IR 05000498/2024301
| ML24276A201 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/07/2024 |
| From: | Heather Gepford NRC/RGN-IV/DORS/OB |
| To: | Harshaw K South Texas |
| References | |
| IR 2024301 | |
| Download: ML24276A201 (1) | |
Text
October 07, 2024
SUBJECT:
SOUTH TEXAS PROJECT, UNITS 1 AND 2 - NRC EXAMINATION REPORT 05000498/2024301; 05000499/2024301
Dear Ms. Harshaw:
On September 23, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an initial operator license examination at South Texas Project Units 1 and 2. The enclosed report documents the examination results and licensing decisions. The preliminary examination results were discussed on September 5, 2024, with Mr. John Hoffman, Training Director, and other members of your staff. A telephonic exit meeting was conducted on September 23, 2024, with Mr. Carl Moore, Operations Training Supervisor, who was provided the NRC licensing decisions.
The examination included the evaluation of four applicants for reactor operator licenses and one applicant for an instant senior reactor operator license. The license examiners determined that all of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued. There were no post-examination comments submitted by your staff. The enclosure contains details of this report.
One Severity Level IV violation was identified during this examination. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety Docket Nos. 50-498; 50-499 License Nos. NPF-76; NPF-80 Enclosure:
Examination Report 05000498/2024301 and 05000499/2024301 Electronic distribution via LISTSERV Signed by Gepford, Heather J.
on 10/07/24
ML24276A201 SUNSI Review:
ADAMS:
Non-Publicly Available Non-Sensitive Keyword:
By: tjf Yes No Publicly Available Sensitive NRR-079 OFFICE SOE:DORS/OB OE:DORS/OB OE:DORS/OB C:DORS/OB NAME TFarina DYou CHarrington HGepford SIGNATURE
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DATE 10/02/24 10/03/24 10/02/24 10/07/24
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Examination Report Docket Numbers:
05000498, 05000499 License Numbers:
NPF-76, NPF-80 Report Numbers:
05000498/2024301; 05000499/2024301 Enterprise Identifier:
L-2024-OLL-0036 Licensee:
STP Nuclear Operating Company Facility:
South Texas Project Electric Generating Station, Units 1 and 2 Location:
Wadsworth, Texas Inspection Dates:
September 3, 2024, to September 23, 2024 Inspectors:
T. Farina, Senior Operations Engineer (Chief Examiner)
D. You, Operations Engineer C. Harrington, Operations Engineer Approved By:
Heather J. Gepford, Ph.D., Chief Operations Branch Division of Operating Reactor Safety
SUMMARY Examination Report 05000498/2024301 and 05000499/2024301; September 3-23, 2024; South Texas Project, Units 1 and 2; Initial Operator Licensing Examination Report The NRC examiners evaluated the competency of four applicants for reactor operator licenses and one applicant for an instant senior reactor operator license at South Texas Project, Units 1 and 2.
The licensee developed the examinations using NUREG-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 12. The written examination was administered by the licensee on September 11, 2024. The NRC examiners administered the operating tests on September 3-6, 2024.
The NRC examiners determined that all of the applicants satisfied the requirements of 10 CFR Part 55, and the appropriate licenses have been issued.
A.
NRC-Identified and Self-Revealing Findings Failure to Implement Exam Security Standards Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 5000498,05000499/2024301-01 Open/Closed Not Applicable NUREG-1021 The inspectors reviewed a Severity Level IV non-cited violation (NCV) of 10 CFR Part 55.49, Integrity of Examinations and Tests, in which the licensee failed to adhere to examination security measures in the submittal of draft operating test materials for the 2024 initial licensing exam. Specifically, on June 17, 2024, the licensee emailed the draft exam submittal cover letter to a public distribution list and included as an attachment NRC Form 2.3-2, Operating Test Quality Checklist, among other forms. This checklist included quantitative scenario attributes which should not have been shared with individuals not signed on to the exam security agreement.
B.
Licensee-Identified Violations None.
REPORT DETAILS OTHER ACTIVITIES - INITIAL LICENSE EXAMINATION
.1 License Applications a.
Scope The NRC examiners reviewed all license applications submitted to ensure each applicant satisfied relevant license eligibility requirements. The NRC examiners also audited two 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 examiners reviewed integrated examination outlines and draft examinations submitted by the licensee against the requirements of NUREG-1021. The NRC examiners conducted an onsite validation of the operating tests.
b.
Findings The NRC examiners provided outline, draft examination and post-validation comments to the licensee. The licensee satisfactorily completed comment resolution prior to examination administration.
The NRC examiners determined the written examinations and operating tests initially submitted by the licensee were within the range of acceptability expected for a proposed examination.
.3 Operator Knowledge and Performance a.
Scope On September 11, 2024, the licensee proctored the administration of the written examinations to all five applicants. The licensee staff graded the written examinations, analyzed the results, and presented their analysis to the NRC on September 18. 2024.
The NRC examination team administered the various portions of the operating tests to all applicants on September 3-6, 2024.
b.
Findings No findings were identified.
All applicants passed the written examination and all parts of the operating tests. The final written examinations and post-examination analysis may be accessed in the ADAMS system under the accession numbers noted in the attachment. There were no post-examination comments as indicated in the licensee submittal.
The examination team noted no generic weaknesses associated with applicant performance on the operating tests. Post-examination analysis revealed one generic weakness associated with applicant performance on the written examination.
Specifically, question 66 had a miss rate greater than 50 percent. This deficiency was captured in the licensees corrective action program as Condition Report 24-9209.
