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| issue date = 04/11/2018
| issue date = 04/11/2018
| title = NRC Initial License Examination Report 05000341/2018301
| title = NRC Initial License Examination Report 05000341/2018301
| author name = Orlikowski R J
| author name = Orlikowski R
| author affiliation = NRC/RGN-III/DRS
| author affiliation = NRC/RGN-III/DRS
| addressee name = Polson K
| addressee name = Polson K
Line 9: Line 9:
| docket = 05000341
| docket = 05000341
| license number = NPF-043
| license number = NPF-043
| contact person = Zoia C D
| contact person = Zoia C
| document report number = ER 2018301
| document report number = ER 2018301
| package number = ML17164A398
| package number = ML17164A398
Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:ril 11, 2018
[[Issue date::April 11, 2018]]


Mr. Keith Polson, Senior VP and Chief Nuclear Officer DTE Energy Company Fermi 2 - 260 TAC 6400 North Dixie Highway Newport, MI 48166
==SUBJECT:==
 
FERMI POWER PLANT, UNIT 2NRC INITIAL LICENSE EXAMINATION REPORT 05000341/2018301
SUBJECT: FERMI POWER PLANT, UNIT 2
-NRC INITIAL LICENSE EXAMINATION REPORT 05000341/2018 301


==Dear Mr. Polson:==
==Dear Mr. Polson:==
On March 1 3, 201 8, 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 examination s. Preliminary observations noted during the examination process were discussed on March 2, 2018 , with yourself and other members of your staff.
On March 13, 2018, 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 2, 2018, with yourself and other members of your staff. An exit meeting was conducted by telephone on March 15, 2018, with members of your staff, and Mr. C. Zoia, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation, the final grading of the written examination for the license applicants was discussed.
 
An exit meeting was conducted by telephone on March 15, 201 8 , with members of your staff, and Mr. C. Zoia, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation , the final grading of the written examination for the license applicants w as discussed.
 
The NRC examiners administered an initial license examination operating test during the week of February 26, 201 8. The written examination was administered by Fermi Power Plant, Unit 2, training department personnel on March 2, 201 8. Two Senior Reactor Operator and two Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on March 13, 201 8. Four applicants passed all sections of their respective examinations; two applicants were issued senior operator license s and two applicants were issued operator licenses.


The administered written examination and operating test, as well as documents related to the development and review (outlines, review comments and resolution s, etc.) of the examination will be withheld from public disclosure until March 2, 20 20.
The NRC examiners administered an initial license examination operating test during the week of February 26, 2018. The written examination was administered by Fermi Power Plant, Unit 2, training department personnel on March 2, 2018. Two Senior Reactor Operator and two Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on March 13, 2018. Four applicants passed all sections of their respective examinations; two applicants were issued senior operator licenses and two applicants were issued operator licenses.


K.Polson-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
The administered written examination and operating test, as well as documents related to the development and review (outlines, review comments and resolutions, etc.) of the examination will be withheld from public disclosure until March 2, 2020. 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 2.390, Public Inspections, Exemptions, Requests for Withholding.
-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, "Public Inspections, Exemptions, Requests for Withholding."


Sincerely,
Sincerely,
/RA/ R obert J. Orlikowski, Chief Operations Branch Division of Reactor Safety Docket No. 50
/RA/
-341 License No. NPF
Robert J. Orlikowski, Chief Operations Branch Division of Reactor Safety Docket No. 50-341 License No. NPF-43
-43 Enclosures: 1.OL Examination Report 05000341/201 8 301 2.Post-Examination Comments, Evaluation,and Resolutions 3.Simulation Facility Fidelity Reportcc: Distribution via LISTSERV A.Pullam , Training Manager,Fermi Power Plant, Unit 2 K.Polson-3-Letter t o Keith Po ls on from R obert O rlikowski da ted April 11 , 201


SUBJECT: FERMI POWER PLANT, UNIT 2-NRC INITIAL LICENSE EXAMINATION REPORT 05000341/2018 301 DISTRIBUTION
===Enclosures:===
: Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMFermi2 Resource RidsNrrDirsIrib Re source Steven West Darrell Roberts Richard Skokowski
1. OL Examination Report 05000341/2018301 2. Post-Examination Comments, Evaluation, and Resolutions 3. Simulation Facility Fidelity Report


Allan Barker DRPIII DRSIII Caroline Randiki
REGION III==
Docket No: 50-341 License No: NPF-43 Report No: 05000341/2018301 Licensee: DTE Energy Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: February 26, 2018, through March 13, 2018 Examiners: C. Zoia, Senior Operations Engineer - Chief Examiner D. Reeser, Operations Engineer - Examiner Approved by: R. Orlikowski, Chief Operations Branch Division of Reactor Safety Enclosure 1


Colleen Schmidt ADAM Accession Number: ML18101A244 OFFICE RIII RIII RIII RIII NAME CZoia:jw ROrlikowski DATE 04/10/18 04/11/18 OFFICIAL RECORD COPY
=SUMMARY=
 
Examination Report 05000341/2018301; 02/26/2018-03/14/2018; DTE Energy Company,
Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION
 
==REGION III==
Docket No:
50-341 License N o: NPF-43 Report No:
05000 341/20 1 8 301 Licensee: DTE Energy Company Facilit y: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: February 2 6, 2018, through March 1 3, 201 8 Examiners: C. Zoia , Senior Operations Engineer
- Chief Examiner D. Reeser, Operations Engineer
- Examiner Approved by:
R. Orlikowski, Chief Operations Branch Division of Reactor Safety 2


=SUMMARY=
Fermi Power Plant, Unit 2; Initial License Examination Report.
Examination  


Report 05000341/2018301
The announced initial operator licensing examination was conducted by regional Nuclear Regulatory Commission examiners in accordance with the guidance of NUREG-1021,
; 02/26/201 8-03/1 4/201 8; DTE Energy Company , Fermi Power Plant, Unit 2
Operator Licensing Examination Standards for Power Reactors, Revision 11.
; Initial License Examination Report.


