IR 05000341/2024301

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NRC Initial License Examination Report 05000341/2024301
ML24089A143
Person / Time
Site: Fermi 
Issue date: 04/01/2024
From: Paul Zurawski
NRC/RGN-III/DORS/OB
To: Peter Dietrich
DTE Electric Company
Iskierka-Boggs T
Shared Package
ML22251A164 List:
References
IR 2024301
Download: ML24089A143 (1)


Text

SUBJECT:

FERMI POWER PLANT, UNIT 2 - NRC INITIAL LICENSE EXAMINATION REPORT 05000341/2024301

Dear Peter Dietrich:

On March 11, 2024, 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 documents the results of those examinations. Preliminary observations noted during the examination process were discussed on March 5, 2024, with Mike Ciko, Operations Director, and other members of your staff. An exit meeting was conducted by Microsoft Teams meeting on March 13, 2024, between Stephanie Banker, Vice President, Engineering and Technical Support, and other members of your staff and Travis Iskierka-Boggs, Senior Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants.

The NRC examiners administered an initial license examination operating test during the week of February 26, 2024. The written examination was administered by Fermi Power Plant training department personnel on March 6, 2024. Nine Senior Reactor Operator and four Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on March 21, 2024. Twelve applicants passed all sections of their respective examinations. One applicant was issued a Preliminary Results letter. Eight were issued senior operator licenses and four were issued operator licenses.

The as-administered written examination and operating test, as well as documents related to the development and review (outlines, review comments and resolution, etc.) of the examination will be withheld from public disclosure until March 11, 2026. The enclosure contains details of this report.

However, since one applicant received a Preliminary Results letter because of receiving a less than passing grade on one portion of the operating test, the applicant was provided a copy of those portions of the operating test affected. For examination security purposes, your staff should consider those portions of the operating test uncontrolled and exposed to the public.

April 1, 2024 This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations, Part 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Paul J. Zurawski, Chief Operations Branch Division of Operating Reactor Safety Docket No. 50-341 License No. NPF-43 Enclosure:

1. Examination Report 05000341/2024301 2. Simulator Fidelity Report cc: Distribution via LISTSERV Justin Angel, Director - Nuclear Training, Fermi Power Plant Signed by Zurawski, Paul on 04/01/24

SUMMARY OF FINDINGS

ER 05000341/2024301; 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 12.

Examination Summary:

Twelve of thirteen applicants passed all sections of their respective examinations. Eight applicants were issued senior operator licenses, and four applicants were issued operator licenses. One applicant was issued a Preliminary Results letter for failure of one section of the administered examination. (Section 4OA5.1).

REPORT DETAILS

4OA5 Other Activities

.1 Initial Licensing Examinations

a. Examination Scope

The NRC examiners and members of the facility licensees staff used the guidance prescribed in NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 12, to develop, validate, administer, and grade the written examination and operating test. The written examination outlines were prepared by the NRC staff and were transmitted to the facility licensees staff. Members of the facility licensees staff developed the operating test outlines and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of January 29, 2024, with the assistance of members of the facility licensees staff. During the on-site validation week, the examiners audited all license applications 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 February 26, 2024, through March 1, 2024. The facility licensee administered the written examination on March 6, 2024.

b. Findings

None.

(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.

During validation of the written examination, several questions were modified or replaced. 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 2.3-5, Written Examination Review Worksheet.

The Form 2.3-5, the written examination outlines, and both the proposed and final written examinations, will be available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRCs Agencywide Documents Access and Management System (ADAMS) on March 11, 2026 (ADAMS Accession Numbers ML22251A169, ML22251A161, ML22251A160, ML22251A163 respectively).

The NRC examiners graded the written examination on March 21, 2024, and conducted a review of each missed question to determine the accuracy and validity of the examination questions. Post-examination analysis revealed generic weaknesses in applicant performance with one Emergency and Abnormal Plant Evolutions question with more than 50 percent of applicants answering incorrectly.

(2) Operating Test The NRC examiners determined that the operating test, as originally proposed by the licensee, was within the range of acceptability expected for a proposed examination.

Less than 20 percent of the proposed operating test portion of the examination was determined to be unsatisfactory and required modification or replacement.

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. Changes made to the operating test portion of the examination, were made in accordance with NUREG-1021, "Operator Licensing Examination Standards for Power Reactors, and documented on Form 2.3-3, Operating Test Review Worksheet. The Form 2.3-3, the operating test outlines, and both the proposed and final as administered dynamic simulator scenarios and JPMs, will be available electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's ADAMS on March 11, 2026 (ADAMS Accession Numbers ML22251A169, ML22251A161, ML22251A160, ML22251A163 respectively).

The NRC examiners completed operating test grading on March 21, 2024.