Copies of all individual examination reports were sent to the facility training manager for evaluation and determination of appropriate remedial training.
.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.
.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 examination security and applicant control were reviewed and discussed with licensee personnel.
b.
Findings Failure to Implement Exam Security Standards Cornerstone Severity Cross-Cutting Aspect Report Section Not Applicable Severity Level IV NCV 5000498,05000499/2024301-01 Open/Closed Not Applicable NUREG-1021 The inspectors reviewed a Severity Level IV non-cited violation (NCV) of 10 CFR Part 55.49, Integrity of Examinations and Tests, in which the licensee failed to adhere to examination security measures in the submittal of draft operating test materials for the 2024 initial licensing exam. Specifically, on June 17, 2024, the licensee emailed the draft exam submittal cover letter to a public distribution list and included as an attachment NRC Form 2.3-2, Operating Test Quality Checklist, among other forms. This checklist included quantitative scenario attributes which should not have been shared with individuals not signed on to the exam security agreement.
Description: On June 17, 2024, the licensee sent to the NRC its draft exam submittal. The submittal in its entirety was transmitted to the NRC securely via the Box file transfer
portal. The licensee additionally transmitted a copy of the submittal cover letter via email to a licensing distribution list of 33 people, which included individuals who were not signed on to the exam security agreement. The email submittal redacted most exam materials, but included as attachments three exam quality forms: NRC Form 2.3-1, Examination Outline Quality Checklist, NRC Form 2.3-2, Operating Test Quality Checklist, and NRC Form 2.3-4, Written Examination Quality Checklist. Although none of the materials contained detailed exam content, the operating test quality checklist contains a section documenting quantitative attributes of each scenario, including the number of malfunctions after EOP entry, abnormal events, major transients, EOPs entered, EOP contingency procedures entered, and preidentified critical tasks.
NUREG 1021, Operator Licensing Examination Standards for Power Reactors, Rev 12, Section 1.3, Examination Security, Section C.3, Instruction and Restrictions for Facility Licensee Personnel, states, facility licensee personnel must not disclose specific attributes of the examinations content (e.g., how many JPMs or scenarios come directly from the bank, how many alternate path JPMs are on the examination, how many technical specification calls are in the scenarios). This guidance establishes a clear restriction on the pre-exam disclosure of quantitative examination data, regardless of specificity. Facility procedure 0PNT01-ZT-0203, NRC License and Final Audit Exams: Overview and Generic Exam Activities, Section 6.0, NRC Submittals/Correspondence, states, Copies of company correspondence are required to be distributed to individuals not on the exam security agreement, however, NO ATTACHMENTS THAT CONTAIN SPECIFIC EXAM INFORMATION ARE TO BE INCLUDED. SPECIFIC EXAM INFORMATION IS TO ONLY BE SENT TO THE INTENDED RECIPIENT. This guidance establishes a licensee expectation that the referenced attachments should not have been included with the publicly disseminated cover letter.
Corrective Actions: The chief examiner upon receiving this email contacted the licensees exam lead and discussed that this information should be controlled under exam security requirements. The sender then initiated an email recall attempt. The email was unable to be recalled from all recipients. As a mitigating action, the licensee promptly modified the quantitative attributes of the draft exam submittal; further modifications to the exam content were made as part of the draft exam comment resolution process for both the operating test and written exam. Finally, some numbered scenario designations were swapped, such that the final exam scenario numbering was not the same as the draft exam scenario numbering.
Corrective Action References: Condition Report 24-9022 Performance Assessment: None. There is no associated finding because the violation was not assessable under the ROP.
Enforcement: The ROPs significance determination process does not specifically consider the 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. Specifically, the release of exam-related material to individuals not subject to exam security could have impacted equitable and consistent administration of an initial licensing exam, and thereby licensing decisions, if not detected.
Severity: The failure of the licensee to meet 10 CFR 55.49 requirements was determined to be a Severity Level IV (SL-IV) violation because it is consistent with section 6.4.d, Violation Examples: Licensed Reactor Operators, of the Enforcement Policy. Section 6.4.d states,
Severity Level IV violations involve for example: a non-willful compromiseof an application, test, or examination required by 10 CFR part 55. The violation could have impacted the regulatory process if licensing decisions were made with applicants who had prior knowledge of examination materials.
Violation: Title 10 CFR Part 55.49, Integrity of Examinations and Tests, requires, in part, that applicants, licensees, and facility licensees shall not engage in any activity that compromises the integrity of any application, tests, or examination required by this part. The integrity of any 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, the licensee engaged in an activity that compromised the integrity of an application, test, or examination required by this part. Specifically, the licensee failed to ensure the requirements of 10 CFR Part 55.49 were met in the submittal of the draft examination on June 17, 2024. If not for detection, this could have affected the equitable and consistent administration of the written examination. This is a violation of 10 CFR 55.49, Integrity of Examinations and Tests.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS Exit Meeting Summary The chief examiner presented the preliminary examination results to Mr. John Hoffman, Training Director, and other members of the staff on September 5, 2024. A telephonic exit was conducted September 23, 2024, between Mr. T. Farina, chief examiner, and Mr. C. Moore, Operations Training Supervisor. The licensee did not identify any information or materials used during the examination as proprietary.
ADAMS DOCUMENTS REFERENCED Accession No. ML24271A300 - FINAL WRITTEN EXAMS Accession No. ML24271A301 - FINAL OPERATING TEST Accession No. ML24271A302 - POST-EXAMINATION ANALYSIS