Why is Wolf Creek In Trouble II?

As a message to the employees of Wolf Creek nuclear plant, throw me some insider not known executive wrongdoing. Tell me about secret problems they wouldn't fix or if they are not following the rules...I promise you I will get the NRC's attention. I will make their lives so miserable I will make them cry. I will fix Wolf Creek for you. My phone number and email is at the top of my blog...

For everyone else, you can talk to me about training or simulator troubles. You executives would regret they lived?  

I ask the right question worry about if something deeper was going in early Oct 2014. This is a horrible report card for the whole training and licensed operator ranks. There is no question the NRC down played this. But it is only going to get horrible worst.    

Why is Wolf Creek In Trouble? 

***During the facility-administered annual operating tests of licensed operators, the licensee training staff evaluated crew and individual operator performance during dynamic simulator scenarios and individual operator performance during job performance measures. There were two crew failures and 11 individual failures. The licensee remediated and retested the staff prior to returning them to licensed duties. Analysis. In accordance with Inspection Procedure 71111.11, each of the following was a performance deficiency against expected licensed operator knowledge and abilities: 1) Greater than 20 percent of the crews failing their scenarios and 2) greater than 20 percent of the licensed operator staff failing their operating tests. Using the Inspection Manual Chapter 0612, Appendix B, "Issue Screening," the inspection determined that the finding was more than minor because the performance deficiency was associated with the Mitigating Systems Cornerstone attribute of human performance, and affected the cornerstone objective of ensuring the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspector determined that this finding could be evaluated using Inspection Manual Chapter 0609, Appendix I, "Licensed Operator Requalification Significance Determination Process." This finding was of very low safety significance (Green) because the finding was related to the requalification

I'd like to know how they come up with the 40% failure rate is unsafe?

exam results, did not result in a failure rate of greater than 40 percent, and the licensed operators were remediated prior to returning to shift. This finding has a cross-cutting aspect in the area of human performance associated with Green. The inspector reviewed a self-revealing finding associated with licensed operator performance on the annual requalification operating tests. Specifically, 2 of 8 crewThmance measure portions of the operating tests. The licensee remediated and retested the staff prior to returning them to licensed duties. Wolf Creek entered this finding into their corrective action program as Condition Report 75336.

This kind of plant ownership is very dangerous. A split ownership between two small potatoes utilities. 

You are see the worst of the NRC here. So the simulator was inaccurate and the safety knowledge of the licensed operators was really poor. They bufucated the depth of the problem or diluted the magnitude the the problems by separating these problems between two independent inspection reports. I am certain the NRC seen the inadequacies of the licensed operators training and the inadequacies of accurate simulator modeling at the same time. They strategized to separated the issues to minimize the violations for their buddies. 

If they would have hit these guys with these two problems at the same time, jacked up the violation level...threw it into the special inspection...these guys would have gotten the message to clean up their act really hard. Everyone else would have seen this saying, we can't let this happen to us.

Better yet, failed training and shut them down for a month or so for retraining...this wouldn't be seen in the nuclear industry for a decade or more.        

Enforcement. This finding does not involve enforcement action, because no violation of a regulatory requirement occurred. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000482/2014005-01, “Failure to Conduct and Evaluate Simulator Testing In Accordance With ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998.”

Can you believe from the latest inspection report in the above... that training the licensed operator with a inaccurate simulator is not against the rules. Only campaign contributions buys you that 

WOLF CREEK GENERATING STATION – NRC INSPECTION REPORT - Dated February 10, 201 

by Bob Meyer : How comfortable are you with your simulator performance? Does your simulator provide negative training to the operators? This inspection finding is a shot over the bow for the industry. If you are putting up with poor performance on your simulator, look at this inspection report. 

Licensed Operator Requalification Program and Licensed Operator Performance (71111.11) 

Violation: The inspectors identified a Green finding for the inadequate conduct and evaluation of simulator performance testing in accordance with the standards of ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.” Specifically, Wolf Creek Nuclear Operating Corporation (WCNOC) did not adequately identify that the simulator responses during 2008 through 2014 tests of Transient 3, “Simultaneous Closure of All Main Steam Isolation Valves,” did not meet the acceptance criteria described in Section 4.1.4 of ANSI/ANS 3.5-2009 (or the 1998 edition), which if left uncorrected, could have resulted in negative training of licensed operators and call into question Wolf Creek’s ability to conduct valid licensing examinations with the simulator. WCNOC initiated condition reports 90179 and 90417 and simulator discrepancy report. A14-154. WCNOC also plans to conduct benchmarking at other sites to compare simulator responses during applicable testing, and is evaluating the need for additional procedure revisions or other corrective actions. 

