ML20147J339

Staff Exhibit S-3,consisting of Forwarding Joint Affidavit of Bs Norris & DM Silk Re Senior Operator License Exam,In Response to 871124 Memorandum & Order,As Clarified by 871217 Memorandum & Order

ML20147J339
Person / Time
Site:	05560755
Issue date:	02/21/1988
From:	Woodhead C NRC OFFICE OF THE GENERAL COUNSEL (OGC)
To:	Atomic Safety and Licensing Board Panel
References
SP-S-003, SP-S-3, NUDOCS 8803100088
Download: ML20147J339 (33)

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. Charles Bechhoefer, Esq. ?RAllCH Administrative Judge Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 in the Matter of ALFRED J. MORABITO (Senior Operator License for Beaver Valley Nuclear Power Station, Unit 1)

Docket No. 55-60755

Dear Judge Rechhoefer:

I am forwarding to you, Mr. Morabito and Dr. Hetrick copies of the

( "Joint Affidavit of Barry S. Norris and David M. Silk" in response to the

questions attached to ye Memorandum and Order dated November 24, 1987, as clarified by your Memorandum and Order dated December 17, 1987.

Sincerely, Colleen P. Woodhead Counsel for NRC Staff

Enclosure:

As stated cc w/ encl.: . r Morabito V

Dr. Hetrick cc w/o encl.: Rest of Service List fy O/h 3 gm eA O

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LNiTED STATES OF M. ERICA M)CLF>R REGJLATmY CDMISSKN BEKFE THE ADA!NISTRATIVE JLOG In the matter of )

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ALFRED ). MJPN317D ) Docket No. 55-60755

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(Senior Operator License for )

Beaver Valley Nuclear Power )

Station, Unit-1) )

JOINT AFFIDAVIT OF P/PFY S. POPPis AT DAVID M. Sil.X Rarry S. Norris and David M. Silk do depose and say:

1. I, Barry S. Norris, am a Senior Operations Engineer (Exaniner/ Inspector) in the Pressurized Water Reactor Section, Cperations Branch, Division of Reactor Safety at the lhlted States ibciear Regulatory Cmmission, Region i

1. At the timp of the examination of Alfred J. Morabito, ny position was Reactor Ercineer (Examiner) within Section 1C of the Division of Reactor Prejects. M/ responsibilitles relatIvc to that examinatlor vere as the certified examiner observing David M. Slik's adninist rat ion of the sirulator and oral examinations. I err.isted in proctoring the written exanination and I was responsible for the quality assurance review of the grading of that examinaticn. See attactment to the Joint Affidavit of Barry S. Norris and David M. Silk (Af fidavit), dated October 9,1987, for ny professional cualifications.

2. I, David M. Silk, am an Operations Engineer (Fxaminer/ Inspector) in the Pressurized Water Reactor Section, Operations Bra'nch, Division of Reactor O s f*tY t the united States Nuclear Regulatory Conmission, 'Pegl'on 1. At

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the time of the examination of Al fred J. Abrabi to, ny position was Peactor Engineer (Examiner) within Section 1C of the Division of Reactor Projects. My responsibilities relative to that examination were that I prepared, echlini s tered, and graded the written examinatlon; and .I ach;inistered the oral and sinulator e><aminations under the observation of Barry S. Morris. See attachnent to the Af fidavi t dated October 9,1987, for ny professional qualifications.

3. The following is sutmitted in response to the quest iens posed by Judge Bechhoefer in the Merorandtm and Order (Need for Further infonmtion and Pequirement for Oral Presentatlon) dated Noverrber 24, 1987, as anended by the f.'arorar.dte and Order (Ruling er Motion for P.econsiderat ion) dated Decent >c r 17, 1987. All answers provided v.hich concern operator licensing procedures refer to those procadures in effect in July,1986 (that is, htREC-1021, .tevision 2) .

4. Written Excmination Question 6.03h Judge Bechhoefer's Quest ion A.1.a:

This (examination) question asked for three design features of the conperent cooling water systmi which minimize the effects of a rupture of the PfP thenml barrier. Che of Mr. f.brabito's answers which was judged incorrect was "Ability to manually isolate the thermal barriers." The Staff explains (Af fidavi t Idated October 9, 1987), i 10) that "[a]

containrent entry, which is a lengthy and involved process, would be required to isolate the carponent and would not provide inmedia te reduction in the severity of the rupture" (erphasis added). The Staff goes on to state (Affidavit [ dated October 9, 1987), i 11) that isolation valves are "normally designed to allow maintenance * *

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(O not to minimize the effects of a corrponent fai lure" (eriphasis added).

(1) In view of the fact that the question mcde no reference to the timing of the minimization of the effects of a rupture and no reference to any "nonval" design feature to accceplish that purpose, is not Mr. Abrabito's ansver technically correct? (2) in any event, does not the arrbiguous scope of the question as described herein warrant the deletion of question 6.03h?

