ML17355A415

Forwards Summary of 990812-13 Training Managers Conference in Atlanta,Georgia Re Recent Changes to Operator Licensing Program.List of Conference Attendees,Copy of Slide Presentations & List of Participant Questions Encl

ML17355A415
Person / Time
Site:	Turkey Point, Saint Lucie
Issue date:	09/01/1999
From:	Christensen H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Plunkett T FLORIDA POWER & LIGHT CO.
References
NUDOCS 9909150141
Download: ML17355A415 (86)

Text

September 1,

1999 Florida Power and Light Company ATTN:

Mr. T. F. Plunkett President - Nuclear Division P. O. Box 14000 Juno Beach, FL 33408-0420

SUBJECT:

TRAININGMANAGERS CONFERENCE MEETING

Dear Mr. Plunkett:

On August 12 - 13, 1999, Region II hosted a Training Managers Conference on recent changes to the operator licensing program. The meeting covered changes to the Regulations, the Examination Standards (NUREG 1021), the new inspection program, and other training issues.

Enclosure 1 is the list of attendees and Enclosure 2 is a copy ofthe slide presentations. is a list of questions received from the participants.

These questions willbe reviewed and addressed at a future date.

Ifyou have any questions concerning the conference, please contact me at 404-562<638.

Sincerely, Original signed by Harold 0. Christensen Harold O. Christensen, Chief

'perator Licensing and Human Performance Branch Division of Reactor Safety Docket Nos. 50-335, 50-389, 50-250, 50-251 License Nos. DPR<7, NPF-16, DPR-31, DRPQ1

Enclosures:

1.

2.

3.

List ofAttendees LIcensee Presentation Handouts Participants Questions cc w/encls:

J.A. Stall Vice President St. Lucie Nuclear Plant 6351 South Ocean Drive Jensen Beach, FL 34957

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FP8L cc w/encis cont;d:

D. L. Fadden Training Manager St. Lucie Nuclear Plant 6351 South, Ocean Drive Jensen Beach, FL 34957 R. G. West Plant General Manager St. Lucie Nuclear Plant Electronic Mail Distribution E. J. Weinkam Licensing Manager St. Lucie Nuclear Plant Electronic Mail Distribution Plant General Manager Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW 344th Street Florida City, FL 33035 R. J. Hovey Site Vice President Turkey Point Nuclear Plant Florida Power and Light Company 9760 SW 344th Street Florida City, FL 33035 Steve Franzone Licensing Manager Turkey Point Nuclear Plant Florida Power and Light Company Electronic Mail Distribution Maria L. Lacal Training Manager Turkey Point Nuclear Plant 9760 S.W. 344~ Street Florida City, FL 33035 Distribution w/encl: (See page 3)

FP&L Distribution w/encl W. Gleaves, NRR K. Jabbour, NRR R. Gallo, NRR D. Trimble, NRR R. Conte, Rl.

D. Hill, Rill J. Pellet, RIV PUBLIC OFFICE SIGNATURE HAKE RI I:DRS HChristensen R

RP oland DATE

/

/99

/

/99 8/

/99 8/

/99 8/

/99 8/

8/

/99 COPY NO E

NO YES NO YES KO YES NO OFFICIAL RECORD C PY DOCUHENT HAKE:

Gt~DOCUHEHT~FPLLXFPLSUHIIARY.NPd YES NO YES NO

LIST OF ATTENDEES U. S. NUCLEAR REGULATORYCOMMISSION Luis A. Reyes, Regional Administrator Victor McCree, Deputy Director, Division of Reactor Safety (DRS)