The announced initial operator licensing examination was conducted by regional Nuclear Regulatory Commission examiners in accordance with the guidance of NUREG
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.
-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 1 1. Examination Summary Four of four applicants passed all sections of their respective examinations. Two applicant s were issued senior operator licenses and two applicants were issued operator licenses.  (Section 4OA5.1).


3
(Section 4OA5.1).


=REPORT DETAILS=
=REPORT DETAILS=
Line 81: Line 61:


====a. Examination Scope====
====a. Examination Scope====
The U.S. Nuclear Regulatory Commission (NRC)examiners and members of the facility licensee's staff used the guidance prescribed in NUREG
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 11, 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 prepared 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, 2018, with the assistance of members of the facility licensees staff. During the on-site validation week, the examiners audited two 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, 2018, through March 1, 2018. The facility licensee administered the written examination on March 2, 2018.
-1021, "Operator Licensing Examination Standards for Power Reactors," Revision 1 1, 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 licensee's staff.
 
Members of the facility licensee's staff prepared 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, 201 8, with the assistance of members of the facility licensee's staff. During the on
-site validation week, the examiners audited two license application s for accuracy. The NRC examiners, with the assistance of members of the facility licensee's staff, administered the operating test, consisting of job performance measures and dynamic simulator scenarios, during the period of February 2 6, 2018, through March 1, 201 8. The facility licensee administered the written examination on March 2, 2018
.


====b. Findings====
====b. Findings====
Line 93: Line 68:
Less than 20 percent of the proposed examination questions were determined to be unsatisfactory and required modification or replacement.
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 9, "Written Examination Review Worksheet
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.
." On March 8, 201 8 , the licensee submitted documentation noting that there was one post-examination comment for consideration by the NRC examiners when grading the written examination. The post
 
-examination comment and the NRC resolution for the post-examination comment is included as Enclosure 2 to the report.
On March 8, 2018, the licensee submitted documentation noting that there was one post-examination comment for consideration by the NRC examiners when grading the written examination. The post-examination comment and the NRC resolution for the post-examination comment is included as Enclosure 2 to the report.


The written examination outlines and worksheets, the proposed written examination, as well as the final as
The written examination outlines and worksheets, the proposed written examination, as well as the final as-administered examination and answer key, will be available in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS Accession Number ML17164A400).
-administered examination and answer key, will be available in 24 months , electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS Accession Number ML17164A400
). The NRC examiners graded the written examination on March 1 3, 2018, and conducted a review of each missed question to determine the accuracy and validity of the examination questions.


4
The NRC examiners graded the written examination on March 13, 2018, and conducted a review of each missed question to determine the accuracy and validity of the examination questions.
: (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. Following the review and validation of the operating test, minor modifications were made to several Job Performance Measures (JPMs), and some minor modifications were made to the dynamic simulator scenarios.
: (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.


During administration of the operating test, one Simulator Control Room JPM was replaced after it was foun d to be flawed. Specifically, critical steps would be met automatically if corrective actions were delayed beyond the ir nominally expected time. Th is flaw was not identified until after the JPM had been administered to several applicants.
Following the review and validation of the operating test, minor modifications were made to several Job Performance Measures (JPMs), and some minor modifications were made to the dynamic simulator scenarios.


Th us , another bank JPM was selected, significantly modified, validated, and administered to all applicants.
During administration of the operating test, one Simulator Control Room JPM was replaced after it was found to be flawed. Specifically, critical steps would be met automatically if corrective actions were delayed beyond their nominally expected time.


In addition, one Senior Reactor Operator (SRO) Administrative JPM required several changes to enhance its clarity and accuracy during exam administration. All changes and related explanatory notes were documented as mark
This flaw was not identified until after the JPM had been administered to several applicants. Thus, another bank JPM was selected, significantly modified, validated, and administered to all applicants.
-up s to the as-administered JPM file. Also , a Simulator Control Room JPM assigned to only the Reactor Operator (RO) applicants was administered to both RO and SRO applicants. Th e administration error was corrected by reassigning an approved JPM originally assigned to be given to all applicants, and administering it only to the RO applicants
 
. The revised SRO JPM set was verified to meet all required criteria. Finally, a training building-wide power outage occurred during the administration of a scenario, resulting in an approximately 1-hour delay because all building lighting and simulator power were lost. The scenario was just started, so there was minimal impact on the exam
In addition, one Senior Reactor Operator (SRO) Administrative JPM required several changes to enhance its clarity and accuracy during exam administration. All changes and related explanatory notes were documented as mark-ups to the as-administered JPM file.
. All applicants were sequestered until power was restored , hardware impacts were addressed, and the simulator was reset to th at point in the scenario whe n the power loss occurred
 
