ML070440231

IR 05000220-06-011, 05000410-06-011; 10/16/06 - 1/09/07; Nine Mile Point, Units 1 and 2; Licensed Operator Requalification Program, Inspection Procedure Attachment 71111.11

ML070440231
Person / Time
Site:	Nine Mile Point
Issue date:	02/13/2007
From:	Blough A Division of Reactor Safety I
To:	O'Connor T Nine Mile Point
Shared Package
ML053400259	List: ML070440231
References
EA-07-001 IR-06-011
Download: ML070440231 (26)

See also: IR 05000220/2006011

Text

February 13, 2007

EA-07-001

Mr. Timothy J. OConnor

Vice President Nine Mile Point

Nine Mile Point Nuclear Station, LLC

P.O. Box 63

Lycoming, NY 13093

SUBJECT: NRC LICENSED OPERATOR REQUALIFICATION PROGRAM INSPECTION

REPORT 05000220/2006011 AND 05000410/2006011;

PRELIMINARY WHITE FINDING - NINE MILE POINT NUCLEAR STATION

Dear Mr. OConnor:

During the period October 16, 2006 through January 9, 2007, the US Nuclear Regulatory

Commission (NRC) conducted an inspection of the Nine Mile Point Nuclear Station Licensed

Operator Requalification Program activities. The enclosed report documents the inspection

findings, which were discussed on January 18, 2007 in an onsite exit meeting with you and

members of your staff.

The inspection examined activities conducted under your license as they relate to safety and

compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed

personnel. The inspection consisted of a review of the licensed operator requalification

program. Findings identified during the inspection are discussed in detail in the enclosed

inspection report.

This report documents a preliminary White finding that appears to have low to moderate safety

significance. As described in Section 1.R11 of this report, your Licensed Operator

Requalification Training Program allowed operating crews to validate simulator exam scenarios

that were substantially the same as those that were later administered to these crews as part of

their annual operating test. This shortcoming had the unintentional effect of compromising

your Unit 1 2005 and 2006 dynamic simulator exam scenarios. The apparent compromise of

the 2005 Unit 1 simulator exam scenarios is considered more serious and the basis for the

preliminary White finding since the apparent compromise was not corrected by Constellation

prior to returning licensed operators to normal duties. In contrast, for the 2006 exam

compromise problems Constellation took remedial actions by retesting all operators prior to the

end of the exam cycle. This finding was assessed using the Operator Requalification Human

Performance Significance Determination Process as a potentially safety significant finding that

was preliminarily determined to be White; i.e., a finding with some increased importance to

safety, which may require additional NRC inspection. The issue has a low to moderate safety

significance because it represented a failure to recognize and correct an apparent examination

compromise of the 2005 Unit 1 simulator exam scenarios, and a subsequent return to normal

T. OConnor 2

watch-standing duties by the licensed operators without adequate compensatory actions for the

compromised examinations. This finding was not an immediate safety concern for the following

reasons: (1) there were no significant plant performance issues related to operator knowledge

and abilities; (2) all licensed operators had participated in a continuous requalification training

program; (3) this issue, while pervasive, was limited to the 2005 and 2006 exams and did not

extend to the 2004 exams; and (4) Constellation took immediate remedial actions by

invalidating the simulator exam scenario portion of the 2006 annual operating exams and

administering new and more comprehensive simulator exam scenarios to all licensed operators

upon discovery of this concern by the NRC.

The finding is also an apparent violation of NRC requirements and is being considered for

escalated enforcement action in accordance with the Enforcement Policy, which can be found

on the NRCs web site at http://www.nrc.gov/reading-rm/adams.html.

Before we make a final decision regarding the preliminary White finding, we are providing you

an opportunity (1) to attend a Regulatory Conference where you can present to the NRC your

perspective on the facts and assumptions the NRC used to arrive at the finding and assess its

significance, or (2) submit your position on the finding to the NRC in writing. If you request a

Regulatory Conference, it should be held within 30 days of the receipt of this letter and we

encourage you to submit supporting documentation at least one week prior to the conference in

an effort to make the conference more efficient and effective. If a Regulatory Conference is

held, it will be open for public observation. If you decide to submit only a written response, such

submittal should be sent to the NRC within 30 days of the receipt of this letter.

Please contact Mr. Marvin Sykes at (610) 337-5046 within 10 business days of the date of your

receipt of this letter to notify the NRC of your intentions. If we have not heard from you within

10 days, we will continue with our significance determination and enforcement decision and you

will be advised by separate correspondence of the results of our deliberations on this matter.

Since the NRC has not made a final determination in this matter, no Notice of Violation is being

issued for this inspection preliminary White finding at this time. In addition, please be advised

that the number and characterization of the apparent violation described in the enclosed

inspection report may change as a result of further NRC review.

In addition, the report documents three NRC-identified findings of very low safety significance

(Green). One of these findings was determined to involve a Unit 2 violation of NRC

requirements involving similar but less significant exam compromise issues to those identified

for Unit 1 for reasons detailed in the enclosed report. The unintentional 2006 Unit 2 simulator

exam scenario compromise was assessed separately due to Unit 1 and 2 plant design

differences that require unique training programs for each unit, as well as unique plant and

operator licenses. However, because of the very low safety significance and because it is

entered into your corrective action program, the NRC is treating the Unit 2 exam compromise

finding as a non-cited violation (NCV) consistent with Section VI.A.1 of the NRC Enforcement

Policy. If you contest this NCV, you should provide a response within 30 days of the date of

this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission,

ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional

Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory

Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Nine Mile Point

Nuclear Station.

T. OConnor 3

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html.

Sincerely,

/RA/

A. Randolph Blough, Director

Division of Reactor Safety

Docket No: 50-220, 50-410

License No: DPR-63, NPF-69

Enclosure: Inspection Report 05000220/2006011 and 05000410/2006011

T. OConnor 4

cc w/encl:

M. J. Wallace, President, Constellation Generation

M. Heffley, Senior Vice President and Chief Nuclear Officer

C. W. Fleming, Esquire, Senior Counsel, Constellation Energy Group, LLC

M. J. Wetterhahn, Esquire, Winston and Strawn

P. Smith, President, New York State Energy, Research, and Development Authority

J. Spath, Program Director, New York State Energy Research and Development Authority

P. D. Eddy, Electric Division, NYS Department of Public Service

C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law

Supervisor, Town of Scriba

T. Judson, Central NY Citizens Awareness Network

D. Katz, Citizens Awareness Network

T. Shortell, Manager, Nuclear Training

S. Glenn, INPO

T. OConnor 5

Distribution w/encl:

ADAMS (PARS)

