IR 05000440/2024301
| ML25023A013 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 01/23/2025 |
| From: | Paul Zurawski NRC/RGN-III/DORS/OB |
| To: | Penfield R Vistra Operations Company |
| Nance J. | |
| Shared Package | |
| ML23336A063 | List: |
| References | |
| 50-440/24-301 50-440/OL-24 | |
| Download: ML25023A013 (1) | |
Text
SUBJECT:
PERRY NUCLEAR POWER PLANT - NRC INITIAL LICENSE EXAMINATION REPORT 05000440/2024301
Dear Rod Penfield:
On December 19, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed the initial operator licensing examination process for license applicants employed at your Perry Nuclear Power Plant. The enclosed report documents the results of those examinations. Preliminary observations noted during the examination process were discussed on December 17, 2024, with you and other members of your staff. An exit meeting was conducted by teleconference on January 16, 2025, between you and James Nance, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. During the teleconference conversation, the NRC noted that no post-examination comments were submitted by the facility, in its post-examination submittal package received by the NRC on December 19, 2024.
The NRC examiners administered an initial license examination operating test during the week of December 9, 2024. The written examination was administered by training department personnel on December 17, 2024. Nine Senior Reactor Operator and three Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on January 17, 2025. Eleven applicants passed all sections of their respective examinations. Eight were issued senior operator licenses and three 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 December 19, 2026. The enclosure contains details of this report.
However, since one applicant received a Preliminary Results letter because of a written examination score of less than 80.0 percent, the applicant was provided a copy of the written examination. For examination security purposes, your staff should consider that written examination uncontrolled and exposed to the public.
January 23, 2025 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. 50-440 License No. NPF-58 Enclosure:
1. Examination Report 05000440/2024301 2. Simulator Fidelity Report cc: Distribution via LISTSERV Scott Plymale, Director of Nuclear Training Signed by Zurawski, Paul on 01/23/25
SUMMARY OF FINDINGS
ER 05000440/2024301; 12/09/2024-12/19/2024; Vistra Operations Company LLC, Perry
Nuclear Power Plant. 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:
Eleven of twelve applicants passed all sections of their respective examinations. Eight applicants were issued senior operator licenses and three 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. The NRC examiners developed the operating test outlines and developed the written examination and operating test. The NRC examiners validated the proposed examination during the week of November 4, 2024, with the assistance of members of the facility licensees staff.
During the on-site validation week, the examiners audited six 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 December 9, 2024, through December 13, 2024. The facility licensee administered the written examination on December 17, 2024.
On December 19, 2024, the licensee submitted documentation noting that there were no post-examination comments for consideration by the NRC examiners.
b. Findings
- (1) Written Examination 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 December 19, 2026, (ADAMS Accession Numbers ML22336A062, ML22336A061, ML22336A060, and ML22336A065 respectively).
The NRC examiners graded the written examination on January 8, 2025, 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 two Emergency and Abnormal Plant Evolutions, two Plant Systems, and two Fundamentals Knowledge questions with more than 50 percent of applicants answering incorrectly.
- (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. 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 December 19, 2026, (ADAMS Accession Numbers ML22336A062, ML22336A061, ML22336A060, and ML22336A065 respectively).
The NRC examiners completed operating test grading on January 8, 2025.
Post-examination analysis revealed generic weaknesses in applicant performance in the area(s) of procedural compliance, locations of components in the control room and plant, implementation of Technical Specification requirements, the use of critical parameters, and how to implement Emergency Operating Procedure directed actions that are essential to an events overall mitigative strategy. It is expected that significant delta training will be conducted.
- (3) Examination Results Nine applicants at the Senior Reactor Operator (SRO) level and three applicants at the Reactor Operator (RO) level were administered written examinations and operating tests. Eleven applicants passed all portions of their examinations and were issued their respective operating licenses on January 17, 2025. One applicant was issued a Preliminary Results letter for failure of the written examination overall section of the administered examination on January 17, 2025.
.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, 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
- (1) The back door to the Admin JPM exam room was not posted prior to moving exam material into the room. This was discovered by the Chief Examiner prior to any applicants entering the room and did not result in the compromise of any exam material.
Therefore, this issue has been determined to be minor.
- (2) During Scenario #4, a member of Crew #3 discovered a procedure that had been marked up by the previous Crew and had not been cleaned up. The individual who discovered the marked up procedure immediately pointed out the marked up procedure to the Chief Examiner who was immediately in front of him. Because the marked up information did not provide an advantage to the crew member who discovered it the issue was also determined to be minor.
4OA6 Meetings
.1 Debrief
The chief examiner presented the examination team's preliminary observations and findings on December 17, 2024, to Rod Penfield, Site Vice President and other members of the Perry Nuclear Power Plant staff.
.2 Exit Meeting
The Chief Examiner conducted an exit meeting on January 16, 2025, with Rod Penfield, Site Vice President, by teleconference. The NRCs final disposition of the licensees grading of the written examination was discussed during the teleconference. 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
- R. Penfield, Site Vice President
- S. Plymale, Director of Nuclear Training
- M. McFarland, Operations Training Manager
- W. Partridge, Regulatory Compliance
- R. Chiarelli, Exam Writer/Simulator Engineer
- T. Morris, Nuclear Shift Manager / Facility Reviewer
U.S. Nuclear Regulatory Commission
- J. Beavers, Senior Resident Inspector
- T. Ospino, Resident Inspector
- J. Nance, Chief Examiner
- B. Bergeon, Senior Operations Engineer
- T. Henning, Senior Operations Engineer
- B. Jebbia, Operations Engineer
- T. Wingfield, Operations Engineer
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed, and Discussed
None
LIST OF ACRONYMS USED
Agencywide Document Access and Management System
NRC
U.S. Nuclear Regulatory Commission
Reactor Operator
Senior Reactor Operator
SIMULATION FACILITY FIDELITY REPORT
Facility Licensee:
Perry Nuclear Power Plant
Facility Docket No:
Operating Tests Administered:
December 9 - 13, 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
The simulator has a fault which randomly brings in an Alarm Panel
P804 alarm. This is a known deficiency that has been identified not
only at Perry but at other BWR 6 facilities and is apparently a coding
issue. The staff at Perry created a work around, an inject from the
simulator operators, for when this alarm would come in. These
spurious alarms occurred in almost every scenario during the exam
and led to unnecessary cues being inserted into the scenarios and
causing crews to react to unplanned alarms.
On Wednesday morning, December 11, 2024, before the start of the
first scenario of the day, an applicant discovered that thermal power
for the 1 and 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> average was above the licensed thermal power
limit of the plant. This caused the crew to be sequestered across the
hall while the simulator operators resolved the issue. The issue is
believed to be due to the initial conditions running too long.