Harold Christensen, Chief, Operator Licensing L Human Performance Branch, (OLHP), DRS Fred Guenther, Senior Reactor Engineer, Nuclear Reactor Regulator Ronald F. Aiello, Reactor Engineer, OLHP, DRS Richard S. Baldwin, Reactor Engineer, OLHP, DRS Michael E. Ernstes, Reactor Engineer, OLHP, DRS George T. Hopper, Reactor Engineer, OLHP, DRS Larry S. Mellen, Reactor Engineer, OLHP, DRS Beverly Michael, Licensing Assistant, OLHP, DRS Mark S. Miller, Reactor Engineer, OLHP, DRS Charles Payne, Reactor Engineer, OLHP, DRS Marvin Skyes, Reactor Engineer, OLHP, DRS Hironori Peterson, Senior Examiner, Region III LICENSEE CAROLINAPOWER AND LIGHTCOMPANY Max Herrell, Training Manager, Brunswick Ralph Mullis, Operations Training Superintendent, Brunswick Gregg Ludlam, Supervisor - Operator Continue Training, Brunswick Mark Keef, Training Manager, Harris Thomas Natale, Operations Training Manager, Robinson DUKE ENERGY CORPORATION Al Lindsay, Training Manager, Catawba James Teofilac, Operations Training Manager, Catawba Al Orton, Operations Training Manager, McGuire Ronnie White, Site Training Manager, McGuire Robby Pope, Supervisor of License Requal Training, McGuire Gary Yeller, Operations Human Performance Manager, McGuire Tom Coutu, Superintendent of Operations, Oconee John Steely, Supervisor Nuclear Operator Training, Oconee Paul Stovall, Manager Operator Training, Oconee Scott Hollingsworth, Operations Training Liaison, Oconee Rick Robinson, Operations Training Liaison, Oconee Jack Brission, Operations, Oconee Enclosure 1

FLORIDA POWER AND LIGHTCOMPANY Mark Shepard, Operations Training Supervisor, St. Lucie Jo Magennis, Nuclear Assurance, St. Lucie Maria Lacal, Training Manager, Turkey Point Phillip Finegan, Operations Training Supervisor, Turkey Point Bill Burrow, Online Schedule Supervisor, Turkey Point FLORIDA POWER CORPORATION Ken McCall, Operations Training Manager, Crystal River Frank Dola, Senior Nuclear Operations Specialist, Crystal River Tony Roberts, (FRG Corporation) Representative SOUTHERN NUCLEAR OPERATING COMPANY INC.

Scott Fulmer, Training Manager, Farley Joe Powell, Nuclear Operations Senior Instructor, Farley Gerry Laska, Nuclear Operations Instructor, Farley Gary O'Hustede, Operation Training Plant Instructor, Farley John Lewis, Training Manager, Hatch Steven Grantham, Operations Training Supervisor, Hatch Robert Brown, Plant Training & Emergency Preparedness Manager, Vogtle SOUTH CAROLINAELECTRIC AND GAS COMPANY Albert Koon, Operations Training Manager, Summer Perry Ramicone, Lead Instructor Exam Development, Summer James Callicott, Training Evaluation Coordinator, Summer TENNESSEE VALLEYAUTHORITY Daniel Sanchez, Training Manager, Browns Ferry Ardie Champion, Operations Training Manage, Browns Ferry Denny Campbell, Shift Operations Supervisor Instructor, Browns Ferry John Parshall, Shift Operations Supervisor Instructor, Browns Ferry Richared Driscoll, Training Manager, Sequoyah Walt Hunt, Operations Training Manager, Sequoyah John Rodden, Operations Training Manager, Watts Bar Tom Wallace, Operations Superintendent, Watts Bar VIRGINIAELECTRIC AND POWER COMPANY Joe Scott, Operations Training Supervisor, North Anna Steve Crawford, Senior Instructor Nuclear, North Anna David Llewellyn, Superintendent of Nuclear Training, Surry Harold McCallum, Operations Training Supervisor, Surry Michael Brady, Supervisor of Nuclear Training, Surry OTHERS James Makucin, INPO Bob Post, NEI Enclosure 1

0 TRAININGMANAGERS CONFERENCE August 12-13, 1999 COMMENTS/QUESTIONS A.

Written Examination uestions:

1.

The most common issue raised by Hot License Candidates and Requal license holders surround the issue of "trickquestions" and operator written exams not being a fair test of operator knowledge.