SECY

CA

OEMAIL

OEWEB

L Reyes, EDO

W Kane, DEDR

C Carpenter, OE

L Lopez, OE

O Samuel, OE

D Solorio, OE

L Trocine, OE

L Chandler, OGC

B Jones, OGC

M Elwood, OGC

J Dyer, NRR

M Weber, NRR

B Boger, NRR

D. Pickett, PM, NRR

P. Milano, PM (backup) NRR

M. David, NRR

J Lamb, OEDO

S Collins, RA

M Dapas, DRA

Enforcement Coordinators RII, RIII, RIV

E Hayden, OPA

H Bell, OIG

G Caputo, OI

L Tremper, OC

D Screnci/N Sheehan, RI

B. McDermott, DRP

K Farrar, RI

D Holody, RI

R Summers, RI

C ODaniell, RI

J Schlueter, FSME

RidsFSMEdmssa

R1DRP_Mail

Region I OE Files (with concurrences)

A. R. Blough, DRS

J. Caruso, Chief Examiner, DRS

L. Cline, SRI - NMP

E. Knutson, RI - NMP

K. Kolek, OA - NMP

DRS Master Exam File ©. Bixler (w/concurrences)

DRS File

T. OConnor 6

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OFFICE RI/DRS RI/DRS RI/DRS RI/ORA RI/DRS

NAME JCaruso/JGC MSykes/MDS BMcDermott/BJM RSummers/RJS WSchmidt/WLS

DATE 02/05/07 02/05/07 02/07/07 02/06/07 02/06/07

OFFICE RI/DRS

NAME ABlough/ARB

DATE 02/13/07

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No: 50-220, 50-410

License No: DPR-63, NPF-69

Report Nos: 05000220/2006011, 05000410/2006011

Licensee: Nine Mile Point Nuclear Station, LLC (NMPNS)

Facility: Nine Mile Point, Units 1 and 2

Location: Lake Road

Oswego, NY

Dates: October 16, 2006 - January 9, 2007

Inspectors: J. Caruso, Senior Operations Engineer

P. Presby, Operations Engineer

R. McKinley, Operations Engineer (under-instruction)

J. Sullivan, Operations Engineer (under-instruction)

Approved by: Marvin D. Sykes, Chief

Operations Branch

Division of Reactor Safety

SUMMARY OF FINDINGS

IR 05000220/2006-011, 05000410/2006-011; 10/16/06 - 1/09/07; Nine Mile Point, Units 1 and

2; Licensed Operator Requalification Program, Inspection Procedure Attachment 71111.11.

This inspection was conducted by two NRC region-based inspectors and two inspectors under

instruction. Three Green findings and one Apparent Violation (AV) with potential safety

significance greater than Green, were identified. The significance of most findings is indicated

by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609,

Significance Determination Process (SDP). Findings for which the SDP does not apply may

be Green or be assigned a severity level after NRC management review. The NRCs program

for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.

A. NRC-Identified and Self-Revealing Findings

Cornerstone: Mitigating Systems

• TBD. An apparent violation of 10 CFR 55.49, Integrity of Examinations and

Tests, was identified, concerning an apparent compromise of the 2005 and the

2006 annual operating exams at Unit 1. NRC inspectors identified practices that

collectively had the impact of compromising, albeit unintentionally, the

examinations; these practices included: 1) a lack of simulator exam scenario

diversity (i.e., The scenarios were substantially the same including: critical tasks;

major transients; Emergency Operating Procedure flow paths; and emergency

classifications); 2) an overuse of a single emergency operating procedure

strategy (i.e., full core Anticipated Transient Without Scram); and 3) a pattern of

crews validating scenarios substantially similar to their exam scenario sets.

Constellation had not identified and compensated for the compromise prior to

completing the 2005 exam and returning the operators to normal control room

duties. Following NRC identification of the compromise in 2006, Constellation

took immediate and substantive corrective actions prior to completion of the

annual operating exam cycle. Based on the Licensed Operator Requalification

Significance Determination Process (SDP) this finding was preliminarily

determined to be of low to moderate safety significance (White). The licensee

initiated Condition Report CR-NM-2006-4808, dated October 19, 2006, that

documented this issue and later initiated a Category I Root Cause Analysis (CR-

NM-2006-4808), Annual Licensed Operator Requalification Exam Compromise.

This finding was more than minor because it was associated with the Human

Performance attribute of the Initiating Events, Mitigation Systems, and Barrier

Integrity cornerstones and affected the combined objective of: limiting the

likelihood of; ensuring the availability and reliability of mitigating systems to

respond to; and providing reasonable assurance that physical barriers protect

the public from radio-nuclide releases caused by, initiating events.

The finding has a cross-cutting aspect in the area of problem identification and

resolution because Constellation did not effectively collect, evaluate, and

ii Enclosure

communicate applicable external operating experience to affected internal

stakeholders nor did they conduct self-assessments that were comprehensive,

appropriately objective, and self-critical such that either Unit 1 2005 exam

compromise issues were avoided altogether or identified and corrected prior to

the end of the 2005 annual operating exam cycle. (Section 1R11.1)

• Green. A Green NRC-identified non-cited violation (NCV) of 10CFR55.49 was

identified, concerning an apparent compromise of the 2006 annual operating

requalification examinations at Unit 2. NRC inspectors identified practices that

collectively had the impact of compromising, albeit unintentionally; the

examinations, these practices included: 1) a lack of simulator exam scenario

diversity (i.e., The scenarios were substantially the same including: critical tasks;

major transients; Emergency Operating Procedure flow paths; and emergency

classifications); 2) an overuse of a single emergency operating procedure

strategy (i.e., full core Anticipated Transient Without Scram); and 3) a pattern of

crews validating scenarios substantially similar to their exam scenario sets. The

licensee initiated CR-NM-2006-4808 that documented this concern and later

initiated a Category I Root Cause Analysis.

This finding was more than minor because it was associated with the Human

Performance attribute of the Initiating Events, Mitigation Systems, and Barrier

Integrity cornerstones and affected the combined objective of: limiting the

likelihood of; ensuring the availability and reliability of mitigating systems to

respond to; and providing reasonable assurance that physical barriers protect

the public from radio nuclide releases caused by, initiating events. The finding

was assessed as having very low safety significance because immediate and

substantive corrective actions were taken by Constellation prior to the end of the

current exam cycle.

The finding has a cross-cutting aspect in the area of problem identification and

resolution because Constellation did not effectively collect, evaluate, and

communicate applicable external operating experience to affected internal

stakeholders nor did they conduct self-assessments that were comprehensive,

appropriately objective, and self-critical such that the 2006 Unit 2 exam

compromise issues were either avoided altogether or at least identified and

corrected by Constellation prior to the start of this inspection. (Section 1R11.2)

• Green. A finding of very low safety significance was identified at Unit 1. The

finding was associated with crew performance on the simulator during the 2006

facility-administered requalification examinations. Of the six crews evaluated,

two failed to pass their simulator examinations when the newly developed more

comprehensive exams were re-administered in response to the above noted

preliminary White finding. The failures are documented in licensee-initiated

Condition Report CR 2006-5797, which resulted in Constellation conducting a

Category I Root Cause Analysis.