5. Staff Response:

(1) What the Staf f stated (Affidavit dated October 9, 1987, if 10 and

11) v.as that manual isolation valves are not normally used for minir11 zing the ef fects of a failure. The literature proviaed by the facility for preparation of the written examination did not Indicate that the manual isolation valves were a deslG n feature for minimizing the effects of a failure of the RCP therma l barrier. Mr. Morabito's answer did not describe a design feature for minimizing the effects of a thenrol barrier failure, but rather a sysicm ccnponent used during maintenance. (2) With respect to the question of anbiguity, a reviev of the answers provided by the other three SRO cendidates who took this excmination revealed no irdication that the question was artbiguous or vacue. The Staff believes that there is no basis for deletion of this cuestion, it should be noted that the training department of Beaver Valley Unit-1 reviewed the examination cuestion and answer key. No ccaments were surriitted by the factiity for cuestion 6.03.b for eIther the wording of the question or the technical accuracy. l

6. Judce Bechhoefer's Question A.1.b: l 0 l n, , , , , . . , _ -

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.. 4-d in F.n examination question of this type (requesting a specified rut >er of enswers), has the Staff invariably used the method of grading described in i 15 of its Af fidavit [ dated October 9, 1987]? (The staf f _ should e> plain what is rneant by the word "routinely" set forth in i 15, line 9, of its Aff! davit [ dated October 9,1987).)

7. Sta f f Pospense:

Many rmthods are available for grading questions of this type. It is our opinicn that the trethod used (giving credi t for the nttrber of correct answers as a percentaae of the total ruber of answers provided) is the most accurate neasure of the candidate's true knowledge. By ignoring incorrect answers, the candidate would be allowed to provide as nuch information as possible with the hope that scme of the answers would be correct. As used in the Af fidavit dated October 9, 1987, (1 15), the word "routinely" is referring to the method most o f ten used by experienced examiners, in addition, the NRC Technical Training Center, in Gattanooaa, has used this rrethod for many years ard has incorporated it into cr. Irstruction.

8. Judge Bechhoefer's Ouestion A.1.c:

Were candidates advised not to supply more than the requested ntnber of znswers to questions such as question 6.03b?

9. Staff Response:

The candidates were not speci fically advised, by the mC examiners, not to provide trore than the requested ntrrber of answers. Vhether or not the faciIity provid,e.d guidance to the candidates is not kncvn by the Staf f.  ;

10. Judge Bechhoefer's Ouestion A.1.d:

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(1) Were candidates advised of penalties (either discretionary or mandatory) for a wrong answer accmpanied by a sufficient nmber of correct answers? (2) Were they infonned, prior to or at the time of the wri t ter examina t ion, of the method of grading which the Staf f is now utilizing -- i.e., that they would be given credit only for the percentage of correct / incorrect answers where rure than three answers v.nre supplied (Staff Af fidavit [ dated October 9,1987], f 15)?

11. Staf f Response:

(1) We examiners did not discuss with the candidates how each type of cuest icn v.ould be graded. The candidates should have been infonTed by ,

the facility training staf f as to how a wrong answer rry be graded. (2)

Again. the FFC examiners did not infonn the candidates of the method of 9radiro to be used.

12. Judne Bechhoe fer's Quest ion A.1.d(i): 4 l

1f so, why was Mr. Abrabito initially given 1/3 credit (0.5 points) when '

only one of the four answers supplied was considered correct? If the Staff were utilizire the grading method described in i 15 of its Affidavit, should not Mr. Abrabito initlaily have been given only 1/4 credit (0.375 points)? ,

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13. Sta ff Response:

As discussed in f 7, many methods are avaliable to be used for grading questions of this type. The method used by Mr. Silk when initially grading the examination was to give credit for correct answers only.

Curing a regrade, the Headquarters Staff used the method of correct 4

answers as a percentage of total enswers supplied.

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v i 14. Judge Bechhoefer's Question A.1.d(li):

I f Mr. Vorabi to was not infonred of the grading system, should he not elther be given credit for at least 2 correct answers out of 3 (1.0 points) or, alternatively, should not the question have been deleted?

15. Staf f Response:

Incorrect answers derronstrate deficient knowledge Just as correct answers derronstrate adequate knowledge. Both correct and incorrect answers are s igni ficant , in our opinion, to give Mr. Abrabito credit for two correct answers without penalizing him for two incorrect answers would not account for the lack of knowledge indicated by the two incorrect answers.

The m C licensing process seeks to examine the candidate's knowledge and abiiity to cope with the dutles and responsibilitles associated with the O iiceese. w see no reesom to deiete the question. nor do we beiieve it is necessary to discuss the Staff'r grading methods in advance.

16. Written Examination Question 6.06a Judge Bechhoefer's Question A.2.a:

Does the phrase "cold solid plant operations" in examination question 6.00a refer only to standby conditions, or could it refer to a stage during plant startup?

17. Staff Response:

The operational modes of the plant are listed in the Beaver Valley thit-1 Technical Speci fications, Table 1.1. Abde 6 is "coid shutdown" and is defined as (1) the reactor is shutdown and (2) the average tarperature of the reactor coolant systcm (RCS) is less than or equal to 200 F. The phrase "cold jolid plant operations" is a description of a specific set O- of conditions of cold shutdown in addition to the pressurizer being fuil

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18. Judae Bcchhoefer's Guestion A.2.b:

is the overpressure protection syst m ever used "during cold solid plant operations"? I f so. explain.

19. Stef f Response:

Yes, the Overpressure Protection systern is required to be operable per Technical Speci fications. 7he power operated relief valves (PCVW's) are part of the system, and the setroint on the RDRV's is reduced when the pressure in the RG is less than a certain value. thever , the IUN's P

b should not be open unless en overpressure condition existed in the RG.

