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{{#Wiki_filter:NRC INSPECTION MANUAL                                                   IOLB INSPECTION MANUAL CHAPTER 0609 APPENDIX I LICENSED OPERATOR REQUALIFICATION SIGNIFICANCE DETERMINATION PROCESS Effective Date: xx/xx/2018 0609I-01         PURPOSE The Licensed Operator Requalification Significance Determination Process (SDP) is used for determining the risk significance of findings identified during the inspection of licensed operator requalification activities and licensed operator performance.
{{#Wiki_filter:Issue Date: DRAFT 1
0609I-02         BACKGROUND This SDP was designed to assess the risk significance of findings associated with Inspection Procedure 71111, Attachment 11 (IP 71111.11), Licensed Operator Requalification Program and Licensed Operator Performance in the following areas: (1) requalification examination results, (2) biennial requalification written examinations, (3) annual requalification operating tests, (4) administration of an annual requalification operating test, (5) requalification examination security, (6) remedial training and re-examinations, and (7) the control room simulator.
0609 App I NRC INSPECTION MANUAL IOLB INSPECTION MANUAL CHAPTER 0609 APPENDIX I LICENSED OPERATOR REQUALIFICATION SIGNIFICANCE DETERMINATION PROCESS Effective Date: xx/xx/2018 0609I-01 PURPOSE The Licensed Operator Requalification Significance Determination Process (SDP) is used for determining the risk significance of findings identified during the inspection of licensed operator requalification activities and licensed operator performance.
0609I-02 BACKGROUND This SDP was designed to assess the risk significance of findings associated with Inspection Procedure 71111, Attachment 11 (IP 71111.11), Licensed Operator Requalification Program and Licensed Operator Performance in the following areas: (1) requalification examination results, (2) biennial requalification written examinations, (3) annual requalification operating tests, (4) administration of an annual requalification operating test, (5) requalification examination security, (6) remedial training and re-examinations, and (7) the control room simulator.
In regard to conformance with operator license conditions, such as the medical fitness of licensed operators and compliance with the regulations contained in 10 CFR 55.53, traditional enforcement may result. This is consistent with current and past NRC practice. In addition, conformance with operator license conditions and other violations of 10 CFR 55 may be addressed by referring to Inspection Manual Chapter (IMC) 0609, Appendix M, Significance Determination Process Using Qualitative Criteria.
In regard to conformance with operator license conditions, such as the medical fitness of licensed operators and compliance with the regulations contained in 10 CFR 55.53, traditional enforcement may result. This is consistent with current and past NRC practice. In addition, conformance with operator license conditions and other violations of 10 CFR 55 may be addressed by referring to Inspection Manual Chapter (IMC) 0609, Appendix M, Significance Determination Process Using Qualitative Criteria.
0609I-03         GUIDANCE Figure I.1, a flowchart contained on the following pages, presents a series of yes/no decision blocks for assessing licensed operator requalification and licensed operator performance findings. Following the flowchart, a description of each flowchart block is presented.
0609I-03 GUIDANCE Figure I.1, a flowchart contained on the following pages, presents a series of yes/no decision blocks for assessing licensed operator requalification and licensed operator performance findings. Following the flowchart, a description of each flowchart block is presented.  
Issue Date: DRAFT                                  1                                      0609 App I


Figure I.1 - Licensed Operator Requalification SDP Flowchart 1
Issue Date: DRAFT 2
Licensed Operator Requalification Finding 2                                           4 Related to       NO                           Related to    NO Biennial Requal.      Go to A Requalification                                                    on page 3 Exam Results?                                  Written Exam Quality?
0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart 1
YES YES 5
Licensed Operator Requalification Finding 2
3                                  Were greater than Failure rate      NO  Green                  40% of the   NO Green greater than          Finding              reviewed written   Finding 40%?                                      examination questions flawed?
Related to Requalification Exam Results?
YES YES White Finding                                 White Finding Issue Date: DRAFT                              2                            0609 App I
3 Failure rate greater than 40%?
White Finding NO Go to A on page 3 YES YES NO Green Finding 4
Related to Biennial Requal.
Written Exam Quality?
NO 5
Were greater than 40% of the reviewed written examination questions flawed?
YES YES White Finding NO Green Finding  


Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)
Issue Date: DRAFT 3
A from page 2 6                                         9 Related to     NO                      Related to Licensee Admin. of an Annual NO  Go to B Annual Requal.
0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)
Operating Test                             Requal. Operating      on page 4 Quality?                                      Test?
A from page 2 YES Green Finding NO White Finding YES 6
YES YES Green Finding 7
Related to Annual Requal.
Were greater   YES than 40% of the           White reviewed JPMs             Finding flawed?
Operating Test Quality?
NO 8
7 Were greater than 40% of the reviewed JPMs flawed?
Were greater than 40% of the         YES    White reviewed simulator             Finding scenario events flawed?
NO Go to B on page 4 YES Green Finding NO 9
NO Green Finding Issue Date: DRAFT                                3                          0609 App I
Related to Licensee Admin. of an Annual Requal. Operating Test?
8 Were greater than 40% of the reviewed simulator scenario events flawed?
White Finding YES NO  


Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)
Issue Date: DRAFT 4
B from page 3 10                                     12 Related to      NO                    Related to     NO  Go to C Requalification                           Licensee          on page Exam Security?                        Remedial Training        5 and Re-exams?
0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)
YES                                    YES Green Finding 11 Was there an actual effect on the equitable   NO and consistent             Green administration of any           FindingN examination required           CV by 10 CFR 55.59?
B from page 3 YES YES NO 10 Related to Requalification Exam Security?
11 Was there an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59?
NO Go to C on page 5
YES Evaluate using traditional enforcement against 10 CFR 55.49.
YES Evaluate using traditional enforcement against 10 CFR 55.49.
and evaluate using IMC 0609 Appendix M.
and evaluate using IMC 0609 Appendix M.
Issue Date: DRAFT                                4                          0609 App I
Green FindingN CV NO 12 Related to Licensee Remedial Training and Re-exams?
Green Finding


Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)
Issue Date: DRAFT 5
C from page 4 13 Related to Simulator Performance,         NO                          16 Testing,                           Re-evaluate the finding by Maintenance, or                        entering the SDP at block 1.
0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)
Modification?
C from page 4 YES White FindingReference appropriate SDP to determine significance of operator performance issues YES Green Finding NO 13 Related to Simulator Performance,
YES 14 Was a simulator             (Simulator testing, performance,      NO                                              Green maintenance, or                         Finding modeling, or              modification deficiency) fidelity deficiency identified?
: Testing, Maintenance, or Modification?
YES 15 Did deficient simulator performance, modeling, or fidelity negatively impact       NO            Green operator performance in                       Finding anthe actual plant event during a plant event where the risk increase due to the operator performance the event was >10E-6 delta CDF YES White FindingReference appropriate SDP to determine significance of operator performance issues Issue Date: DRAFT                                      5                                        0609 App I
16 Re-evaluate the finding by entering the SDP at block 1.
NO 14 Was a simulator performance, modeling, or fidelity deficiency identified?
(Simulator testing, maintenance, or modification deficiency) 15 Did deficient simulator performance, modeling, or fidelity negatively impact operator performance in anthe actual plant event during a plant event where the risk increase due to the operator performance the event was >10E-6 delta CDF YES Green Finding NO