This finding was more than minor because it was associated with the Human

Performance attribute of the Initiating Events, Mitigation Systems, and Barrier

Integrity cornerstones and affected the combined objective of: limiting the

iii Enclosure

likelihood of; ensuring the availability and reliability of mitigating systems to

respond to; and providing reasonable assurance that physical barriers protect

the public from radio nuclide releases caused by, initiating events. The finding

was assessed as having very low safety significance because: 1) the failures

occurred during annual testing of the operators on the simulator; 2) there were

no actual consequences to the failures; 3) the crews were removed from watch

standing duties, retrained and re-evaluated before they were authorized to return

to control room watches; and, 4) because the crew failure rate for the 2005 Unit

1 Annual Operating Exams was less than 20%. (Section 1R11.3)

• Green. A finding of very low safety significance was identified at Unit 2. The

finding was associated with crew performance on the simulator during the 2006

facility-administered requalification examinations. Of the six crews evaluated,

two failed to pass their simulator examinations when the newly developed more

comprehensive exams were re-administered in response to the above noted

preliminary White finding. The failures are documented in licensee-initiated

Condition Report CR 2006-5797, which resulted in Constellation conducting a

Category I Root Cause Analysis.

This finding was more than minor because it was associated with the Human

Performance attribute of the Initiating Events, Mitigation Systems, and Barrier

Integrity cornerstones and affected the combined objective of: limiting the

likelihood of; ensuring the availability and reliability of mitigating systems to

respond to; and providing reasonable assurance that physical barriers protect

the public from radio nuclide releases caused by, initiating events. The finding

was assessed as having very low safety significance because: 1) the failures

occurred during annual testing of the operators on the simulator; 2) there were

no actual consequences to the failures; 3) the crews were removed from watch

standing duties, retrained and re-evaluated before they were authorized to return

to control room watches; and, 4) because the crew failure rate for the 2005 Unit

2 Annual Operating Exams was less than 20%. (Section 1R11.4)

B. Licensee-Identified Findings

None.

iv Enclosure

REPORT DETAILS

1. REACTOR SAFETY

1R11 Licensed Operator Requalification Program (71111.11)

a. Inspection Scope

The following inspection activities were performed using NUREG-1021, Rev. 9,

Operator Licensing Examination Standards for Power Reactors, Inspection Procedure

Attachment 71111.11, Licensed Operator Requalification Program, and NRC Manual

Chapter 0609, Appendix I, Operator Requalification Human Performance Significance

Determination Process (SDP), as acceptance criteria.

During the first onsite inspection week of October 16, 2006, inspectors observed

administration of licensed operator requalification exams on Unit 1, including two

dynamic simulator scenarios, three simulator Job Performance Measures (JPMs) and

two in plant JPMs for one operations crew. Following an NRC debrief on the preliminary

inspection issues identified, the licensee invalidated all of the dynamic simulator exams

for 2006 on both units and initiated development of new 2006 exam scenarios (see

Findings section of this report for further details). As a result of these identified issues

the scope of this inspection was expanded. During the weeks of November 20,

December 4 and December 11, 2006, the inspectors observed and assessed

Constellations administration of newly developed exam scenarios to all six of the Unit 1

operating crews and two of the Unit 2 operating crews. In addition, the inspectors

observed the administration of retake exam scenarios for one Unit 1 and one Unit 2

operating crew following their exam failures and subsequent training remediations.

The inspectors reviewed all three Unit 1 exam sets for both the comprehensive Reactor

Operator (RO) and Senior Reactor Operator (SRO) biennial written exams, as well as all

the newly developed simulator exam scenarios for both Unit 1 and 2, and a sample (i.e.,

exam weeks 1, 3, 4) of the Unit 1 JPMs administered during this current exam cycle to

ensure the quality of these exams met or exceeded the criteria established in the

Examination Standards and 10 CFR 55.59. In addition, both the Unit 1and 2 simulator

exam scenarios administered as part of the 2005 annual operating exams were

reviewed and evaluated as part of an exam compromise extent of condition review.

Simulator performance was evaluated through observation during the conduct of the

examinations, a review of simulator performance tests (e.g., steady state performance

tests, selected transient tests, and selected scenario-based tests), and a review of

Simulator Deficiency Reports to verify compliance with the requirements of 10 CFR

55.46 and guidance contained in ANSI/ANS-3.5-1998. Corrective actions were

reviewed associated with NCV 2004005-02 (Failure of NMP Simulator to Demonstrate

Expected Plant Response). No significant simulator issues were identified (see

document list attached).

Enclosure

2

The inspectors reviewed documentation of operating history since the last requalification

program inspection. The inspectors also discussed facility operating events with the

resident staff. Documents reviewed included NRC inspection reports, Plant

Performance Insights, licensee event reports (LERs), and licensee condition reports

(CRs) that involved human performance issues for licensed operators to ensure that

operational events were not indicative of possible training deficiencies.

The following record reviews were conducted: remediation plans for seven cyclic written

exam failures and one evaluated Operating Exam segment; seven medical records;

eight quarters of time on shift records; and, ten operator license reactivations.

On January 9, 2007, the inspectors conducted an in-office review of the full

requalification exam results to assess whether pass rates were consistent with the

guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human

Performance Significance Determination Process (SDP). Results are listed below.

Unit 1 Results:

• Crew failure rate on the dynamic simulator was less than 34%. The threshold for

a Green finding is a failure rate between 20% and 33%.

(Failure rate was 33.33%.)

• Individual failure rate on the dynamic simulator test was less than or equal to

20%. (Failure rate was 19.0%.)

• Individual failure rate on the walk-through test (JPMs) was less than or equal to

20%. (Failure rate was 2.4%.)

• Individual failure rate on the comprehensive biennial written exam was less than

or equal to 20%. (Failure rate was 2.4%)

• More than 75% of the individuals passed all portions of the exam (78.5% of the

individuals passed all portions of the exam).

Unit 2 Results:

• Crew failure rate on the dynamic simulator was less than 34%. The threshold for

a Green finding is a failure rate between 20% and 33%.

(Failure rate was 33.33%.)

• Individual failure rate on the dynamic simulator test was less than or equal to

20%. (Failure rate was 12.5%.)

• Individual failure rate on the walk-through test (JPMs) was less than or equal to

20%. (Failure rate was 0.0%.)