20. Written Exrmination Question 6.06b Judoe Bechhoefer's Question A.3:

Asstmlng that some points sFeuid have been deducted for Mr. Abrabito's acknowledged ilstinC of an incorrect setpoint, would not a deduction of 0.1 points (rather than 0.2 points) have oeen rnre appropriate, given the nature ar<' signi ficance of the mistake? Please explain.

21. Staff Response:

The examiner who did the regrade of Mr. Abrabito's examination decided that a description of each of the interlocks would be worth 0.3 points and that the setpoint for each interlock would be worth 0.2 points. The only guidance given by NJPEG-1021 (ES-109) i s , that the assigrment of partial credit nust be consistent for all candidates takirg that examination. As discussed in the Af fidavi t dated October 9, 1987, (i

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22), the significance of knowing the correct setpoint is Inportant to ensurire proper operation of the interlock.

22. Written Examination Question 6.07a Judoe Bechhoefer's Questlon A.4:

Mr. f.brabito stated that the steam generator code safety valves provide the "first" means of protection for Tavg increases. The Sta f f suggests another "normal fi rst response." The Staff also indicates that the steam centrator safety valves previde a "secondary or tertiary protection for T average in a limited rarse of pcmer levels." Because the question asked for the irrpor tance of steam generator code safety valves, without specifyirg whether primary, secondary or tertiary protection was sought, shculd not Mr. Vorabito have been given at least partial credit for his A

V answer?

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23. Staf f Response:

This question was answered in ti 19-24 of our Af fidavi t dated Dececher 21, 1987. Sirrply put, Mr. Abrabito's answer is ircorrect and we have no basis to award par t ia l credit. We believe the question is clear and unantiguous and that the correct answer wuld be obvious to a candidate who unde rs tands , and i s fami l i a r wi th , the plant design and operation.

24. Wr!tten Examination Ouestion 6.07b Jtdie Bechhoefer's Ques tion A.S.a:

What is the purpose of the parenthetical phrase "(NOT Rf0ITIOS)" in the exanination cuestion 6.07b?

25. Staf f P.esponse:

'lhe parenthetical phrase was intended as a clarification to the question; O l.e., to guide the candidate in the right direction. It was meant to

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f distinguish between "Reason" (de fined as a statement offered in explanation or just i ficat ion) and "Condition" (defined as something essential to the appearance or occurrence of something else).

(Webster's Ninth New Colleolate Dictionary, copyright 1985 by Abrriart-Webster Inc.)

26. Judoe Bechhoe fer's Quest ion A.5.b The question asks for tv.o reasons v.hy the A61V's are required to close during a main steam line rupture. Mr. Abrabito's references to pages 10.3-2 and 10.3-5 of the FSAR appear to provide di f ferent reasons why the ASIV shuts -- i.e., as the primary isolator of a leak or as the backup to a non-return valve. Was not Region I correct in stating that the "facility literature provides many varied reasons for closing the ASIVs" and thus that "there is no definitive answer to the question" and that the cuestion should be deleted (letter dated Noverber 12, 1986 to AV.

Abrabito, At tachrent 1)?

27. Sta f f Response:

The reasons (see i 25 for de fini t ion) that the steam generator is isolated (ASIV's shut) during a steam line rupture are correct as listed in the original answer key. Vhat Mr. Abrabito provided in his answer was essentially a restatsmnt of the question. The purpose of the A51V's, as designed and installed, is to isolate the steam generator during verlous normaI and energency conditions; one of the conditions is a steam iIne rupture. Upon initial grading, Mr. Abrabito was given no credit for his answer. A regional regrade resulted in the question being deleted. AV.

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'l reinstated. Headquarters personnel reviewed the examination, reinstated quest ion 6.07.b, and awarded ha l f credi t based on the two statments being essentially repetitive. The Staff believes that there is no basis for deletirt the question based on the above infonratlon.

28. Sinulator Examination, General Questions Judge Bechhoefer's Ouestion B.1.a.(i):

Yhich, if any, of the four' rat Ings of U [unsat is factory] in this examination would be considered adequate for failure of the examination in the event that it becme the only conpetency so rated?

29. Staf f Response:

In the case of Mr. P.brabito, any one of the four conpetencies evaluated as unsatisfactory was signi ficant enough, by itself, to warrant an overall failure of the sirrula tor examination. In each conpetency, Mr. 7/crabito's actions ard statments denonstrated an overall lack of understanding, kncwiedge, and skills necessary for an SRO license.

30. Judge Bechhoefer's Question B.1.a. (l l):

May a candidate pass the examination with rating of U in two of the eight cor:retencies?

31. Staff Pesponse:

Yes. The Examiner's Standards do not addrcss the maxirur nurber of cccpetencies that may be rated as unsatisfactory before it is recuired that the candidate fall the sinulator exanina t ion. The Examiner's i Standards do state that an unsatisfactory rating in even one conpetency may be basis ,for an overall failure of the sinulator examination (htFIG-1021, ES-302, It o f F.3).

is our understanding that unsatisfactory rotirs in two or trore cmpetencies would generally result an i

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32. Jtd;c Dechhoefer's Ouestion B.1.b:

Hcw did the Staf f devetop the overalI ratirg for AV. Abrabito?