2.

IfINPO creates a national initial licensed operator exam bank, willthe NRC consider the INPO bank to be current questions that cannot be used as new questions on the exam to be developed' 3.

Do not feel that the written exam is a discriminatory tool. How many people do poorly on the written exam that are not weak on the operating test'?

Let us use our process to take care of the written with our audit exam.

4.

The utilities should NOT be the ones to develop the sample plan. This should be developed by the NRC for all examinations administered in the region.

5.

NRC needs to understand that increased difficultyof exam process is a negative motivator and could be a distraction to competent board operators.

Recommend Survey to Understand Scope and Potential Impact on Safe Plant Operations.

6.

Evaluate changing initial exam grading to a curve for pass/fail.

7.

Exam difficultyhis gone beyond reason and is impacting the requal program.

People are not willingto put up with the hassle and it does not result in better operators.

It is impossible to meet question standards and avoid "Tricky" questions, very knowledgeable operators can appear less that competent based on complexity of question rather than a test of knowledge.

8.

The NRC exam has become an exercise in exam taking skills instead of a knowledge assessment.

9.

Would you comment on the following proposal '? Have a "team" from the utility come to the region and work directly with the chief examiner to develop the written exam.

I would propose that a team of experienced utilityinstructions could bring the exam bank and associated reference material and they, with the chief, could produce the written exam in less than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

Benefits - lower man hours cost, reduced security concerns (less time on site),

fever negative exam report corrects.

If.the utilityis producing the written exam, when (how may days/weeks) is your expectation for the chief to get the sample plan to the utility'? The point is - getting the.-

sample plan in accordance with NUREG 1021 willnot work.

ln light of the NRC's new goals of reducing unnecessary regulatory burden and increasing efficiency and effectiveness, would it be possible to allow a licensee to build an initial license exam entirely from the bank (rather than 50% new questions), assuming the bank was an appropriate size and security concerns could be solved.

The examination process seems to be getting harder as compared to a few years ago.

Once we use a comprehensive level question, does it become a knowledge base questions the next time we use it.

We may want to have an exam writing workshop.

0 eratin Examination uestions:

The continuous racheting of expectations is bypassing the SAT process.

Example-Cannot use a high importance JPM because it is perceived to be too easy, and operators are trained and tested on it.

Current subjectivity on what is a discriminatory JPM with the removal of the questions.

Need region workshops to calibrate us on future JPM direction.

Why can't the selection of JPM's for the license exam be driven by the SAT process and K/Avalue'? "Lowdiscriminatory valve" is a euphemism for "too easy" and as a result, the difficultyof the exam is racheting up to an unreasonable level. This is contrary to the NRC stated goals.

Open Reference Tech Spec. - it's too complicated to memorize.

Tech Specs should be open reference or better yet covered by Operating Exams (JPM). We do not want our Operators to spend valuable time memorizing ITS, nor do we want them to operate from memory.

0 eratin Exam - Section "A"Admin.

Cate o: This "category" of the new exam process needs to be integrated into the written and JPM (walk thru) segments, and eliminated as a separate entity - only a couple of areas are examined, with no margin for errorl An individual can scope high on the written exam, do excellent on the simulator, and pass all of the systems JPMs yet fail to get licensed due to not passing a couple of admin "questions" - the knowledge and/or abilities could easily be included with other exam segments.

C.

Licensed 0 erator Ex erience uestions:

What are experience requirements for SRO/RO'?

2.

For a SAT-based program, what and where are the requirements for "responsible power plant" experience?

3.

Question - Experience Requirements

~

3 years

~

1 year

~

6 months on site What are the real requirements ifyou have SAT based program' 4.

"Res onsible" ower lant ex erience This issue needs to be resolved INPO, NRC, NEI 'need to determine the specifics and let us know.

We need to know without reservation that SRO-instant candidates meet this ambiguous "experience" requirements~rior to them entering a license class.

D.

SAT Pro ram uestions:

1.

