05000254/FIN-2017004-01
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Finding | |
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| Title | Repeat Use of Written Exams during Licensed Operator Requalification Examinations |
| Description | a. Inspection ScopeThe following inspection activities were conducted during the weeks of October 9 and October 16, 2017, to assess: (1) the effectiveness and adequacy of the facility licensees implementation and maintenance of its systems approach to training (SAT) based LORT Program put into effect to satisfy the requirements of 10 CFR 55.59; (2) conformance with the requirements of 10 CFR 55.46 for use of a plant referenced simulator to conduct operator licensing examinations and for satisfying experience requirements; and (3) conformance with the operator license conditions specified in 10 CFR 55.53. The documents reviewed are listed in the Attachment to this report.Licensee Requalification Examinations (10 CFR 55.59(c); SAT Element 4 as Defined in 10 CFR 55.4): The inspectors reviewed the licensees program for development and administration of the LORT biennial written examination and annual operating tests to assess the licensees ability to develop and administer examinations that are acceptable for meeting the requirements of 10 CFR 55.59(a).- The inspectors conducted a detailed review of one biennial requalification written examination versions to assess content, level of difficulty, and quality of the written examination materials. (02.03)- The inspectors conducted a detailed review of ten job performance measures and four simulator scenarios to assess content, level of difficulty, and quality of the operating test materials.(02.04)- The inspectors observed the administration of the annual operating test to assess the licensees effectiveness in conducting the examination(s), including the conduct of pre-examination briefings, evaluations of individual operator and crew performance, and post-examination analysis. The inspectors evaluated the performance of one crew in parallel with the facility evaluators during two dynamic simulator scenarios, and evaluated various licensed crew members concurrently with facility evaluators during the administration of several job performance measures. (02.05)- The inspectors assessed the adequacy and effectiveness of the remedial training conducted since the last requalification examinations and the training planned for the current examination cycle to ensure that they addressed weaknesses in licensed operator or crew performance identified during training and plant operations. The inspectors reviewed remedial training procedures and individual remedial training plans. (02.07) Conformance with Examination Security Requirements (10 CFR 55.49): The inspectors conducted an assessment of the licensees processes related to examination physical security and integrity (e.g., predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests. The inspectors observed the implementation of physical security controls (e.g., access restrictions and simulator I/O controls) and integrity measures (e.g., security agreements, sampling criteria, bank use, and test item repetition) throughout the inspection period. (02.06)Conformance with Operator License Conditions (10 CFR 55.53): The inspectors reviewed the facility licensee's program for maintaining active operator licenses and to assess compliance with 10 CFR 55.53(e) and (f). The inspectors reviewed the procedural guidance and the process for tracking on-shift hours for licensed operators, and which control room positions were granted watch-standing credit for maintaining active operator licenses. Additionally, medical records for seven licensed operators were reviewed for compliance with 10 CFR 55.53(I). (02.08)Conformance with Simulator Requirements Specified in 10 CFR 55.46: The inspectors assessed the adequacy of the licensees simulation facility (simulator) for use in operator licensing examinations and for satisfying experience requirements. The inspectors reviewed a sample of simulator performance test records (e.g., transient tests, malfunction tests, scenario based tests, post-event tests, steady state tests, and core performance tests), simulator discrepancies, and the process for ensuring continued assurance of simulator fidelity in accordance with 10 CFR 55.46. The inspectors reviewed and evaluated the discrepancy corrective action process to ensure that simulator fidelity was being maintained. Open simulator discrepancies were reviewed for importance relative to the impact on 10 CFR 55.45 and 55.59 operator actions as well as on nuclear and thermal hydraulic operating characteristics. (02.09)Problem Identification and Resolution (10 CFR 55.59(c); SAT Element 5 as Defined in 10 CFR 55.4): The inspectors assessed the licensees ability to identify, evaluate, and resolve problems associated with licensed operator performance (a measure of the effectiveness of its LORT Program and their ability to implement appropriate corrective actions to maintain its LORT Program