An apparent violation of
10 CFR 55.49, Integrity of Examinations and Tests, was identified, concerning an apparent compromise of the 2005 and the 2006 annual operating exams at Unit 1. NRC inspectors identified practices that collectively had the impact of compromising, albeit unintentionally, the examinations; these practices included: 1) a lack of simulator exam scenario diversity (i.e., The scenarios were substantially the same including: critical tasks; major
transients; Emergency Operating Procedure flow paths; and emergency classifications); 2) an overuse of a single emergency operating procedure strategy (i.e., full core Anticipated
Transient Without
Scram); and 3) a pattern of crews validating scenarios substantially similar to their exam scenario sets. Constellation had not identified and compensated for the compromise prior to completing the 2005 exam and returning the operators to normal control room duties. Following NRC identification of the compromise in 2006, Constellation took immediate and substantive corrective actions prior to completion of the annual operating exam cycle. Based on the Licensed Operator Requalification
Significance Determination Process (
SDP) this finding was preliminarily determined to be of low to moderate safety significance (White). The licensee initiated Condition Report CR-NM-2006-4808, dated October 19, 2006, that documented this issue and later initiated a Category I Root Cause Analysis (CRNM- 2006-4808), Annual Licensed Operator Requalification Exam Compromise. This finding was more than minor because it was associated with the Human Performance attribute of the
Initiating Events, Mitigation Systems, and
Barrier Integrity cornerstones and affected the combined objective of: limiting the likelihood of; ensuring the availability and reliability of
mitigating systems to respond to; and providing reasonable assurance that physical barriers protect the public from radio-nuclide releases caused by,
initiating events. The finding has a cross-cutting aspect in the area of problem identification and resolution because Constellation did not effectively collect, evaluate, and communicate applicable external operating experience to affected internal stakeholders nor did they conduct self-assessments that were comprehensive, appropriately objective, and self-critical such that either Unit 1 2005 exam compromise issues were avoided altogether or identified and corrected prior to the end of the 2005 annual operating exam cycle. (Section 1R11.1)
