ML20210H892
| ML20210H892 | |
| Person / Time | |
|---|---|
| Site: | 05561425 |
| Issue date: | 08/04/1997 |
| From: | Caruso J, Guenther S NRC (Affiliation Not Assigned) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20210H877 | List: |
| References | |
| 97-725-02-SP, 97-725-2-SP, SP, NUDOCS 9708140234 | |
| Download: ML20210H892 (22) | |
Text
August 4,1997 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Before Presiding Officer:
G. Paul Bollwerk, Ifi, Adminletrative Judge Special Assistant:
Thomas D. Mughy, Administrative Judge In the Matter of )
) Docket No. 55-61425-SP FRANK J. CALABRESE, JR. )
) ASLB No. 725-02.SP (Denial of Application for Senior )
Reactor Operator License) )
STAFF RESPONSE TO PRESIDING OFFICER QUESTIONS <
IN THE FORM OF AN AFFIDAVIT BY SIEGFRIED GUENTHERJ JOHN G. CARUSO. AND TRACY E. WAIEFR We, Siegfried Guenther, John G. Caruso, and Tracy E. Walker, having first been duly sworn, do hereby state as follows:
I. In a MEMORANDUM AND ORDER dated July 23,1997, the Presiding Officer requested that the Staff address the following questions, in writing, under oath or affumation, with appropriate supporting hm- :Ary data, informational material, or other written evidence.
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2-S A. Regarding the Staffs June 19,1997, joint affidavit: 1 t 1. Did Siegfried Guenther, John G. Caruso, and Tracy E. Walker sponsor each of the paragraphs la the afrxiavit in toto? If not, please indicate which affiants did not sponsor which particular paragraphs of that affutavit.
Response: 1he Pr~'**% states the Staffs view of the situation and each of the affiants stands by the truth and accuracy of each and every paragraph. .
- 2. What was Mr. Guenther's role in the staff review of Mr. Calabrese's application?
Resoonse: Mr. Guenther is a Senior Reactor Engineer in the Operator Licensing Branch (OLB), Division of Reactor Controls and Human Factors, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatoly Commission (NRC), Washington, D.C. The OLB is charged with managing and overseeing the-NRC's operator ernmination and licensing programs, including the examination appeal process, which is conducted in accordance with Section ES 502 of NUREG-1021, " Operator Licensing Eraminar Standards.
Mr. Guenther is an experienced exatniner who is very familiar with the NRC's .
examination procedures and expectations regarding operator performance. Mr. Guenther did not become involved with Mr. Calabrese's examination or his appeal until be was -
tasked with collecting the information for the Hearing File and subsequently with preparing
' the NRC Staffs Presentation dated June 30,1997, based on information provided by the other affiants and agency records. Although Mr. Guenther was not present during
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. 3 I Mr. Calabrese's simulator test, he has no reason to doubt that the Presentation is f completely tmthful and accurate.
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! B. Did Mr. Sisco create any contemporaneous notes regarding the simulator test in which Mr. Calabrese and Mr. Avery participated? If so, please explain when and why i those notes were destroyed.
Resoonu . As stated in the attached Affidavit, Carl E. Sisco did take notes 1
regarding the conduct of the applicant he was testing. He discarded his notes when his l
Branch Chief signed the license of the applicant he had examineA. His actions were consistent with his usual and standard practice and in compliance with Section 3.b of i
ES 303 (page 7 of-27) and Section D.1 of ES 501 (page 2 of 24) of NUREG-1021, Revision 7, Supplement 1, which was then in effect. Those standards direct the examiner to retain the rough notes and documentation until the chief examiner and management have 4
reviewed arid concurred in the results and to discard them thereafter.
In addition, the Staff, after reviewing the affidavit of Mr. Avery, who was examined by Mr. Sisco, concluded, that none of the statements made in the affidavit 3
conflicted with the staffs recollection and, further, that Mr. Avery's statements would not affect Mr. Calabrese's scoring on the exam.
C. If staff examiners (1) had observed Mr. Calabrese having difficulty finding the procedure board for EO-100-112, and/or (2) if Mr. Calabrese had indicated to staff exansners after the simulator exercise that initially he was unable to locate the procedure board for EO-100112, would that information have affected the scoring of his test? If that
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-information would not have affected Mr. Calabrese's score, please explain in detail why not. If that information would have affectad his score, please explain in detail how and why.