up to date). The inspectors reviewed documents related to licensed operator performance issues (e.g., licensee condition/problem identification reports including documentation of plant events and review of industry operating experience from previous 2 years). The inspectors also sampled the licensees quality assurance oversight activities, including licensee training department self-assessment reports. (02.10)This inspection constituted one Biennial LOR Program inspection sample as defined in IP 71111.1105.b. FindingsIntroduction: While performing an assessment of the licensees processes related to examination physical security and integrity (e.g. predictability and bias) to verify compliance with 10 CFR 55.49, Integrity of Examinations and Tests, the inspectors
10 identified that Quad Cities 2015 LOR written examinations were duplicated from the 2013 LOR examinations, that 2017 LOR written examinations were duplicated from the 2015 LOR examinations, and that four individuals were administered the same written examinations from the previous exam cycle.Description: The inspectors identified that, with few exceptions, the licensee had duplicated or reused questions from the 2015 written exam when they created the 2017 written exam. The licensee created six LOR written exam versions (i.e., AF), one for each crew. For the 2017 biennial exam, the licensee essentially swapped exam versions from 2015 that were given to each crew (i.e., the 2015 Version A was given to crew B in 2017 and Version B was given to crew A, etc.). The inspectors noted that no crew received the same exam version in 2017 as they did in 2015. However, due to crew personnel adjustments/realignments, the inspectors requested the licensee to investigate if, and how many, operators were going to receive the same exam in 2017 as in 2015. The licensee identified that one reactor operator had already taken the same exam in 2017 that they were given in 2015. In addition, the licensee also identified that two additional licensed operators were scheduled to take the same exam they had taken in 2015, but they had not yet been given the exam due to the exam schedule. After discussing the issue and concern with the inspectors, the licensee decided to administer those two individuals different exam versions to which they had not been previously exposed. In addition, the inspectors inquired how long the particular set of exam versions had been reused and swapped among the crews (i.e., before 2015). The licensee reviewed biennial written exams in 2013 and 2011 and determined the exam content was different and stated, there was no predictable pattern in exam versions. After reviewing all of the 2013 exam versions, the inspectors identified that three versions were a mixture of questions between reused and new questions. For example, 2013 Version A was a mixture of questions of 2015 exam Versions C and D and twounique questions. The 2013 Version B was a mixture of 2015 Version C and D and seven unique questions. The 2013 Version F was a mixture of 2015 D and F and fiveunique questions. The three remaining versions from 2013 were replicated in 2015, but given to different crews. The inspectors requested the licensee determine the number of personnel that took the same exam in 2015 as in 2013, and the licensee identified three individuals who were given the same exam in 2013 and 2015 (two senior reactor operators and one reactor operator). The inspectors are considering this issue to be an unresolved item (URI) concerning whether the repeated use of a biennial written examination for sequential requalification programs (consecutive 24 month periods), and the resulting predictability induced to the examination process, constitutes a violation of 10 CFR 55.49, Integrity of Examinations and Tests. The inspectors have requested the licensee provide the written examinations in question to the inspectors for further review. The inspectors will review individual questions of the written examinations in order to determine if there were sufficient differences between the examinations to characterize the examinations as either different or similar. The results of the review will be used to determine if a violation of 10 CFR 55.49 requirements exists. (URI 05000254/201700401; 05000265/201700401: Repeat Use of Written Exams during Licensed Operator Requalification Examinations) |
| Site: | Quad Cities  |
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| Report | IR 05000254/2017004 Section 1R11 |
| Date counted | Dec 31, 2017 (2017Q4) |
| Type: | URI: Green |
| cornerstone | Physical Protection |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.11 |
| Inspectors (proximate) | R Murray K Carrington J Beavers B Bergeon J Cassidy N Fields M Garza V Meghani K Walton |
| INPO aspect | |
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Finding - Quad Cities - IR 05000254/2017004 | |||||||||||||||||||||||||||||
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Finding List (Quad Cities) @ 2017Q4
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