33. Staf f Pesponse:

In the case of A'r. Vorabito, the overall rating of failure was based on the fact that four of the eight ccrpetencies (50%) were determined to be urs a t i s fac tory. The overa l l rating was determined af ter each of the l

cight corrpet encies had been evaluated. The rre thod for grading of i s irrula tor exarr.ina t ions is detailed in RREG-1021, ES-302, section F.

34. Judge Pechhoefer's Quest ion B.1.c:

Y!as any a t t(rpt made at quantitative evaluation of perfonT.nce? For exartple , one could count the ntrber of inproper decisions, weigh them according to the degree of undesirable cr.nsequences, and ccrpare with the ntnt>cr of correct decisions.

35. Staf f Pesponse:

No attenpt was made to quanti fy the exarr.ination results. The sirmlator e.vmirst',on is, by design and necessity, not a quantitative exanination.

RFEG-1021, FS-303, T B, states, in part: "The examiner i s ul t ima t e ly responsible for makirg a professional, subjective judgerent on whether a candidate should pass or fall this segrrent of the examination. The forms pertaining to the oral examination should only be used as an aid to the examiner in conducting the examination and as a treans of doctnenting the

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( 36. Judge Bechhoefer's Question B.1.d:

Is it appropriate for a single observation or comrent by an examiner to be used as a basis for a "U" rating in more than o.ie conpetency? I f so, what effect would such nultiple use of a single observation or ccmnent have en a candidate's overall rating?

37. Staff Response:

The cmpetencies are not rmtually exclusive; therefore, a sirgie action or sta tment by a candidate could reflect a lack of understanding or abi!Ity in two or more of the cmpetencies. If the candidate's action or statement is signi ficant er.ough , it may even be apprcpriate for that sirgle cction or statement to be the basis for failure of the entire s frulater examinatlon.

36. Judge Bechhnefer's Oues t ion 0.1.e:

f The candidate's Specification of Claims includes eight I tcms which address ei ther ES-301 or ES-305 of the examination report. Only cne of these itms (5.2.A on page 6 of ES-305) is related to cmments in the s irrula tor examination stirmary sheet (ES-302-11 and at tactments).

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. Staff response addresses the candidate's claims concerning ES-302-11, includir9 the subject matter of 5.2.A, but does not address the other seven c l a ire.s . [ Spec i fical ly, cmments 2.5.H (ES-301, p 5), 5.1.C (ES-305, p 6), 2.5.E (ES-305, p 8), 7.1 (ES-305, p 8), 6.A.7 (ES-305, p 10a), 8.8.4 (ES-305, p 10a), and 8.C.2 (ES-305, p 10a)) (i) Mhat is the relevance of the eight ccrrpetencies in ES-301 and ES-305 (other than 5.2.A) to the sirrulator exWr.atio77 (i i) that is the significance of the' circled letters A crd E in tt$e coltam headings of ES-305, page 67 O

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39. Staff Response:

(i) tLFEG-1021, ES-303, section 2, details the minintm ruber of Control Rocm systems that trust be discussed during the oral examination. It also allov.T the examiner to reduce the ruther of systems to be covered during the oral examination if a sirrulator examination is given in conjunction with the oral examination. The Staf f doctmented the results of the systms covered during the sirrulator enmination on the same fom as the systcrs covered during the oral examination. Chly one of the above eight itens cited by Mr. Morabito in his Specification of Claims Report was related to the sirulator exmination, the other seven were to doctment deficiencies noted during the oral extrnina t ion. Since Mr. Merabito passed the oral ex mination, the Staf f did not address the ccriments O pertaining only to the oral extrnina t ion. Bis was explained in the Staf f Pesponse to the Specification of Claims dated October 9,1987, on pages 3 and 4. (ii) On pegc. 4 of the Exaralnation Report, letters A, D and G are circled; a note at the botten of the page explains that those coltarns were covered during the s inulator examination, he circled letters A ard E on page 6 of the D: amination Report also indicate which of the r.ystems were covered during the sinulator enmination.

40. Judge Bechhoe'er's Question B.1.f:

Were the procedures of M.FEG-1021 (Rev. 2), ES-301, E fol lowed wi th respect to the orientation of the examiners who actnini stered Mr.

Morabito's sinulator examinatlon? Provide details.

41. Staff Pesponse: ,,

Yes. Both examiners in question had been at Beaver Valley Milt-1 during the examinations which took place in February, 1986 (Mr. Morabito's  ;

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I sinulator examination was achiinistered on July 23, 1986). Mr, Norris achtinistered sinulator exaninations during the February,1986 trip; and prior to that examination, Mr. Norris had made a trip to the_ site in January,1986, specifically for a famliiarization with the Beaver Valley s inula tor. Mr. Silk vos an observer during the February, 1986 exarnina t i on. Mdi t ional ly, the day before the sirrulator examinations started (Tuesday, July 22, 1986) 7.b s s rs . Silk and Norris spent the af terr.ccr conducting plant and sinulator familiarization.

42. Sinuf ator Examhation, Ccopliance/Use of Procedures ExarrIner's Crmnent 1 Judge Bechhoe fe r 's Oue s t i on R. 2. a f i ) :

Mhy were two prv.er range instrtirents giving indications di f ferent from the other tvo?

43. Staf f P.esponse:

The examiners do not krcw why the power range instrtsrents were not consistent, it was not part of the planned scenario. Various sinulated plant conditions could have caused the phencrrenon, or it could have been a sinulator mai functlon.