What is/where do I find my "Commission Approved" Training program?

2.

How familiar are, and what kind of training have the examiners received on the SAT

'rocess'?

How familiar (knowledgeable) are the headquarters management on the SAT process'?

What kind of training have they received?

E.

Reactivit Mani ulation uestions:

10 CFR 55.59-the use of SAT based program vice regulatory based programs.

Why do you have to track individual control manipulations ifyou have a SAT based program' "Control Manipulations" in Requai - a prior guidance from previous NRC meeting clearly indicated bean counting control manipulation from the Denton letter was a thing of the past - SAT based requal training would naturally contain a large portion of the annual/biennial tasks and evolutions, therefore, program participants would be involved during simulator training/evaluation, and/or annual Op. Eval. JPMs; "individuals simulator critical tasks" went away and "crew critical tasks" were required.

Teamwork/communications command's control/by the team was the most important.

Bottom line - the implied expectation expressed on 8/12/99 is not congruent with that

. providedin1989by T. Peebles, S. Lawyer, andotherswho provides us guidance.

It appears that we are returning to the middle to early 80's again.

3.

Reactivity Manipulations: 1) For ILO training what is the status of allowing simulator manipulations. (when unable to perform in-plant): also, define (What constitutes a control manipulation); why is a rod operability surveillance ok at one plant but not anothe/?

What constitutes a large change'?

2) For LOCT-INPO's policy for tracking manipulation seems to be in conflictw/NRC requirement (INPO doesn't require tracking on individual basis).

F.

GFES uestons or Concerns:

2000 GFES Dates: Licensee have developed schedules and allocated resources to participate in a AprilGFES.

Changing to a February, June, October schedule would be disruptive, perhaps a April, June schedule for 2000 would allow for a smooth transition (others Licensees made same comment).

2.

In order to facilitate transition to administering 3 GFE/year, is it possible to consider administering exams in April, June, and October during year 2000? This would minimize the impact on utilities that already have an exam scheduled.

Ifimplementation occurs in FY 2000 and exams are given in February, June, and October (as proposed),

unnecessary burden on these utilities could result.

G.

Miscellaneous uestions:

ES-302 - General (D.1.j) - What determines ifa STA is."necessary"'?

2.

When evaluating SRO success in "Classifying the REP" during the operating exam, what criteria do the examiners use for, when to start the 15 minute clock (expectation)'?

(15 minute from event to classification) 3.

Use of instructors is still an issue.

The use of an instructor, who is on the exam security agreement, can't teach candidates attending the Requal program. This is an unnecessary burden on resource restrictions.

4.

Is there some way to do a better distribution of clarifications/rulings from one site in the region to another?

This would help all of us meet your expectations.

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WELCOME TO U.. S. NUCLEARREGUIATORYCOMMISSION REGION 0 G RUMMAGER'S CONFERENCE AUGUST 12-13, 1999 SARI %JUL~ A APEDES, CEN'IXR 61 PORSYIH SW, SUITE 23T85 A

A, GA 30303 ENCLOSURE 2

REGION II TRAININGMANAGERCONFERENCE AGENDA Thursday, August 12, 1999 B:30- 9:00 a.m.

Sam Nunn Atlanta Federal Center (Bridge Conference Room B)

Introduction L. Reyes V. McCree C. Christensen 9:00-10:00 a.m.

Summary of Significant NUREG 1021 Changes C. Christensen 10:00-1 0:15 a.m.

10:15 - 11:45 a.m.

11:45 a.m. - 1:00 p.m.

1:00-, 2:00 p.m.

2:00-2:15 p.m.

2:15 - 3:45 p.m.

3:45 -'4:DD p.m.

4:00- 5:00 p.m.

Friday, August 13, 1999 B:00- B:15 a.m.

B:15-9:45 a.m.

9:45 - 10:00 a.m.

10:00 - 11:00 a.m.

11:00 a.m. - 12:00 p.m.

12:00 - 1:00 p.m.