Enclosure

3

• Individual failure rate on the comprehensive biennial written exam was less than

or equal to 20%. (Not applicable - not administered this year)

• More than 75% of the individuals passed all portions of the exam (87.2% of the

individuals passed all portions of the exam).

b. Findings

1. Failure to Ensure Integrity of Unit 1 Examinations and Tests

Introduction. An apparent violation of 10 CFR 55.49, Integrity of Examinations and

Tests, was identified, concerning an apparent compromise of the 2005 and the 2006

annual operating exams at Unit 1. Constellation had not identified and compensated for

the compromise prior to completing the 2005 exam and returning the operators to

normal control room duties. Following NRC identification of the compromise in 2006,

Constellation took immediate and substantive corrective actions prior to completion of

the annual and biennial operating exam cycles. Based on the Licensed Operator

Requalification Significance Determination Process (SDP) this was preliminarily of low to

moderate safety significance (White).

Description. The inspectors identified that the exam practices used by Constellation at

Nine Mile Point resulted in an apparent compromise of the simulator exam scenario

portion of both the 2005 and 2006 annual operating tests. The apparent compromise is

considered widespread, because all licensed operator requalification crews were

affected on both the 2005 and 2006 exams. The apparent compromise of the 2005

Unit 1 simulator exam scenarios is considered more serious than the 2006 exam

compromises and the basis for the preliminary White finding since the 2005 apparent

exam compromises were not corrected by the licensee prior to returning licensed

operators to normal watch-standing duties. In contrast, in 2006 when the exam

compromises were identified by the NRC and brought to the attention of Constellation

remedial actions were taken to retest all of the operators prior to the end of the exam

cycle.

The issue was identified while conducting the Unit 1 biennial Licensed Operator

Requalification Training (LORT) Program inspection during the week of October 16,

2006. Constellation allowed operating crews to validate simulator exam scenarios that

were substantially the same as the simulator exam scenarios that were later

administered to these crews as part of their annual operating test, thus preconditioning

the operators. These practices did not comply with Constellations procedural guidance,

NMP-TR-1.01-20, Attachment 5, Section B.2 states, Personnel shall not validate any

materials to be used on their exams, and Section D stipulates each section of the

requalification exams will contain at least 50% new material.

Enclosure

4

The inspectors identified that the scenarios validated by Unit 1 A crew (September 12-

16, 2006) were substantially similar in content to the two simulator exam scenarios that

were administered to A crew on October 17, 2006. With the exception of a few

malfunctions, the scenarios were substantially the same, i.e., the same critical tasks,

major transients, Emergency Operating Procedure (EOP) flow paths, and emergency

classifications. In addition, on October 16, 2006, one day before taking their annual

operating test using scenario #4, A crew was administered exam scenario #2 for

validation/practice. The inspectors determined that scenario #2 was substantially the

same as scenario #4. The inspectors determined that the other crews examined during

the first three weeks of the exam cycle had also validated scenarios that were

substantially similar in content to the simulator exam scenarios administered during their

exam weeks.

The inspection team further noted that twelve of the sixteen new simulator exam

scenarios developed for the Unit 1 2006 annual operating test cycle involved a full core

Anticipated Transient Without Scram (ATWS) theme and varied primarily by changing

several malfunctions for each scenario. This lack of exam diversity, an overuse of the

ATWS theme, and a pattern of crews validating scenarios substantially similar to their

exam scenario sets collectively had the effect of compromising the exams. In addition,

the over-emphasis on examining the ATWS theme resulted in not testing other

important EOP mitigation strategies (e.g., secondary containment and radiation release

strategies). Furthermore, the inspectors determined that the scenario exam sets

previously administered during weeks 1 and 2 were scheduled to be re-administered

during exam weeks 5 and 6 respectively.

The NRC inspection team communicated these issues to Constellation representatives.

On October 20, 2006, representatives of Constellation management agreed with the

NRC inspection teams assessment of the issues. Constellation determined that the

2006 Unit 1 and 2 annual license simulator exam scenarios administered to date were

invalid due to the pervasive nature of the apparent exam compromise. Exam

administration was suspended at both units pending development of new exams. The

licensee initiated Condition Report CR-NM-2006-4808, dated October 19, 2006 that

documented this issue and later initiated a Category I Root Cause Analysis (CR-NM-

2006-4808), Annual Licensed Operator Requalification Exam Compromise. Note: A

Category I Root Cause Analysis is conducted by independent parties, involves a

thorough investigation of the details that led to the problem, identifies the root as well as

contributing causes, and assigns corrective actions to prevent re-occurrence of the

problem.

Following the onsite visit, the NRC inspection team conducted an in-office extent of

condition review of the Unit 1 2005 simulator exam scenario portion of the annual

operating tests. The team determined that the 2005 simulator exam scenarios were

compromised and this problem went undetected and uncorrected by the licensee. The

problem remained undetected until it was identified by the NRC and brought to the

attention of Constellation. The problems with the 2005 simulator exam scenarios were

similar to those identified on the 2006 dynamic exams and included a lack of exam

diversity, an overuse of the ATWS theme (8 of 11 scenarios), and a pattern of crews

Enclosure

5

validating scenarios that were substantially similar to their exam scenario sets. In

contrast to the 2006 exam, the compromise to the simulator scenario exam portion of

2005 annual operating test was undetected and uncorrected, led to licensed operators

returning to normal watch-standing duties without adequate compensatory actions being

taken and therefore, is the basis for the preliminary White finding.

Inspectors conducted interviews with the exam development team and reviewed

associated development records for the 2005 and 2006 exams. Based on this review, it

appeared that the exam compromise issue resulted from NMP staff inexperience and

lack of management oversight of the exam development process. Constellations

emphasis on maintaining exam security resulted in self-imposed restrictions on

management oversight of the exam development process. In addition, the exam

development team operated under some misconceptions including: 1) due to a recent

upgrade to the simulator model, rather than modifying existing exam scenarios, the

exam team needed to draft all new simulator exam scenarios; 2) all revisions to exam

scenarios had to be validated by an operating crew which, in some cases, resulted in

multiple crew exposures to a single scenario; 3) minor revisions to an exam scenario

were enough to consider the scenario sufficiently unique to be considered a new

scenario; 4) it is acceptable for a crew to validate a simulator exam scenario

substantially the same as their exam scenario, provided this is done six weeks in

advance; and 5) each exam had to include events which challenged one or more critical

tasks from a small pre-existing list of critical tasks which did not encompass the full

range of major events. These misconceptions resulted in a narrowly focused exam

which over-tested the ATWS theme at the exclusion of other equally important EOP

mitigation strategies. The inspectors did not find any indication that the compromises

were intentional.