Response: Mr. Calabrese's score on Rating Factor 4.a. (i.e, reference to procedures) would not have been affected even if he had indicated, or a staff examiner had observed, that he was having difficulty finding EO-100-112 for the following rease .
Section 6.18.6.f of Susquehanna Nuclear Department Procedure OP-AD-001,
". Operations Policies and Work Practices," states that "EOP (emergency operating b procedure) flowchart [s] shall be present arid continuously referred to while being executed." If Mr. Calabrese was having difficulty locating EO-100-112, he should have delayed the rapid depressurization until he obtained a copy of the procedure. By the time the rapid depressurization was started, the radiation fields in two areas had already exceeded mrximum safe levels. Delaying the rapid depressurization for one more minute to find the procedure woa'd not have made a significant difference in the radiation levels.
In many cases, the potential consequences of performing incorrect actions _when directing
- actions from memory are more significant than the consequences of delaying action in order to refer to the procedure. For this reason, many facilities, including Sug=h==,
- have defined a limited number of activities which are time critical and should be performed from memory. Rapid depressurization is not considered a time critical activity.
As explained in paragraph 36 of the Staff Presentation, the symptom-based emergency operating procedures differ from other procedures used in the control room in
that the Unit Supervisor (US) has sole responsibility for obtaining the correct proc,edure, determining the proper course of action, and giving appropriate directions to the other members of the operating crew. Attesopting to locate the emergency operating procedures
- is not sufficient to justify a satisfactory grsd
- on Rating Factor 4.a. which requires i
applicants to obtain and refer to the correct procedures, as appropriate. Mr. Calabrese has l
not disputed the fact that ht did not refer to EO 100112 prior to directing the rapid depressurization.
Because Scenaric No. 2 was the only scenario in which Mr. Calabrese filled the role of the US, it provided the NRC with its only opportunity to evaluate Mr. Calabrese's understanding of and ability to execute the emergency operating procedures in a dynamic and realistic operating environment. The fact that Mr. Calabrese correctly referred to a l
number of other procedures many of them as an RO . during his simulator operating test does not rritigate the significance of the errors that he committed as the US, the SRO licensed position for which Mr. Calabrese was attempting to qualify. The Staff fully expected that Mr. Calabrese, a su SRO upgrade applicant with over five years' experience as an RO, would perform satisfactorily at the RO level during Scenario No. 3.
As noted in paragraph 34 of the Staff Presentation, the Staff evaluated Mr. Calabrese's failure to refer to EO-100112 in light of the ' behavioral anchors' for Rating Ft.ctor 4.a on Form ES 303 4, 'SRO Competency Grading Worksheets for Integrated Plant Operations.' 'Ihe Staff concluded that Mr. Calabrese's performance with regard to that rating factor most tbsely matched the description for a grade of *1' on the
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6 3 point rating scale in that he failed to correctly nfer to procedures in an important l
instance.
r-Finally, as explained in Paragraph 46 of the Staffs Presentation, it is impossible l
l for the NRC to test each license applicant under every situation to which he or she might I
l have to respond as an operator. Therefore, the Staff must draw inferences regarding an I
applicant's overall cotop t::.ce based on a liuinted set of observations. Mr. Calabrene's l
failure to refer to the required emettency operating procedures raises serious doubts about his ' ability to function within the control room team as appropriate to the assigned position, in such a way that the facility licensee's procedures are adhered to and that the limits of its license and amendments are not violated.' (10 C.F.R. I 55.4$(a)(13))
D. Regarding the tallboard discussion with the other operators: '
- 1. In scoring a simulator exam, would staff examiners normally make an effort to listen in on a tailboard discussion and take that discussion into account in assigning an examination score? If not, please explain in detail why not.
Response: NRC cuminers are trained and expected to monitor all communications that take place among the operators on the simulator crew as well as those that take place between the operators and outside personnel, such as an auxiliary operator or load dispatcher. Such observations are necessary for the examiners to evaluate the applicants' performance on 0:ei- =y 6 (i.e., communications and crew lateraction), in accordance with Section ES 303 of NUREG 1021, and are often documented in the e==l=r's field notes, Hearing File Items 6 and 7 contain several examples of such commurJcations, some 4
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as routine as an announcr. ment that a particular alarm had actuated or that the I&C (instrumentation and control) staff had been called to investigate an equipment problem.
it is probable, but not necessarily assured, that a tailboard discussion of a nature that I examiners are accustomed to seeing (l.a., a briefing in which the planned course of action is discussed in some detail) would be remembered and recorded in the summiners' field notes, it is possible that Mt. Calabrese's conception of a "tallboard" is different from that generally understood by NRC examiners.