1:00- 2:DD p.m.

2:00- 3:00 p.m.

Changes in the NRC Break B. Boger ES-300 Series (Operating Test)

R. Aiello Break New Inspection Program C. Christensen Day 2 Opening Remarks C. Christensen ES-400 Series (Written Exams)

R. Baldwin Break ES-500 Series (Post-Exam Process)

C. Payne Recent Training Program Issues G. Hopper Lunch ES - 600 Series (Requal Program)

Closing Remarks M. Sykes G. Hopper L. Reyes V. McCree C. Christensen Break ES-200 Series (Exam Process)

M. Emstes Lunch

TRAlNlNGMANAGERS CONFERENCE August 12-13, 1999

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TRAININGMANAGERS CONFERENCE INTRODUCTION

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~ 9:00 a.m.

<<10:00 a.m.

~ 10:15 a.m.

~ 11:45 a.m.

~ 1:00 p.m.

2:00 p.m.

~ 2:15 p.m.

<<3:45 p.m.

~ 4:00 p.m.

<<5:00

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Introduction NUREG 1021 Changes Break Exam Process Lunch Changes in the NRC Break Operating Test Break New Inspection Program End Da One

TRAININGMANAGERS CONFERENCE

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VICTORM. McCREE Deputy Ditector, DivisionofReactor Safety Region ii August l2-13, l999 REGULATORYTRENDS

~ BACHGROUND

~ DESCRIBE THE CHALLENGEFACING NRR

~ EXPLAINHOW NRR IS IslEETLNGTHE CHALLENGE

~ DISCUSS HOSY NRR IS DEFININGSUCCESS

~ DISCUSS STATUS OF HIGH PRIORITY AREAS FOR ACTION

~ THEN, NOhY ANDTHE FUTURE (V)

BACKGROUND

~ US. Nuclear Rcaetor Industry Averaee Safety Pcrformancc Has Improved Steadily

~ Number ofAccident Sequence I'rccursors Declined Stentlicantty Since 1944

~ Five ofThe NRC Tracked Performance Indicators Show Sienincant improvement Since I9$5 {automatic scrams. safety systcln actuations, stenincant events. equipment forced outaecs ond cottcetive radiation esposure)

~ Chattcnee 4 to Dcnne Proaroms {InRapidly Chaneina Business And Rceutatoty Environments) at a Level Vr'htcht

~ hlaintatn Sa(cty

~ Reduce Unnecessary Reautatoty Burden

~ Increase Public Confidence

~ Improve Efncicncy And Effectiveness

AREAS OF NRC STAKEHOLDER CONCERN

~ Senate & House Committee Reports on NRC Appropriations-Early June, 1998

~ Commission Meeting With Stakeholders-July 17* Nov. 13, 1998

~

NRC Oversight Hearing With Senate Subeommittee<uly 30, 1998

~ Regulatory Framework Needs to Bc Predictable, Objective, And Timely

~ Concern Exists That Some NRC Regulations And Regulator Practice Pose Uaneccssary Burden on Licensees

~ In Deregulated Electric UtilityEnvironment, Unnecessary Regulatory Burden Is ofSignificant Concern to Licensees

~ iNeed For Coatiauous Improvemeat in Regulatory Effectiveness Aad Efficiency

(&) POST-HEARING TASKINGMEMO

~ hlcmo From Chairman to EDO August 7. 1998

~ ldentilics Commissioa Pro posed High Priority Areas For Action

~ Tasking Memo Response-August 28, 1998-Contains Short And Loag Term Actions (Updated hlonthly)

~ hlaintaining Sal'ety Remains ~H'est Priority

~ hinny Tasks Previously ldentilied And in Operating Plan; Remaining Tasks Added

~ Some Existing Tasks hlay Be Appropriate to Slow, Defer, Cancel, Other to Accelerate

~ Challenge ls to Maintain Safety While Reducing Vnneecssary Burden PERFORMANCE GOALS FOCUS ATTE.'iTIONTO MEASURE NUCLEARREACTOR SAFETY PROGRAh1 OUTCO81 ESt o MAI.iTAINSAFETY