The licensees root cause team later concluded, ...that similarities in the scenarios in

the 2006 Unit 1 exam set caused unintentional preconditioning of the crew by exposing

them to scenarios during validation that were essentially the same as the scenarios

used for their exam ... and reviewed the 2005 Unit 1 exam sets and found issues similar

to those associated with the 2006 Unit 1 exam. The root cause team identified two

primary causes: 1) policy guidance, management expectations, and job performance

standards were not well-defined or understood, the process provides minimal direction

and guidance, which the inexperienced team was not able to compensate for through

their knowledge; and 2) a rigorous review and analysis of the exam by an experienced

exam author did not occur during the review/challenge process. No one outside the

immediate exam development team performed a comprehensive exam set review.

New and more comprehensive simulator scenario exams were developed and

administered to all licensed operators between November 20 and December 14, 2006.

The inspection team observed the re-testing of all Unit 1 licensed operators and noted

the following improvements: 1) development and administration of new, more

comprehensive simulator exam scenarios; 2) one-on-one operator evaluations; 3)

rotating watch positions for the SROs as well as the ROs between scenarios; 4)

evaluation of Shift Technical Advisor position; and 5) conducting more detailed post

exam critiques.

Enclosure

6

Analysis. The unintentional integrity comprise of the simulator exam scenario portion of

the Unit 1 2005 and 2006 annual operating exams was a performance deficiency, in that

Constellation failed to follow their established requalification procedures and resulted in

an apparent violation of 10 CFR 55.49. Integrity of Exams and Tests. Specifically, in

2005 and initially in 2006 the operators were tested using requalification simulator exam

scenarios substantially similar to simulator exam scenarios that they had previously

validated. Therefore, the validation process, in combination with a lack of exam

diversity, caused exam integrity to be compromised. Traditional enforcement does not

apply because the issue did not have any actual safety consequences, potential for

impacting the NRCs regulatory function, and was not the result of any willful violation of

NRC requirements or Constellations procedures. This finding was more than minor

because it was associated with the Human Performance attribute of the Initiating

Events, Mitigation Systems, and Barrier Integrity cornerstones and affected the

combined objective of: limiting the likelihood of; ensuring the availability and reliability of

mitigating systems to respond to; and providing reasonable assurance that physical

barriers protect the public from radio nuclide releases caused by, initiating events.

This finding was determined preliminarily to have low to moderate safety significance

(White) using the Licensed Operator Requalification Human Performance Significance

Determination Process (SDP) Inspection Manual Chapter 0609, Appendix I. Block 21

applies, Has the integrity of the scenario been compromised? This is a failure to

control the scenario identity or material including the validation process such that the

operating test integrity is affected. The answer to the Block 21 question is yes, the

operators were tested using requalification exam scenarios substantially similar to exam

scenarios that they had previously validated. Therefore, the validation process, in

combination with a lack of scenario diversity, led to an unintentional exam compromise.

Block 26 also applies, When the compromise was discovered, or should have been

discovered, did the licensee take immediate compensatory measures. The answer to

the Block 26 question is no, as Constellation did not identify and take immediate

corrective actions for the 2005 Unit 1 exam compromises (Block 21 - Yes and Block 26 -

No). This simulator exam scenario integrity compromise finding should have been

discovered and corrected by Constellation, prior to NRC identification. Constellation

should have discovered the problem in 2005 or at least prior to the NRCs identification

because: 1) a similar issue was described in 2002 Industry Operating Experience

involving exam compromise; 2) Constellation completed a self audit in August 2006 that

failed to identify this issue; and 3) the practices clearly violated NRC guidance and

requirements, as well as Constellations procedural guidance aimed at preventing exam

compromise. More importantly, however, in 2005, because the issue was not identified

at the time, Constellation had not taken compensatory actions prior to returning the

operators to normal control room duties. Following identification of this issue by the

NRC, the licensee took immediate and substantive corrective actions to remedy the

2006 annual operating exam compromise, by developing new exams and re-testing all

the Unit 1 licensed operators within the required annual and biennial exam cycles.

The cause of the finding has a cross-cutting aspect in the area of problem identification

and resolution in that Constellation did not effectively collect, evaluate, and

Enclosure

7

communicate applicable external operating experience to affected internal stakeholders

nor did they conduct self-assessments of sufficient depth that were comprehensive,

appropriately objective and self-critical such that the Unit 1 2005 exam compromise

issues were avoided altogether or at least identified and corrected prior to the end of the

2005 annual operating exam cycle.

Enforcement. 10 CFR 55.49, requires, in part, that, ...licensees shall not engage in any

activity that compromises the integrity of any application, test, or examination required

by this part. The integrity of a test or examination is considered compromised if any

activity, regardless of intent, affected, or, but for detection, would have affected the

equitable and consistent administration of the test or exam. Contrary to this

requirement, the Unit 1 2005 and 2006 annual operating tests were compromised since

the process used to validate the simulator exam scenarios resulted in licensed operators

being knowledgeable of a significant portion of the test prior to its administration.

This finding was not an immediate safety concern for the following reasons: 1) there

were no significant plant performance issues related to operator knowledge and

abilities; 2) all licensed operators had participated in a continuous requalification training

program; 3) this issue, while pervasive, was limited to the 2005 and 2006 exams and did

not extend to the 2004 exams; 4) Constellation took immediate remedial actions by

administering new and more comprehensive simulator exam scenarios to all Unit 1

licensed operators upon discovery of this concern by the NRC. Some individual and

crew weaknesses were identified, as evidenced by the individual and crew failure rates,

however the performance on these new exams was overall satisfactory. (AV 50-

220/2006011-01, Failure to Ensure Integrity of Unit 1 Examinations and Tests)

2. Failure to Ensure Integrity of Unit 2 Examinations and Tests

Introduction. A non-cited violation of 10 CFR 55.49, Integrity of Examinations and

Tests, was identified, concerning an apparent compromise of the 2006 annual

operating exams at Unit 2. Following NRC identification of the compromise,

Constellation took adequate compensatory measures, prior to completion of the annual

and biennial exam cycles.

Description. The inspectors identified that the exam practices used by Constellation at

Nine Mile Point resulted in an apparent compromise of the dynamic scenario portion

the 2006 annual operating tests.

The issue was identified while conducting the Unit 1 biennial LORT Program inspection

during the week of October 16, 2006. Constellation allowed operating crews to validate

simulator exam scenarios that were substantially the same as the simulator exam

scenarios that were later administered to these crews as part of their annual operating

test, thus preconditioning the operators (see preliminary white finding discussed in item

b.1 above for details). These practices did not comply with Constellations procedural

guidance, in NMP-TR-1.01-20, Attachment 5, Section B.2 which states, Personnel shall

not validate any materials to be used on their exams, and Section D which stipulates

Enclosure

8

each section of the requalification exams will contain at least 50% new material.

The NRC inspection team communicated these issues to Constellation representatives.