. A Condition Assessment Resolution Document 18-21907 was written to document the power loss, and three power losses that subsequently occurred when no NRC simulator exam was in
Also, a Simulator Control Room JPM assigned to only the Reactor Operator (RO)applicants was administered to both RO and SRO applicants. The administration error was corrected by reassigning an approved JPM originally assigned to be given to all applicants, and administering it only to the RO applicants. The revised SRO JPM set was verified to meet all required criteria.
-progress. All changes made to the operating test were made in accordance with NUREG
 
-1021, "Operator Licensing Examination Standards for Power Reactors," and were documented on Form ES 7, "Operating Test Review Worksheet.The Form ES 7, the operating test outlines (ES 1, ES-301-2, and ES-D-1s), and both the proposed and final operating tests, will be available, in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS Accession Numbers ML17164A40 3 and ML17164A400, respectively
Finally, a training building-wide power outage occurred during the administration of a scenario, resulting in an approximately 1-hour delay because all building lighting and simulator power were lost. The scenario was just started, so there was minimal impact on the exam. All applicants were sequestered until power was restored, hardware impacts were addressed, and the simulator was reset to that point in the scenario when the power loss occurred. A Condition Assessment Resolution Document 18-21907 was written to document the power loss, and three power losses that subsequently occurred when no NRC simulator exam was in-progress.
). The NRC examiners completed the operating test grading on March 1 3, 201 8.
 
All changes made to the operating test were made in accordance with NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and were documented on Form ES-301-7, Operating Test Review Worksheet. The Form ES-301-7, the operating test outlines (ES-301-1, ES-301-2, and ES-D-1s), and both the proposed and final operating tests, will be available, in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS Accession Numbers ML17164A403 and ML17164A400, respectively).
 
The NRC examiners completed the operating test grading on March 13, 2018.
: (3) Examination Results Two applicants at the SRO level and two applicants at the RO level were administered written examinations and operating tests.
: (3) Examination Results Two applicants at the SRO level and two applicants at the RO level were administered written examinations and operating tests.
 
* Four applicants passed all portions of their examinations and were issued their respective operating licenses on March 13, 2018.
Four applicants passed all portions of their examinations and were issued their respective operating licenses on March 1 3, 201 8.


===.2 Examination Security===
===.2 Examination Security===


====a. Scope====
====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 Title 10 of the Code of Federal Regulations , Part 55.49, "Integrity of Examinations and Tests.
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, Part 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.
 
The examiners used the guidelines provided in NUREG-1021, "Operator Licensing Examination Standards for Power Reactors
," to determine acceptability of the licensee
's examination security activities.


====b. Findings====
====b. Findings====
None.
None.
{{a|4OA6}}
{{a|4OA6}}
==4OA6 Management Meetings==
==4OA6 Management Meetings==


===.1 Debrief The chief examiner presented the examination team's preliminary observations and findings on March 2, 201 8 , to Mr. K. Polson, Senior Vice President===
===.1 Debrief===


, and Chief Nuclear Officer , and other staff members of Fermi Power Plant, Unit 2
The chief examiner presented the examination team's preliminary observations and findings on March 2, 2018, to Mr. K. Polson, Senior Vice President, and Chief Nuclear Officer, and other staff members of Fermi Power Plant, Unit 2. 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 meeting.
. 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 meeting.


===.2 Exit Meeting===
===.2 Exit Meeting===


The chief examiner conducted an exit meeting on March 15, 201 8, with Mr. A. Pullam , Training Manager , and other members of the Fermi Power Plant, Unit 2
The chief examiner conducted an exit meeting on March 15, 2018, with Mr. A. Pullam, Training Manager, and other members of the Fermi Power Plant, Unit 2, staff by telephone. The NRCs final exam results were disclosed during the exit meeting.
, staff by telephone. The NRC
 
's final exam results were disclos ed during the exit meeting
ATTACHMENT:  
. ATTACHMENT:


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC
SUPPLEMENTAL INFORMATION
T Licensee  
KEY POINTS OF CONTACT
: [[contact::K. Polson ]], Senior Vice President and Chief Nuclear Officer
Licensee
: [[contact::L. Bennett]], Operations Director  
: [[contact::K. Polson]], Senior Vice President and Chief Nuclear Officer
: [[contact::L. Bennett]], Operations Director
: [[contact::A. Pullam]], Training Manager
: [[contact::A. Pullam]], Training Manager
: [[contact::S. Maglio]], Licensing Manager
: [[contact::S. Maglio]], Licensing Manager
: [[contact::M. Donigian]], Operations Training Lead  
: [[contact::M. Donigian]], Operations Training Lead
: [[contact::J. Vanbrunt]], Operations Training
: [[contact::J. Vanbrunt]], Operations Training
: [[contact::S. Schmus]], Operations Training
: [[contact::S. Schmus]], Operations Training
U.S Nuclear Regulatory
U.S Nuclear Regulatory Commission
Commission  
: [[contact::C. Zoia]], Chief Examiner
: [[contact::C. Zoia]], Chief Examiner
: [[contact::D. Reeser]], Examiner
: [[contact::D. Reeser]], Examiner
: [[contact::T. Briley ]], Senior Resident Inspector
: [[contact::T. Briley]], Senior Resident Inspector
: [[contact::P. Smagacz]], Resident Inspector ITEMS OPENED, CLOSED, AND DISCUSSED
: [[contact::P. Smagacz]], Resident Inspector
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened, Closed, and Discussed
Opened, Closed, and Discussed
None LIST OF ACRONYMS USE
None
D JPM Job Performance Measures
LIST OF ACRONYMS USED
NRC U.S. Nuclear Regulatory Commission
JPM             Job Performance Measures
RO Reactor Operator
NRC             U.S. Nuclear Regulatory Commission
SRO Senior Reactor Operator
RO             Reactor Operator
 