~ REDUCE UNNECESSARY REGULATORYBURDEN o INCREASE PUBLIC CONFIDENiCE

~ I.'iCREASE EFFICIENCY/EFFECTIVENESS OF HEY NRC PROCESSES Determined by NRC Nuclear Reactor Regulation Team Working Contractor to Define And Implement Planning. Budgeting, Aad Performance Maaagement Process(PBP81)

With

~~i PRIMARYAREAS OF AGENCY FOCUS

~ Risk-Inforined And Performance Based Regulation

~ Reactor Inspection And Enforcement

~ Reactor Licensee Performance Assessment

~ Reactor Licensing And Oversight

~ IfRC Organixational Structure And Resources

~ Other Agency Programs And Areas of Focus ti.e. license Transfers.

Dry Cask Storage, Decommissioning)

~ Uranium Recovery Issues

~ Changes to i>RC's Hearing Process REACTOR OVERSIGHT (K)

PROCESS IMPROVEMENTS ASSESSMEIIT.LISPECTIOlf AffDKÃFORCKhIElfT

~Suspended SALP Program, hlodiCicd Periodic Plant Reviews

~ Perfonnance Results %1tl Be Evaluated to Determine When Enhanced NRC Diagnosis of Licensee Performance Is Warranted. A Risl Informed Baseline inspeedon Program %1ll Be Pcrformcd For AllSita.

'Framework: Performance Indicators And Risk-Informed Inspection Results Qgll Bc Used to hlcasurc Licensee Safety Performance, Results WillBc Evaluated Using Equivalent Risk'-Informed Scales. tThrcsholds)

~ Inspections ldll Become hlore Risk Informed and Results \\VillBe Kwluatcd For Their Risk Signilicanee Using Rules-Based (Esamples)

Scale.

~Asscssmentt a Streamlined, Structured Review Proccss%1II Bc Used. An Action hlatrix WillProvide Consistency in hlaking Response Decisions.

REGULATORYFKQVlEWORK Please See Handout

ACTIONMATRIX Please See Handout

P TRAININGMANAGERS CONFERENCE AGENDA-DAYTWO

~ 8:00 a.m.

~ 8:15 a.m.

~ 9:45 a.m.

I

~ 10:00 a.m,

~ 11:00 a.m.

~ 12:00 p.m.

~ 1:00 p.m.

~ 2:00 p.m.

Opening Remarks Written Examination Break Post Exam Process Recent Training Program Issues Lunch Requal Program Closing Remarks Question From the Last Training Managers Conference November 5, 1998

~ Need to stay flexible on exam schedule and do not wait until the last minute to accept the criteria from licensee.

Suggested method was to accept the criteria early in process of the prep week. Would prefer to have 30<5 days prior to the scheduled Exam.

~ The Finial Rev 8 Examiner Standard now request that Outlines be sent 75 days prior to the exam date and that the Exam be sent 45 days prior to the exam date. This can be negotiated with the Chief Examiner.

Last Conference Questions

~ The NRC should publish the exam schedule early. Suggestion was to publish at least 1

,yearin advance.

An Operator Licensing WEB page willbe coming'oon and it willhave the exam schedules.

Additionally, we have been sending confirmation letters to each licensee on the exam schedule.

Recommend the NRC turn over the GFES to the Licensee.

~ The near term we plan to go to three GFES exams per year. Long Term we plan to develop a computerized GFES.

Last Conference Questions

~ The issue of written exams and limited staff in NRC create a "de facto" situation for licensees to have to write their own exams.

~ For FY2000 we are writing more exams and Headquarters has requested for additional resourses.

However you may be requested to write an exam ifyou want a given date.

~ The issue oftying up exam writers.

~ The security requirements are like Requal exam requirements now.

Questions for last Conference

~ There is inconsistency in the examiner

'tandards and the K/Amanual.

For example the sampling plan and Part 20 references.