On October 20, 2006, representatives of Constellation management agreed with the

NRC inspection teams assessment of the issues. The licensee then conducted an

extent of condition review for Unit 2 annual license operating tests administered to date

and determined the exams administered to date were invalid due to the pervasive nature

of the apparent exam compromise. Exam administration was suspended at both units

pending development of new exams. The licensee initiated Condition Report CR-NM-

2006-4808, dated October 19, 2006 that documented this issue and later initiated a

Category I Root Cause Analysis (CR-NM-2006-4808), Annual Licensed Operator

Requalification Exam Compromise.

Following the onsite visit, the NRC inspection team conducted an in-office extent of

condition review of the Unit 2 2005 dynamic operating tests. The team determined that

the 2005 Unit 2 dynamic exams were not affected.

The licensees root cause team later concluded, ...that similarities in the scenarios in

the 2006 Unit 1 exam set caused unintentional preconditioning of the crew by exposing

them to scenarios during validation that were essentially the same as the scenarios

used for their exam ... and reviewed the 2006 Unit 2 and 2005 Unit 1 exam sets and

found issues similar to those associated with the 2006 Unit 1 exam.

New and more comprehensive scenario exam scenarios were developed and

administered to all licensed operators between November 20 and December 14, 2006.

The inspection team observed the re-testing of all Unit 1 and some of the Unit 2 licensed

operators.

Analysis. The unintentional integrity compromise of the simulator exam scenario portion

of the 2006 Unit 2 annual operator exams was a performance deficiency, in that

Constellation failed to follow their established requalification procedures and violated

10 CFR 55.49. Integrity of Exams and Tests. Specifically, initially in 2006 the

operators were tested using simulator exam scenarios substantially similar to simulator

exam scenarios that they had previously validated. Therefore, the validation process, in

combination with a lack of exam diversity, caused exam integrity to be compromised.

Traditional enforcement does not apply because the issue did not have any actual safety

consequences or potential for impacting the NRCs regulatory function and was not the

result of any willful violation of NRC requirements or Constellations procedures. This

finding was more than minor because it was associated with the Human Performance

attribute of the Initiating Events, Mitigation Systems, and Barrier Integrity cornerstones

and affected the combined objective of: limiting the likelihood of; ensuring the availability

and reliability of mitigating systems to respond to; and providing reasonable assurance

that physical barriers protect the public from radio nuclide releases caused by, initiating

events.

This finding was determined to have very low safety significance (Green) using

Appendix I of the SDP. Block 21 applies, Has the integrity of the scenario been

Enclosure

9

compromised? This is a failure to control the scenario identity or material including

the validation process such that the operating test integrity is affected. The answer

to the Block 21 question is yes, the operators were tested using requalification exam

scenarios substantially similar to exam scenarios that they had previously validated.

Therefore, the validation process in combination with a lack of scenario diversity, led to

an exam compromise. Block 26 also applies, When the compromise was discovered,

or should have been discovered, did the licensee take immediate compensatory

measures also applies. The answer to the Block 26 question is yes resulting in a

green finding (Block 21 - Yes and Block 26 - Yes), This simulator exam scenario

integrity compromise finding should have been discovered and corrected prior to NRC

identification. However, following identification Constellation took immediate and

substantive compensatory actions to remedy the 2006 annual operating exam

compromise, by developing new exams and re-testing all the Unit 2 licensed operators

within the required annual and biennial exam cycles. Further, the inspectors verified

that the Unit 2 2005 simulator exam scenario portion of the annual operating exam had

not been compromised in a similar fashion.

The cause of the finding has a cross-cutting aspect in the area of problem identification

and resolution in that Constellation did not effectively collect, evaluate, and

communicate applicable external operating experience to affected internal stakeholders

nor did they conduct self-assessments of sufficient depth that were comprehensive,

appropriately objective and self-critical such that the 2006 Unit 2 exam compromise

issues were either avoided altogether or at least identified and corrected by

Constellation prior to the start of this inspection.

Enforcement. 10 CFR 55.49, requires, in part, that, ...licensees shall not engage in any

activity that compromises the integrity of any application, test, or examination required

by this part. The integrity of a test or examination is considered compromised if any

activity, regardless of intent, affected, or, but for detection, would have affected the

equitable and consistent administration of the test or exam. Contrary to this

requirement, the 2006 Unit 2 annual operating tests were compromised since the

process used to validate the simulator exam scenarios resulted in licensed operators

being knowledgeable of a significant portion of the test prior to its administration.

(NCV 05000410/2006011-02, Failure to Ensure Integrity of Unit 2 Examinations and

Tests)

3. Unit 1 Crew Failure Rate on the Dynamic Simulator Portion of the Annual Operating

Examinations

Introduction. A finding of very low safety significance (Green) was identified at Unit 1,

based on two of six crews failing their facility-administered annual simulator

examinations.

Description. During facility-administered annual operating testing of the licensed

operators, licensee training staff evaluated crew performance on simulator exam

scenarios using performance standards derived from NUREG-1021, Operator

Enclosure

10

Licensing Examination Standards for Power Reactors. Facility results of crew

performance showed that two of the six crews evaluated (33%) did not pass their

simulator exams. The failures are documented in licensee-initiated Condition Report

CR 2006-5797, which resulted in Constellation conducting a Category I Root Cause

Analysis. Constellations root cause analysis report stated, The number of individual

and crew failures could be indicative of programmatic weaknesses that if unresolved,

could affect operator performance on shift, ... 9 of 14 individuals failing the annual

operating exam had been noted as needing improvement in the same areas as on the

annual exam (within the last 2 years). 3 of 4 crews failing the annual exam failed a

recent evaluated scenario (in 2006) and all 4 crews had failed a scenario in the last 2

years. Ops Management was not fully aware of these performance weaknesses. Other

than documentation of remediation for failures, no other documentation was found as

described performance improvement plans for individuals noted as needing

improvement as required by GAI-OPS-13. GAI-OPS-13, Attachment 1.2, states that,

...a score of one or two in any competency area or on any event or evolution requires

development of a plan for improving performance. NRC inspectors observed the

administration of the simulator exam scenario evaluations for all six crews and also

observed the retest of one of the remediated crews that failed their exam during a

previous week.

Analysis. A performance deficiency (PD) was identified in that the Systems Approach to

Training (SAT) feedback mechanism standards associated with the Nine Mile Point

LORT program were not utilized. Specifically, individual and crew weaknesses were not

appropriately identified, evaluated and corrective actions taken. In addition, corrective

actions taken for previously identified individual and crew weaknesses were not fully

effective (i.e., a Category 1 CR written in 2004 to document a green finding from crew

failures on an annual exam). As a result, two of six licensed operator crews

demonstrated knowledge and ability weaknesses resulting in less than adequate

performance on an NRC required requalification test administered by the licensee.

