ML18178A571

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IMC 0609 Appendix I Licensed Operator Requalification Significance Determination Process
ML18178A571
Person / Time
Issue date: 01/10/2019
From: Brian Tindell
NRC/NRR/DIRS/IOLB
To:
Tindell B 415-2026
Shared Package
ML18177A399, ML19009A075 List:
References
CN 19-001, DC 18-016
Download: ML18178A571 (9)
v • d • e


Text

NRC INSPECTION MANUAL IOLB INSPECTION MANUAL CHAPTER 0609 APPENDIX I LICENSED OPERATOR REQUALIFICATION SIGNIFICANCE DETERMINATION PROCESS Effective Date: 01/01/2019 0609I-01 PURPOSE The Licensed Operator Requalification Significance Determination Process (SDP) is used for determining the risk significance of findings identified during the inspection of licensed operator requalification activities and licensed operator performance.

0609I-02 BACKGROUND This SDP was designed to assess the risk significance of findings associated with Inspection Procedure 71111, Attachment 11 (IP 71111.11), Licensed Operator Requalification Program and Licensed Operator Performance in the following areas: (1) requalification examination results, (2) biennial requalification written examinations, (3) annual requalification operating tests, (4) administration of an annual requalification operating test, (5) requalification examination security, (6) remedial training and re-examinations, and (7) the control room simulator.

With regard to conformance with operator license conditions, such as the medical fitness of licensed operators and compliance with the regulations contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 55.53, it may be appropriate to use traditional enforcement to disposition violations. Inspectors should refer to guidance in Inspection Manual Chapter 0612, Issue Screening, and the Enforcement Manual.

0609I-03 GUIDANCE Figure I.1, a flowchart contained on the following pages, presents a series of yes/no decision blocks for assessing licensed operator requalification and licensed operator performance findings. Following the flowchart, a description of each flowchart block is presented.

Issue Date: 01/10/19 1 0609 Appendix I

Figure I.1 - Licensed Operator Requalification SDP Flowchart 1

Licensed Operator Requalification Finding 2 4 Related to NO Related to NO Biennial Requal. Go to A Requalification NO on page 3 Exam Results? Written Exam Quality?

YES YES 5

3 Were greater than Failure rate NO Green 40% of the NO Green greater than Finding reviewed written Finding 40%? examination questions flawed?

YES YES White Finding White Finding Issue Date: 01/10/19 2 0609 Appendix I

Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)

A from page 2 6 9 Related to NO Related to Licensee NO Go to B Annual Requal. NO Admin. of an Annual Operating Test Requal. Operating on page 4 Quality? Test?

YES YES Green Finding 7

Were greater YES than 40% of the White reviewed JPMs Finding flawed?

NO 8

Were greater than 40% of the YES White reviewed simulator Finding scenario events flawed?

NO Finding Green Finding Issue Date: 01/10/19 3 0609 Appendix I

Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)

B from page 3 10 12 Related to NO Related to NO Go to C Requalification NO Licensee on page Exam Security? Remedial Training 5 and Re-exams?

YES YES Green Finding 11 Was there an actual effect on the equitable NO and consistent Green administration of any Finding examination required by 10 CFR 55.59?

YES Evaluate using traditional enforcement against 10 CFR 55.49.

and evaluate using IMC 0609 Appendix M.

Issue Date: 01/10/19 4 0609 Appendix I

Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)

C from page 4 13 Related to Simulator Performance, NO 16 Testing, Re-evaluate the finding by Maintenance, or entering the SDP at block 1.

Modification?

YES 14 Was a simulator (Simulator testing, performance, NO Green maintenance, or Finding modeling, or modification deficiency) fidelity deficiency identified?

YES 15 Did deficient simulator performance, modeling, or fidelity negatively impact NO Green operator performance in an Finding actual plant event where the risk increase due to the operator performance was

>10E-6 delta CDF or >10E-7 delta LERF?