44. Juckie Bechhoefer's Quest lon R.2.a(li):

is a procedure required for every smalI pov.er reduct lon, rmardless of the reascr?

45. Staf f Response:

No. Initial re ference to a procedure might not be necessary in an errergency situation where the operators are expected to take Imrediate actions, as necessary, to protect the plant from exceedino any safety limits. Hcn. eve r , the examiner's ctrment relates to the fact that no

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. ( procedure was re ferenced when the power range instrtments were inconsistent. Mr. Abrabito should have referenced the abnormal procedure for mal functioning nuclear instrtrwntation until such time as he could prove that all instrtsrents were operating properly.

46. Judge Bechhoefer's Question B.2 ,(ill):

that is a surveillance - cedure (Staf f af fidavit [ dated October s 9, 1987], page 14, f 41)?

47. Staf f Pesponse:

A surveillance procedure is a procedure, approved for use by station personnel, to veri fy that the operability of conpenents and systems is maintaired, that facility operation wliI be within the safetv iimits, and that the Iimiting conditions for operations wliI be tret.

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( 48. Judge Bechhoefer'r. Quest ion D.2.a f iv):

Ybat is the meaning of the phrase "bel ieve a l l irdications" in Staff a f fidavi t [ dated October 9, 1987), page 14, T 41, in the event of inconsistent Indicatlens?

49. Staf f Response:

As stated in the Af fidavi t dated October 9, 1987, believing all indications is a basic tenet of safe nuclear power plant operations. If redundant indications are not consistent, then an operator nust deterTnine vhich of the indications, if any, are not correct. In the case of the two pover ranges belro di fferent from the other tvm pover ranges, this condition could exist in the reactor if the neutron flux was not evenly distributed throughout the core.

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50. Judge Eechhoefer's Question B.2.a(v):

Would this ccmrent by itself Justify a grade of U for this cmpetency?

51. Staff Response:

Fo. This comrent by i tsel f vxuld not justify a grade of unsatisfactory for the cmpetency of Ccepliance/Use of Procedures.

52. Fgcmirer's Ccmnent 2 Judne Rechbcefer's Quest lon R.2.b:

Yhat is the relevance of the examiner's ccmmnt [ntrrber 2] to the "Ccrpt lance /Use of Procedures" conpetency?

53. Staf f Pesponse:

All precedures are written with the premise that correct information wiil be used in the determination of actions. If Mr. Ibrabito was not in a O positiem to verify the geremeter: then, reiher inen guess, he sneuid have v.alted for cnd insisted upon a repert frcm the appropriate board ope ra tor. if Mr. f.brabito had proceeded based on incorrect information, Fe rray not have been mi tigating the accident but could have actually been worsenirc the conditlon.

54. Examiner's Ccmnent 4 Juck:e. Bechhoe fer's Quest ion B.2.cfi):

Y.hy is this not a minor event that a'ao I!!ustrates good tearmork?

55. Staf f Response:

The caission of one of the inmediate action steps is generally not a rmjor deficiency by Itself: hoveve r , the operators are required to tremori ze the ,jmrediate action steps of the Erergency Operating Procedures. With respect to whether or not this dmonstrates good O temverk: the correction of the oversight does dmonstrate good temwork 6

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on the part of the other candidate, but the reliance upon anotiwr operator does not denenstrate good teanwork on the part of Mr. Abrabito.

56. Judae Bechhoefer's Question B.2.c(li):

V'euld this cmment by itsel f Justify a grade of U for the ccnpetency?

57. Staf f F.csponse:

No. "This conment by itsel f would not justify a orade of unsatisfactory for the ccrpetency of Ccnpliance/Use of Procedures.

58. Jucbe Bechhoefer's Question B.2.c(lii):

Was Mr. L'orabi t o inforrred prior to the examination that he would be responsible for knowina frcm merrory the inmediate actions of energency procedures? If so, when er how? (See t1RB3 1021 (Pev. 2), ES-301,H)

59. Staff Response:

Yes. Prior to each sirulator and oral examination, the Briefing Check List (NEEG-1021, ES-302, Attachrent 10) is read to all candidates. The first instruction states "Prirmry Pesponsibility - Operate the sirulator as the plant until the exercise is ended." The facility's actninistrative precedures require the inrediate action steps of tsnergency operating procedures to be rrstori zed such that they can be performed wi thcot reference to the procedures.

60. Judge Bechboefer's Question B.2.c(iv):

How would the Staff respond to the four rhetorical questions posed by Mr.

Abrabito in his reply (H 2a-d, at pp 8-9)? Answers should be provided for all sinulator exaninat ions fo r Beaver Va l ley, Uni t-1. [The four cuestions are as follows: (2a) Pas every licensed operator or senior eperator l en examined on his ability to rawber and perforr) all 20 O Imrediate action steps in sequence? (2b) Pas any licensed cperator or a

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senior operator ever gained his'ilcense even though he may have missed an inmediate action step? (2c) Do the ex miners restrict the senior reactor operators frcm reading the inmediate action steps out loud from t' he procedure af ter about the seventh step? If they were going to examine an operators sbility to memorize and perform all inmediate action steps, they would have to restrict the senior operator frcm reading the steps.