The performance deficiency is more than minor because it adversely impacted 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 not correcting noticeable differences between the simulator and the reference plant could cause negative training of licensed operators and call into question WCNOC’s ability to conduct valid licensing examinations with the simulator. Utilizing Inspection Manual Chapter 0609, “Significance Determination Process,” Attachment 4, Tables 1 and 2 worksheets, issued June 19, 2012, and flowchart block 14 of Appendix I, “Licensed Operator Requalification Significance Determination Process (SDP),” issued December 6, 2011, the finding was determined to have very low safety significance (Green), because the deficiencies were associated with simulator testing, modifications, and maintenance, and there was no evidence that the plant-referenced simulator does not demonstrate the expected plant response or have uncorrected modeling and hardware deficiencies.

This finding has a cross-cutting aspect in the area of problem identification and resolution, Identification, because WCNOC personnel did not implement a corrective action program with a low threshold for identifying issues. Specifically, this issue was first identified when the RETRAN-3D code analysis was first used in 2008 transient testing, and additional tests performed in 2008, 2009, 2010, and 2012 were opportunities to identify the performance deficiency; however, the issue was not entered into the corrective action program, a noticeable difference was not evaluated, a training needs assessment was not performed, and the process used to conduct simulator transient testing, as described in Procedure Al 30C-006, was not updated to include all of the minimum acceptance criteria described in the ANSI/ANS 3.5 standard. Hence, simulator issues expected to be identified during the testing process could potentially be missed by implementing the AI 30C-006 procedure, which did not include all of the minimum acceptance criteria described in the ANSI standard [P.1]. 

71111.11 Findings 

Introduction. The inspectors identified a Green finding for WCNOC inadequately conducting and evaluating simulator performance testing in accordance with the standards of ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998, “Nuclear Power Plant Simulators for Use in Operator Training and Examination.” Specifically, WCNOC did not adequately identify that the simulator responses during 2008 through 2014 tests of Transient 3, “Simultaneous Closure of All Main Steam Isolation Valves,” did not meet the acceptance criteria described in Section 4.1.4 of ANSI/ANS 3.5-2009 (or the 1998 edition), which if left uncorrected, could have resulted in negative training of licensed operators and call into question Wolf Creek’s ability to conduct valid licensing examinations with the simulator.

Description. In order to maintain an NRC approved simulation facility, licensees are required to conduct performance testing throughout the life of the simulator to ensure that it can be used to model control manipulations consistent with the actual plant. An acceptable method for conducting this testing is by using industry standard ANSI/ANS 3.5. This industry standard has been endorsed by the NRC in Regulatory Guide 1.149, “Nuclear Power Plant Simulation Facilities for Use in Operator Training, License Examinations, and Applicant Experience Requirements,” Revision 4 (and Revision 3), as an acceptable method to complete required simulator testing to meet the requirements of 10 CFR 55.46. WCNOC procedure AI 30C-001, “Continued Assurance of Simulator Fidelity,” Revision 15, references ANSI/ANS 3.5-2009 as the standard for its simulator testing.

Part of the required testing detailed in the ANSI/ANS 3.5 standard includes transient performance tests, which include simulator tests on 11 specific transients specified in Section B.3.2 of Appendix B of the ANSI/ANS 3.5 standard. Section B.1.2 of Appendix B of the ANSI/ANS 3.5 standard states that the acceptance criteria for these tests are documented in Section 4.1.4 of the ANSI/ANS 3.5 standard. This section states that simulator response during transient testing will meet the following acceptance criteria:

(1) “The simulator allows the use of applicable reference unit procedures;

(2) Any observable change in simulated parameters corresponds in direction to the change expected from actual or best estimate response of the reference unit to the transient test;

(3) The simulator shall not fail to cause an alarm or automatic action if the reference unit would have caused an alarm or automatic action under identical circumstances; and

(4) The simulator shall not cause an alarm or automatic action if the reference unit would not cause an alarm or automatic action under identical circumstances.”

A failure to meet these acceptance criteria constitutes a difference in the dynamic response between the simulator and the reference unit that is distinguishable by an observer and confirmed by a subject matter expert. This is defined as a noticeable difference by the ANSI/ANS 3.5 standard. Noticeable differences are evaluated by performing a training needs assessment in accordance with Section 4.2.1.4 of the ANSI/ANS 3.5 standard. This assessment helps in determining the appropriate corrective actions, as well as in identifying potential negative effects the noticeable difference can have on licensed operator training.