YES Reference appropriate SDP to determine significance of operator performance issues Issue Date: 01/10/19 5 0609 Appendix I

Flowchart Block Descriptions:

  1. 1 - The SDP starts after a single licensed operator requalification finding is identified from IP 71111.11 and screened through Manual Chapter 0612, Appendix B. Each specific finding must be evaluated separately.
  1. 2 - This is the top-level entry block associated with licensed operator performance as measured by the results of the requalification examinations required by 10 CFR 55.59(a)(2).

This block is answered yes or no based upon completing the specific guidance contained in Section 03.03 of IP 71111.11 and upon completing the screening of inspection issues in accordance with IMC 0612.

  1. 3 - Based upon the requalification examination results collected at the end of the testing cycle, was the failure rate greater than 40%? This block will be answered yes if either:

(a) The individual examination failure rate is greater than 40% (IP 71111.11, Line 4 of Table 03.03-1), or (b) The crew simulator scenario failure rate is greater than 40% (IP 71111.11, Line 7 of Table 03.03-1).

  1. 4 - This is the top-level entry block associated with the quality of biennial requalification written examinations that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in Section 03.04.a and Appendix B of IP 71111.11.
  1. 5 - Were greater than 40% of the reviewed written examination questions flawed? In answering this question, the inspector will need to review the results from section 03.04.a and Appendix B of IP 71111.11. If the answer to this block is yes, then a White finding results, based upon a higher percentage of flawed written examination questions used on a requalification examination required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a Green finding results, based upon a lower percentage of flawed questions or other written examination deficiency.
  1. 6 - This is the top-level entry block associated with the quality of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in Section 03.04.b and Appendix C of IP 71111.11.
  1. 7 - Were greater than 40% of the reviewed job performance measures (JPMs) flawed? In answering this question, the inspector will need to review the results from Section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a White finding results, based upon a higher percentage of flawed JPMs used on a requalification examination required by 10 CFR 55.59(a)(2).
  1. 8 - Were greater than 40% of the reviewed simulator scenario events flawed? In answering this question, the inspector will need to review the results from Section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a White finding results, based upon a higher percentage of flawed simulator scenario events used on a requalification examination required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a Green finding results, Issue Date: 01/10/19 6 0609 Appendix I

based upon a lower percentage of flawed simulator scenario events and JPMs (checked in block 7 above), or based upon some other operating test deficiency.

  1. 9 - This is the top-level entry block associated with the licensees administration of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in Section 03.04.c and Appendix D of IP 71111.11.
  1. 10 - This is the top-level entry block associated with requalification examination security. This block is answered yes or no based upon completing the specific guidance contained in Section 03.04.d and Appendix E of IP 71111.11.
  1. 11 - Was there an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59? In these instances, a licensed operator has gained an unfair advantage on an examination required by 10 CFR 55.59, and this condition was not corrected prior to being authorized to resume licensed duties. These occurrences can be willful or intentional (cheating) or unintentional. Examples of gaining an unfair advantage on an examination include: (1) a licensed operator obtains unauthorized assistance during an examination, such as by receiving assistance on a test item during an examination from an unauthorized individual or by copying answers from another examinee; (2) a licensed operator obtains specific knowledge of or is exposed to requalification examination content prior to taking the requalification examination; (3) a licensed operator is used to validate requalification examination test items during exam development, and is then subsequently administered a requalification examination with any test items duplicated from those that the operator previously validated. IMC 0609, Appendix M should be used to evaluate the significance of these types of inspection findings. Note that the traditional enforcement process may also be used for violations of 10 CFR 55.59 (e.g., in cases where the violation involves willfulness or impacts the NRCs ability to perform its regulatory function). Refer to IMC 0612 and the Enforcement Manual for guidance on dispositioning traditional enforcement violations.
  1. 12 - This is the top-level entry block associated with remedial training and re-examinations, which occurs whenever a licensed operator fails any portion of a requalification examination required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in Section 03.04.e and Appendix F of IP 71111.11.
  1. 13 - This is the top-level entry block associated with control room simulator performance, maintenance, and testing, as specified in 10 CFR 55.46. This block is answered yes or no based upon completing the specific guidance contained in Section 03.04.g and Appendix G of IP 71111.11.
  1. 14 - Was a simulator performance, modeling, or fidelity deficiency identified? This block is used to differentiate between deficiencies associated with simulator performance (including deficiencies with modeling or fidelity) and deficiencies associated with simulator testing, maintenance, and modification. These issues are treated slightly differently in the SDP, due to the potential for unrealistic operator training due to deficient simulator performance. If this block is answered no, the deficiency is associated with simulator testing, maintenance, or modification (as verified in the next block), and results in a Green finding. If this block is answered yes, proceed to block 15.
  1. 15 - Did deficient simulator performance, modeling, or fidelity negatively impact operator performance in the actual plant during a plant event? The concern with this block is that the Issue Date: 01/10/19 7 0609 Appendix I