Traditional enforcement does not apply because the issue did not have any actual safety

consequence or potential for affecting the NRCs regulatory function and was not the

result of any willful violation of NRC requirements or licensee procedures. This finding

was more than minor because it was associated with the Human Performance attribute

of the Initiating Events, Mitigation Systems, and Barrier Integrity cornerstones and

affected the combined objective of: limiting the likelihood of; ensuring the availability and

reliability of mitigating systems to respond to; and providing reasonable assurance that

physical barriers protect the public from radio nuclide releases caused by, initiating

events. Specifically, the finding reflected the potential inability of the crews to take

appropriate safety-related actions in response to actual abnormal or emergency

conditions while they were on-shift prior to the requalification testing.

Since this is a more than minor requalification training issue, the risk importance

associated with the number of crews failing the annual operating tests is provided in

Appendix I of the SDP. The Simulator Operational Evaluation Matrix was entered using

the number of crews that took the simulator test, six, and the number of crews with less

than adequate performance, two. Based on these numbers, the finding was

characterized by the SDP as having very low safety significance (20 - 34% failure rate),

Enclosure

11

or Green. The finding is of very low safety significance because the failures occurred

during annual testing of the operators on the simulator, because there were no actual

consequences to the failures, because the crews were removed from watch standing

duties, retrained, and re-evaluated before they were authorized to return to control room

watches, and because the crew failure rate for the 2005 Unit 1 Annual Operating Exams

was less than 20%.

Enforcement. NRC regulations require that licensed operators pass an annual

operating test; the regulations do not specify pass/fail rates. When a failure occurs,

requirements are met by restricting the operator from licensed duties until the operator

has been retrained and successfully retested, steps which licensee staff completed.

Therefore, no violation of regulatory requirements occurred. Crew performance on the

2006 annual operating exams has been entered into the corrective action program

(CAP) as CR 2006-5797, and Constellation performed a level 1 root cause analysis of

these crew failures. (FIN 05000220/2006011-03, Unit 1 Crew Failure Rate on the

Dynamic Simulator Portion of the Annual Operating Examinations)

4. Unit 2 Crew Failure Rate on the Dynamic Simulator Portion of the Annual Operating

Examinations

Introduction. A finding of very low safety significance (Green) was identified at Unit 2,

based on two of six crews failing their facility-administered annual simulator

examinations.

Description. During facility-administered annual operating testing of the licensed

operators, licensee training staff evaluated crew performance on simulator exam

scenarios using performance standards derived from NUREG-1021, Operator

Licensing Examination Standards for Power Reactors. Facility results of crew

performance showed that two of the six crews evaluated (33%) did not pass their

simulator exams. The failures are documented in licensee-initiated Condition Report

CR 2006-5797, which resulted in Constellation conducting a Category I Root Cause

Analysis. Constellations root cause analysis report stated, The number of individual

and crew failures could be indicative of a programmatic weaknesses that if unresolved,

could affect operator performance on shift, ... 9 of 14 individuals failing the annual

operating exam had been noted as needing improvement in the same areas as on the

annual exam (within the last 2 years). 3 of 4 crews failing the annual exam failed a

recent evaluated scenario (in 2006) and all 4 crews had failed a scenario in the last 2

years. Ops Management was not fully aware of these performance weaknesses. Other

than documentation of remediation for failures, no other documentation was found as

described performance improvement plans for individuals noted as needing

improvement as required by GAI-OPS-13. GAI-OPS-13, Attachment 1.2, states that,

...a score of one or two in any competency area or on any event or evolution requires

development of a plan for improving performance. NRC inspectors observed the

administration of the simulator exam scenario evaluations for two of six crews and also

observed the retest of one of the remediated crews that failed their exam during a

previous week.

Enclosure

12

Analysis. A performance deficiency (PD) was identified in that the Systems Approach to

Training (SAT) feedback mechanism standards associated with the Nine Mile Point

LORT program were not utilized. Specifically, individual and crew weaknesses were not

appropriately identified, evaluated and corrective actions taken. In addition, corrective

actions taken for previously identified individual and crew weaknesses were not fully

effective (i.e., a Category 1 CR written in 2004 to document a green finding from crew

failures on an annual exam). As a result, two of six licensed operator crews

demonstrated knowledge and ability weaknesses resulting in less than adequate

performance on an NRC required requalification test administered by the licensee.

Traditional enforcement does not apply because the issue did not have any actual safety

consequence or potential for affecting the NRCs regulatory function and was not the

result of any willful violation of NRC requirements or licensee procedures. This finding

was more than minor because it was associated with the Human Performance attribute

of the Initiating Events, Mitigation Systems, and Barrier Integrity cornerstones and

affected the combined objective of: limiting the likelihood of; ensuring the availability and

reliability of mitigating systems to respond to; and providing reasonable assurance that

physical barriers protect the public from radio nuclide releases caused by, initiating

events. Specifically, the finding reflected the potential inability of the crews to take

appropriate safety-related actions in response to actual abnormal or emergency

conditions while they were on-shift prior to the requalification testing.

Since this is a more than minor requalification training issue, the risk importance

associated with the number of crews failing the annual operating tests is provided in

Appendix I of the SDP. The Simulator Operational Evaluation Matrix was entered using

the number of crews that took the simulator test, six, and the number of crews with less

than adequate performance, two. Based on these numbers, the finding was

characterized by the SDP as having very low safety significance (20 - 34% failure rate),

or Green. The finding is of very low safety significance because the failures occurred

during annual testing of the operators on the simulator, because there were no actual

consequences to the failures, because the crews were removed from watch standing

duties, retrained, and re-evaluated before they were authorized to return to control room

watches, and because the crew failure rate for the 2005 Unit 2 Annual Operating Exams

was less than 20%.

Enforcement. NRC regulations require that licensed operators pass an annual

operating test; the regulations do not specify pass/fail rates. When a failure occurs,

requirements are met by restricting the operator from licensed duties until the operator

has been retrained and successfully retested, steps which licensee staff completed.

Therefore, no violation of regulatory requirements occurred. Crew performance on the

2006 annual operating exams has been entered into the corrective action program

(CAP) as CR 2006-5797, and Constellation performed a level 1 root cause analysis of

these crew failures. (FIN 05000410/2006011-04, Unit 2 Crew Failure Rate on the

Dynamic Simulator Portion of the Annual Operating Examinations)

4. OTHER ACTIVITIES (OA)

Enclosure

13

4OA5 Other

1. Acceptability or Suitability of Nine Mile Point Unit 1 and Unit 2 Simulator Scenario-

Based-Tests (SBTs) For Meeting ANSI/ANS-3.5-1998 Performance Testing Criteria

The inspectors reviewed actions taken by Constellation since this item was opened

during a 2004 Licensed Operator Requalification Program inspection and determined

that this item will remain open pending further NRC review (i.e., the NRC has not

reached final resolution with the industry regarding an acceptable level of test

documentation to support this approach). (URI 05000220&410/2004005-03,

Acceptability or Suitability of Nine Mile Point Unit 1 and Unit 2 Simulator Scenario-

Based-Tests (SBTs) For Meeting ANSI/ANS-3.5-1998 Performance Testing Criteria)

4OA6 Meetings, including Exit

The lead inspector and the NRC Region I Operations Branch Chief presented the

inspection results to members of licensee management team in an onsite meeting at the

conclusion of the inspection on January 18, 2007. No materials reviewed were

identified by the licensee as proprietary.