The likelihood that the NRC examiners would have heard a tallboard discussion is ,
.l supported by the fact that Mr. Caruso and Ms. Walker were standing within a few feet from their respective applicants throughout most of the simulator test and that all four individuals were in close proximity to each other. '!he physical area in which the simulator test took place is not large. The staff examiners were not only in a position to observe clo!ely everything their applicants said and did but also to hear and observe the comments and responses of the other applicants. Moreover, at this critical junctu~ in the '
scenario, Ms. Walker's applicant, Mr. Robinson, was carrying out the directions given by Mr. Calabrese to rapidly depressurire the plant, themfore, she was very focused on the directions provided by Mr. Calabrese as well as the actions taken by Mr. Robinson.
Additionally, as noted in Paragraph 50 of the Staff's Presentation, the summiners have no reason to believe that the applicants were not instructed per Attachment 1
" Operating Test Briefing," of ES 302 that they should speak loudly and clearly, even
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during discussions among themselver, so that the examiners could evaluate their perfonnance without hindering their ability to operate the simulator.
The Staff disagrees with the assertion in Mr. Calabrese's Reply Presentation of 1
July 17,1997, that there was no reason why the NRC ernminers would remember a detail such as the tallboard discussion and that the simulator test, which occuned eight months j l
ago, is not likely to have been particalirly signirsant to any of the NRC examiners. '!he l
-additional effort required to evaluate and document unsadsfactory performance on a license -
1 examination coupled with the implications of denying a license application causes NRC examiners to focus their attention on thosa few operators who fall to perfonn at an acceptable level, thereby enhancing their recollection of those tests.
Furthennore, in accordance with Section C.3.m of ES402 the examiners are 1
required to confer after completing the simulator test m compare notes and the chief examiner is required to ensure that the e==l=es' observations are consistent and that their fmdings are murually supportive. In this case, since the actions of more than one applicant were in question, all three examiners discussed the specifics of the scenario prior to leaving ]
1 the site on the day of the simulator tests. This meeting included detailed discussions that focusal, in particular, on the performance of Messrs. Calabrese aE Robinson since it was clear to the examirers that their actions did not meet expectations. 'Ibese factors combined with the fact that the examiners have been extensively involved with Mr. Calabrese's appeal proceedings have maintained and reinforced their recollection of the facts.
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Furthermore, the chief examiner's involvement in a licensed operator 42 qualification program inspection at the Susquehanna facility in February 1996 as documented in the attached inspection report dated April 9,1996, belghtened her interest in Scenario No. 2.
In Section 2.2 of that report, the examiner documented a concern that the facility's simulator scenarios generally contained a limited number of success paths and little variation in event severity. The success path in 2.2 of the 27 non ar'icipated transient without scram scenarios was to rapidly depressurize the reactor vessel. None of these i scenarios contained a failure in which all the control rods did not insert which would vary ,
the required operator actions (i.t., require the operators to terminate and prevent low
.. pressure injection without having deliberately lowered RPV water level). Because of these limitations, the chief examiner modified the scenario that had been proposed by the facility licensee for the October 1996 examination to specifically test the applicants' ability to terminate and prevent irdection by the low pressure systems when all control rods were not insened, but RPV water level had not been deliberately lowered. For this reason, the chief examiner had a professional interest in and was likely to recall the applicants' performance in Scenario No. 2.
- 2. if the answer to question D.1. is yes, assuming the tallboard discussion between Mr. Calabrese, Mr. Gordon Robinson, and Mr. Avety occurred as it is described in Mr. Calabrese's May 30, 1997 affidavit and the July 11,1997 affidavits of Mr. Calabrese, Mr. Robinson, and Mr. Avery, and the staff was cognizant of the substance of that discussion, would that discussion have affected
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the scoring of Mr. Calabrene's test? If staff knowledge of the discubion as
! described in the affidavits would not affect M4 Calabrew's score, please explain in detail why not. If staff knowledge of the discussion as described in the affidavits l
would have affected Mr. Calabrese's score, please explain in detail how and why.