Flowchart Block Descriptions:
Issue Date: DRAFT 6
#1 - The SDP starts after a single licensed operator requalification finding is identified from IP 71111.11 and screened through Manual Chapter 0612, Appendix B. Each specific finding must be evaluated separately.
0609 App I Flowchart Block Descriptions:  
#1 - The SDP starts after a single licensed operator requalification finding is identified from IP 71111.11 and screened through Manual Chapter 0612, Appendix B. Each specific finding must be evaluated separately.  
#2 - This is the top-level entry block associated with licensed operator performance as measured by the results of the requalification examinations required by 10 CFR 55.59(a)(2).
#2 - This is the top-level entry block associated with licensed operator performance as measured by the results of the requalification examinations required by 10 CFR 55.59(a)(2).
This block is answered yes or no based upon completing the specific guidance contained in section 03.03 of IP 71111.11 and upon completing the screening of inspection issues in accordance with IMC 0612.
This block is answered yes or no based upon completing the specific guidance contained in section 03.03 of IP 71111.11 and upon completing the screening of inspection issues in accordance with IMC 0612.  
#3 - Based upon the requalification examination results collected at the end of the testing cycle, was the failure rate greater than 40%? This block will be answered yes if either:
#3 - Based upon the requalification examination results collected at the end of the testing cycle, was the failure rate greater than 40%? This block will be answered yes if either:
(a) The individual examination failure rate is greater than 40% (IP 71111.11, Line 4 of Table 03.03-1), or (b) The crew simulator scenario failure rate is greater than 40% (IP 71111.11, Line 7 of Table 03.03-1).
(a) The individual examination failure rate is greater than 40% (IP 71111.11, Line 4 of Table 03.03-1), or (b) The crew simulator scenario failure rate is greater than 40% (IP 71111.11, Line 7 of Table 03.03-1).  
#4 - This is the top-level entry block associated with the quality of biennial requalification written examinations that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.a and Appendix B of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
#4 - This is the top-level entry block associated with the quality of biennial requalification written examinations that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.a and Appendix B of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.  
#5 - Were greater than 40% of the reviewed written examination questions flawed? In answering this question, the inspector will need to review the results from section 03.04.a and Appendix B of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed written examination questions used on a requalification examination required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a green finding results, based upon a lower percentage of flawed questions or other written examination deficiency.
#5 - Were greater than 40% of the reviewed written examination questions flawed? In answering this question, the inspector will need to review the results from section 03.04.a and Appendix B of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed written examination questions used on a requalification examination required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a green finding results, based upon a lower percentage of flawed questions or other written examination deficiency.  
#6 - This is the top-level entry block associated with the quality of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.b and Appendix C of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
#6 - This is the top-level entry block associated with the quality of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.b and Appendix C of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.  
#7 - Were greater than 40% of the reviewed job performance measures (JPMs) flawed? In answering this question, the inspector will need to review the results from section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed JPMs used on a requalification examination required by 10 CFR 55.59(a)(2).
#7 - Were greater than 40% of the reviewed job performance measures (JPMs) flawed? In answering this question, the inspector will need to review the results from section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed JPMs used on a requalification examination required by 10 CFR 55.59(a)(2).  
#8 - Were greater than 40% of the reviewed simulator scenario events flawed? In answering this question, the inspector will need to review the results from section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed simulator scenario events used on a requalification examination Issue Date: DRAFT                                6                                      0609 App I
#8 - Were greater than 40% of the reviewed simulator scenario events flawed? In answering this question, the inspector will need to review the results from section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed simulator scenario events used on a requalification examination  


