ML17255A730
| ML17255A730 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 03/16/1984 |
| From: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Macinska F AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML17255A731 | List: |
| References | |
| NUDOCS 8404040276 | |
| Download: ML17255A730 (5) | |
Text
March 16, 1984 Frank L. Haciuska 1528 Elderberry Circle
- Walworth, New York 14568
Dear Hr. Naciuska:
The purpose of this letter is to respond to your questions of January 26, 1984 and subsequent letters of February 2 and 14,'984, regarding the recent NRC involvement in the requalification program at the Ginna Station.
As you know, NRC licenses for Reactor Operators (RO) and Senior Reactor Opera-tors (SRO) are issued on the basis of having satisfactorily demonstrated to the NRC staff the required level of knowledge and skill.
To maintain the license, operators are required to participate in a requalification program that has been approved by the NRC.
This program includes a variety of training mechan-isms, including formal classroom instruction, quizzes and annual tests.
The NRC has both the authority and responsibility to audit such programs to ensure that they are being properly carried out and that they are performing their intended purpose.
These audits may consist of a review of the records docu-menting the program or may include more direct NRC involvement in the requali-fication of, the operators to assure the program's adequacy.
The NRC's authority to conduct such audits and evaluations is contained in th',
Atomic Energy Act and the NRC Rules and Regulations, specifically 10 CFR Parts 50 and 55.
Although the NRC has the authority under 10 CFR, Part 55, to test a licensed operator directly, that was not the purpose of the testing you have called into question at Ginna.
To provide for a uniform approach the NRC staff has established procedures and practices that are to be used in the licensing of operators and in the evalua-tion of requalification programs.
These procedures and policies are discussed and described in NUREG 1021 (Operator Licensing Examiner Standards).
As you correctly have noted, these do not have the force and effect of law; on the
- contrary, these describe the methods used to satisfy ourselves that the NRC Rules and Regulations are properly complied with.
Standard 601 specifically addresses the NRC staff evaluation of licensee requalification programs.
The evaluation process includes the option of using 'an NRC-prepared examination as a substitute for the annual test, normally prepared and administered by your training department.
In this manner, we gain useful information and insights relative to the effectiveness of the training program.
Consequently, on the basis of a sample audit of both written exams and discussions with licensed operators, we reach conclusions about the adequacy of the administration of the requalification program and the extent of its compliance witlj NRC requi rements.
Let me reemphasize that we are evaluating the
Nr. Frank L. Haciuska requalification program by relying on an approach that tests/assesses a limited number of licensed operators.
Using thi s approach we believe that we have a
more reasonable basis for judging the effectiveness of the requalification program.
In summary, the utility conducts a requalification program which includes oral quizzes and written tests.
The NRC staff evaluates this program to obtain a
firsthand understanding of the program's success.
In this regard, we have provided to the training depar'tment all of the examinations we administered on January 27, 1984.
I am enclosing the 'original of your examination.
We are not retaining any copies of this examination.
Furthermore, any corresp'ondence related to our efforts in this matter
'does not specifically discuss any indi-vidual by name and is retained in our docket files for the facility license and is not included as part of any individual's license file.
This is done be-cause we are auditing the facility's pr'ogram and not your individual per-formance.
I thank you for your participation and cooperation in this aspect of our evaluation.
Your feedback is importan't.
We are continuing to work with Rochester Gas and Electric Company to ensure that the results are applied to improve the Ginna requalification program for the benefit of all licensed operators.
If you have any additional questions, let me know'.
Sincerely, cc:
Rep.
Frank Horton Or~pi.".ol sag.",od by 2'.c'.
.'..v.l'.J.8$
Thomas E. Hurl'ey, Regiohal'Administrator
The Honorable Frank Horton United States House of Representatives ffashington, DC 20515 Dear Congressman f{orton:
In your letter dated February 8, 1984, to Chairman Palladino, you forwarded a
tter from Nr. Frank Haciuska, an operator at the R.
E. Ginna Nuclear Power P
nt and a letter that f)r. Haciuska had sent to our Regional Administrator at egion I.
f/fr. ffaciuska raised questions about the legality of a Requa ification'Audit Examination conducted by our NRC Region I Office at the Ginna tation January 25-27, 1984.
On March
, 1984, Hr.