Response: Even if the tallboard discussion had occurred precisely as described in l
Mr. Calabre'e's affidavits, it would not have affected the scoring of G. Calabrese's-simulator test for the following reasons:
Mr. Calabrese failed the simulator test because he failed to properly refer to and unsult EO 100112 and EO 100113, as explained in Paragraphs 34 42 cf the Staff's
- Presentation. Whether or not he conducted a tallboard discussion has no bearing on the Staffs evaluation of Rating Factors 4.a (i.e., reference to the correct procedures) and 4.b (i.e., compliance with procedural steps).
With regard to Rating Factor 4.3, the NRC Staff concluded that Mr. Calabrese's-performance most closely matched the description for a grade of "1" on the 3 point rating scale in that he failed to correctly refer to procedures in an important instance.1he Staff considered the intermediate behavioral anchor (i.e., the one associated with a grade of "2")
and concluded that it was inappropriate because the consequences of the error (possible severe core damage) rose above the level of what could reasonably be classified as a
" minor" lapse in referring to or locating the correct procedure.
With regard to Rating Factor 4 b. the NRC Staff concluded that Mr. Calabrese's performance most closely matched the description for a grade of "1" on the 3 point rating i
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scale in that he made a significant error that degraded the plant unnecessarily by ine'reasing the risk of a power excursion and severe core damage. Here again, the Staff cond*.ered the intermediate behavioral anchor and concluded that it was inappropriate because the coruequences of the error (possible severe core damage) rose above the level of what could
! reasonably be classified as " minor."
The Stafra ; valuation of Rating Factor 4.b was based on Mr. Calabrese's failure to comply with Step RD 5 of EO-100112, in that he did not wait until all low pressure RPV injection was stopped and prevented befort he directed that all ADS valves be opened to rapidly depressurize the RPV. Moreover, Mr. Calabrese did not comply with Step
, LQ/L 19 of EO 100113, as clarified below:
EO 104113 consists of three legs, 'Q/Q," "LQ/L," and 'LQ/P " all of which the Unit Supervisor must monitor and control concurrently. Mr. Calabrese had entered EO 10411? when he could not determine that the reactor would remain shutdown under all conditions without boron due to the failure of several control rods to insert. At the time he concluded that rapid depressurization was required, Mr. Calabrese should have been maintaining reactor water level in accordance with Step LQ/L 12 of EO 100113 and waiting for the hot shutdown boron weight to be igjected so that be could continue in accordance with Step LQ/L 17. Steps LQ/L-12 and LQ/L-17 are both located below Step LQ/L-9, which is an override step that directs transition to Step LQ/L 19 when rapid depre:mrizatioa is required. 'therefore, when the conditions of Step LQ/L 9 were met, Mr. Calabrese should have transitioned to Step LQ/L-19, which directs that iq}ection from i
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1 12 all but four high pressure systems (i.e., standby liquid control, control rod drive,' reactor core isolation cooling, and high pressure coolant idection) be stopped and prevented.
Mr. Calabrese's statement that he was never at Step 14/b9 of EO 100113 (see Paragraph 4 of his supplemental amdavit) confirms the Staffs conclusion that Mr.
l Calabrese did not comply with EO 100113.
Mr. Avery's amdavit does not indicate that Mr. Calabrese directed him te de action to prevent injection from the condensate system or to confum that idection was prevented. This further supports the Staffs position that Mr. Calabrese did not comply with Step LQ/L 19 of EO 100113, in that he failed to direct action to prevent idection
- from the condensate system.
Paragraphs 4, 5, and 6 of Mr. Robinson's affidavit curioWrate the fact that Mr. Calabrese ;,se the order to rapidly depressurize before inhibiting the low pressure ECCS pumm even though there was no assurance that the reactor would remain shutdown under all conditions without boron. Even if Mr. Calabrese had stated that it would be necessary to prevent low pressure injection during his discussions with Mr. Robinson, he failed to direct that the action be performed.
The Staff also notes that Mr. Robinson's concern that he could not question-Mr. Calabrese's order because it would ba. considered prompting is cuoo.ry to the ,
instructions that the examiners have every reason to believe he was provided during the pre test briefing (Refer to Paragraph 50 of the Staff Presentation). Item C.1 of Attachment 1 to ES 302 states that if an applicant recognizes, but fails to correct an
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erroneous action by the crew, that the examiner will conclude that the applicantIngreed with the item. Mr. Robinson's failure to cornet Mr. Calabrese's erroneous order to open I
the ADS valves before preventing low pressure ECCS lidection is reflected in his score of j
- 1" in Rating Factor 3.c because be did not demonstrate an understanding of how his actions affected plant conditions.