Enclosure

A-1

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. OConnor, Site Vice President/Plant General Manager

M. Schimmel, Plant General Manager

N. Conicella, Operations Manager

T. Shortell, Training Manager

M. Miller, Director Licensing

B. Brown, General Superintendent Operations Training

J. Krakuzeski, Unit 1 Operations Supervisor

R. Slade, Unit 2 Operations Supervisor

D. Newman, Supervisor Operations Requal

M. McCrobie, Simulator Support Supervisor

M. Peterson, U1 Simulator Test Specialist

E. Benedicto, U1 Simulator Software Engineer

D. Kelly, Requal Exam Developer

G. Bobka, Operations Training

W. Coppom, Operations Training

NRC Personnel

L. Cline, Senior Resident Inspector

E. Knutson, Resident Inspector

J. Caruso, Senior Operations Examiner/Inspector

P. Presby, Operations Examiner/Inspector

R. McKinley, Operations Examiner/Inspector (UI)

J. Sullivan, Operations Examiner/Inspector (UI)

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000220/2006011-01 AV Failure to Ensure Integrity of Unit 1 Examinations and

Tests (Section 1R11.1)05000410/2006011-02 NCV Failure to Ensure Integrity of Unit 2 Examinations and

Tests (Section 1R11.2)05000220/2006011-03 FIN Unit 1 Crew Failure Rate on the Dynamic Simulator Portion

of the Annual Operating Examinations (Section 1R11.3)

Attachment

A-2

05000410/2006011-04 FIN Unit 2 Crew Failure Rate on the Dynamic Simulator Portion

of the Annual Operating Examinations (Section 1R11.4)

Discussed

05000220&410/2004005-03 URI Acceptability or Suitability of Nine Mile Point Unit 1 and

Unit 2 Simulator Scenario-Based-Tests (SBTs) For

Meeting ANSI/ANS-3.5-1998 Performance Testing Criteria

LIST OF DOCUMENTS REVIEWED

Procedures:

TAP-TQS-04 NMP Examination Standard Rev. 07

NTP-TQS-102 Licensed Operator Requalification Training Rev. 35

NTP-TQS-400 Instructions for Completing and Processing NRC Forms 396 and 398 Rev. 18

S-FFD-16 Fitness for Duty Procedure Rev. 04

S-ODP-TQS-0101 Administrative Controls for Maintaining Active License Status at NMP Rev.

04

GAI-OPS-13 Operations Score Card Program Rev. 03

NMP-TR-1.01-10 Analysis Phase Activities Rev. 0

NMP-TR-1.01-20 Design Phase Activities Rev. 0

NMP-TR-1.01-30 Development Phase Activities Rev. 0

NMP-TR-1.01-40 Implementation Phase Activities Rev. 0

NMP-TR-1.01-50 Evaluation Phase Activities Rev. 0

NMP-TR-1.01-60 Simulator Operation & Testing Rev. 0

NMP-TR-1.01-70 Training Administration Rev. 0

Other:

CR-NM-2006-4808

Category I Root Cause Analysis (CR-NM-2006-4808), Annual Licensed Operator

Requalification Exam Compromise

NMP1 2006 Biennial Exam Sample Plan

NMP1 Biennial Schedule 05/06 Rev.1

NMP1 Independent Self-Assessment Report, Assessment #: FSA-2006-43

Scenarios:

• O1-OPS-009-1-DY-71 rev. 0 AWTS w/ Main Condenser

• O1-OPS-009-1-DY-63 rev. 0 AWTS w/ Main Condenser

• O1-OPS-009-1-DY-05 rev. 4 AWTS w/o Main Condenser

• O1-OPS-009-1-DY-11 rev. 4 AWTS w/o Main Condenser

• O1-OPS-009-1-DY-17 rev. 2 AWTS w/o Main Condenser

• O1-OPS-009-1-DY-18 rev. 8 AWTS w/ Main Condenser

• O1-OPS-009-1-DY-25 rev. 6 Steam Leak in Drywell w/ blowdown

• O1-OPS-009-1-DY-39 rev. 6 Steam Leak in Drywell

Attachment

A-3

• O1-OPS-009-1-DY-48 rev. 4 AWTS w/ Main Condenser

• O1-OPS-009-1-DY-50 rev. 2 AWTS w/ Main Condenser and Torus Leak

• O1-OPS-009-1-DY-53 rev. 3 Steam Leak in Drywell

• O1-OPS-009-1-DY-54 rev. 3 AWTS w/o Main Condenser

• O1-OPS-009-1-DY-55 rev. 1 AWTS w/ Main Condenser

Open Simulator Deficiency Reports (DRs)

Scheduled Simulator Enhancements

Simulator Training Load Acceptance Reports

- June to August 2006

- Dec. 2005 to March 2006

- Sept. to Dec. 2005

- July to Sept. 2005

Simulator Exceptions List

Simulator Four Year Test Schedule

Simulator Configuration Control Board (SCCB) Meeting Minutes:

- October 19, 2005

- August 4, 2006

- July 14, 2006

Simulator Documents related to Jan 2004 Emer Cooling Test (NCV05000220/2004005-02)

- DR 3531

- DR 3538

- Upgrade DR 80

2005 Simulator Model Test, ANSI 3.5 Appendix "B" B1.2(3) Simultaneous Closure of All MSIVs

Simulator Deficiency Reports

- DR 3884, Recirc Pump Metering

- DR 3799, Offgas Controller

- DR 3798, RWCU Conductivity

- DR 3797, Indicator Should Read Downscale

- DR 3789, Safety Valve Outlet High Temperature

- DR 3782, Pressure Oscillation with TC05 Initiated

- DR 3760, Malfunctions FW29A&B Do Not Work

- Upgrade DR 165, Change Sim Status Hi Press Setting

Condition Reports Related to Simulator

- CR-NM-2005-542, NRC Identified Green NCV

- CR-NM-2005-615, NRC Identified URI on Suitability of SBTs

Simulator Scenario Based Tests for Cycle C09 and Cycle 10 (2006)

Simulator vs. Plant Comparison for Stuck Open ERV

Simulator vs. Plant Comparison for 8/3/04 Feedwater Spiking, Manual Scram

2005 Simulator Steady State Comparisons at 40%, 75% and 100%

Attachment