IR 05000341/2015301
| ML15281A407 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 10/07/2015 |
| From: | Hironori Peterson Operations Branch III |
| To: | Fessler P DTE Energy |
| References | |
| 50-341/15-301 | |
| Download: ML15281A407 (10) | |
Text
UNITED STATES ber 7, 2015
SUBJECT:
FERMI POWER PLANT, UNIT 2 NRC INITIAL LICENSE EXAMINATION REPORT 05000341/2015301
Dear Mr. Fessler:
On September 3, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed the initial operator licensing examination process for license applicants employed at your Fermi Power Plant, Unit 2. The enclosed report documets the results of those examinations.
Preliminary observations and findings noted during the examination process were discussed on August 28, 2015, with you and other members of your staff. An exit meeting was conducted by telephone on September 8, 2015, between Mr. T. Holmberg, Assistant Manager-Nuclear Training, other members of your staff and Mr. M. Bielby, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. There were no post examination comments provided by the training department on the operating test and the written examination, received by the NRC on September 3, 2015.
The NRC examiners administered an initial license examination operating test during the week of August 24, 2015. The written examination was administered by training department personnel on August 28, 2015. Two Senior Reactor Operator (SRO) and two Reactor Operator (RO) applicants were administered license examinations. The results of the examinations were finalized on September 11, 2015. All four applicants passed all sections of their respective examinations, and two SROs were issued senior operator licenses and two ROs were issued operator licenses. The written examination and other related written examination documentation will be withheld from public disclosure for 24 months per your request.
Additionally, the NRC identified one finding involving examination security. The finding was evaluated under traditional enforcement and determined to be Severity Level IV. Because of the very low safety significance and because it was entered into your Corrective Action Program, the NRC is treating this finding as a Non-Cited Violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the subject or severity of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, Region III; the Director, Office of Enforcement, U.S.
Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Fermi Power Plant. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's 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/
Hironori Peterson, Chief Operations Branch Division of Reactor Safety Docket No. 50-341 License No. NPF-43
Enclosures:
1. Operator Licensing ER 05000341/2015301 w/Attachment: Supplemental Information 2. Simulator Fidelity Report
REGION III==
Docket No: 50-341 License No: NPF-43 Report No: 05000341/2015301 Licensee: DTE Energy Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: August 24 through September 3, 2015 Inspectors: M. Bielby, Senior Operations Engineer C. Zoia, Operations Engineer J. Seymour, Operations Engineer Approved by: H. Peterson, Chief Operations Branch Division of Reactor Safety Enclosure 1
SUMMARY
Examination Report 05000341/2015301; 08/24/2015 - 09/03/2015; DTE Energy Company,
Fermi Power Plant, Unit 2. Initial License Examination Report.
The announced initial operator licensing examination was conducted by regional Nuclear Regulatory Commission (NRC) examiners in accordance with the guidance of NUREG-1021,
Operator Licensing Examination Standards for Power Reactors, Revision 10.
Examination Summary:
Four of four applicants passed all sections of their respective examinations. Two applicants were issued Senior Operator Licenses, and two applicants were issued Operator Licenses.
(Section 4OA5.1).
NRC-Identified
Finding
Cornerstone: Mitigating Systems
- SL-IV. Title 10, Code of Federal Regulations (CFR), Part 55.49, Integrity of examinations and tests, states, in part, that a licensee shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Contrary to this, the licensee failed to clean a marked-up hard card prior to a job performance measure (JPM) during administration of the operating tests. To correct this issue, the licensee initiated corrective action CARD number 15-26003. Additionally, a replacement JPM was administered to the applicant affected by the compromised JPM.
The failure of the licensees staff to ensure that previously used examination materials were not available for an applicant during the initial examination administration was a performance deficiency. The performance deficiency was evaluated through the traditional enforcement process because it impacted the ability of the NRC to perform its regulatory oversight function. This resulted in assignment of a Severity Level IV non-cited violation because it involved a non-willful compromise of examination integrity and is consistent with Section 6.4.d of the NRC Enforcement Policy. (Section 4OA5.2)
REPORT DETAILS
4OA5 Other
.1 Initial Licensing Examinations
a. Examination Scope
The U.S. Nuclear Regulatory Commission (NRC) examiners and members of the facility licensees staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 10, to develop, validate, administer, and grade the written examination and operating test. Members of the facility licensees staff prepared the outline and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of August 3, 2015, with the assistance of members of the facility licensees staff.