If the NRC Staff 1.cd taken issue with Mr. Calabrese's conduct of a taubard discussion, it would have been documented and scored in connection with Competency 6, l
l l " Communications and Crew Interactions," or Couvay 7. " Directing Shift Operations." l Mr. Calabrese's score for Rating Factor 7 b reflects the fact that be did not provide directions for the other applicants to rapidly depressurize for approximately five minutes after the radiation levels in two areas reached the maximum safe value. However, his overall scores for Competencies 6 and 7 were satisfactory and are not in dispute.
Before gning on to the next question, the Staff wishes to address Mr. Calabrese's erroneous interpretation of NRC examiner Caruso's field notes (Hearing File item 6).
Mr. Calabrese, in his July 11, 1997 affidavit, misquoted the examiner's entry at time 12:37 to read that Mr. Calabrese had "[rlequested info from both operators" (emphasis added) and used it to tt.ttress his argument that a tailboard had w 4. (See Calabrese reply at 6, third full sentence.) In reality, the e==laar's parenthetic note reads
, *[r]equested info from booth operator" (emphasis added) to document that the examiner had requested the simulator booth operator (i.e., the Susquehanna training staff employee operating /centrolling the simulator) to provide information regarding the exact time that
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the two plant areas had exceeded the maximum safe radiation levels because it might have a bearing on how he would grade Mr. Calabrese's performance on the required competencies. The examiner knew that the applicants had been slow to identify the condition requiring the rapid depressurhation (about five minutes after actually reaching the maximum safe levels), so be was coacemed with accurately recording the time.
l The NRC examinecs do recall that Mr. Calabrese declared his intention to rapidly-l.
depressurhe the plant to the other applicants, but they do not recall that he assigned specific responsibilities or reviewed procedure requirements with the crew as is comraonly the case in a tallboard/ crew briefing. Mr. Avery's affidavit (paragraph 4), which simply
- . states that *Mr. Calabrese held a tailboard discussion with me and Mr. Robinson" and
" told us we were going to rapid depressurhation" is consistent with the NRC examiners' recollection. The difference of opinion on whether the applicants held a tallboard may come down to a question of semantics. Regardless of the definition of a *tallboard," the NRC examiners heard and saw what transpired during the simulator test.
E. Regarding the low pressure iqjection:
- 1. Relative to the simulator recordings:
- a. .Was a corporate notification letter (such as the sample in ES-201, attachment 1) sent to the licensee of the Susquehanna Electric Station,= Units 1 and 2, asking that it retain simulator materials relative to the simulator tests being given to Mr. Calabrese and others in October 19967 If so, when was it sent?
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Response: Yes, a corporate notification letter was sent on June 13,1996,iand an additional letter with supplemental / corrected information was sent on June 27,1996. A copy of each letter is attached.
b; What funher efforts, if any, did the chief e==l= make after the simulator test given to Mr. Calabrese to obtain any relevant simulator recordings relative to Mr. Calabrese's performan.ce on that test?
Response: As noted in the response to Question C, the NRC examiners conferred immediately after completing the simulator test involving Messrs. Calabrese, Robinson.
l and Avery to compare notes and discuss the applicants' performance. Mr. Caruso and Ms. Walker concluded that the recordings would- not be necessary to support Mr. Calabrese's failure on the basis of procedural reference and compliance. They concluded that the failure was warranted whether or not the low pressure ECCS pumps actually inlected water into the reactor vessel, so they did not pursue obtaining the recordings from the facility licensee, notwithstanding the guidance in NUREG-1021.
- 2. Assuming low pressun igjection did not take place, _would that affect the staff's scoring of Mr. Calabrese's simulator test? If low pressure injection not occurring would affect Mr. Calabrese's score, please explain in detail how and -
why. If low pressure injection not occurring would as affect Mr. Calabrese's score, phase explain in detail why, and, in doing so, please address why this result is consistent with the principle outlined in the ES 303 provision regarding the Category B " Control Room Systems / Facility Walk through" portion of an
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operator's license examination that states "[l)f the applicant missed a critfcal step but later performed it correctly and accomplished the task standard without degrading the condition of the system or the plant, the applicant's performwr on that [}ob performance measure (IPM)] should be graded as antisfactory."