(2d) Do the reactor operator and balance of plant operator always perform only the inTrediate actions which af fect their area o--* !s their constant interactlon tmerg them such that one crerator performs steps that the other cperater forgets and do the steps vhich each operator performs vary from crew to crew?]

61. This question w?s clarified in the Order dated Decenter, 17, 1987, as follows: Was Mr. f.brabi to held to a higher standard than other car.dida tes in similar e m inations? The Staf f may answer rhetorical rpestions 2a-c using ar.y ntriber of exrminations vhich can reasonably be categorized as statistically significant. As for rhetorical question 2d, this cuestion is intended to be ansv.nred only with respect to sinulator examinationc, and the grading practices used by the Staff for such ent"Ina t ions . For clarity, the question is hereby rrodi fied to inquire whether a candidate do rmkes an error which is quickly recti fled by ccrmunicative interaction with another operator would necessarily receive a "U" rating with respect to knowledge of the irrmedia te actions of emergency procedures.

62. Staff Pesponse:

Siric'e examiner,s are only required'to doctment actions to support a rating O of unsatisfactory, it is not possible to fird answers to these questiens l

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in other candidate's records. However, to the best of the Staff's knowledge, based on years of experience in the Operator I.icensing Branch, the ansvers to the questions are as follows: (2a) No, every licensed operator has not been examined on his abliity to perform all Imrrdiate action steps. In accordance wi th N. PEG-1021, ES-302, f D.3.d, all operators rust be examined on a major plant transient which will exercise their understanding of the EOPs. Each scenario used is unioue in that it is used only once and is applicable only to a specific facility. This diversity is intentional te ensure that all sinulator and oral examinations achini stered are di f ferent. Many of the scenarios are developed to cause the SRO to charoe to another EOP before all of the irrediate action steps have been ccrpleted; thus, not all candidates are exarined on all of the inmediate act ion steps. (2b) Yes, candidates e

have received their licenses even though they may not have performed an Imrediate actior step. It is inctrtent upon the individual examiner to decide if a necative ccrrrent we.s verranted for a candidate who missed an intredia t e action step. This decision v.ould be based on the safaty significar.ce of the step missed. If the only deficiency noted for a candidate v.as the crr.irsion of a single inmediate action step, that would prcbably not be a sufficient basis for a failure. (2c) No, the examiners do not restrict the SPO frcrn reeding the inmediate action steps. It is the responsibility of the individual examiner to observe the candidate and detemine whether an Imrediate action step was missed. (2d) No, the two board operators are not restricted to separate portions of the control boards; rather, the boards are divided such that each has primary responsibility for certain equipnent during nonral operations. In the

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l event of an errergency, if one sees smethirg on the other's portlon of the control boards, he shculd inform the other for the ultimate protection of the plant.

63. Judge Bechhoefer's Cuestion B.2.c(v):

The St a f f concedes (a f fic!r.vi t idated Cttober 9, 1987] f 50) that "this vzs the only evaluation made of the candidate's abilltv to properly perforn the renuired irmediate actiers of the energency procedures as a control Ecard operator." In view of the significance of this single evaluatiori, did the Staf f perform folloeup questionire as stggested by iLPEG 1021 (Rev. 2), ES-303, B, te determine whether a ratirg of "M" or "S" would have been rnre appropriate? If so, please provide details. If not, please explain.

64 Staf f Pesponse:

No follow-up discussion was necessary to determine if Mr. Morabito could per form the required irrnediate act ion steps. The examiner observed the candidate's actions. The ra tirg of unsat isfac tory in the area of Cmp!!ance/l'se of Procedures was based on the four deficiencies noted on the Exarninat ion P.eport.

65. Siru!ator Exarrination, Centrol Board Operations Exarniner s Conment 1 Juck3 o Pechboofer's Question B.3.a:

Would this cmment bv Itself justify a crade of U for the ccnpetency?

66. Staff Response:

No. This cwment by itself v.ould not justify a grade of unsatisfactory for the cmpetency of Control Board (perations.

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.'. 67. Examiner's Coninent 2 Jtrlge Bechhoefer's Ouestion B.3.b(1):

V.hy is this r.ct a minor event that also illustrates good teanwork?

68. Staff Pesponse:

This is not a minor deficiency because i t denons t ra teu an inability to operate a piece of equiprent on the control board. It cannot be considered coed tearwork if assistence is required in an area for which the canciidate is responsible.

69. Judge Bechhoefer's Ckestion B.3.b(ll):

Yhy ret c'e l e tc this ccmrent in view of the examineri s confusion about irdica tor lights?

, 70. Staf f Response:

O 'The fact that the examiner uns confused about the presence of Indicator lights does rot neoate the fact that ?&. Abrabito could not veri fy the 1 position of the valve, as required by the ECPs, withcot the assistance of

the other board operator.

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71. Examirer 's Conmcnt 3 Judge Bechhoefer's Question B.3.c(1):

V.hy is this not a minor event that also illustrates gocd tearwork?

72. Staf f Response:

The ability to quickly and accurately locate equipnent on the control i toards is paremount te the cbility of the operators to protect the plant, 4

and therefore to protect the health and safety of the public. Because l

Mr. Abrahito stopped the wrong purp, he demonstrated a lack of farillari ty vilth the location of the ecylprent on the control boards.

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73. Judge EMchhoefer's Cuestion D.3.c(ll):

Ycu!d this ccmrent by itself justi fy a grade of U for the conpetency?

