IR 05000352/2024302

Revised Initial Operator Licensing Examination Report 05000352/2024302 and 05000353/2024302

ML24141A087
Person / Time
Site:	Limerick
Issue date:	05/20/2024
From:	Diane Jackson NRC/RGN-I/DORS/OB
To:	Rhoades D Constellation Energy Generation, Constellation Nuclear
References
IR 2024302
Download: ML24141A087 (1)

Text

May 20, 2024

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2 - REVISED INITIAL OPERATOR LICENSING EXAMINATION REPORT 05000352/2024302 AND 05000353/2024302

Dear David Rhoades:

On December 8, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an examination at Limerick Generating Station, Units 1 and 2. The results of that examination were published in NRC examination report 05000352(3)/2024301, dated February 2, 2024. The examination report can be found in the NRCs Agencywide Documents Access and Management System (ADAMS), Accession number ML24033A072. ADAMS can be accessed at the NRCs website at http://www.nrc.gov.

The report documented that nine of the 10 applicants passed all parts of the examination and were issued the appropriate licenses. One applicant for an instant senior reactor operator license failed the written examination and was issued a preliminary denial letter. Since the publishing of that examination report, the applicant who failed the written examination filed a request for an Administrative Review and successfully appealed the results of the written examination. As a result, the applicant was issued a senior reactor operator license on April 17, 2024. This report is being issued to document the change in results for the examination. The enclosed examination report documents the revised examination results, which were discussed on May 9, 2024, with Kostas Dovas, Fleet Vice President of Training, and other members of your staff.

During the Administrative Review, Region I identified that the written exam administered by Constellation to all candidates included changes to three questions that were not approved by the NRC. Specifically, questions 46 and 88 included formatting differences, and question 85 included changes to the stem which removed detail about plant conditions pertinent to the question that helped clarify the stem. Region I contacted Constellation regarding the discrepancies found by Region I in these three questions. Constellation performed a review and determined that the as-administered version of the exam differed from the Region I approved version in the same three questions, and concurred with the Region I assessment that the questions had been changed after the exam was approved. Constellation performed an investigation and determined that the changes were made by an exam writer who was on the exam security agreement. The issue has been entered into Constellations corrective action program for follow-up.

The NRC has completed its review of this exam security issue. One Severity Level IV violation without an associated Reactor Oversight Process (ROP) finding is identified in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. The details of the NCV are in the enclosure of this report. We have determined that additional follow-up inspection for this NCV is not warranted because the cause of the NCV is clearly understood by Constellation, and corrective actions have been taken to address the cause.

If you contest the violation or the severity of the violation documented in this examination report, you should provide a response within 30 days of the date of this examination 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 I; the Director, Office of Enforcement; and the NRC Senior Resident Inspector at Limerick Generating Station, Units 1 and 2.

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 (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Donald E. Jackson, Chief Operations Branch Division of Operating Reactor Safety

Docket Nos. 05000352 and 05000353 License Nos. NPF-39 and NPF-85

Enclosure:

As stated

REGION I==

Docket Numbers:

05000352 and 05000353

License Numbers:

NPF-39 and NPF-85 Report Numbers:

05000352/2024302 and 05000353/2024302

Licensee:

Constellation Energy Generation, LLC

Enterprise Identifier:

L-2024-OLL-0054 Facility:

Limerick Generating Station, Units 1 and 2

Location:

Pottstown, PA Dates:

December 4-8, 2023 (Operating Test Administration)

December 14, 2023 (Written Examination Administration)

December 21, 2023 (Licensee Submitted Post Exam Package)

January 3-19, 2024 (NRC Examination Grading)

January 25, 2024 (Nine Licenses Issued)

January 26, 2024 (Request for Administrative Review)

April 12, 2024 (Administrative Review Results Issued)

April 17, 2024 (License Issued to Appellant)

Examiners:

T. Setzer, Chief Examiner, Operations Branch C. Crisden, Operations Engineer T. Fish, Sr. Operations Engineer J. Kepley, Operations Engineer C. Lally, Sr. Operations Engineer L. Sinclair, Operations Engineer (in training)

Approved By:

Donald E. Jackson, Chief Operations Branch Division of Operating Reactor Safety

SUMMARY

ER 05000352/2024302 and 05000353/2024302; 12/04/2023 - 12/8/2023; Limerick Generating

Station, Units 1 and 2; Revised Initial Operator Licensing Examination Report.

Five NRC examiners evaluated the competency of two applicants for reactor operator licenses, seven applicants for instant senior reactor operator licenses, and one applicant for an upgrade senior reactor operator license. The NRC developed the examinations using NUREG-1021,

Operator Licensing Examination Standards for Power Reactors, Revision 12.

