ML16097A269
| ML16097A269 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/29/2016 |
| From: | - No Known Affiliation |
| To: | Rules, Announcements, and Directives Branch |
| References | |
| 81FR63011 00007, NRC-2016-0006 | |
| Download: ML16097A269 (4) | |
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PUBLIC SUBMISSION Docket: NRC-2016-0006 Page 1of1 As of: 3/31/16 11:23 AM Received: March 29, 2016 Status: Pending_ Post Tracking No. lk0-8ors-hkxr Comments Due: April 05, 2016 Submission Type: Web Operator Licensing Examination Standards for Power Reactors, NUREG-1021, Revision 11 Comment On: NRC-2016-0006-0005 Operator Licensing Examination Standards for Power Reactors; Extension of Comment Period
- Document: NRC-2016-0006-DRAFT-0015 Comment on FR Doc # 2016-04 7 48 Submitter Information Name: Anonymous Anonymous General Comment See attached file( s)
V.C. Summer Comments SUNSI Review Complete Template= ADM -013 E-RIDS= ADM-03
, Add~'-?Jz.go4~~u_;Q _!
r11~&axj Attachments Jj<J'j;;u; I IP
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.~1 I
CJ https ://www.fdms.gov/f dms/ getcontent?o bj ectld=0900006481 ee867b&format=xml&showorig=false 03/31/2016
Paragraph R<<;?v. 11 Front section description Actual wording Comment ES-201, C.1.h Added words "in any way" to the For those items that were derived by modifying The wording "in any way" needs to be eliminated second bullet to specify that a Bank existing bank items in any way, note the changes or clarified. If a bank question is revised in the question revised "in any way" needs to that were made or submit a copy of the item existing test bank to address typographical errors, be submitted to the NRC as part ofthe from which it originated.
spacing or minor style or wording issues, the exam submittal based feedback from question then becomes the current bank version regional offices.
and can be submitted as such. There is no substantive reason to maintain an accounting of before and after versions when the change is not a significant modification. This results in unnecessary accounting of archived versions, extra volume in the submittal, and the potential creation of virtually equivalent questions in the bank to maintain the "before" version. The paragraph can be clarified by stating that any question that is counted toward the significantly modified category of questions must have the source version included with the submittal.
ES-201, C.1.k Added clarification that examination
- k. The facility licensee shall meet with the NRC The passage should be revised to eliminate the comments should be reviewed with (normally the chief examiner) to review and preference of phone conferencing. There may be NRC and licensee over the phone, discuss all substantive comments from the a case in which it is more productive or otherwise although it is acceptable to schedule a quality reviews of the examination outlines and better suited to meet in person. Eliminating the meeting at the NRC regional proposed examinations. These meetings will preference would allow for an easier headquarters or the licensee site. This normally be conducted via telephone, but with accommodation of a facility request to meet in incorporates guidance to promote approval from NRC regional management and person.
consistency between the regions.
concurrence of both parties, may be conducted in the regional office or at the facility ES-201, C.2.g Replaced paragraph with additional
- g. All assigned examiners should attend onsite This passage needs to be clarified. The validation guidance on importance of the validation activities if possible. This is the most activities specified are part of the preparatory visit preparatory site visit.
efficient and effective means for examiners to and not part of the facility internal validation become familiar with examination materials and activities that occur prior to submittals.
to provide the chief examiner with feedback on the quality of each component of the operating tests. It also serves to orient new examiners with the facility, or to refresh examiners who have previously visited the facility with site-specific details, such as plant layout and simulator operation. There may be circumstances, such as retake operating tests, where validation activities can be conducted onsite just prior to
Paragraph Rev. 11 Front section description Actual wording Comment the scheduled administration date. This alternative to a separate validation week minimizes agency costs and the impact on facility licensee training activities.
ES-201, C.3.a Added additional guidance that a new When assigned to administer operating tests for Same as previous comment for ES-201, C.2.g. This examiner attend validation week.
the first time at a particular facility, the passage needs to specify "during the preparatory Based on a recommendation from OLIT examiner should inform the chief examiner and visit" to make clear that it is not intended for Team 5.
the responsible supervisor so that arrangements examiners to attend the facility's internal can be made to ensure participation in onsite validation activities.
validation activities as described in C.2.g. If the examiner is unable to attend validation, then the chief examiner and responsible supervisor should consider if an orientation trip to the facility is deemed appropriate.