Hugh L. Thompson, Jr., Director, Division of Human Factors Safety (DIIFS), Office of the Nuclear Reactor Regu'lation (ONRR),
Mr. Oon Bec am, Chief, Operator Licensing Branch, DHFS, and Mr. Carlton Kammerer, Director, Office of Congressional Affairs, met uith you to discuss our concerns with the requalification audit examination at the Ginna facil ty.
In that discussion, ffr. Thompson indicated that t<RC shares your conc ms that, while the requalification training for licensed operators at nucl yr power plants must be of the highest quality, the tfRC audit of those pro) ams should not be one that harasses the licensed operators.
While the NRC has auth rity under the Atomic Energy Act, as implemented by 10 CFR Part 55, to requi)f e additional information, including examination of all licensed operators, t at is not the intent of the requalification program audit.
As Dr. Thomas ffur y, Regional Administrator for Region I, indicates in his letter to fir. Hacius a (copy enclosed),
our program is an evaluation of the requalification train' program, not of individual operators.
Hhile we use a variety of technique including NRC examinations to determine the effectiveness of the training t'ogram, the results do not affect the individuals'icenses.
lie inten that a representative sample of licensed operators and senior operators be examined.
If programmatic deficiencies are indicated, program improvements ar identified.
Sometimes, as was the case at Ginna, our initial audit indicat s that a problem exist, but follow-up examinations are needed to identify he extent of the program deficiencies.
From the follow-up examinations, prog am improvements are identified and, if necessary, the individual operators re eive the needed training.
In these cases, all of the original examinations are returned to the individuals examined.
Hr. Haciuska's examination wa returned with the letter from Dr. Hurley.
A second operator at Ginna,
- r. John T. St. Hartin, has also written to Dr. Hurley on this subject.
He will receive his examination with Dr. tfur ley's reply.
OFFICE/
SURNAME)
DATEP NRC FORM 3)8 ()0/80) NRCM 0240 OFFICIAL RECORD COPY
- ~
1
- UZ. QPO 1983~00.247 u A-:;-
vwv
~w ~-r re+-, c
The Honorable Frank Horton United States House of Representatives Washingto DC 20515 Dear Congres an Horton:
In your letter ated February 8, 1984, to Chairman P
ladino, you forwarded a
letter from Mr.
rank Maciuska, an operator at the E. Ginna Nuclear Power Plant and a lette that Mr. Maciuska had sent to ur Regional Administrator at Region I.
Mr. Mac'uska raised questions about e legality of a Requalification Aud t Examination conducted b
our NRC Region I Office at the Ginna station Januar 25-27, 1984.
On March 6, 1984, Mr.
gh L. Thompson.
.. Director, Division of Human Factors Safety (DHFS),
fice of the Nu ear Reactor Regulation (ONRR),
Mr.
Don Beckham, Chief, 0 erator Lice ing Branch, DHFS, and Mr. Carlton C.
Kammerer, Director, Office f Congre sional Affairs, met with you to discuss your concerns with the requa ifica on audit examination at the Ginna facility.
In that discussion, Mr Thompson indicated that NRC shares your concerns that, while the requa ication training for licensed operators at nuclear power plants must be of e highest quality.
The NRC audit of those programs should not be one -
d do not believe it to be one - that harasses the licensed operators as cl imed b
one of your constituents.
While the NRC has authori under the omic Energy Act, as implemented by 10 CFR Part 55, to require ditional info ation, including examination of all licensed operators, tha is not the inten of the requalification program audit.
As Dr. Thomas urley, Regional Adms istrator for Region I, indicates in his letter to Mr. Mac uska (copy enclosed),
ur program is an evaluation of the requalification raining program, not of dividual operators.
While we use a variety of te hniques, including NRC exa nations to determine the
~
effectiveness of t e training program, the resul s do not affect the individuals lice ses.
We intend that a represen ative sample of licensed operators and se ior operators be examined.
If pr grammatic deficiencies are indicated, pro am improvements are identified.
So etimes, as was the case at Ginna, our ini ial audit indicates that a problem ex its, but follow-up examinations re needed to identify the extent of the program deficiencies.
From the fol ow-up examinations, program improvements are identified and if necessary, the individual operators receive the needed training.
In these
- cases, all of the original examinations are returned to the individuals examined.
Mr. Maciuska's examination was returned with the'etter from Dr. Murley.
All of the operators at Ginna who participated in a NRC examination will have their original examinations returned to them.
V c
II
/
/