required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a green finding results, based upon a lower percentage of flawed simulator scenario events and JPMs (checked in item
Issue Date: DRAFT 7
#7 above), or based upon some other operating test deficiency.
0609 App I required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a green finding results, based upon a lower percentage of flawed simulator scenario events and JPMs (checked in item  
#9 - This is the top-level entry block associated with the licensees administration of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.c and Appendix D of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
#7 above), or based upon some other operating test deficiency.  
#10 - This is the top-level entry block associated with requalification examination security. This block is answered yes or no based upon completing the specific guidance contained in section 03.04.d and Appendix E of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
#9 - This is the top-level entry block associated with the licensees administration of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.c and Appendix D of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.  
#11 - Was there an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59? In these instances, a licensed operator has gained an unfair advantage on an examination required by 10 CFR 55.59, and this condition was not corrected prior to being authorized to resume licensed duties. Use IMC 0609, Appendix M to evaluate the significance of more-than-minor performance deficiencies. These occurrences can be willful or intentional (cheating) or unintentional. Under these circumstances, tTraditional enforcement against 10 CFR 55.59 should also be considered when, since the regulatory process has likely been impacted. Examples of gaining an unfair advantage on an examination include: (1) a licensed operator obtains unauthorized assistance during an examination, such as by receiving assistance on a test item during an examination from an unauthorized individual or by copying answers from another examinee; (2) a licensed operator obtains specific knowledge of or is exposed to requalification examination content prior to taking the requalification examination; (3) a licensed operator is used to validate requalification examination test items during exam development, and is then subsequently administered a requalification examination with any test items duplicated from those that the operator previously validated.
#10 - This is the top-level entry block associated with requalification examination security. This block is answered yes or no based upon completing the specific guidance contained in section 03.04.d and Appendix E of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.  
#12 - This is the top-level entry block associated with remedial training and re-examinations, which occurs whenever a licensed operator fails any portion of a requalification examination required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.e and Appendix F of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
#11 - Was there an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59? In these instances, a licensed operator has gained an unfair advantage on an examination required by 10 CFR 55.59, and this condition was not corrected prior to being authorized to resume licensed duties. Use IMC 0609, Appendix M to evaluate the significance of more-than-minor performance deficiencies. These occurrences can be willful or intentional (cheating) or unintentional. Under these circumstances, tTraditional enforcement against 10 CFR 55.59 should also be considered when, since the regulatory process has likely been impacted. Examples of gaining an unfair advantage on an examination include: (1) a licensed operator obtains unauthorized assistance during an examination, such as by receiving assistance on a test item during an examination from an unauthorized individual or by copying answers from another examinee; (2) a licensed operator obtains specific knowledge of or is exposed to requalification examination content prior to taking the requalification examination; (3) a licensed operator is used to validate requalification examination test items during exam development, and is then subsequently administered a requalification examination with any test items duplicated from those that the operator previously validated.  
#13 - This is the top-level entry block associated with control room simulator performance, maintenance, and testing, as specified in 10 CFR 55.46. This block is answered yes or no based upon completing the specific guidance contained in section 03.04.g and Appendix G of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
#12 - This is the top-level entry block associated with remedial training and re-examinations, which occurs whenever a licensed operator fails any portion of a requalification examination required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.e and Appendix F of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.  
#14 - Was a simulator performance, modeling, or fidelity deficiency identified? This block is used to differentiate between deficiencies associated with simulator performance (including deficiencies with modeling or fidelity) and deficiencies associated with simulator testing, maintenance, and modification. These issues are treated slightly differently in the SDP, due to the potential for unrealistic operator training due to deficient simulator performance. If this block is answered no, the deficiency is associated with simulator testing, maintenance, or Issue Date: DRAFT                                  7                                    0609 App I
#13 - This is the top-level entry block associated with control room simulator performance, maintenance, and testing, as specified in 10 CFR 55.46. This block is answered yes or no based upon completing the specific guidance contained in section 03.04.g and Appendix G of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.  
#14 - Was a simulator performance, modeling, or fidelity deficiency identified? This block is used to differentiate between deficiencies associated with simulator performance (including deficiencies with modeling or fidelity) and deficiencies associated with simulator testing, maintenance, and modification. These issues are treated slightly differently in the SDP, due to the potential for unrealistic operator training due to deficient simulator performance. If this block is answered no, the deficiency is associated with simulator testing, maintenance, or  


modification (as verified in the next block), and results in a green finding. If this block is answered yes, proceed to block 15.
Issue Date: DRAFT 8
0609 App I modification (as verified in the next block), and results in a green finding. If this block is answered yes, proceed to block 15.  
#15 - Did deficient simulator performance, modeling, or fidelity negatively impact operator performance in the actual plant during a plant event? The concern with this block is that the simulator provided un-realistic or negative training to licensed operators (due to deficiencies in simulator performance, modeling, or fidelity), and that this un-realistic simulator training negatively impacted operator performance during an event. Reference appropriate SDP guidance (At-Power, Shutdown, or others) to determine if the negative operator performance resulted in a risk increase of greater than 10E-6 delta CDF or greater than 10E-7 delta LERF.
#15 - Did deficient simulator performance, modeling, or fidelity negatively impact operator performance in the actual plant during a plant event? The concern with this block is that the simulator provided un-realistic or negative training to licensed operators (due to deficiencies in simulator performance, modeling, or fidelity), and that this un-realistic simulator training negatively impacted operator performance during an event. Reference appropriate SDP guidance (At-Power, Shutdown, or others) to determine if the negative operator performance resulted in a risk increase of greater than 10E-6 delta CDF or greater than 10E-7 delta LERF.
Qualitative SDP results may also be used to determine if the risk increase is greater than green.
Qualitative SDP results may also be used to determine if the risk increase is greater than green.
If the answer to this block is yes, then this results in a white finding with significance commensurate with the risk increase due to the negative operator performance, based upon the appropriate SDP guidance. deficient simulator performance affecting licensed operator performance during a plant event of NRC concern. If the answer to this block is no, then this results in a green finding, since deficient simulator performance was still identified.
If the answer to this block is yes, then this results in a white finding with significance commensurate with the risk increase due to the negative operator performance, based upon the appropriate SDP guidance. deficient simulator performance affecting licensed operator performance during a plant event of NRC concern. If the answer to this block is no, then this results in a green finding, since deficient simulator performance was still identified.  
#16 - Re-evaluate the finding by entering the SDP at block 1. The SDP is arranged as a series of top-level entry blocks, and block #16 should not occur unless all the entry blocks have been answered NO. If this is the case, re-evaluate the finding and enter the SDP at block #1, in case an error was made.
#16 - Re-evaluate the finding by entering the SDP at block 1. The SDP is arranged as a series of top-level entry blocks, and block #16 should not occur unless all the entry blocks have been answered NO. If this is the case, re-evaluate the finding and enter the SDP at block #1, in case an error was made.
Issue Date: DRAFT                                  8                                        0609 App I


