRC Resolution: Recommendation accepted. The second part of the question included the
following fill-in-the-blank statement:
If below the required RCS Subcooling for 4-EOP-E-3, then transition to _____.
The fill-in-the-blank statement tested the applicants ability to determine whether to transfer to 4-
EOP-ECA-3.1 versus EOP-ECA-3.3, when RCS subcooling was less than 50 degrees. The
step in 4-EOP-E-3 which directed transferring to EOP-ECA-3.1 was the Response Not
Obtained (RNO) column of step 21. Step 21 was listed before the step 23 RNO column, which
contained the (incorrect) guidance to transfer to EOP-ECA-3.3. The original answer key
incorrectly listed the correct answer as C (EOP-ECA-3.3). Choice A was the only correct
answer based on the precise wording of the fill-in-the-blank statement.
SIMULATOR FIDELITY REPORT
Facility Licensee: Turkey Point Nuclear Power Plant
Facility Docket No.: 50-250 and 50-251
Operating Test Administered: December 6 - 8, 2011
No simulator fidelity or configuration issues were identified.