Final Rev B issued, however we need more information to better answer questions.

~ In using the Requal procedure, is the NRC going to inspect manipulations for reactivity levels on an individual basis?

Or can the record be maintained as a team.

Records should be individual because the license is issued to an individual.

Questions for last Conference

..~ Would like NRC clarification on followingthe 10 CFR for an SAT program rather than followingthe guidance in the memo once issued by the Director of NRR.

~ You can followyour SAT based program, however ifyou have a Tech Spec or FSAR requirement you need to followthose requirements or get them changed.

~ Written exams are getting harder due to the raising cognitive levels. Can there be less of acceptance

% for the higher level.

.Rev B placed a limiton the higher level questions 50-60% and no more. Additionally, the time limit for the exam has been extended to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

SUMMARY

OF SIGNIFICANT CHANGES OR CLARIFICATIONS Chris Christensen sos Ilzcg Mp

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SUMMARY

OF SIGNIFICANT CHANGES OR CLARIFICATIONS

~ Changes to 10 CFR 55 New 10 CFR 55.40

- Exams Prepared Using NUREG-1021 Licensees may Prepare, Proctor and Grade Written l

Exam Licensees May Prepare Operating Test

- Licensees Shall Establish Procedures to Control Exam Security and Integrity When Preparing Examinations

-Authorized Representative Shall Approve Exams Before Submittal to NRC Licensees Must Receive NRC Approval of Exam

- NRC shall Prepare, Proctor and Grade Examinations Upon Licensee's Written Request

SUMMARY

OF SIGNIFICANT CHANGES OR CLARIFICATIONS

~ Changes to 10 CFR 55

~ 10 CFR 55.49 Was Revised to Clarify Compromise and Security Expectations e Changes to NUREG 1021

~ ES 200 Series: Examination Process Due dates for Exam Outline and Draft Exam Advanced Personnel Restrictions are Like Requal The Region May Approve Separating the Written Exam and Operating Test By up to 30 Days

SUMMARY

OF SIGNIFICANT CHANGES OR CLARIFICATIONS

~ Change's to NUREG 1021 ES 300 Series: Operating Tests Dominant Accident Sequences Should Be Considered for Sampling During Operating Test Prescripted JPM Questions Deleted

- Can use fol~p questions for Cause

- Aaeinate path JPMs increased to 40%

No Reuse ofMaterial on Subsequent Days

- STA Use OK per Licensee Practice

SUMMARY

OF SIGNIFICANT CHANGES OR CLARIFICATIONS

~ Changes to NUREG 1021 ES 400 Series: Written Examination Systematic Sampling Required for Outline Conslrucbon Learning Objectives Not Required Higher Cognitive Questions 50- 60% of Exam New and Updated Forms 30 Question Sampling Review Exam Time Raised to 5 Hours Clean Copy ofAnswer Sheet Required ES 500 Series: Post Examination May Hold Ucense for 8041% Passes

- Administrative Review Process Streamlined

- Licensee May be Requested to Provrde Reference Material and Technical Information

SUMMARY

OF SIGNIFICANT CHANGE OR CLARIFICATIONS

~ Changes to NUREG 1021

~ ES 600 Series: Requalification Test Item Duplication Expectations Clarified Licensed Operators Detailed Off-site Clarified Proficiency Watch Expectations Ctarifred ES 700 Series: Limited SRO 50 Question Written Examination

~ Appendices Guidance for Developing Multiple Choice Quesfions in App. B

- App. E - Clarified Making Assumptions

-App. F-Defined:

- Responsible Power Ptsnt Experience

- Technical SpeciTcations as a Rererence

1" Examination Process ES-200 Series, Mike Emstes ES-201 Examination Process B,

Faotxy svetoped exahxtstxxts must meet me ossowxtt)

(1) txxnpty w'xh NUREG-1 021 i

(2) stsoxxtt, xhptement end msxttsin securey procedures (5) exam suomxtsts mutt be approved by an authortxed represersstive (s) NRC must approve ths proposed exahxtatens.