ATTACHMENT 1 - Revision History - IMC 0609, Appendix I Commitment     Accession                 Description of Change             Description of Training Comment Resolution and Tracking          Number                                                      Required and            Closed Feedback Form Number          Issue Date                                                    Completion Date        Accession Numbers Change Notice                                                                          (Pre-Decisional, Non-Public Information)
Issue Date: DRAFT Att1-1 0609 App I ATTACHMENT 1 - Revision History - IMC 0609, Appendix I Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public Information)
N/A     ML021060448     Revised the description of the flow chart       None                    N/A 03/27/2002      blocks to: 1) incorporate the first years CN 02-011      lessons learned, 2) reflect the change to 10 CFR 55.46 (Simulator Rule), and 3) align with 10 CFR 55.49 (integrity of examinations and tests).
N/A ML021060448 03/27/2002 CN 02-011 Revised the description of the flow chart blocks to: 1) incorporate the first years lessons learned, 2) reflect the change to 10 CFR 55.46 (Simulator Rule), and 3) align with 10 CFR 55.49 (integrity of examinations and tests).
N/A     ML0524300990   Revised to match current revision to IP         None                    N/A 8/22/2005      71111.11 (Operator Requalification) and to fix CN 05-023      several flaws that have been identified and will enhance the flowchart and matrix.
None N/A N/A ML0524300990 8/22/2005 CN 05-023 Revised to match current revision to IP 71111.11 (Operator Requalification) and to fix several flaws that have been identified and will enhance the flowchart and matrix.
N/A     ML113270313     Complete re-write of document. Arranged         Training held by        ML113250576 12/06/11        flowchart to mirror inspection areas of revised teleconference with CN 11-040      IP 71111.11, removed all minor finding blocks   Regional examiners on (minor findings should be screened out prior to 11/30/11 reaching the SDP), and simplified examination results logic.
None N/A N/A ML113270313 12/06/11 CN 11-040 Complete re-write of document. Arranged flowchart to mirror inspection areas of revised IP 71111.11, removed all minor finding blocks (minor findings should be screened out prior to reaching the SDP), and simplified examination results logic.
ML18257A059     Made public to solicit industry comments DRAFT N/A     ML18178A571x   Reformatted and streamlined to reflect revision None                    ML18177A421 x/xx/18        to IMC0040. Added guidance to refer to IMC CN 18-xxx      0609 Appendix M in certain instances. Tied                               Closed FF:
Training held by teleconference with Regional examiners on 11/30/11 ML113250576 ML18257A059 DRAFT Made public to solicit industry comments N/A ML18178A571x x/xx/18 CN 18-xxx Reformatted and streamlined to reflect revision to IMC0040. Added guidance to refer to IMC 0609 Appendix M in certain instances. Tied white finding for simulators to the delta CDF and delta LERF of the actual plant event.
white finding for simulators to the delta CDF                           0609I-1849 and delta LERF of the actual plant event.                               ML18178A205 0609I-2232 ML18178A225 0609I-2160 ML18178A232 0609I-2309 ML18178A260 Issue Date: DRAFT                                          Att1-1                                                0609 App I}}
None ML18177A421 Closed FF:
0609I-1849 ML18178A205 0609I-2232 ML18178A225 0609I-2160 ML18178A232 0609I-2309 ML18178A260}}

Latest revision as of 13:04, 5 January 2025

IMC 0609 App I Licensed Operator Requalification Program Significance Determination Process Public Draft
ML18257A059
Person / Time
Issue date: 09/14/2018
From: Brian Tindell
NRC/NRR/DIRS/IOLB
To:
Tindall B
Shared Package
ML18177A399 List:
References
DC 18-016
Download: ML18257A059 (9)


Text

Issue Date: DRAFT 1

0609 App I NRC INSPECTION MANUAL IOLB INSPECTION MANUAL CHAPTER 0609 APPENDIX I LICENSED OPERATOR REQUALIFICATION SIGNIFICANCE DETERMINATION PROCESS Effective Date: xx/xx/2018 0609I-01 PURPOSE The Licensed Operator Requalification Significance Determination Process (SDP) is used for determining the risk significance of findings identified during the inspection of licensed operator requalification activities and licensed operator performance.

