ML17179A819

Informs of Evaluation of Licensee Requalification Program Scheduled for Wk of 930802 & Onsite Exam Preparation Scheduled for Wk of 930712.Forwards Listed Enclosures for Licensee to Furnish Prior to Exam Date

ML17179A819
Person / Time
Site:	Dresden
Issue date:	03/31/1993
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Delgeorge L COMMONWEALTH EDISON CO.
References
NUDOCS 9304060109
Download: ML17179A819 (11)

Text

~'

e Docket No.

50~237 Docket No.

50~249 Commonwealth Edison Company MAR 3 1 1993 ATTN:

Mr. L. 0. DelGeorge, Vice President e

Nuclear Oversight and Regulatory Services Executive Towers West III 1400 Opus Place, Suite 300 Downers Grove, IL 60515 *

SUBJECT:

REQUALIFICATION PROGRAM EVALUATION In a telephone conversation on March 29, 1993, ~r: Burns and Ms. Shembarger arranged to eval~ate the requalification program and licensed personnel (8 SROs, 6 ROs, 1 LSRO and l SRO Retake) at the Dresden Station. ' The evaluation is scheduled for the week of August 2, 1993.

Onsite exam preparation is scheduled for the week of July 12~ 1993.

NRC examiners and evaluators from your facility will conduct requalification examin~tions, and the NRC will evaluate the facility licensee's requalification pro~ram in accordance with Sections ES-601 through ES-604 of NUREG-1021, "Operator Licensing Examiner Standards," Revision 7.

You are encouraged to ensure that your training staff and proposed examinees are familiar with these standards.

For the NRC to adequately prepare for this evaluation, the facility licensee will ne.ed to furnish~ the NRC the* approved items listed in Enclosure 1, "Reference Material Guidelines;"

You are also requested to submit, at your option, a proposed examination for use during the examination week;

However, if you do submit a proposed examination, the personnel participating in its development may become subject to the security restrictions described in this letter.

Please review the guidance promulgated in Revision 7 to NUREG-1021 on-the content and scope of simulator examination scenarios.

The scenario examination bank should cover the entire spectrum of emergency oper~ting procedures (EOPs), including alternative decision paths within the EOPs, and it should incorporate a range of failures with various degrees of severity for the same type of event.

Each scenario should contain simultaneous events that require the senior reactor operator (SRO) to pri~ritize his/her action~ and to assign other crew members particular tasks.

E~ch scenario should also require the SRO to decide when to transition between EOPs and decide whiCh actions to take within EOPs.

You are requested to designate at least one employee to be a member of a joint NRC-facility examination team.

The employee is expected to be an active senior reactor operator (SRO) as defined by 10 CFR 5S.53(e) or (f) from the Dresden Station operations department.

You are encouraged to designate a second employee from the training staff to be a member of the examination

. team.

This employee should also be a licensed SRO, but may be a certified instructor. If desired andagreed to by the chief examiner, you may designate

"~rw~<;Witional employee from the training staff with appropriate 9304060109 930331 PDR ADOCK 05000237 V

PDR

Commonwealth Edison Company 2

. MAA 3 1 1993 qualifications to be a member of the examination team.

In addition to these individuals, You will need to designate a simulator operator for stenario preview and validation during the on-site examination preparation week.

In

.some cases, you may need to designate a simulator operator during the test item review period. All of these indi~iduals will be subject to the examinatiori s~turity agreement.

The NRC restricts any facility representatives under the security agreement from knowingly c*ommuni cat i ng by any means the content or scope of the

• examination to una~thorized persons and from participating in any facility licensee programs such as instruction, examination, or tutoring in which an identified requalification examinee(s) will be present. These restrictions apply.from the day that the facility licensee representative signs the examination security agreement indicating that the representative understands that he or she has specialized knowledge of the examination.

The chief examiner will determine when a facility licensee representative has received specialized knowledge concerning the examination and will execute an examination security agreement.

In most cases, the examination team members will not be required to enter into an examination security agreement more than

• 60 days before the examination week.

The simulator operator will normally become subject to the security restrictions during the examination preparation

.and validation week; however, this may occur as much as 45 days before the examination week.

Sixty days before the exami~ation administration date, please provide the NRC regional office-with a list of proposed licensees, including crew composition,*

for the examination.

The facility licensee training staff should s~nd this information directly to the NRC's chief examiner.