NUREG 1021. ES 303, at 4 of 27.
i j- Response: If it could be proven that low pressure lidection did not take place it l
would all affect the NRC Staff's conclusion that Mr. Calabrese failed the simulator test.
As explained in Paragraphs 45 - 46 of the Staff's Presentation, Mr. Calabrese's procedural violations were significant, and the assertion in his Presentation of June 4
. 1997, that 'there was no risk of a power spike and consequent fuel damage" is totally incorrect. The Staff believes that the suggestion in Paragraph 8 of Mr. Robinson's affidavit (l.c., that the change in RHR flow indication may have been a simulator response problem) has merit and is consistent with the examiners' notes. However, a significant fact not addressed by Mr. Robinson or Mr. Calabrese is that when Mr. Kobinson depressed the initiation buttons for the RHR systems (as described in Paragraph 10 of Mr. Calabrese's affidavit), a signal was also sent to open the RHR RPV indection valves.
With these valves open and an RHR pump running, irdection will occur as soon as reactor pressure drops below the RHR pump discharge pressure. Since there was no way to anticipate or control the rate of pressure decrease once the ADS valves were opened, h was imperative that the low pressure ECCS prnps be disabled by initiating the systems and preventing their irdection bef9ts the rapid depressurization was initiated. This was the
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I only way to ensure that reactor pressure did not drop below the shutoff head of the ECCS pumps before they were secured, resulting in an inadvertent igjection and possible power spike.
The fact that Mr. Calabrese successfully depressurized the reactor and stopped the leak without damaging the reactor fuel does not mean that he has mastered the eight competencies in which the NRC expects its licensed SROs to be proficient. In light of the procedural violations commined during his simulator test, the Staff is not confident of Mr. Calabrese's ' ability to function within the control room team as appropriate to the assigned position, in such a way that the facility licensee's procedures are adhered to and that the limits of its license and amendments are ret violated." (10 C.F.R. I $5.45(a)(13))
Mr. Calabrese's performance during the rapid depressurization would have been unsatisfactory even if it had been conducted and graded as a job performance measure (JPM) in accordance with the provisions outlined in Revision 7 Supplement 1 of NUREG 1021. As stated in Section D 1.j of ES 301, the guidelines in ES-603 are to be followed when developing JPMs. Form ES 6031, " Job Performance Measure Quality Checklist," requires each JPM to identify which steps are critical to successful completion of the task and restrictions on the sequence in wb3ch the steps are to be performed, if applicable. .. Furthermore, in accordance with Attachment 1 " Operating Test Briefing,"
of ES 302, Mr. Calabrese was briefed that he would be " expected to make decisions and take actions based on the facility's procedural guidance and the indications available."
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If this had been a JPM, conducting the steps in sequence in accorda'we with EO 100112 would certainly have been critical to satisfactory completion of the task.
Since Mr. Calabrese did not perform the steps in the proper sequence, he would have failed this JPM even though he completed the task without damaging the plant.
Furthennore, the guidance in ES 303 about grading critical steps that are missed .
1 but later perfonned correctly applies to situations when applicants make er s.., that can be l l
corrected and do not by themselves represent unsafe practices. For example, in starting or stopping equipment, applicants sometimes start or stop the wrong component if their error has little consequence regarding the incorrect equipment and is not an unsafe practice, the applicant would normally be graded satisfactory if he or she recognized the l error and corrected it. However, Mr. Calabrese's error represented an unsafe practice by itself and, therefore, would not have been graded as satisfactory. In an analogous way, an applicart for a driver's license might not be penalized for malag a wrong turn, but i
would likely fall the examination if the wrong turn was made down a one way street or through a red light, even if no accident resulted.
F. In summary, the NRC Staff concludes the following based upon its review of all relevant documents, including Mr. Calabrese's Presentations and afrulavits, as well as the affidavits of Messrs. Avery and Robinson:
Contrary to the NRC's and PP&L's requirements and er.pectations, Mr. Calabrese did not have the EO 100112, ' Rapid Depressurization," flowchart prescat and refer to it continuously when the conditions requiring a rapid depressurization were encountered
. during his simulator operating test. Regardless of the difficulty that Mr. Calabrese. claims to have'had in locating E0400112 and notwithstanding the alleged conduct of a tallboard discussion, the fact that Mr. Calabrese did not refer to the emergency operating procedures in this important instance demonstrated an unacceptable willingness to proceed with a risky evolution without the support of procedural guidance.
