05000298/FIN-2012301-01
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Finding | |
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| Title | Failure to Maintain Initial Licensing Examination and Licensed Operator Examination Integrity |
| Description | The examiners identified a non-cited violation of 10 CFR Part 55.49, Integrity of Examinations and Tests, for the failure of the licensee to ensure the integrity of initial licensing exams and licensed operator annual operating tests from 1997 to 2012. During validation activities being conducted supporting the 2012 initial licensing examination, the NRC identified a failure to implement the sites simulator Security Procedure OTP 810, Operations Department Examination Security (Revision 11). Additional follow up revealed that there was a portion of the licensees computer network tied to their simulator that had not been isolated from the simulator during exam activities (initial and requalification examinations) for a period of approximately 15 years. Both provided plant staff the ability to view exam material in an uncontrolled manner. Providing this ability to view exam material in this manner is considered an exam integrity compromise. However, an evaluation involving site access logs, personal interviews with staff, and review of trends in exam results showed that the compromise did not have an actual effect on the equitable and consistent administration of the affected exams. The licensee entered the finding into the corrective action program as Condition Reports CR-CNS-2012-06335 and -06336. The failure of the licensees training staff to maintain the integrity of examinations administered to initial license applicants and licensed operations personnel was a performance deficiency. The finding was more than minor because it adversely affected the Human Performance attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Additionally, if left uncorrected, the performance deficiency could have become more significant in that allowing licensed operators to return to the control room without valid demonstration of appropriate knowledge on their annual operating tests, or allowing operators to obtain licenses based on a compromised examination, could be a precursor to a more significant event. Using NRC Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Tables 1 and 2 worksheets; and the corresponding Appendix I, Licensed Operator Requalification Significance Determination Process, the finding was determined to have very low safety significance (Green). Although the 2012 finding resulted in a compromise of the integrity of initial licensing examinations and annual operating tests for approximately 15 years, with no compensatory actions immediately taken when the compromise should have been discovered, the equitable and consistent administration of the examinations in question were not actually affected by this compromise. In addition, the failure to meet 10 CFR 55.49 was evaluated through the traditional enforcement process, which resulted in its association with a Severity Level IV violation consistent with Sections 2.2.4 and 6.4.d of the NRC Enforcement Policy. This finding has a cross-cutting aspect in the human performance area associated with the resources component because the licensee failed to ensure that procedures were adequate to assure nuclear safety. Development and maintenance of Procedure OTP 810 had not involved review by the simulator support staff since the procedures inception. The simulator support staff is responsible for the configuration of computer networks that are connected to the simulator facility. |
| Site: | Cooper  |
|---|---|
| Report | IR 05000298/2012301 Section 4OA5 |
| Date counted | Mar 31, 2013 (2013Q1) |
| Type: | TEV: Severity level IV |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | V Gaddy M Bloodgood S Hedger N Hernandez |
| Violation of: | 10 CFR 55.49 |
| CCA | H.7, Documentation |
| INPO aspect | WP.3 |
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Finding - Cooper - IR 05000298/2012301 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Cooper) @ 2013Q1
Self-Identified List (Cooper)
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