The facility licensee may request that the NRC chief examiner or,another NRC representative meet with the licensees to be examined and the licensee managers during the examination preparation week, normally 2 weeks before the examination.

However, if the schedule does not allow them to meet during the

' preparation week, they may meet.at any mutually agreeable time.

The NRC

• examiner will explain the examination and grading processes and will respond to any questions that licensees may have about NRC's examination procedures.

The facility licerisee training staff should schedule this meeting, if it is desired, with the NRC chief examiner..

The facility licensee is re~uested to distribute the, "Requalification Examiriation Feedback Form," attached ~s Ertclosure 3.

The NRC requests that this feedback form be completed by all operators, evaluators, and facility licensee representatives participating in the NRC requalification examination, including facility licensee managers.

The results from this survey will be used to measure the success of the NRC and facility licensee's.efforts to reduce undue stress during the requalificati~ri examination.

Commonwealth Edison Company 3

MAR

~~ 1 i993

• The facility licensee staff is responsible for providing adequate space and accommodations to properly develop and conduct the ex.aminations.,

. "Administration of Requalification Examinations," describes our requirements for developing and conducting the examinatiOns. Also, a facility operations management representative above a shift supervisor level should observe the simulator examination process at the site.

The request for requalification examination material is covered by Office of Management and Budget Clearance Number 3150-0101, ~hich expires October 31, 1995.

The estimated average burden is 7.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per response, including gathering, copying, and mailing the required material.

Send comments regarding this burden estimate or any other aspect of this collection of information~ including suggestion~ for reducing this burden, to the Information and Rec6rds Management Branch, MNBB-7714, Division of Information Support Services, Office of Information Resources Management, U.S; Nuclear Regulatory Commission, Washington, DC 20555; and to the Paperwork Reduction Project (3150-0101), Office of Information and Regulatory Affairs, NEOB-3019, Office of Management and Budget, Washington, DC 20503.

The request for responses to the Requalification Feedback Form is covered by Office of Management and Budget Clearance Number 3150-0159, which expires Feb~uary 28, 1996~ The estimated average burden is.30 minutes per res~ons~,

including copying and mailing the completed responses; Send comments about this. burden estimate or ariy other aspect of this collection of information, including suggestions for reducing this burden, to the Records and Reports Managem~nt* Branch, MNBB-7714~ Division of Information Support Seivice~, Office of Information Resources Management,

~.S. Nuclear Regulatory Commission, Washington, DC 20555; and to the Paperwork Reduction Project (3150-0159),

. Office of Information and Regulatory Affairs, NEOB-3019, Office.of Management and Budget, Washington, DC 20503.'

Thank you for your cooperation in this matter.

Mr. Burns has been advised of the NRC gui~elines ~nd policies addres~ed in this lettei. If you have any que$tions on the evaluation protess, please contact Mr. McNeil at (708) 790-5550.

Sincerely~

• r;;Tgina! Sfgnea oy" Mar~ A. H'in[1 Mark A; Ring, Chief Operations Branch Division of Reactor Safety See Attached Enclosures and Distribution RIII r<rns Shembarger/cg 03/30 /93 OlYJ RIIm Jar~

03fJ:- /93

-~

Ring 03/}>I /93 RI!*

Davis 03[>( /93

-Commonwealth Edison Company.

Enclosures and Distribution

Enclosures:

1.

Reference Material Guidelines

2.

Administration of Requalification Examinations 4

3.

Requalification Examination Feedback Form cc w/encl osure.s:

M. 0. Lyster, Site Vice President

. C. Schroeder,. Station Manager J. Shields, Regulatory Assurance Supervisor D.. Farrar, Nuclear Regulatory Services Manager

. OC/LFDCB Resident Inspectors LaSalle, Dresden, Quad Cities Richard Hubbard J. W. Mccaffrey, Chief, Public Utilities Division.

Robert Newmann, Office of Pubiic Counsel, State of Illinois Center State Liaison Officer Chairman, Illinois Commerce*

. Commission*

H. J. Miller, Riii T. 0. Martin,.Riii J. E. Oyer, NRR E. J. Leeds, NRR M. J. Jordan, ~III

• C. 0. Pederson, Riii S. Stasek; SRI, Davis-Besse Ri C. Weidner, Training Manager cc w/o enclosures:

R. M. Gallo, Branch Chief, OLB B. L. Siegel, Project Mariager, NRR P. L. Hiland, Section Chief, DRP

.bee:

PUBLIC - IE42 MAR 0 l 1993

ENCLOSURE I Reference Material Guidelines I.