The written examination was administered by the facility on December 14, 2023. NRC examiners administered the operating tests on December 4 through 8, 2023. The license examiners determined that nine of the 10 applicants satisfied the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 55, and the appropriate licenses were issued on January 25, 2024. One applicant for an instant senior reactor operator license failed the written examination. The applicant later filed a request for an Administrative Review and successfully appealed the results of the written examination. The applicants license was issued on April 17, 202

List of Findings and Violations

Failure to Ensure Integrity of Limerick 2023 Written Examination Cornerstone Severity Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000352(3)/2024302-01 Open/Closed Not Applicable 4OA5.5 Other Activities Initial Operator License Examination / Examination Security The examiners identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR 55.49,

Integrity of Examinations and Tests, when Constellation failed to ensure the equitable and consistent administration of the 2023 initial licensed operator written examination. Specifically,

Constellation failed to administer an NRC approved version of the 2023 initial license operator written examination to the 2023 initial licensed operator class on December 14, 2023.

REPORT DETAILS

4OA5 Other Activities Initial Operator License Examination

.1 License Applications

a. Scope

The examiners reviewed all license applications submitted by the licensee to ensure the applications reflected that each applicant satisfied relevant license eligibility requirements. The applications were submitted on NRC Form 398, Personal Qualification Statement, and NRC Form 396, Certification of Medical Examination by Facility Licensee. The examiners also audited 10 percent 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 Operator Knowledge and Performance

a. Examination Scope

On December 14, 2023, 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 to the NRC on December 21, 2023.

The NRC examination team administered the various portions of the operating examination to all applicants on December 4 through 8, 2023. The applicants for reactor operator licenses participated in three dynamic simulator scenarios, a control room and facilities walkthrough test consisting of 11 system tasks, and an administrative test consisting of four administrative tasks. The applicants seeking an instant senior reactor operator license participated in at least two dynamic simulator scenarios, a control room and facilities walkthrough test consisting of 10 system tasks, and an administrative test consisting of five administrative tasks. The applicant seeking an upgrade senior reactor license participated in one dynamic simulator scenario, a control room and facilities walkthrough test consisting of five system tasks, and an administrative test consisting of five administrative tasks.

b. Findings

Nine applicants passed all parts of the operating test and the written examination, and the appropriate licenses were issued on January 25, 2024. One applicant for an instant senior reactor operator license failed the written examination and was issued a preliminary denial letter. The applicant later filed a request for an Administrative Review and successfully appealed the results of the written examination. The applicants license was issued on April 17, 2024.

For the written examinations, the reactor operator applicants average score was 87.8 percent and the senior reactor operator applicants average score was 86.2 percent.

The text of the examination questions may be accessed in the ADAMS system under the accession numbers noted in the Attachment. In accordance with current NRC policy, the release of this written examination in ADAMS to the public will be delayed for two years.

Chapter ES-4.4 of NUREG 1021 requires the licensee to analyze the validity of any written examination questions that were missed by half or more of the applicants.

Licensee training staff performed this analysis and forwarded it to the Chief Examiner.

The licensee submitted post-examination comments on December 21, 2023. The licensee requested the NRC accept more than one correct answer on questions 17, 46, and 92. The licensee provided a formal written analysis with references for each of the three questions. There were no post-examination comments provided on the operating test portion of the examination.

The NRC reviewed the post-examination comments and made changes to the exam key for all three written exam questions. Specifically, the NRC deleted question 17 and accepted two correct answers for both questions 46 and 92. Due to one question being deleted, all reactor operator and senior reactor operator applicants were regraded based on a total of 74 and 99 questions, respectively. Credit was given to applicants who answered one of the two acceptable answers on questions 46 and 92. The licensees post-examination comments and the NRCs resolution to those comments may be accessed in the ADAMS system under the accession numbers noted in the Attachment.

In accordance with current NRC policy, the post-examination comments and the NRCs resolution to those comments will be available immediately.

The applicant who initially failed filed a request for an Administrative Review (informal review) on January 26, 2024. The Administrative Review concluded that question 85 required deletion. The applicant was regraded based on a basis of 98 questions. The results of the Administrative Review were issued on April 12, 2024. The applicants license was issued on April 17, 2024. The documents associated with the Administrative Review are withheld from public disclosure in accordance with the NRCs Privacy Act on personally identifiable records.

.3 Initial Licensing Examination Development

a. Examination Scope

The licensee developed the examinations in accordance with NUREG-1021, Revision 12. All licensee facility training and operations staff involved in examination preparation and validation were listed on a security agreement. The licensee submitted the operating examination outline on July 7, 2023. The Chief Examiner reviewed the outlines against the requirements of NUREG-1021 and provided comments to the licensee. The licensee submitted the draft examination package on October 3, 2023.

The Chief Examiner reviewed the draft examination package against the requirements of NUREG-1021 and provided comments to the licensee on the examination on October 21, 2023. Additional draft submittals were provided by the licensee on November 10, 2023, and November 14, 2024. The NRC conducted an onsite validation of the operating examinations and provided further comments during the week of October 9, 2023. The licensee satisfactorily completed comment resolution on November 28, 2023.

b. Findings

NRC examination report 05000352(3)/2024301, dated February 2, 2024, documented that the overall written exam submittal was outside the acceptable quality range expected by the NRC. Specifically, the report documented that the licensees draft written exam submittal included 18 reactor operator license level questions and 10 senior reactor level license questions that required replacement or significant modification (24 percent and 40 percent unsatisfactory, respectively). Since the publishing of that examination report, the applicant who failed the written examination successfully appealed question 85 (deleted). This question is therefore included in the total number of unsatisfactory questions. As a result, the draft written exam submittal included 18 reactor operator license level questions and 11 senior reactor level license questions (24 percent and 44 percent, respectively) that were considered unsatisfactory.