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

In regard to conformance with operator license conditions, such as the medical fitness of licensed operators and compliance with the regulations contained in 10 CFR 55.53, traditional enforcement may result. This is consistent with current and past NRC practice. In addition, conformance with operator license conditions and other violations of 10 CFR 55 may be addressed by referring to Inspection Manual Chapter (IMC) 0609, Appendix M, Significance Determination Process Using Qualitative Criteria.

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

Issue Date: DRAFT 2

0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart 1

Licensed Operator Requalification Finding 2

Related to Requalification Exam Results?

3 Failure rate greater than 40%?

White Finding NO Go to A on page 3 YES YES NO Green Finding 4

Related to Biennial Requal.

Written Exam Quality?

NO 5

Were greater than 40% of the reviewed written examination questions flawed?

YES YES White Finding NO Green Finding

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0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)

A from page 2 YES Green Finding NO White Finding YES 6

Related to Annual Requal.

Operating Test Quality?

7 Were greater than 40% of the reviewed JPMs flawed?

NO Go to B on page 4 YES Green Finding NO 9

Related to Licensee Admin. of an Annual Requal. Operating Test?

8 Were greater than 40% of the reviewed simulator scenario events flawed?

White Finding YES NO

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0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)

B from page 3 YES YES NO 10 Related to Requalification Exam Security?

11 Was there an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59?

NO Go to C on page 5

YES Evaluate using traditional enforcement against 10 CFR 55.49.

and evaluate using IMC 0609 Appendix M.

Green FindingN CV NO 12 Related to Licensee Remedial Training and Re-exams?

Green Finding

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0609 App I Figure I.1 - Licensed Operator Requalification SDP Flowchart (continued)

C from page 4 YES White FindingReference appropriate SDP to determine significance of operator performance issues YES Green Finding NO 13 Related to Simulator Performance,

Testing, Maintenance, or Modification?

16 Re-evaluate the finding by entering the SDP at block 1.

NO 14 Was a simulator performance, modeling, or fidelity deficiency identified?

(Simulator testing, maintenance, or modification deficiency) 15 Did deficient simulator performance, modeling, or fidelity negatively impact operator performance in anthe actual plant event during a plant event where the risk increase due to the operator performance the event was >10E-6 delta CDF YES Green Finding NO

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0609 App I Flowchart Block Descriptions:

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

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

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

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

  1. 4 - This is the top-level entry block associated with the quality of biennial requalification written examinations that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.a and Appendix B of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
  1. 5 - Were greater than 40% of the reviewed written examination questions flawed? In answering this question, the inspector will need to review the results from section 03.04.a and Appendix B of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed written examination questions used on a requalification examination required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a green finding results, based upon a lower percentage of flawed questions or other written examination deficiency.
  1. 6 - This is the top-level entry block associated with the quality of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.b and Appendix C of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
  1. 7 - Were greater than 40% of the reviewed job performance measures (JPMs) flawed? In answering this question, the inspector will need to review the results from section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed JPMs used on a requalification examination required by 10 CFR 55.59(a)(2).
  1. 8 - Were greater than 40% of the reviewed simulator scenario events flawed? In answering this question, the inspector will need to review the results from section 03.04.b and Appendix C of IP 71111.11. If the answer to this block is yes, then a white finding results, based upon a higher percentage of flawed simulator scenario events used on a requalification examination

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0609 App I required by 10 CFR 55.59(a)(2). If the answer to this block is no, then a green finding results, based upon a lower percentage of flawed simulator scenario events and JPMs (checked in item