ES-202, C.l.a Provided additional guidance to If the applicant previously passed either the The change from 'requested within one year' to address excusals and deferrals and written examination or the operating test, he or
'retake within one year' seems too limiting. Time consolidated references to location and she may request to be excused from should allow for insertion into next license class. It instructions for NRC Form 398 and 396.
re-examination on that portion of the licensing would be better ifthe statement said 2 years or Revised the instructions for submitting examination. Such excusals are limited to the next License Exam (whichever is sooner).
excusals: the retake examination must first re-application and the corresponding retake occur within 1 year of the date that the examination must take place within 1 year of the applicant completed the original date on which the applicant completed the examination. Deleted the requirement original examination.
for excusals to be requested with 1 year ofthe original exam. This is to match guidance in ES-204 for the same re-take exam process.
ES-204, D.l.a Added guidance to address excusals If an applicant failed only one portion of the site-Request adding to section D.1 to allow excusal of and provided examples of what the specific initial licensing examination (i.e., either portions passed without NRR/NRO approval:
licensee should submit as justification the written examination overall, the SRO-only
- 1.
passing a single portion ofthe exam for an excusal of some examination section of the written examination, the without taking the rest of the exam the requirements. Added guidance for simulator operating test, the walk-through applicant has passed previously when an excusal is appropriate and overall, or the administrative portion of the
- 2.
changing the excusal time requirement to noted that licensees should use the SAT walk-through), the region may excuse the 2 years or next License Exam (whichever is process to determine and conduct applicant from re-examination for those sooner).
remedial training.
examination areas that were passed. This is only applicable for the first retake examination and only if it takes place within 1 year ofthe date on
- Paragraph:: ;,,:
ES-302, D.3.n Added language from FAQ 302.8 for classifying an emergency event at the end of a simulator operating test. The NRC does not require the SRO applicant to complete the emergency classification within the normal event classification period of time during a simulator operating test. Added reference to Appendix D which states that performance of an event classification does not meet the CT criteria.
which the original examination was completed.
Because the simulator operating tests for the initial licensing examination are conducted with only one applicant in the SRO position, the NRC does not require the SRO applicant to complete the emergency classification within the normal event classification period of time. In most cases, the applicant is asked to classify the event after the scenario is complete and the simulator is in freeze. As explained in Appendix D performance of an event classification does not meet the CT criteria.
Comment:~
This passage needs to prohibit requiring
. candidates to provide a time line of classifications.
A real classification in real time would be performed by a Shift Manager in an oversight role.
Because the SRO candidate is actually directing shift activities, he or she may miss conditions for the earliest cl.assification(s). If a classification is required, then only the highest level classification at the conclusion of the scenario should be sought and evaluated. A timeline that describes the lowest to highest over the scenario duration should not be pursued.
'\\
PUBLIC SUBMISSION Docket: NRC-2016-0006 Page 1of1 As of: 3/31/16 11:23 AM Received: March 29, 2016 Status: Pending_ Post Tracking No. lk0-8ors-hkxr Comments Due: April 05, 2016 Submission Type: Web Operator Licensing Examination Standards for Power Reactors, NUREG-1021, Revision 11 Comment On: NRC-2016-0006-0005 Operator Licensing Examination Standards for Power Reactors; Extension of Comment Period
- Document: NRC-2016-0006-DRAFT-0015 Comment on FR Doc # 2016-04 7 48 Submitter Information Name: Anonymous Anonymous General Comment See attached file( s)
V.C. Summer Comments SUNSI Review Complete Template= ADM -013 E-RIDS= ADM-03
, Add~'-?Jz.go4~~u_;Q _!
r11~&axj Attachments Jj<J'j;;u; I IP
~1r!l ~gtJ/- /
w
.~1 I
CJ https ://www.fdms.gov/f dms/ getcontent?o bj ectld=0900006481 ee867b&format=xml&showorig=false 03/31/2016
Paragraph R<<;?v. 11 Front section description Actual wording Comment ES-201, C.1.h Added words "in any way" to the For those items that were derived by modifying The wording "in any way" needs to be eliminated second bullet to specify that a Bank existing bank items in any way, note the changes or clarified. If a bank question is revised in the question revised "in any way" needs to that were made or submit a copy of the item existing test bank to address typographical errors, be submitted to the NRC as part ofthe from which it originated.
spacing or minor style or wording issues, the exam submittal based feedback from question then becomes the current bank version regional offices.
and can be submitted as such. There is no substantive reason to maintain an accounting of before and after versions when the change is not a significant modification. This results in unnecessary accounting of archived versions, extra volume in the submittal, and the potential creation of virtually equivalent questions in the bank to maintain the "before" version. The paragraph can be clarified by stating that any question that is counted toward the significantly modified category of questions must have the source version included with the submittal.
