The inspectors identified a finding, associated with simulator operability testing, for the failure of the licensee to track and incorporate actual plant data into their cyclic operability tests, as required by American National Standards Institute-3.5-2009, Nuclear Power Plant Simulators for Use in Operator Training and Examination. With the exception of one
transient, the licensee exclusively used engineering analysis from the RETRAN code as baseline data without reference to plant events that may have been related to the required
transient tests. This issue was entered into the licensees corrective action program as Condition Report 15-21463. The failure to track and incorporate plant events into baseline data for simulator operability testing is a performance deficiency. It is more than minor and, therefore, a finding because it is associated with the human performance attribute of the
Mitigating Systems Cornerstone and negatively affected the objective to ensure the reliability and capability of systems that respond to
initiating events to prevent undesirable consequences. Specifically, if simulator performance is not being compared to the most relevant baseline data from the plant, the reliability of the simulator performance is reduced. Using
Inspection Manual Chapter 0609,
Significance Determination Process, Phase 1 worksheets, and the corresponding Appendix I, Licensed Operator Requalification
SDP (block 14), the finding was determined to have very low safety significance (Green) because it is a Simulator testing, maintenance, or modification deficiency. This finding has a cross-cutting aspect in the procedure adherence component of the human performance cross-cutting area because the licensee failed to ensure that individuals follow processes, procedures, and work instructions in that the American National Standards Institute-3.5-2009 guidance for selecting baseline data for simulator testing was not followed.