74. Staf f Response:

No. Bis cerment by itself would not justify a grade of unsatisfactory for the cropetency of Control Board Crerations.

75. Exan,iner's Cxmnent 4 l Juckje Bechhoefer's Ouest len B.3.d:

V'o uld this ccmrent by Itseif justify a grade of U for the cmpetency?

76. Staff Response:

No. bis cmment by i t sel f would not justify a grade of unsatisfactory for the eccpetency of Control Board Cperations.

77. Sinulator ExWnat i_cn. Supervisory Abili ty ,

,Extminer's Ccrment 1 Judge Bechhoefer's Outstion B.4.a f i):

Yhat is the relevance of the examiner's ccrment to the "Supervisory

/bl!I ty" cccpetency?

78. Sta ff Pespense:

! As the supervisor, Mr. Morebito did not notice that the bypass valve w?s open; nor did he aggressively pursue e solution to the unresolved problem I i

of a misrmtch between the stean ficw and feed flow indications for that steam generator. The SRO, as the supervisor, is responsible for knowing the status of all plant equiprnent. If a condition arises that is not  !

explained, then the supervisor nust attmpt to find out why that problem  !

exists.

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79. Judge Bechhoefer's Ouestion B.4.a(II):

Was an alarm intended to be part of the scenario in question?

80. Staff Response:

Yes, when the scenario was initially designed, an alann was expected for this r'alfur,ction (as evidenced by the scenarlo Sirulator Mninistration Form attached to the Examination Report, Scenario No. SB-2, Event No.1, page 1 of 4). Y. hen the mal function (feed regulating bypass valve falls open) was initieted, no alarm was received because other autcma t ic cortreir r:Itigated and rnasked the fai fure (the rmin feec' regulating valve closed to ccrpensate for the increasing level in the steam gererator).

81. Judne Fcchhoefer's Question B.4.af ill):

Was there a sirmiator rm i funct ion?

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Yes, during earlier scenarios that day, electrical probles in the sirmlator had been causing spikes on various recorders. Mcmever, the spiking of the recorder does net negate the fact that the feed flow and

the steam flow indications were not tratched. The cei-Jidates had been instructed, prior to the start of the scenarlos, to consider all prooles l as real ars r.ot to attritute the problem to a sfrulator mal function.

Contrary to this instruction, and by his om ackission (Speci fication, pages 21 and 26), A'r Abrabi to considered the mal funct ion to be a sirmlator prchim and cild not readily pursue a resolution to the problen.

83. Judge Bechhoefer's Question B.4.afiv):

How do exarriners allow for sirula tor ma l funct lons in rnakirg their l

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84. Staf f Response:

As in the plant, where rmifunctions occur without warning, the sinulator may also cause unexpected malfunctions of equipnent and indications. The Chief Examiner will (liscuss any tralfunctions with the other examiners and the sinulator instructors to determine if (1) It is still possible to continue with the scenario as written or with minor changes and (2) the ability of the examiners to evaluate their candidates is not inpa i red, then the scenarlo wii l cer t inue. If elther of the above conditlons does r.o t exist, the scerario will be sicpped and either the scenario will certinue after the rmifunction has been correctc- .~n

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conpetencies of Cmpliance/Use of Procectrres and' Camunications/ Crew Interactions that directly reflected on Mr . Abrabi to's inability to perforr ir the position of a supervisor.

89. Jtrics Ecchhoefer's Quest ion B.4.bf il):

Hce cices the use of hand sigrels in the ciretrnstance cited bear on the "Supervisory Ability" cmpetency? (See Staff affidavit (dated October 9, 1987], % 71)

90. Staff Pesponse:

As stated in the Af fidavit dated October 9, 1987, 1 77, the use of hanci signets in the control room of a ruclear pcwer plant is not a reliable rneans of ccrmunication. As the supervisor, the SRO rust ensure that all of the operators' actions and ccrmunications in the control rocrn are O proper and precIso.

91. Sirrulator Examination, Ccmiunications/ Crew Interactions haminer's Cmment 1 Judge Bechhor:fer's Oues t ion B.S.a(l):

Y t.a t is the relevance of the examiner's ccmNnt to the "Camunications/

Crew Interactions" cmpetency?

92. Staf f Response:

Mr. 1.brabi to should have confirmed with his beard eperator that the mergency tosses were deenergized prior to entering procedure ECA-0.0.

By not confirming his asstrrption with the board cperator, he started to use the procedure for loss of all electrical powe r, lhat procedure asstres that there is no electrical power for ,the emergency equipnent; when, in fac t , one of the emergency busses was energized.. Thus, Mr.

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Abrabito's failure to interact properly with his crew led to the use of an incorrect procedure.

93. Judge Bechhoefer's Quest ion B.5.a(l l):

Would the candidate nonrally be expected to comunicate with the operator be'cro acting in this situation?

94. Staff Response:

Yes. As the supervisor, the SPO should not be involved with the board cperctions, tut nust maintain the everall plant conditions in e safe tranner.

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95. Judge Bechhoefer's Ouestion B.S.a(lii):

Were the syrptoms of the arergency sufficiently understood by the candidate?

96. Staf f Response:

There is no way for the Staf f to kncw this information et this time, a However, based on the actions taken by Mr. Abrabito on the day of the examination, it is our opinion that he did not have a good understanding of the situation.