SRO             Senior Reactor Operator
POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION
POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION
QUESTION No.
QUESTION No. 22
The plant has been operating at 100
The plant has been operating at 100 percent power for 300 consecutive days, when the
percent power for 300 consecutive days, when the following events
following events occur:
occur:  A reactor scram causes the crew to place the Mode Switch in Shutdown.
        * A reactor scram causes the crew to place the Mode Switch in Shutdown.
The MSIVs closed 10
        *  The MSIVs closed 10 minutes later.
minutes later.
        *  RPV Pressure is currently 1095 psig.
RPV Pressure is currently 1095 psig.
        *  The CRLNO has been directed to maintain RPV Pressure 900-1050 psig.
The CRLNO has been directed to maintain RPV Pressure 900
How many SRVs are going to be required to restore and maintain RPV pressure in the desired
-1050 psig.
control band considering heat input by DECAY HEAT GENERATION ONLY?
How many SRVs are going to be required to restore and maintain RPV pressure in the desired control band considering heat input by DECAY HEAT GENERATION ONLY?
A. One SRV opening and closing at its Low-Low Set setpoints.
A. One SRV opening and
: [[contact::B. One open SRV will restore RPV pressure in band]], then it can be closed
closing at its Low-Low Set setpoints.
for the duration of the event.
: [[contact::B. One open SRV will restore RPV pressure in band]], then it can be closed for the duration of the
: [[contact::C. One Low-Low Set SRV will be open continuously]], with the second
event.  
opening and closing at its Low-Low Set setpoints.
: [[contact::C. One Low-Low Set SRV will be open continuously]], with the second opening and closing at its Low-Low Set setpoints.
D. Both Low-Low Set SRVs will be open continuously with the CRLNO
D. Bot h Low-Low Set SRVs will be open continuously with the CRLNO opening and closing one additional
opening and closing one additional SRV.
SRV. Answer: A Answer Explanation:
Answer: A
The conditions in the stem of the question have caused a High Reactor Pressure. The candidate will have to determine the impact of decay heat generation so as to
Answer Explanation:
correct the High Reactor Pressure and control RPV Pressure in the designated control band for the duration of the event. Decay heat produced is at a level dependent on power history.
The conditions in the stem of the question have caused a High Reactor Pressure.
From a scram at 100
The candidate will have to determine the impact of decay heat generation so as to correct
percent power, initially the thermal output of the reactor
the High Reactor Pressure and control RPV Pressure in the designated control band for the
will be about
duration of the event. Decay heat produced is at a level dependent on power history. From
100 percent power, 7 percent supplied by decay heat.
a scram at 100 percent power, initially the thermal output of the reactor will be about
Thermal heat output decreases rapidly
100 percent power, 7 percent supplied by decay heat. Thermal heat output decreases rapidly
to the decay heat level.
to the decay heat level. Eight to ten seconds after the scram, thermal output is due mainly to
Eight to ten seconds after the scram, thermal output is due mainly to decay heat and drops to 7
decay heat and drops to 7 percent of rated thermal output. After approximately 1 minute,
percent of rated thermal output.
thermal output is 3 to 5 percent of rated and drops to about 2 percent after about 10 minutes.
After approximately
One hour after a scram, decay heat is about 1 percent rated thermal output. The information
minute, thermal output is 3 to 5
given in the stem of the question indicates that the reactor has been shut down for about
percent of rated and drops to about 2
minutes, so decay heat generation will be approximately 2 percent. SRV capacity (steam
percent after about
flow) is given in Updated Final Safety Analysis Report Paragraph 5.2.2.3.3.4 as 87E4 lb./hr. (or
minutes. One hour after a scram, decay heat is about 1
870,000 lb./hr.) at 1090 psig, which is approximately where the stem of the question has the
percent rated thermal output.
plant. Updated Final Safety Analysis Report Section 1.2.2, Plant Description, shows that rated
The information given in the stem of the question indicates that the reactor has been shut
steam flow at Fermi 2 is 14.9 lb./hr., at 991 psia., 2 percent of this value is 298,000 lb./hr., which
down for about
is within the capacity of one SR
minutes, so decay heat generation will be approximately 2
: [[contact::V. Therefore]], the candidate should determine that one SRV.
percent. SRV capacity (steam flow) is given in Updated Final Safety Analysis Report
opening and closing at its Low-Low setpoint will be enough to control the steam generated from
Paragraph 5.2.2.3.3.4 as 87E4 lb./hr. (or 870,000 lb./hr.) at 1090 psig, which is approximately where the stem of the question has the plant. Updated Final Safety Analysis Report
decay heat approximately 10 minutes after plant shutdown from 100 percent power operation.
Section 1.2.2, Plant Description, shows that rated steam flow at Fermi 2 is 14.9 lb./hr., at 991 psia., 2 percent of this value is 298,000 lb./hr., which is within the capacity of one SR
: [[contact::V. Therefore]], the candidate should determine that one SRV. opening and closing at its Low
-Low setpoint will be enough to control the steam generated from decay heat approximately 10
minutes after plant shutdown from 100
percent power operation.
 
POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION
POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION
Distractor Explanation
Distractor Explanations:
s: Distractors are incorrect and plausible because:
Distractors are incorrect and plausible because:
B. The candidate could determine that there is no significant decay heat generation
B.     The candidate could determine that there is no significant decay heat generation
minutes after shutdown and, once RPV pressure is lowered back in band by opening an SRV, it will
minutes after shutdown and, once RPV pressure is lowered back in band by opening
remain in band with no further SRV actuations.
an SRV, it will remain in band with no further SRV actuations. This is incorrect because
This is incorrect because decay heat, in the 2
decay heat, in the 2 percent range, exists and will continue to exist at the 1 percent
percent range, exists and will
value one hour after shutdown, so further SRV actuation must occur to control RPV
continue to exist at the 1
pressure.
percen t value one hour after shutdown, so further SRV actuation must occur to
C.     The candidate could determine that the decay heat generated 10 minutes after
control RPV pressure. C. The candidate could determine that the decay heat generated 10
shutdown is above the capacity of one, but within the capacity of two Low-Low Set
minutes after shutdown is above the
SRVs. This is a common misconception because most candidates readily remember
capacity of one, but within the capacity of two Low
that decay heat drops to 7 percent within several seconds of a plant shutdown, due to
-Low Set SRVs. This is a common misconception
the decay of delayed neutrons and they determine that 7 percent is the capacity of about
because most candidates readily remember that decay heat drops to 7
one and a half SRVs. However, as stated above, after approximately 10 minutes,
percent within several seconds of a
thermal output due to decay heat drops to about 2 percent, which is within the capacity
plant shutdown, due to the decay of delayed neutrons and they determine that 7
of one Low-Low Set SRV.
percent is the capacity of
D.     The candidate could determine that the decay heat generated 10 minutes after
about one and a half SRVs.
shutdown is above the capacity of both Low-Low Set SRVs, which would require the
However, as stated above, after approximately
operator to manually actuate one additional SRV to control RPV pressure in band.
minutes, thermal output due to decay heat drops to about 2
This is incorrect, however, as stated above, because after approximately 10 minutes,
percent, which is within the capacity of one Low
thermal output due to decay heat drops to about 2 percent, which is within the capacity
-Low Set SRV.
of one Low-Low Set SRV.
D. The candidate could determine that the decay heat generated 10
minutes after shutdown is above the
capacity of both Low
-Low Set SRVs, which would require the operator to manually actuate one
additional SRV to control RPV pressure in band. This is incorrect, however, as stated above, because
after approximately
minutes, thermal output due to decay heat drops to about 2
percent, which is within
the capacity of one Low
-Low Set SRV.
Reference Information:
Reference Information:
BR08Sr5 Operational
BR08Sr5 Operational Physics May 2011 - Reactor Operational Physics GFE Student Text,
Physics May 2011  
Page 33; description of decay heat generation after shutdown from 100 percent power.
- Reactor Operational Physics GFE Student Text, Page 33; description of decay heat generation after shutdown from 100
UFSAR Section 1.2.2, Plant Description.
percent power. UFSAR Section 1.2.2, Plant Description.
UFSAR Section 5.2.2.3.3.4, Safety/Relief Valve Characteristics.
UFSAR Section 5.2.2.3.3.4, Safety/Relief Valve Characteristics.
APPLICANT COMMENT/CONTENTION
APPLICANT COMMENT/CONTENTION
The applicant contended that the question
The applicant contended that the question was not about what the plant will do.
was not about what the plant will do.
FACILITY RESPONSE AND PROPOSED RESOLUTION
FACILITY RESPONSE AND PROPOSED RESOLUTION
Based on the stem of the question, actual plant response
Based on the stem of the question, actual plant response is not the answer. The question is
is not the answer.
about the capacity of SRVs, not about a timeline of events in which an SRV opens.
The question
i s about the capacity of SRVs, not about a timeline of events in which an SRV opens.
 
POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION
POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION
Valid Question. Answer (A) is correct and the distractors are wrong. Distractor (C) was selected by the applicant. The candidate determined that the decay heat generated 10
Valid Question. Answer (A) is correct and the distractors are wrong. Distractor (C) was
minutes after shutdown is above the capacity of one, but within the capacity of two Low
selected by the applicant. The candidate determined that the decay heat generated 10 minutes
-Low Set SRVs.
after shutdown is above the capacity of one, but within the capacity of two Low-Low Set SRVs.
This is a common misconception because most candidates readily remember that decay heat drops to 7
This is a common misconception because most candidates readily remember that decay heat
percent within several seconds of a plant shutdown, due to the decay of delayed neutrons , and they determine that 7
drops to 7 percent within several seconds of a plant shutdown, due to the decay of delayed
percent is the capacity of about one and a
neutrons, and they determine that 7 percent is the capacity of about one and a half SRVs.
half SRVs.
NRC EVALUATION/RESOLUTION
NRC EVALUATION/RESOLUTION
Upon reviewing
Upon reviewing the technical information from the applicant and the facility, the NRC agrees
the technical information from the applicant and the facility, the NRC agrees that answer (A) is the correct answer.
that answer (A) is the correct answer. The decay heat at 10 minutes will be approximately
The decay heat at
percent of rated thermal output, well within the capacity of one SRV opening and closing
minutes will be approximately
at its Low-Low Set setpoints.
percent of rated thermal output
The stem of the question asks How many SRVs are going to be required to restore and
, well within the capacity of one SRV
maintain RPV pressure in the desired control band considering heat input by DECAY HEAT
opening and closing
GENERATION ONLY?, given several conditions. The applicant and the licensee agree that
at its Low-Low Set setpoints
the question is not about providing plant response. The NRC also agrees that the answer
. The stem of the question asks "How many SRVs are going to be required to restore and maintain RPV pressure in the desired control band considering heat input by DECAY HEAT GENERATION ONLY?
required involves SRV capacity, and not about providing plant response.
", given several conditions. The applicant and the licensee agree that the question
CONCLUSION
is not about providing plant response. The NRC also agrees that the answer required involve s SRV capacity, and not about providing plant response
Based the information provided, the NRC concludes that answer (A) is correct answer, per the
. CONCLUSION
original answer key, and the question is considered acceptable as-administered.
Based the information provided, the NRC concludes that
answer (A) is correct answer, per the original answer key, and the question
is considered acceptable as
-administered
.
SIMULATION FACILITY FIDELITY REPORT
SIMULATION FACILITY FIDELITY REPORT
Facility Licensee:
Facility Licensee:                     Fermi Power Plant, Unit 2
Fermi Power Plant, Unit 2
Facility Docket No:                     050-341
Facility Docket No:
Operating Tests Administered:           February 26, 2018, through March 1, 2018
50-3 4 1 Operating Tests Administered:
The following documents observations made by the U.S. Nuclear Regulatory Commission
February 2 6, 2018, through March 1, 201 8 The following documents observations made by the U.S. Nuclear Regulatory
examination team during the initial operator license examination. These observations do
Commission 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,
not constitute audit or inspection findings and are not, without further verification and review, indicative of non
indicative of non-compliance with Title 10 of the Code of Federal Regulations 55.45(b). These
-compliance with Title 10 of the Code of Federal Regulations
observations do not affect U.S. Nuclear Regulatory Commission certification or approval of the
55.45(b). These observations do not affect U.S. Nuclear Regulatory
simulation facility other than to provide information which may be used in future evaluations.
Commission 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.
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
During the conduct of the simulator portion of the operating tests, the following items were
observed:
ITEM                                         DESCRIPTION
None
None
3
}}
}}

Latest revision as of 00:11, 19 December 2019

NRC Initial License Examination Report 05000341/2018301
ML18101A244
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 04/11/2018
From: Robert Orlikowski
Division of Reactor Safety III
To: Polson K
DTE Electric Company
Zoia C
Shared Package
ML17164A398 List:
References
ER 2018301
Download: ML18101A244 (13)


Text

ril 11, 2018

SUBJECT:

FERMI POWER PLANT, UNIT 2NRC INITIAL LICENSE EXAMINATION REPORT 05000341/2018301

Dear Mr. Polson:

On March 13, 2018, 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 2, 2018, with yourself and other members of your staff. An exit meeting was conducted by telephone on March 15, 2018, with members of your staff, and Mr. C. Zoia, Chief Operator Licensing Examiner, to review the proposed final grading of the written examination for the license applicants. During the telephone conversation, the final grading of the written examination for the license applicants was discussed.

The NRC examiners administered an initial license examination operating test during the week of February 26, 2018. The written examination was administered by Fermi Power Plant, Unit 2, training department personnel on March 2, 2018. Two Senior Reactor Operator and two Reactor Operator applicants were administered license examinations. The results of the examinations were finalized on March 13, 2018. Four applicants passed all sections of their respective examinations; two applicants were issued senior operator licenses and two applicants were issued operator licenses.

The administered written examination and operating test, as well as documents related to the development and review (outlines, review comments and resolutions, etc.) of the examination will be withheld from public disclosure until March 2, 2020. 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 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Robert J. Orlikowski, Chief Operations Branch Division of Reactor Safety Docket No. 50-341 License No. NPF-43

Enclosures:

1. OL Examination Report 05000341/2018301 2. Post-Examination Comments, Evaluation, and Resolutions 3. Simulation Facility Fidelity Report

REGION III==

Docket No: 50-341 License No: NPF-43 Report No: 05000341/2018301 Licensee: DTE Energy Company Facility: Fermi Power Plant, Unit 2 Location: Newport, MI Dates: February 26, 2018, through March 13, 2018 Examiners: C. Zoia, Senior Operations Engineer - Chief Examiner D. Reeser, Operations Engineer - Examiner Approved by: R. Orlikowski, Chief Operations Branch Division of Reactor Safety Enclosure 1

SUMMARY

Examination Report 05000341/2018301; 02/26/2018-03/14/2018; 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 examiners in accordance with the guidance of NUREG-1021,

Operator Licensing Examination Standards for Power Reactors, Revision 11.