.4 Simulation Facility Performance

a. Examination Scope

The examiners observed simulator performance with regard to plant fidelity during the examination validation and administration.

b. Findings

No findings were identified.

.5 Examination Security

a. Examination Scope

The examiners reviewed examination security for examination development and during both the onsite preparation week and examination administration week for compliance with NUREG-1021, Revision 12 requirements. Plans for simulator security and applicant control were reviewed and discussed with licensee personnel.

b. Findings

One Severity Level IV NCV was identified by the examiners.

Failure to Ensure Integrity of Limerick 2023 Written Examination Cornerstone Severity Cross-cutting Aspect Report Section Not Applicable Severity Level IV NCV 05000352(3)/2024302-01 Open/Closed Not Applicable 4OA5.5 Other Activities Initial Operator License Examination /

Examination Security The examiners identified a Severity Level IV Non-Cited Violation (NCV) of 10 CFR 55.49, Integrity of Examinations and Tests, when Constellation failed to ensure the equitable and consistent administration of the 2023 initial licensed operator written examination. Specifically, Constellation failed to administer an NRC approved version of the 2023 initial license operator written examination to the 2023 initial licensed operator class on December 14, 2023.

Description:

On January 26, 2024, the NRC was contacted by a senior reactor operator license applicant who requested an Administrative Review (informal staff review) of their written examination results. Specifically, the applicant had failed the initial licensed operator written examination administered on December 14, 2023, and requested the NRC accept two correct answer choices for questions 57, 77, 84, and 85. During the review of the applicants submittal, the Chief Examiner identified that the written exam administered by Constellation to all applicants included changes to three questions that were not approved by the Chief Examiner. Specifically, questions 46 and 88 included formatting differences, and question 85 included changes to the stem which removed detail about plant conditions.

The Chief Examiner contacted Constellation regarding the discrepancies in these three questions. Constellation performed a review and determined that the as-administered version of the exam differed from the NRC Region I approved version in the same three questions, and concurred with the Region I assessment that the questions had been changed after the exam was approved.

Corrective Actions: Constellation performed an investigation and determined that the changes were made by an exam writer who was on the exam security agreement.

The issue has been entered into Constellations corrective action program for follow-up.

Corrective Action References: AR 4750850

Performance Assessment:

The examiners determined that Constellations failure to ensure the equitable and consistent administration of the 2023 initial licensed operator written examination was a performance deficiency that was reasonably within Constellations ability to foresee and correct and should have been prevented. The examiners determined that this issue impacted the regulatory process; therefore, Traditional Enforcement applies.

Specifically, Constellation administered an unapproved version of the written examination whose results were material to NRC operator licensing decision making.

Because the underlying performance deficiency was minor, no associated ROP finding was identified.

Enforcement:

The ROPs significance determination process does not specifically consider regulatory process impact in its assessment of licensee performance. Therefore, it is necessary to address this violation which impedes the NRCs ability to regulate using Traditional Enforcement to adequately deter non-compliance.

Severity: The examiners reviewed the NRC Enforcement Policy Section 6.0, Violation Examples, to determine the Severity Level. The examiners determined that Section 6.4, Licensed Reactor Operators, Example d.1 applied. Specifically, this was determined to be a non-willful compromise of an examination required by 10 CFR Part 55.

Violation: 10 CFR 55.49, Integrity of Examinations and Tests, requires, in part, that licensees shall not engage in any activity that compromises the integrity of any application, test, or examination. This includes all activities related to the preparation, administration, and grading of the tests and examinations required by this part.

Contrary to the above, on December 14, 2023, Constellation failed to ensure the integrity of the 2023 initial licensed operator written examination when they administered a version of the exam which was not NRC approved.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

4OA6 Meetings, Including Exit

The Chief Examiner presented the examination results to Kostas Dovas, Fleet Vice President of Training, and other members of the licensee's staff on May 9, 2024. The licensee acknowledged the violation presented.

The licensee did not identify any information or materials used during the examination as proprietary.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

Kostas Dovas - Fleet Vice President of Training

Matt Bonanno - Limerick Plant Manager

Tom Dean - Fleet Director of Training Oversight

Chris Giambrone - Limerick Senior Manager of Site Training

Nick Favorito - Limerick Director of Organization, Performance, and Regulatory

Laura Lynch - Limerick Senior Manager of Operations Support and Services

Dan Semeter - Limerick Manager of Operations Training

Jordan Rajan - Limerick Site Regulatory Assurance Manager

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

05000352(3)/2024302-01 NCV Failure to Ensure Integrity of Limerick 2023 Written Examination (Section 4OA5.5)