simulator provided un-realistic or negative training to licensed operators (due to deficiencies in simulator performance, modeling, or fidelity), and that this un-realistic simulator training was the primary cause of negatively impacted operator performance during an event. Reference appropriate SDP guidance (At-Power, Shutdown, or others) to determine if the negative operator performance resulted in a risk increase of greater than 10E-6 delta CDF or greater than 10E-7 delta LERF. Qualitative SDP results may also be used to determine if the risk increase is greater-than-Green. If the answer to this block is yes, then this results in a finding with significance commensurate with the risk increase due to the negative operator performance, based upon the appropriate SDP guidance. If the answer to this block is no, then this results in a Green finding, since deficient simulator performance was still identified.

  1. 16 - Re-evaluate the finding by entering the SDP at block 1. The SDP is arranged as a series of top-level entry blocks, and block 16 should not occur unless all the entry blocks have been answered no. If this is the case, re-evaluate the finding and enter the SDP at block 1, or consult with the program office for guidance.

0609I-04 REFERENCES

1. IP 71111, Attachment 11, Licensed Operator Requalification Program and Licensed Operator Performance
2. IMC 0612, Appendix B, Issue Screening
3. NRC Enforcement Manual
4. IMC 0609, Appendix M, Significance Determination Process Using Qualitative Criteria Issue Date: 01/10/19 8 0609 Appendix I

ATTACHMENT 1 - Revision History - IMC 0609, Appendix I Commitment Accession Description of Change Description of Training Comment Resolution Tracking Number Required and and Closed Number Issue Date Completion Date Feedback Form Change Notice Accession Numbers (Pre-Decisional, Non-Public Information)

N/A ML021060448 Revised the description of the flow chart None N/A 03/27/2002 blocks to: 1) incorporate the first years CN 02-011 lessons learned, 2) reflect the change to 10 CFR 55.46 (Simulator Rule), and 3) align with 10 CFR 55.49 (integrity of examinations and tests).

N/A ML0524300990 Revised to match current revision to IP None N/A 8/22/2005 71111.11 (Operator Requalification) and to fix CN 05-023 several flaws that have been identified and will enhance the flowchart and matrix.

N/A ML113270313 Complete re-write of document. Arranged Training held by ML113250576 12/06/11 flowchart to mirror inspection areas of revised teleconference with CN 11-040 IP 71111.11, removed all minor finding blocks Regional examiners on (minor findings should be screened out prior to 11/30/11 reaching the SDP), and simplified examination results logic.

N/A ML18178A571x Reformatted and streamlined to reflect revision None ML18177A421 01/10/19 to IMC0040. Added guidance to refer to IMC CN 19-001 0609 Appendix M in certain instances. Tied Closed FF:

White finding for simulators to the delta CDF 0609I-2232 and delta LERF of the negative operator ML18178A225 performance. Added reference list. 0609I-2160 ML18178A232 0609I-2309 ML18178A260 Issue Date: 01/10/19 Att1-1 0609 Appendix I

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