Procedure AI 30C-001 describes how WCNOC maintains and tests the simulator to meet the ANSI/ANS 3.5 standard. Section 6.4.2 of AI 30C-001, sub-item 4 states, in part, that transient testing acceptance criteria are contained in procedure AI 30C-006, “Simulator Transient Testing.” Section 6.6.1 of AI 30C-006, Revision 11, states, in part, with respect to acceptance criteria, that “The test plots shall be reviewed by the LSI-Simulator or his designee to ensure that the observable change in parameters correspond in direction to those expected from a best estimate for the simulated transient and do not violate the physical laws of nature.” This is the only portion of the procedure that addresses the acceptance criteria, and it only addresses acceptance criteria (2) of the ANSI/ANS 3.5 standard. 

For a comparison of the simulator results during the testing, licensees use baseline data representing the reference unit, consistent with the preference of data sources stated in Section 5.1.1 of the ANSI/ANS 3.5 standard. In this case, WCNOC used the results from a RETRAN-3D engineering software code analysis prepared in 2006 to specifically support ANSI/ANS transient testing.

During the 2014 performance of Transient 3, the simulator initiated a reactor trip based on steam generator lo-lo level signals between 3.4 and 3.85 seconds into the test. The RETRAN-3D code analysis for Transient 3 showed a reactor trip based on high pressurizer pressure between 7 and 7.5 seconds into the test. In this case, the simulator caused an alarm and automatic action (reactor trip based on steam generator lo-lo levels, showing with lit indication on reactor protection system channels A through D) that the reference unit did not initiate. This test was not successful based on acceptance Criterion 4 of the ANSI/ANS 3.5 standard. In accordance with the ANSI/ANS 3.5 standard, this should have resulted in observation of a noticeable difference. However, an observation of a noticeable difference was not documented, and corrective actions were not evaluated using a training needs assessment.

WCNOC conducted Transient 3 on the simulator on April 10, 2014. The test was considered complete and satisfactory on September 10, 2014. On December 3, 2014, the NRC inspectors communicated to WCNOC that the test results did not meet the acceptance criteria stated in the ANSI/ANS 3.5 standard. On December 9, 2014, further discussion with WCNOC revealed that this issue had been identified when the RETRAN-3D code analysis was first used in 2008 transient testing. With this information, NRC inspectors requested documentation showing that this noticeable difference was evaluated during this time period consistent with Section 4.2.1.4 of the ANSI/ANS 3.5 standard, which would include a training needs assessment. There was no documented evidence provided showing that this evaluation took place. WCNOC initiated Condition Reports 90179 and 90417 and simulator discrepancy report A14-154. WCNOC also plans to conduct benchmarking at other sites to compare simulator responses during applicable testing, and WCNOC is evaluating the need for additional procedure revisions or other corrective actions. 

Analysis. The failure to adequately conduct and evaluate simulator performance testing in accordance with ANSI/ANS 3.5-2009 (and the 1998 edition), as referenced by site procedure AI 30C-001, Revision 15, and as endorsed by Regulatory Guide 1.149, Revisions 3 and 4, was a performance deficiency. The performance deficiency is 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 would have the potential to become more significant in that not correcting noticeable differences between the simulator and the reference plant could cause negative training of licensed operators and call into question WCNOC’s ability to conduct valid licensing examinations with the simulator. Utilizing Inspection Manual Chapter 0609, “Significance Determination Process,” Attachment 4, Tables 1 and 2 worksheets, issued June 19, 2012, and flowchart block 14 of Appendix I, “Licensed Operator Requalification

Significance Determination Process (SDP),” issued December 6, 2011, the finding was determined to have very low safety significance (Green), because the deficiencies were associated with simulator testing, modifications and maintenance, and there was no evidence that the plant-referenced simulator does not demonstrate expected plant response or have uncorrected modeling and hardware deficiencies. 

This finding has a cross-cutting aspect in the area of problem identification and resolution, Identification, because WCNOC personnel did not implement a corrective action program with a low threshold for identifying issues. Specifically, this issue was first identified when the RETRAN-3D code analysis was first used in 2008 transient testing, and additional tests performed in 2008, 2009, 2010, and 2012 were opportunities to identify the performance deficiency; however, the issue was not entered into the corrective action program, a noticeable difference was not evaluated, a training needs assessment was not performed, and the process used to conduct simulator transient testing, as described in Procedure Al 30C-006, was not updated to include all of the minimum acceptance criteria described in the ANSI/ANS 3.5 standard. Hence, simulator issues expected to be identified during the testing process could potentially be missed by implementing the AI 30C-006 procedure, which did not include all of the minimum acceptance criteria described in the ANSI standard [P.1].

Enforcement. This finding does not involve enforcement action, because no violation of a regulatory requirement occurred. Because this finding does not involve a violation and is of very low safety significance, it is identified as FIN 05000482/2014005-01, “Failure to Conduct and Evaluate Simulator Testing In Accordance With ANSI/ANS 3.5-2009 and ANSI/ANS 3.5-1998.