97. Judge Bechhoefer's Ouestion B.5.a(lv):

How rruch irrrnediate diagnosis is required in this particular situation?

98. Staf f Pesponse For imrediate diagnosis, the operator only has to look at two er three l r

treters cnd one breaker indication to verify if the diesel generator has started and is sequencing on the equipTnt. This process should not take more than fi f teen seconds ard should be an automatic ection on the part of the board operator. i

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99. Judge Bechhoefer's Ouestion B.5.a(v):

Would this ccrmient by itself Justify a grade of U for the corrpetency?

100. Staf f Response No. This ccrment by itself would not justify a grade of unsatisfactory for the cerTpetency of Camunication/ Crew Interactions.

101. Examir.er 's Conment 2 Juckje Bechhoefer's Question B.S.b(1):

Are there rules or standards which preclude the use of hand signals?

102. Staf f Response The Sta f f is not aware of any rules or standards, as such, which preclude the use of hand signals. Hovever, we believe it is obvious that the use of hand signals is not a precise means of ccrmunication.

O 103. Judge Bechhoefer's Osostion B.5 b(II):

Was A'r , A'orabi to instructed concerning the ineppropriateness of using hand signals?

1021. Staf f Response The PRC examiners did not give any specific instructions to the candidates regarding the use of hand signals, txit the briefing given to the candidates prior to the sirulator examinaticn directs the candidates to conduct operations in the sinulator as if it vmre the actual control room. We do not know If Duquesne Light Conpany training department specifically discusses this tratter.

105. Judge Bechhnefer's Ouestion B.5.bflii):

Is there any way to resolve the controversy abcut whether the candidate unc'e r s tood t h i s pa r t i cu l a r hand s i gna l ?

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1 106. Staff Response The ccmmnt initially made by the Staff on the Examination Report, Attachient 4, states, in part: "

. . . Cbring follow-up questionirg af ter i the sc e.r.a r i o, the car.didate schitted misunderstandino the operator's report of secondary radiation levels and asstmed there wes no reason to ge to E-3." It is our opinion that there is no confusion as to whether or not ti'e candidate understood the hand signal.

107. Judoe Rechhoefer's Question B.S.b(lv):

Vbuld thir cmment by itself justify a grade of U for the crrpetency (or f or the "Supervisory Abili ty" ccrrpetency)?

108. Staf f Response  !

No. This ccmnent by itself vwid not justify a orade of unsatisfactory for the cecpotency of Ccrmunication/ Crew Interactions.

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109. Exarr.Iner 's Cortment 3 Jt dge Bechhoe fe r 's Oues t i on R. S . c ( i ) :

Are there rules or stardrds against "thinkirc out loud?"

110. Sta f f Response No, there are no rules acainst thinking out l otd. In fact, on the .

Briefing 01erk l.! s t (fLREG-1021, ES-302, At tactment 10) instrtiction 4

ruber 3 states, ir part: "... I t wi l l bene f i t the exar process i f you 1

would verbalize your observations, analysis, and reasons for ections are than would be normal durirg crerations."

111. Judne Bechhoefer's Question B.5.c(ll):

l I f the candida,te's act ions here were judged as merely "thinking out

loud," would that by itself justify an unfavorable ccmnent in this

earrpetency?  !

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112. Staf f Response No. As previously stated in 153 of this doctrrent, the possible results t of proceeding in the direction asstmed by Mr. Morabito could have been detrimental to the plant, if Mr. Abrabito v.as sinply "thinking out loud," then it is indicative of a misurr'crstanding of the plant -

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113. Judge Eechhoefer'r Ouestion B.S.c(iii):

• is Mr. Abrabi to's first verbalization properly characterized as an "incorrect analysis" (Staff affidavit [ dated October 9, 1987], i CO)?

114. Sta ff Response Yes. His statement that the terperature was greater than 395 F v.as an incorrect analysis of the plant conditions based on the cbservable indications on the boaras.

115. Judae Pechhoefer's Question B.S.c(iv):

Yas anyone mislead by Mr. Abrabito's initial verbalization?  !

116. Staff Response Not in our cpinion, since the board cperator corrected Mr. Abrabito's staterrent inmediately.

117. JurJce Ecchhoe fer's Quest ion B.5.c(v):

Vtuld this ccament by i t s e l f j ust i fy a grade o f U for the ccrrpe tency?  !

118. ,Sta f f Response No. This ccrment by itself woulci not justi fy a grade of unsatisfactory i

for the ccrrpetency of Ccemunication/ Crew interactions.

119. Sumery:

The question was asked rmny times "Would this cceent bg>,itself justify a orade of U for the ccrrpetency?" Each time, the Staff answered that the l I

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- O I Individual ccrimen t , in end of itself, would not justify a grade of insatisfactory for the conpetency in question. However, the ntnber of ccrments in each cropetency was the basis for the unsatisfactory ratings and the overall failure of the sinulator exmination. A second question that was free,vently asked was "W1y is this not a . minor event that also I,'lustrates good t earv.ork?" The process for the PRC examination of cardidates to beccrv IIconsed operators is an Individual exactination. We do not examine a team of candidates with the concept of licensing the team as a group.

120. Based on our responses ateve, we believe that there is no tsasis for AY.

Atrtbito to be issued a license.

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122. Ibe foreqcirg are true and cerrect to the best of our knowledge and belief.

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