Contrar) 3.he NRC'und PP&L's requirements and expectations, Mr. Calabrese l '
violated procedures EO 100112 and EO 100113 during his simulator operating test in that he did not prevent irdection from the low presspre ECCS pumps prior to proceeding with a rapid depressarization of the RPV. Regardless whether Mr. Calabrese directed action
- to preveat injection prior to pressure dropping below the shutoff head of the RHR pumps or whether an irdection actually occurred, his errors could have resulted in the addition of cold, unborated water when it was not assured that the reactor wou'ld remain shutdown under all coaditions without boron, thereby unnecessarily increasing the risk of a reactivity addition, power excursion, and severe core damage.
The NRC Staff wishes to make it clear that it has considered Mr. Calabrene's claims that he searched for EO 100112, held a tallboard discussion, and prevented an actual injection of water into the reactor. However, the Staff has concluded that these factors do not affect the original grading of Mr. Calabrese's simulator test. The Staff does not believe that the grading of Mr. Calabrese's simulator examination is based on significant errocs of fact by the Staff, nor does the Staff believe that the NRC's grading standards have been improperly applied or applied too harshly.
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Contrary to the assertion in Mr. Calabrese's aply presentation (first full pahagraph on page 17), the NRC Staff did not ignore what Mr. Calabrese did right in assessing his competence. As a matter of fact, he was given the highest score possible (I.e., "3') on six of the eight competencies applicable to the SRO license level, and his score on one other competency (I.e., No. 7. "DLGug Operations") was also satisfactory. With regard -
l to Competency 4, the Staff considered Mr. Calabrese's overall performance, inch d'c4 what he did correctly, and concluded that the Dgn errors he committed (i.e., his failure to --
refer to the emergency operating procedures when ruguired and his failure to comply with two separate emergency operating procedures) were significant and of sufficient importance to warrant unsatisfactory grades in Rating Factors 4.a and 4.b, regardless whether the Staff applies the current version of NUREG 10218 or the version that was in effect at the time that Mr. Calabrese took his simulator test. Mr. Calabrese's reply admits that "one instance of failure to refer to and use a procedure cank so significant and blatant that in the consideration of overall performance that failure could predominate." (Emphasis added.) This is such a case.
When reviewing nuclear power plant operations, the importance of the operators' actions in protecting public health and safety should not be minimirad. De emergency operating procedures have been developed by experts over the years and endorsed by the NRC and the industry as a whole. The actions of the operators in carrying out those Footnote 8 (at page 17) of Mr. Calabrese's reply presentation references Interim Revision 8 of NUREG 1021, which was issued in February 1997. Mr. Calabrese's examination was conducted and -scored in accordance with Revision 7, with Supplement 1, dated June 1994.
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I procedures are the last line of defense against a serious accident when mechanibal and electrical system failures jeopardize the integrity of the reactor fuel. Regardless whether an individual is taking an examination for a license to operate a nuclear power plant or a motor vehicle, the standard for falling the examination and denying the license does not l require that physical damage or injury actually occur.
l G. We hereby cei:!ff that the foregoing is true and correct to the best of our l knowledge, information, and belief.
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I Siegfried Gu'enther, Senior Reactor Engineer John G. Caruso, Operations Engineer /Framiner
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Tracy E. Walker, Senior Faforcement Specialist Subscribed and sworn to before me ,
this 4th day of August 1997, as M 888VAlso s.varm eas.
& g A da) $ $ $ h _21
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Notary Public My commission expires: /1//,/f 7
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mjG-04-1997 15 43 filLLSTONI RESIDENT OFFICE 203 443 5893 P.01 21 -
procedures are the last line of defense against a serious accident when mechanical and electrical system failures jeopardize the integrity of the reactor fuel. Regardless whether an individual is taking an examination for a licenas to operate a nuclear power plant or a
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motor vehicle, the standard for falling the examination and denying the license does not I require that physical damage or injury actually occur.-
_; w ;g O. We hereby certify that thi foregoing is true and correct to the ben of our
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knowledge, information, and belief. '
I Siegfried Guenther, Senior Reactor Engineer
- W f 7 John G. Caruso Operations Engineer /Examinst Tracy E. Wallar, Senior EnfeceT.snt S,nud Subscribed and sworn to before me -
this 4th day of August 997.
mM Notary Public My commission expires: Io.e 'ilj 200I
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