Provide test items to support all aspects of th_e requalification examination to the NRC 60 d~Ys before the examination date.

2.

The following reference material:

A minimum of 700 t~st items for use _in the written examination equally divided between the two sections of the written examination which cover all safety~related elements of the facility job~ta~k analy~is (JTA).

The facility licensee is expected to maintain a dynamic bank by reviewing, revising or generating at least 150 questions a year.

New questions should cover equipment and system modifications and recent industry and licensee events and procedural changes.

JPMs to eval~ate e~ch reactor operator and senior reactor operator safety-related t_ask identified in the facility JTA, which meet the criteria in ~S-603~ The JPM bank should expand at a rate of at least 10 JPMs per year uritil this goal is reached.

It is estimated that 125-150 JPMs will be the final result.

A bank ~f at least 30 simulator scenarios which reflect al~ abnormal and emergency situations to which a licensee is expeC::ted to respond or control.

At least 5 scenarios per year should be generated until all aspects of the emergency operating procedures are covered with sufficient variation in the type and 'Scope of initiating events and

• level of degradation.

Empha~is should be placed on s~enarios that include applicable industry events.

These target levels are expected to be attained by the facility licensee~ rin 10/1/95, five years after the implementation of Revision 6 of NUREG-1021 (10/1/90)..

3.

For all licensee requalification examin~tion and program evaluation

• visits, the facility shall:

Submit ~n Examination Sample Plan which meets the requirements of

_ ES-601, Attachment 2; Provide the associated examination banks (written, simulator and.

JPM) and associated reference material~ At a minimum, the reference material should include Technical Specifications,

• abnormal and emergency operating procedures, and emergency plan procedures utilized in the requalification training; and Provide additional reference material as requested by the NRC chief examiner.

ENCLOSURE 2 Administration of Requalification Examinations

1.

The NRC must evaluate at _least 12 licensees to perform a program evaluation.

Normally, the.decision to select a licensee or crew for the

-requalification e~amination is based on license renewal needs.. The requalification examination may also include other licensees who ~r~ hot routinely performing shift duties or are not maintaining an active license as defined in 10 CFR 55.53(e). The restrictions on crew compositi~n in the simulator are described in ES-601 Section C.2 and ES-604.

2.

The simulator and simulator operators n~ed to be av~ilable ftir examination development. *The chief examine~ and the facility representatives will agree on the dates and duration of time needed to develop the: examinations. -

3.

The chief eiaminer will review the reference material used in the si~ulator. The NRC will not auth6rize the use of reference material that is not normally used for plant operation in the control room to be used during the simulator test~

4;-

The facility licensee will provide a single room for completing Section 8 of the written examination.

The examination room and the supporting rest room facilities will be located to Rrevent the examinees from contacting all other facility ~nd contractor personnel during the examination.

5.

The chief examiner will inspect the examination room to see that it meets the minimum standard that will ensure examination integrity.

The

.minimum spacing standard consists of one examihee per table and a 3-foot space between tables.

No wall charts, models, or other training materials are allo~ed in the examination room.

6.

The facility licensee is expected to provide a copy of each reference document for each examinee for Section 8 of the written examination.

The material should include documents that are normally available to.the licensees in the control room ~uch as the technical specification~,

operating and abnormal procedures, administrative procedures, and the emergency plans.

• The chief examinet will review the reference material before the examination begins.

7.

The NRC requalification examination will attempt to distingui-sh between RO and SRO knowledge and abilities to the extent that the facility training materials allow the developers to make these distinctions.

8.

Prudent scheduling of examination week activities is importarit to help alleviate undue stress on the licensees.

The facility training staff

• and*the NRC chief examiner should attempt to formulate a schedule that will minimize delays while conducting the examinatiori.

ENCLOSURE 2 (Cont'd)

The following are som~ suggestions for structuring the examination activities to achieve this objective:

Bring in licensees in accordance with their scheduled examinatioh times.*

It is better to segre~ate the*group of licens~~s completing their examinatioh, instead of the group of licens~es that are scheduled to start their ~xamination.

Follo~ing simulator scenarios, the facility evaluators and NRC examiners should quickly determine whether follow-up questioning is required so that the crew members may be released to talk among themselves about the scenarios; Ensure that time validation of JPMs, particularly those performed in the simulator, is accurate.

