Information Notice 1998-15, Integrity of Operator Licensing Examinations

Integrity of Operator Licensing Examinations
	ML031050181
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	04/20/1998
From:	Roe J; Office of Nuclear Reactor Regulation
To:	;
References
	IN-98-015, NUDOCS 9804150189
	Download: ML031050181 (9)
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UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 April20, 1998 NRC INFORMATION NOTICE 98-15: INTEGRITY OF OPERATOR LICENSING

EXAMINATIONS

Addressees

All holders of operating licenses for power reactors except those licensees that have

permanently ceased operations and have certified that the fuel has been permanently removed

from the reactor vessel.

purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to advise

addressees of several instances of potential compromise of the integrity of operator licensing

examinations. It is expected that recipients and individuals with responsibility for development

of initial operator licensing examinations will review the information for applicability to their

facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions

contained in this information notice are not NRC requirements; therefore, no specific action or

written response is required.

Description of Circumstances

Conditions of potential compromise of the integrity of operator licensing examinations requiring

compensatory action on the part of both facility licensees and the NRC have been identified in

all NRC regions:

1. On-Site Custody Control of Examination Materials

a. During preparation for initial operator licensing examinations, after NRC examiners had

complete1 final onsite preparations and examination validation, several pages of a written

examination were found the following Monday in the duplex tray of a photocopier by the

plant clerical staff. The examination was canceled.

b. A job performance measure (JPM) script for a scheduled operating test was inadvertently

printed on a facility local area network printer outside the designated examination

preparation area. At the same facility, the custodial staff found the examination

development area unlocked. The examination was in a locked file cabinet in the room, but

the key to the file cabinet was accessible. Tile subject JPM was replaced, and the

examination was delayed until the facility could develop another examination using the

63 same sample plan.

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IN 98-15

April 20, 1998 2. Control of Physical Access to the Examination Area

a. An instructor who was not included in the existing examination security agreement entered

the simulator while examination scenarios were being validated, even though the doors

were locked and a sign was posted stating NNRC exam in progress. Absolutely no

admittance by unauthorized individuals." The instructor was in the simulator control booth, preparing for a future lesson, for approximately 5 minutes before he was noticed and asked

to leave. The scenario was deleted from the examination and was replaced with an

alternate scenario.

b. During an examination, two license applicants, who were sequestered while waiting to be

called into the simulator, began questioning the proctor about what scenario might likely be

included in their examinations. The proctor, being careful not to confirm any part of the

examination, responded in a negative manner to prompts regarding a specific scenario. By

excluding a familiar and expected scenario from the limited set of validated scenarios, the

applicants could possibly anticipate the diagnostic competencies that they would be

required to demonstrate during the examination. The scenario set that had previously been

validated for that examination was replaced.

3. Off-Site Custody Control of Examination Materials

a. Two examinations, one an NRC license examination and the other an audit examination at

a different facility, were found to be based on identical sample plans and to contain a high

percentage of identical test items. The examinations had been developed by the same

author. The examination similarities were discovered because a reciprocal agreement

existed between the facilities' training departments. New scenarios and test items were

substituted for those that were determined to be potentially compromised.

b. A facility licensee reported to an NRC regional office that examination test items for a

different facility in another NRC region had been discovered in its facsimile equipment by

the clerical staff. It was subsequently determined that a scheduled licensing examination

was being developed by a team of contractors located at three separate facility licensee

sites.

Discussion X

Under the pilot program described in NRC Generic Letter 95-06, 'Changes in the Operator

Licensing Program," and its Supplement, and in anticipation of a rule change to 10 CFR

Part 55, some power reactor facility licensees have undertaken a larger and more active role in

the process of developing examinations through planning, drafting, and validation of

examinations and test items. However, the more active role also increases the availability of

and access to detailed examination materials. These factors, combined with the longer period

of exposure to examination planning and test items, introduce a concomitant increased

vulnerability to inadvertent or deliberate compromise of the process, resulting in potential

challenges to the integrity of the examination.

IN 9-15 April 20, 1998 NUREG-1021, Rev. 8, "Operator Licensing Examination Standards for Power Reactors,"

Section ES-201, 3initial Operator Licensing Examination Process," outlines examination

security considerations that facility licensees may use to form the basis for an effective security

policy with associated administrative procedures for facility examinations. ES-201 provides for

facility licensee personnel and contractors working on the facility licensee's behalf to participate

in the process for developing examinations and to have prior detailed knowledge of examination

content through a security agreement. Each facility licensee employee and contractor with

access to the examination development process becomes party to that agreement. Under the

security agreement (Form ES-201-3, uExamination Security Agreement") no part of the

examination is to be divulged to anyone who has not been authorized by the NRC chief

examiner. The examination security agreement also describes possible consequences of

violations, with which the NRC staff has dealt by replacing the materials that may have been

compromised, delaying or canceling scheduled examinations, and taking enforcement action

against the individual or the facility licensee when appropriate. These actions are based on the

requirements of 10 CFR 55.49, which state that applicants, licensees, and facility licensees

shall not engage in any activity that compromises the integrity of any test or examination. As

noted in the Federal Register (62FR42426) publication of the proposed rule change, the NRC

considers that a violation of 10 CFR 55.49 has occurred when 0(1) a failure to control the

integrity of an examination occurs such that there is a potential for an applicant to have an

unauthorized advantage in the examination process or (2) an applicant obtains an unauthorized

advantage.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact any of the technical contacts listed

below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

k JackW. ing Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contacts: F. Collins, NRR R. Conte, RI T. Peebles, Ril

301415-3173 610-337-5183 404-562-4638 E-Mail: jfcl@nrc.gov E-Mail: tjc@nrc.gov E-Mail: tap@nrc.gov

Melvyn Leach, Rill John Pellet, RIV

630-829-9705 817-860-8159 E-Mail: mnl@nrc.gov E-Mail: jlpenrc.gov

Attachment: List of Recently Issued NRC Information Notices 4 o +-

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Attachment

IN 98-15 April 20, 1998 Page 1 of I

LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

98-14 Undocumented Changes to 4/20/98 All holders of operating licenses

Non-Power Reactor Safety or construction permits for test

System Wiring research reactors

98-13 Post-Refueling Outage Reactor 4/20/98 All holders of operating licenses

Pressure Vessel Leak Testing for nuclear power reactors except

Before Core Criticality those that have permanently

ceased operations and have

certified that fuel has been

permanently removed from the

reactor vessel

98-12 Licensees' Responsibilities 4/3/98 All U.S. Nuclear Regulatory

Regarding Reporting and Follow-up Commission nuclear pacemaker

Requirements for Nuclear-Powered licensees

Pacemakers

98-11 Cracking of Reactor Vessel 3/25/98 All holders of operating licensing

Internal Baffle Former Bolts for pressurized-water reactors

in Foreign Plants (PWRs) except those who have

ceased operation and have

certified that fuel has been

permanently removed from the

reactor vessel.

95-52, Supp.1. Fire Endurance Test Results 3/17/98 All holders of operating

for Electrical Raceway Fire licenses for nuclear power

Barrier Systems Constructed reactors except those who

From 3M Company Interam have permanently ceased

Fire Barrier Materials operation and have certified that

fuel has been permanently

removed from the reactor vessel.

OL = Operating License

CP = Construction Permit

IN 98-15 April 20, 1998

,c NUREG-1021, Rev. 8, Operator Licensing Examination Standards for Power Reactors,"