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).

REPORT DETAILS

4OA5 Other Activities

.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 11, 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 prepared 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, 2018, with the assistance of members of the facility licensees staff. During the on-site validation week, the examiners audited two 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, 2018, through March 1, 2018. The facility licensee administered the written examination on March 2, 2018.

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.

On March 8, 2018, the licensee submitted documentation noting that there was one post-examination comment for consideration by the NRC examiners when grading the written examination. The post-examination comment and the NRC resolution for the post-examination comment is included as Enclosure 2 to the report.

The written examination outlines and worksheets, the proposed written examination, as well as the final as-administered examination and answer key, will be available in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS Accession Number ML17164A400).

The NRC examiners graded the written examination on March 13, 2018, and conducted a review of each missed question to determine the accuracy and validity of the examination questions.

(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.

Following the review and validation of the operating test, minor modifications were made to several Job Performance Measures (JPMs), and some minor modifications were made to the dynamic simulator scenarios.

During administration of the operating test, one Simulator Control Room JPM was replaced after it was found to be flawed. Specifically, critical steps would be met automatically if corrective actions were delayed beyond their nominally expected time.

This flaw was not identified until after the JPM had been administered to several applicants. Thus, another bank JPM was selected, significantly modified, validated, and administered to all applicants.

In addition, one Senior Reactor Operator (SRO) Administrative JPM required several changes to enhance its clarity and accuracy during exam administration. All changes and related explanatory notes were documented as mark-ups to the as-administered JPM file.

Also, a Simulator Control Room JPM assigned to only the Reactor Operator (RO)applicants was administered to both RO and SRO applicants. The administration error was corrected by reassigning an approved JPM originally assigned to be given to all applicants, and administering it only to the RO applicants. The revised SRO JPM set was verified to meet all required criteria.

Finally, a training building-wide power outage occurred during the administration of a scenario, resulting in an approximately 1-hour delay because all building lighting and simulator power were lost. The scenario was just started, so there was minimal impact on the exam. All applicants were sequestered until power was restored, hardware impacts were addressed, and the simulator was reset to that point in the scenario when the power loss occurred. A Condition Assessment Resolution Document 18-21907 was written to document the power loss, and three power losses that subsequently occurred when no NRC simulator exam was in-progress.

All changes made to the operating test were made in accordance with NUREG-1021, Operator Licensing Examination Standards for Power Reactors, and were documented on Form ES-301-7, Operating Test Review Worksheet. The Form ES-301-7, the operating test outlines (ES-301-1, ES-301-2, and ES-D-1s), and both the proposed and final operating tests, will be available, in 24 months, electronically in the NRC Public Document Room or from the Publicly Available Records component of NRC's Agencywide Document Access and Management System (ADAMS Accession Numbers ML17164A403 and ML17164A400, respectively).

The NRC examiners completed the operating test grading on March 13, 2018.

(3) Examination Results Two applicants at the SRO level and two applicants at the RO level were administered written examinations and operating tests.
  • Four applicants passed all portions of their examinations and were issued their respective operating licenses on March 13, 2018.

.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, Part 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

None.

4OA6 Management Meetings

.1 Debrief

The chief examiner presented the examination team's preliminary observations and findings on March 2, 2018, to Mr. K. Polson, Senior Vice President, and Chief Nuclear Officer, and other staff members of Fermi Power Plant, Unit 2. 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 meeting.

.2 Exit Meeting

The chief examiner conducted an exit meeting on March 15, 2018, with Mr. A. Pullam, Training Manager, and other members of the Fermi Power Plant, Unit 2, staff by telephone. The NRCs final exam results were disclosed during the exit meeting.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Polson, Senior Vice President and Chief Nuclear Officer
L. Bennett, Operations Director
A. Pullam, Training Manager
S. Maglio, Licensing Manager
M. Donigian, Operations Training Lead
J. Vanbrunt, Operations Training
S. Schmus, Operations Training

U.S Nuclear Regulatory Commission

C. Zoia, Chief Examiner
D. Reeser, Examiner
T. Briley, Senior Resident Inspector
P. Smagacz, Resident Inspector

ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and Discussed

None

LIST OF ACRONYMS USED

JPM Job Performance Measures

NRC U.S. Nuclear Regulatory Commission

RO Reactor Operator

SRO Senior Reactor Operator

POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION

QUESTION No. 22

The plant has been operating at 100 percent power for 300 consecutive days, when the

following events occur:

  • A reactor scram causes the crew to place the Mode Switch in Shutdown.
  • The MSIVs closed 10 minutes later.
  • RPV Pressure is currently 1095 psig.
  • The CRLNO has been directed to maintain RPV Pressure 900-1050 psig.

How many SRVs are going to be required to restore and maintain RPV pressure in the desired

control band considering heat input by DECAY HEAT GENERATION ONLY?

A. One SRV opening and closing at its Low-Low Set setpoints.

B. One open SRV will restore RPV pressure in band, then it can be closed

for the duration of the event.

C. One Low-Low Set SRV will be open continuously, with the second

opening and closing at its Low-Low Set setpoints.

D. Both Low-Low Set SRVs will be open continuously with the CRLNO

opening and closing one additional SRV.