During the onsite validation week, the examiners audited one license application for accuracy. The NRC examiners, with the assistance of members of the facility licensees staff, administered the operating test, consisting of job performance measures and dynamic simulator scenarios, during the period of August 24 - 27, 2015. The facility licensee administered the written examination on August 28, 2015.
b. Findings
- (1) Written Examination The NRC examiners determined that the written examination, as proposed by the licensee, was within the range of acceptability expected for a proposed examination.
Less than 20 percent of the proposed examination questions were determined to be unsatisfactory and required modification or replacement.
All changes made to the proposed written examination, were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, and documented on Form ES-401-9, Written Examination Review Worksheet, which will be available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Documents Access and Management System (ADAMS).
On September 3, 2015, the licensee submitted documentation noting that there were no post-examination comments for consideration by the NRC examiners when grading the written examination. The proposed written examination, as well as the final as-administered examination and answer key (ADAMS Accession Number ML15268A038), will be available in 24 months electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS.
The NRC examiners graded the written examination on September 11, 2015, and conducted a review of each missed question to determine the accuracy and validity of the examination questions.
- (2) Operating Test During the validation of the operating test, several Job Performance Measures (JPMs)were modified or replaced, and some modifications were made to the dynamic simulator scenarios. The modifications were cosmetic in nature and added descriptions of actions to be performed by the applicants. Changes made to the operating test, documented in a document titled, Operating Test Comments, as well as the final as administered dynamic simulator scenarios and JPMs, are available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS.
The NRC examiners completed operating test grading on September 11, 2015.
- (3) Examination Results Two applicants at the Senior Reactor Operator level and two applicants at the Reactor Operator level were administered written examinations and operating tests. Four applicants passed all portions of their examinations and were issued their respective operating licenses on September 11, 2015.
.2 Examination Security
a. Scope
The NRC examiners reviewed and observed the licensee's implementation of examination security requirements during the examination validation and administration to assure compliance with 10 CFR Section 55.49, Integrity of Examinations and Tests.
The examiners used the guidelines provided in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, to determine acceptability of the licensees examination security activities.
b. Findings
Introduction:
The examiners identified a Severity Level IV Non-Cited Violation of 10 CFR 55.49, Integrity of examinations and tests, for failure of the licensee to ensure the integrity of the initial examination process. Specifically, during the initial examination administration on August 24 - 27, 2015, the licensee failed on one occasion to erase a marked-up hard card prior to a JPM during administration of the operating test.
Description:
The licensee failed to erase a hard card after prior simulator activities. An applicant and the examiners subsequently found this hard card to be already filled-out during a JPM. This allowed the applicant to see annotations written on the hard card that were relevant to the completion of a critical task of the JPM. Since the applicant potentially gained an advantage from viewing these written annotations, the filled-out hard card had the potential to affect the equitable and consistent administration of the operating test. In response to this, the examiners administered a replacement JPM to the affected applicant and did not include the compromised JPM in making a licensing decision for that applicant. The event is indicative of a process failure of the licensees examination security and simulator reset methodology.
Analysis:
The failure to properly prepare the simulator to ensure exam integrity for JPMs was a performance deficiency. The performance deficiency was evaluated using traditional enforcement and was determined to be Severity Level IV because it fits the SL-IV example of Enforcement Policy Section 6.4.d, Violation Examples: Licensed Reactor Operators. This section states, Severity Level IV violations involve, for example: a non-willful compromise of an application, test, or examination required by 10 CFR Part 55. The performance deficiency could have impacted the regulatory process if licensing decisions were made with applicants being aided by the existence of filled-out hard cards containing information relevant to aspects of their operating test.