  1. 7 above), or based upon some other operating test deficiency.
  1. 9 - This is the top-level entry block associated with the licensees administration of annual requalification operating tests that are required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.c and Appendix D of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
  1. 10 - This is the top-level entry block associated with requalification examination security. This block is answered yes or no based upon completing the specific guidance contained in section 03.04.d and Appendix E of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
  1. 11 - Was there an actual effect on the equitable and consistent administration of any examination required by 10 CFR 55.59? In these instances, a licensed operator has gained an unfair advantage on an examination required by 10 CFR 55.59, and this condition was not corrected prior to being authorized to resume licensed duties. Use IMC 0609, Appendix M to evaluate the significance of more-than-minor performance deficiencies. These occurrences can be willful or intentional (cheating) or unintentional. Under these circumstances, tTraditional enforcement against 10 CFR 55.59 should also be considered when, since the regulatory process has likely been impacted. Examples of gaining an unfair advantage on an examination include: (1) a licensed operator obtains unauthorized assistance during an examination, such as by receiving assistance on a test item during an examination from an unauthorized individual or by copying answers from another examinee; (2) a licensed operator obtains specific knowledge of or is exposed to requalification examination content prior to taking the requalification examination; (3) a licensed operator is used to validate requalification examination test items during exam development, and is then subsequently administered a requalification examination with any test items duplicated from those that the operator previously validated.
  1. 12 - This is the top-level entry block associated with remedial training and re-examinations, which occurs whenever a licensed operator fails any portion of a requalification examination required by 10 CFR 55.59(a)(2). This block is answered yes or no based upon completing the specific guidance contained in section 03.04.e and Appendix F of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
  1. 13 - This is the top-level entry block associated with control room simulator performance, maintenance, and testing, as specified in 10 CFR 55.46. This block is answered yes or no based upon completing the specific guidance contained in section 03.04.g and Appendix G of IP 71111.11, and upon completing the screening of inspection issues in accordance with IMC 0612.
  1. 14 - Was a simulator performance, modeling, or fidelity deficiency identified? This block is used to differentiate between deficiencies associated with simulator performance (including deficiencies with modeling or fidelity) and deficiencies associated with simulator testing, maintenance, and modification. These issues are treated slightly differently in the SDP, due to the potential for unrealistic operator training due to deficient simulator performance. If this block is answered no, the deficiency is associated with simulator testing, maintenance, or

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0609 App I modification (as verified in the next block), and results in a green finding. If this block is answered yes, proceed to block 15.

  1. 15 - Did deficient simulator performance, modeling, or fidelity negatively impact operator performance in the actual plant during a plant event? The concern with this block is that the simulator provided un-realistic or negative training to licensed operators (due to deficiencies in simulator performance, modeling, or fidelity), and that this un-realistic simulator training negatively impacted operator performance during an event. Reference appropriate SDP guidance (At-Power, Shutdown, or others) to determine if the negative operator performance resulted in a risk increase of greater than 10E-6 delta CDF or greater than 10E-7 delta LERF.

Qualitative SDP results may also be used to determine if the risk increase is greater than green.

If the answer to this block is yes, then this results in a white finding with significance commensurate with the risk increase due to the negative operator performance, based upon the appropriate SDP guidance. deficient simulator performance affecting licensed operator performance during a plant event of NRC concern. If the answer to this block is no, then this results in a green finding, since deficient simulator performance was still identified.

  1. 16 - Re-evaluate the finding by entering the SDP at block 1. The SDP is arranged as a series of top-level entry blocks, and block #16 should not occur unless all the entry blocks have been answered NO. If this is the case, re-evaluate the finding and enter the SDP at block #1, in case an error was made.

Issue Date: DRAFT Att1-1 0609 App I ATTACHMENT 1 - Revision History - IMC 0609, Appendix I Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public Information)

N/A ML021060448 03/27/2002 CN 02-011 Revised the description of the flow chart blocks to: 1) incorporate the first years lessons learned, 2) reflect the change to 10 CFR 55.46 (Simulator Rule), and 3) align with 10 CFR 55.49 (integrity of examinations and tests).

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

None N/A N/A ML113270313 12/06/11 CN 11-040 Complete re-write of document. Arranged flowchart to mirror inspection areas of revised IP 71111.11, removed all minor finding blocks (minor findings should be screened out prior to reaching the SDP), and simplified examination results logic.

Training held by teleconference with Regional examiners on 11/30/11 ML113250576 ML18257A059 DRAFT Made public to solicit industry comments N/A ML18178A571x x/xx/18 CN 18-xxx Reformatted and streamlined to reflect revision to IMC0040. Added guidance to refer to IMC 0609 Appendix M in certain instances. Tied white finding for simulators to the delta CDF and delta LERF of the actual plant event.

None ML18177A421 Closed FF:

0609I-1849 ML18178A205 0609I-2232 ML18178A225 0609I-2160 ML18178A232 0609I-2309 ML18178A260