ES-201, C.1.k Added clarification that examination
- k. The facility licensee shall meet with the NRC The passage should be revised to eliminate the comments should be reviewed with (normally the chief examiner) to review and preference of phone conferencing. There may be NRC and licensee over the phone, discuss all substantive comments from the a case in which it is more productive or otherwise although it is acceptable to schedule a quality reviews of the examination outlines and better suited to meet in person. Eliminating the meeting at the NRC regional proposed examinations. These meetings will preference would allow for an easier headquarters or the licensee site. This normally be conducted via telephone, but with accommodation of a facility request to meet in incorporates guidance to promote approval from NRC regional management and person.
consistency between the regions.
concurrence of both parties, may be conducted in the regional office or at the facility ES-201, C.2.g Replaced paragraph with additional
- g. All assigned examiners should attend onsite This passage needs to be clarified. The validation guidance on importance of the validation activities if possible. This is the most activities specified are part of the preparatory visit preparatory site visit.
efficient and effective means for examiners to and not part of the facility internal validation become familiar with examination materials and activities that occur prior to submittals.
to provide the chief examiner with feedback on the quality of each component of the operating tests. It also serves to orient new examiners with the facility, or to refresh examiners who have previously visited the facility with site-specific details, such as plant layout and simulator operation. There may be circumstances, such as retake operating tests, where validation activities can be conducted onsite just prior to
Paragraph Rev. 11 Front section description Actual wording Comment the scheduled administration date. This alternative to a separate validation week minimizes agency costs and the impact on facility licensee training activities.
ES-201, C.3.a Added additional guidance that a new When assigned to administer operating tests for Same as previous comment for ES-201, C.2.g. This examiner attend validation week.
the first time at a particular facility, the passage needs to specify "during the preparatory Based on a recommendation from OLIT examiner should inform the chief examiner and visit" to make clear that it is not intended for Team 5.
the responsible supervisor so that arrangements examiners to attend the facility's internal can be made to ensure participation in onsite validation activities.
validation activities as described in C.2.g. If the examiner is unable to attend validation, then the chief examiner and responsible supervisor should consider if an orientation trip to the facility is deemed appropriate.
ES-202, C.l.a Provided additional guidance to If the applicant previously passed either the The change from 'requested within one year' to address excusals and deferrals and written examination or the operating test, he or
'retake within one year' seems too limiting. Time consolidated references to location and she may request to be excused from should allow for insertion into next license class. It instructions for NRC Form 398 and 396.
re-examination on that portion of the licensing would be better ifthe statement said 2 years or Revised the instructions for submitting examination. Such excusals are limited to the next License Exam (whichever is sooner).
excusals: the retake examination must first re-application and the corresponding retake occur within 1 year of the date that the examination must take place within 1 year of the applicant completed the original date on which the applicant completed the examination. Deleted the requirement original examination.
for excusals to be requested with 1 year ofthe original exam. This is to match guidance in ES-204 for the same re-take exam process.
ES-204, D.l.a Added guidance to address excusals If an applicant failed only one portion of the site-Request adding to section D.1 to allow excusal of and provided examples of what the specific initial licensing examination (i.e., either portions passed without NRR/NRO approval:
licensee should submit as justification the written examination overall, the SRO-only
- 1.
passing a single portion ofthe exam for an excusal of some examination section of the written examination, the without taking the rest of the exam the requirements. Added guidance for simulator operating test, the walk-through applicant has passed previously when an excusal is appropriate and overall, or the administrative portion of the
- 2.
changing the excusal time requirement to noted that licensees should use the SAT walk-through), the region may excuse the 2 years or next License Exam (whichever is process to determine and conduct applicant from re-examination for those sooner).
remedial training.
examination areas that were passed. This is only applicable for the first retake examination and only if it takes place within 1 year ofthe date on
- Paragraph:: ;,,:
ES-302, D.3.n Added language from FAQ 302.8 for classifying an emergency event at the end of a simulator operating test. The NRC does not require the SRO applicant to complete the emergency classification within the normal event classification period of time during a simulator operating test. Added reference to Appendix D which states that performance of an event classification does not meet the CT criteria.
which the original examination was completed.
Because the simulator operating tests for the initial licensing examination are conducted with only one applicant in the SRO position, the NRC does not require the SRO applicant to complete the emergency classification within the normal event classification period of time. In most cases, the applicant is asked to classify the event after the scenario is complete and the simulator is in freeze. As explained in Appendix D performance of an event classification does not meet the CT criteria.
Comment:~
This passage needs to prohibit requiring
. candidates to provide a time line of classifications.
A real classification in real time would be performed by a Shift Manager in an oversight role.
Because the SRO candidate is actually directing shift activities, he or she may miss conditions for the earliest cl.assification(s). If a classification is required, then only the highest level classification at the conclusion of the scenario should be sought and evaluated. A timeline that describes the lowest to highest over the scenario duration should not be pursued.