However, since the examiners administered a replacement JPM to the affected applicant and did not include the compromised JPM in making a licensing decision for that applicant, it was deemed that there was no actual effect on the equitable and consistent administration of the examination as a result of the compromise. There are no cross-cutting aspects assigned to traditional enforcement violations.
Enforcement:
Title 10 CFR Part 55.49, Integrity of examinations and tests, states, in part, that a licensee shall not engage in any activity that compromises the integrity of any application, test, or examination required by this part. The integrity of a test or examination is considered compromised if any activity, regardless of intent, affected, or, but for detection, would have affected the equitable and consistent administration of the test or examination. Contrary to the above, from August 24 - 27, 2015, the licensee did not follow a consistent process for ensuring the simulator hard cards were free of all markings from previous crews and applicants prior to administering operating test activities on the simulator. To correct this issue, the licensee initiated corrective action CARD number 15-26003. Because the associated violation resulted in no or relatively inappreciable safety consequences (SL-IV), and the issue was entered into the licensees Corrective Action Program as CARD number 15-26003, this violation is being treated as a Non-Cited Violation, consistent with Section 2.3.2.a of the Enforcement Policy (NCV 05000341/2015301-01, Inadequate Examination Security on a Simulator Reset).
4OA6 Management Meetings
.1 Debrief
The chief examiner presented the examination team's preliminary observations and findings on August 28, 2015, to you and other members of your Fermi 2 staff.
.2 Exit Meeting
The chief examiner conducted an exit meeting on September 8, 2015, with T. Holmberg, Assistant Manager, Nuclear Training, by telephone. The NRC confirmed the plant personnel had no post-examination comments during the telephone discussion.
The examiners asked the licensee whether any of the material used to develop or administer the examination should be considered proprietary. No proprietary or sensitive information was identified during the examination or debrief/exit meetings.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
- P. Fessler, Senior Vice President and Chief Nuclear Officer
- V. Kaminskas, Site Vice President
- M. Philippon, Plant Manager
- B. Crone, Operations Training General Supervisor
- J. Davis, Training Manager
- M. Donigian, Operations Training Supervisor
- J. Ford, Director-Organizational Effectiveness
- T. Holmberg, Assistant Manager, Nuclear Training
- E. Kokosky, QA Manager
- J. Simone, NQA/Shift Manager
- G. Strobel, Operations Manager
- S. Ward, Licensing
U. S. Nuclear Regulatory Commission
- T. Briley, Acting Fermi Senior Resident Inspector
- J. Wojewoda, Resident Inspector in Training
- M. Bielby, Chief Examiner
- C. Zoia, Examiner
- J. Seymour, Examiner
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
05000341/2015301-01 NCV Inadequate Examination Security on a Simulator Reset
(Section 4OA5)
LIST OF ACRONYMS USED
ADAMS Agencywide Document Access and Management System
CFR Code of Federal Regulations
NRC U.S. Nuclear Regulatory Commission
RO Reactor Operator
SRO Senior Reactor Operator
SIMULATOR FIDELITY REPORT
Facility Licensee: Fermi Power Plant, Unit 2
Facility Docket No: 50-341
Operating Tests Administered: August 24 - 27, 2015
The following documents observations made by the NRC examination team during the
initial operator license examination. These observations do not constitute audit or inspection
findings and are not, without further verification and review, indicative of non-compliance with
CFR 55.45(b). These observations do not affect NRC certification or approval of the
simulation facility other than to provide information which may be used in future evaluations.
No licensee action is required in response to these observations.
During the conduct of the simulator portion of the operating tests, the following items were
observed:
ITEM DESCRIPTION
None None
P. Fessler -2-
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy
of this letter, its enclosure, and your response (if any) will be available electronically for public
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
component of the NRC's 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/
Hironori Peterson, Chief
Operations Branch
Division of Reactor Safety
Docket No. 50-341
License No. NPF-43
Enclosures:
1. Operator Licensing ER 05000341/2015301
w/Attachment: Supplemental Information
2. Simulator Fidelity Report
cc w/encl: Distribution via LISTSERV
- J. Davis, Training Manager, Fermi 2