Post-examination analysis revealed generic weaknesses in applicant performance in the areas of Technical Specification recognition and application for inoperable equipment; inconsistent use of verify while implementing procedures; determining conditions met for a difficult to move rod and which procedure to implement in that condition; difficulty determining the guidance available to use to insert a half SCRAM upon failure of a half SCRAM to auto initiate; and procedure use and adherence issues while responding to normal and off-normal situations.

(3) Examination Results Nine applicants at the Senior Reactor Operator (SRO) level and four applicants at the Reactor Operator (RO) level were administered written examinations and operating tests. Twelve applicants passed all portions of their examinations and were issued their respective operating licenses on March 21, 2024. One applicant was issued a Preliminary Results letter for failure of the walkthrough (Systems and Administrative JPMs) section of the administered examination.

.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 Title10 of the Code of Federal Regulations (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

Multiple instances were identified during the administration of the Scenario portion of the operating test in which the facility failed to ensure that all procedures were properly free of all markings prior to the next crew coming in to be examined. The facility had informed the NRC chief examiner during onsite validation that all procedures would be printed, and clean copies would be inserted prior to the start of the next scenario. However, the facility only identified expected procedures that the applicants were to be using and printed those procedures for replacement only. Due to applicants performing actions in procedures that the training staff had not predicted, multiple procedures were identified by the applicants during the administration of the exam as having previously been marked on.

None of the identified procedures that had markings on them resulted in a violation of 10 CFR 55.49 as they did not affect the integrity of the examination nor compromise the fair and equitable administration of the operating test to the candidates.

One instance was identified during the administration of Scenario 2 to the second crew of applicants on February 27, 2024. During the administration of the scenario, the examination team identified that contrary to the turnover provided to all applicants and contrary to the initial simulator set up for the first crew that day, CTG11-1 had a red tag (RT) placed on the component indicating that the component had been removed from service utilizing the equipment clearance tagging process for maintenance. The turnover provided to all applicants stated, in part, CTG11-1 failed during the last shift. The cause is still being investigated. No further information was provided that would lead to the applicants assuming that CTG11-1 had an RT tag placed on the component through the proper process.

Following the scenario, the training staff was asked to explain why the red RT tag had been placed on CTG11-1 by the chief examiner. The simulator lead explained that the facility representative observing the administration of the scenarios instructed them to place the RT tag on the component due to the difficulties observed by the first crew to properly assess the status of CTG11-1 in a timely manner. Furthermore, the facility representative informed the chief examiner that it should have initially had the red RT tag placed based on the component due to the information in the turnover provided to the applicants. The chief examiner informed the facility representative that the turnover did not indicate this information and the red RT tag was removed for subsequent scenarios administered that day. The chief examiner reinforced that changes made to the simulator set up, methods in exam administration and evaluation must be the same for all applicants. Any changes that are required to be made should be brought to the attention of the chief examiner and only changed after the chief examiner has reviewed and agreed upon the changes.

The instance of placing the red RT tag did not result in a violation of 10 CFR 55.49 as it did not affect the overall integrity of the examination nor compromise the fair and equitable administration of the operating test to the candidates. The placement of the red RT tag provided incorrect misinformation that further solidified to the applicants that the CTG11-1 was not available to the crew as a means to restore power.

4OA6 Meetings

.1 Debrief

The chief examiner presented the examination team's preliminary observations and findings on March 5, 2024, to Mike Ciko, Operations Director, and other members of the Fermi Power Plant Operations and Training Department staff.

.2 Exit Meeting

The chief examiner conducted an exit meeting on March 13, 2024, with Stephanie Banker, Vice President, Engineering and Technical Support, by Microsoft Teams. The NRCs final disposition of the stations grading of the written examination and post-examination comments were disclosed and discussed during the meeting. The chief examiner asked the licensee whether any of the retained submitted 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

E. Olson, Site Vice President
J. Angel, Training Director
M. Donigian, Training Supervisor
S. Schmus, Exam Author
B. Skandalaris, Exam Author

U.S. Nuclear Regulatory Commission

T. Taylor, Senior Resident Inspector
J. Gerwargis, Resident Inspector
P. Zurawski, Branch Chief
T. Iskierka-Boggs, Chief Examiner
G. Roach, Senior Operations Engineer
J. Nance, Operations Engineer
R. Williams, Operations Engineer, Region IV

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF ACRONYMS USED

ADAMS

Agencywide Document Access and Management System

NRC

U.S. Nuclear Regulatory Commission

RO

Reactor Operator

SRO

Senior Reactor Operator

SIMULATION FACILITY FIDELITY REPORT

Facility Licensee:

Fermi Power Plant, Unit 2

Facility Docket No:

50-341

Operating Tests Administered:

February 26, 2024 through March 1, 2024

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

CR6839

Condition Report generated for flow indication provided on

T46-R800B, Div 2 Standby Gas Treatment System Exhaust Flow

Recorder, which should have not had any indications on the recorder

at all given the current plant conditions present in the JPM being

administered.