IR 05000352/2024301
| ML24033A072 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 02/02/2024 |
| From: | Diane Jackson NRC/RGN-I/DORS/OB |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| References | |
| Download: ML24033A072 (1) | |
Text
February 2, 2024
David Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer (CNO)
Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 - INITIAL OPERATOR LICENSING EXAMINATION REPORT 05000352/20 24301 AND 05000353/202 4301
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 enclosed examination report documents the examination results, which were discussed on January 25, 2024, with Michael Gillin, Site Vice President, and other members of your staff.
The examination included the evaluation 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 written and operating examinations were developed using NUREG-1021, Operator Licensing Examination Standards for Power Reactors, Revision 12.
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 and was issued a preliminary denial letter.
No findings were 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, Donald E. Jackson, Chief Operations Branch Division of Operating Reactor Safety
Docket Nos. 0 5000352 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: 05000352/2024301 and 05000353/2024301
Licensee: Constellation Energy Generation, LLC
Enterprise Identifier: L-2024-OLL-0000
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 (Licenses Issued)
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
Enclosure
SUMMARY
ER 05000352/ 2024 301 and 05000353/ 2024 301; 12/04/2023 - 12/8/2023; Limerick Generating
Station, Unit s 1 and 2; 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 1 4, 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 and was issued a preliminary denial letter.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES (OA)
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 examiner s 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 (N+1) 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. For the written examinations, the reactor operator applicants average score was 87.8 percent and the senior reactor operator applicants average score was 85.8 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 C hief 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.
.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
The examiners determined that the written examination submitted by the licensee was not within the range of acceptability expected for a proposed examination, and as a result, was not adequate for administration.
Specifically, 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) due to low level of difficulty (LOD 1), incorrect license level, K/A mismatch, more than one implausible distractor, subset or multiple correct answers, stem cueing and stem focus flaws. The licensee made a pre-submittal of 10 questions as allowed by NUREG 1021. These questions and previous NRC exam questions were not counted towards the total or percentage of unsatisfactory questions.
Questions for which an exam key change was made based on post-examination comments (17, 46 and 92) were included in the count of unsatisfactory questions. In addition to the questions that were marked unsatisfactory, many of the questions on both the reactor operator and senior reactor operator portions of the written exam required editing for readability, grammar, and spelling.
The NRC provided comments to the licensee on the written exam. The licensee submitted two additional draft exam submittals on November 10 and 14, 2023, which incorporated many of the changes requested by the examiners. Some questions continued to be flawed or have other issues such as editing for grammar or readability.
The NRC provided additional comments and after all comments were incorporated, the exam was approved by the NRC on November 29, 2023.
The examiners identified one generic weakness i n the written exam submittal.
Specifically, the overall level of difficulty of the draft exam submittal was determined to be low, with numerous questions considered borderline LOD 1. This was in part due to the numerous questions
- (20) that were similar in construction and tested at a low level of knowledge, or tested a trivial aspect of each K/A. These questions were determined to involve minimal analysis and required the candidate to select between distractors that contained binary choices (yes/no, pump running/not running, valve open/closed, etc).
In summary, the overall written exam submittal was outside the acceptable quality range expected by the NRC. The operating portion of the examination was determined to be satisfactory with only minor edits required.
No findings were identified.
.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
No findings were identified.
4OA6 Meetings, Including Exit
The Chief Examiner presented the examination results to Michael Gillin, Site Vice President, and other members of the licensee's staff on January 25, 2024. The licensee acknowledged the observations 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
Michael Gillin - Site Vice President
Matt Bonanno - Plant Manager
Bill Levis, Jr - Operations Director
Kris Strausser - Shift Operations Superintendent
Ryan Harris - Senior Manager of Training
Dan Semeter - Manager of Operations Training
Dave Hall - Initial License Training (ILT) Lead Instructor
Tom Castle - Regulatory Exam Author
Dan Moren - Fleet Regulatory Exam Expert
ITEMS OPENED, CLOSED, AND DISCUSSED
None