Establish a reasonable schedule to pr~vent licensees from waiting for simulator availability to complete their JPMs.

9.

The NRC no lohger requires the.facility licensee tq videotape dynamic simulator examinations.

If the facility licensee requests to videotape the examination, any use of the tape must be completed before the NRC leav~s the site ~t the end of the examinatiori.

If a disagreement over the grading of a lic~nsee still exists at the end of the examination week, the* facility licensee may retain the tape for the purpose of submitting.it.to support a request for regrade by the NRC.

During the

~egrade, the NRC will review only the portion of the videotape under contention. After all requalification examination grades ~re finalized, including the review of any regrade requests, th~ facility licensee is expected 'to erase all video tapes made durin~ the examination.

ENCLOSURE 3 REbUALIFICATION EXAMINATION FEEDBACK FORM

• Introduction The NRC is requesting feedback regarding the conduct of requalification examinations.

The information provided will be used to monitor, on a generic basis, the effectiveness of the NRC's and facility licensee's efforts to minimize undue stress in the examination process.

This form is not intended as a means of resolving technical or process concerns pertaining to a specific examination.

Such concerns will be resolved using the guidance in NUREG-1021, "Operator Licensing Ex.aminer Standards."

Instructions.

Completion of this form is voluntary.

If you choose to provide feedback, please answer the questiohs in accordance with these.instructions:

The questions.in this form regard the examination administered by Region III ~t the Dresden Station during th~ week of August 2, 1993;

• however, comparfsons with previous examinations may be appropriate..

Any examinee or indi~idual involved in the development or administ~ation.

of this ~xamination is encouraged to c~mplete this form.

Mail completed forms to:

U.S. Nuclear.Regulatory Commission Region III ATTN:

Mark A. Ring, Chief Operations Branch 799 Roosevelt Road G l en E 11 yn, Il 1 i no i s ~ 6 0 13 7 Your Background Please check the boxes that describe your involvement in this examination.

I was:

an examinee

---

involved in developing the examination involved in administeri.ng the examination.

---

an examination observer

- other:

ENCLOSURE 3 (Cont'd)

Please check the boxes that describe your cur~ent pos~tion.

(Check all that apply)

RO SRO operating crew member

--- training departmen-=-t=======-operati ons department other:

Stress vs. Undue Stress The following questions require you to make a judgment of whether there was undue stress during the examination.

Examinations are inherently stressful events and, therefore, it is important that you make a distinction between stress and undue stress when making your judgments.

Undue stress is unnecessary or inappropriate stress which can be practically eliminated without compromising the validity of the examination.

The distinction between stress and undue stress is not a matter of whether the stress was extreme or*

mild.

When making your judgments you should follow these ~teps:

First, consi~er the cause of the stress.

Would it have been possible and practi~al to eliminate the cause of the stress without compromising the validity of the examination? If your answer is no, then no undue stress* was present.

(See point #1 on the rating scale below.)

If your answer is yes, consider the magnitude of the stress.* A source*

of stress may be unnecessary but also sufficiently small in magnitude to be unlikely to affect an i~dividual's performance in the e~amination.

(See point #2 on the rating scale below.)

The alternative is that the source may be unnecessary and also of sufficient magnitude to be likely to affect an individual's performance in the examination.

(See point #3 on the rating scale below.)

Rating Scale:

• I.

No undue stress

• 2.

Some undue stress Inappropriate.stress was present that could have been practically avoided but would not likely affect an individual's examination performance.

3.

Significant undue stress Inappropriate stress was present that could have been practically avoided, and it would likely affect an individual's examination performance.

ENCLOSURE 3 {Cont'd)

Examination Feedback Ratings:

Pleas*e use the ratingscale described on the preceding.page to.

indicate your judgment of the degree of undue stress that was present in each aspect of the examination identified below.

Write

.the number {l, 2, or 3) in the space preceding the section.

Comments:

Please comment about the source or cause of ahy undue stress, including who was affected {e.g., examinees, examiners) and suggested practical solutions. Attach additional sheets if necessary.

ENCLOSURE 3 (Cont'd)

Pre-examination Interactions with NRC

~~-

~~- Written Examination: Administrative Controls/Procedural Limits Dynamic Simulator

~~-

Please comment on any pr~ctices which yoti believed were. successftil in reducing undue stress.

Your cooperation in completing this form is appreciated.