Answer: A

Answer Explanation:

The conditions in the stem of the question have caused a High Reactor Pressure.

The candidate will have to determine the impact of decay heat generation so as to correct

the High Reactor Pressure and control RPV Pressure in the designated control band for the

duration of the event. Decay heat produced is at a level dependent on power history. From

a scram at 100 percent power, initially the thermal output of the reactor will be about

100 percent power, 7 percent supplied by decay heat. Thermal heat output decreases rapidly

to the decay heat level. Eight to ten seconds after the scram, thermal output is due mainly to

decay heat and drops to 7 percent of rated thermal output. After approximately 1 minute,

thermal output is 3 to 5 percent of rated and drops to about 2 percent after about 10 minutes.

One hour after a scram, decay heat is about 1 percent rated thermal output. The information

given in the stem of the question indicates that the reactor has been shut down for about

minutes, so decay heat generation will be approximately 2 percent. SRV capacity (steam

flow) is given in Updated Final Safety Analysis Report Paragraph 5.2.2.3.3.4 as 87E4 lb./hr. (or

870,000 lb./hr.) at 1090 psig, which is approximately where the stem of the question has the

plant. Updated Final Safety Analysis Report Section 1.2.2, Plant Description, shows that rated

steam flow at Fermi 2 is 14.9 lb./hr., at 991 psia., 2 percent of this value is 298,000 lb./hr., which

is within the capacity of one SR

V. Therefore, the candidate should determine that one SRV.

opening and closing at its Low-Low setpoint will be enough to control the steam generated from

decay heat approximately 10 minutes after plant shutdown from 100 percent power operation.

POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION

Distractor Explanations:

Distractors are incorrect and plausible because:

B. The candidate could determine that there is no significant decay heat generation

minutes after shutdown and, once RPV pressure is lowered back in band by opening

an SRV, it will remain in band with no further SRV actuations. This is incorrect because

decay heat, in the 2 percent range, exists and will continue to exist at the 1 percent

value one hour after shutdown, so further SRV actuation must occur to control RPV

pressure.

C. The candidate could determine that the decay heat generated 10 minutes after

shutdown is above the capacity of one, but within the capacity of two Low-Low Set

SRVs. This is a common misconception because most candidates readily remember

that decay heat drops to 7 percent within several seconds of a plant shutdown, due to

the decay of delayed neutrons and they determine that 7 percent is the capacity of about

one and a half SRVs. However, as stated above, after approximately 10 minutes,

thermal output due to decay heat drops to about 2 percent, which is within the capacity

of one Low-Low Set SRV.

D. The candidate could determine that the decay heat generated 10 minutes after

shutdown is above the capacity of both Low-Low Set SRVs, which would require the

operator to manually actuate one additional SRV to control RPV pressure in band.

This is incorrect, however, as stated above, because after approximately 10 minutes,

thermal output due to decay heat drops to about 2 percent, which is within the capacity

of one Low-Low Set SRV.

Reference Information:

BR08Sr5 Operational Physics May 2011 - Reactor Operational Physics GFE Student Text,

Page 33; description of decay heat generation after shutdown from 100 percent power.

UFSAR Section 1.2.2, Plant Description.

UFSAR Section 5.2.2.3.3.4, Safety/Relief Valve Characteristics.

APPLICANT COMMENT/CONTENTION

The applicant contended that the question was not about what the plant will do.

FACILITY RESPONSE AND PROPOSED RESOLUTION

Based on the stem of the question, actual plant response is not the answer. The question is

about the capacity of SRVs, not about a timeline of events in which an SRV opens.

POST-EXAMINATION COMMENT, EVALUATION, AND RESOLUTION

Valid Question. Answer (A) is correct and the distractors are wrong. Distractor (C) was

selected by the applicant. The candidate determined that the decay heat generated 10 minutes

after shutdown is above the capacity of one, but within the capacity of two Low-Low Set SRVs.

This is a common misconception because most candidates readily remember that decay heat

drops to 7 percent within several seconds of a plant shutdown, due to the decay of delayed

neutrons, and they determine that 7 percent is the capacity of about one and a half SRVs.

NRC EVALUATION/RESOLUTION

Upon reviewing the technical information from the applicant and the facility, the NRC agrees

that answer (A) is the correct answer. The decay heat at 10 minutes will be approximately

percent of rated thermal output, well within the capacity of one SRV opening and closing

at its Low-Low Set setpoints.

The stem of the question asks How many SRVs are going to be required to restore and

maintain RPV pressure in the desired control band considering heat input by DECAY HEAT

GENERATION ONLY?, given several conditions. The applicant and the licensee agree that

the question is not about providing plant response. The NRC also agrees that the answer

required involves SRV capacity, and not about providing plant response.

CONCLUSION

Based the information provided, the NRC concludes that answer (A) is correct answer, per the

original answer key, and the question is considered acceptable as-administered.

SIMULATION FACILITY FIDELITY REPORT

Facility Licensee: Fermi Power Plant, Unit 2

Facility Docket No: 050-341

Operating Tests Administered: February 26, 2018, through March 1, 2018

The following documents observations made by the U.S. Nuclear Regulatory Commission

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 Title 10 of the Code of Federal Regulations 55.45(b). These

observations do not affect U.S. Nuclear Regulatory Commission 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

3