C l.s Requests for NRC admvxxtmtvxn ofexamxtatxxts must be in wntxtt) xt accontsnce wxh 10 CFR 55.40 (c).

Respond to NRC ernusl arse'xv'strstwe tsoer arel tvseo rst)vtn soprsued ofany chant)es.

Corxsct Rayon llOt.B Branch Chef by phone to negouste exam dsts 5 end development optons. Parcel development msy be negotrsted.

ES-201 Examination Process C.1.b The at)ency enforcemsnt polcy apples to exam compromrxe. has a secten cased other consxferauons'hich was rot in axerxn Rev. B which srxnmarizes sane exam securxy and itet))rxyrxxues C.l.e The amxsstt Of referutxe ma lanai requexted fmm the faxifrtytxenxee Wia be ed(usted octad on the NRC's tave) of tvoovement st me exsmxtsten development pmosss.

The CSef exattxter wis discuss reference mstsnst content and due dates durxtf) the phone css prior to the 1204sy letter.

Tile scsnsee Is requested to submc tress copess of the outtnss snd exsmnstjorN.

Only one copy ofthe referenCes is mqu'red. (Ret)on II lequext)

C.t.f Afsotrty oenerisor or mansper shat) inospenderuty rsw'svr the exsmvtsten outsnss and the proposed exahs before they sre suomcted to the NRc.

I I

Examination Process C.1.Q An aueorltsdrepreentsctive ofee fscilay icorlsee shall approve ee submxtsts before sondinQ earn to ee NRC for review. The suthonrod teoresontstm is not es same person as the ~fscsr reviewer. Tee eulncnzoo telo ~ satire wla be ee s<<ne person tnst ~ch4 ay tatter Is serll lo. He does rica hood al rovisw the test aoms riorbe orl ols secxrlry OQreemsnL C.t.j Feciaty is encxxx>>Qed to ccxnmcmk>>te signifcsnt conc>>ms vne ee contara for darxxray ofeo NRC prepared exam ofee chanQos est ee NRC hss catocted lor as proposed exam.

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upon wieee NRC.

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C2.c About four manes before ee exsmitatkxL ee crv'ef Examiner wia caa lne faorxy to docuss ee nile aerrls sated.

NOQousten of detrrory dates may be made to aaow most etrxssnt renew, C2.f Exsmi>>rs have ee opten to not pancipelo iIee prep week w'sIL ES-20'1 Examination Process c&h Ths wrxtsn end oporscno portions ofthe ex<<IIs mey be spat by up to 30 days.

ca.f amnch ctv'ef vna sjFI the OA shoots when he is ssssried that ee

~xamnstions sle ready for acsrr'eisrrsdcxL C.3,1 Ssmptno Review'f ee wrtaon exsmilsson shaa be completed wchin ono week of tecsvvlQ 010 ox>>llrlsticn arid ee betsnco ofee review completed ithvo weeks Oner rooapL c.3 i sRO upQrsdss raanQ en Ro or Bop posrten do not neoct to be evstu<<od igavidusay, ES-201 Examination Process 02.0 Faoaty should lmx acx>>ss to only eose port'fans wrv'ch ee iafwituat bears teopvuo4cy.

og.b Gives examples of prohcxted sctivx>>s'or iaavxtusts on ee secunty AQreom0rlL Supeisors snd mansQers on ee Sscxxtty AQeemenl may contiare thoi Qerloml ovotsIQnt ol es a'0 rvnQ proQrafn Atclucana review ofexwnvlstiorls and tamed'rarvny.

They msy tax provide ndwxtuat apptcsrc feedback.

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ES-202 Preparing and Review Operator Licensing Applications I

r c.l.a Ifmore own sir months have passed artcc an apptcanrs medcal

~xsmrwoon. ow facsrry shsa certrry dist ow appcarll hss nol developed any peerage contsuors II G2.b The requ'nwnt for rrre tupnccant reactivrty mancsrtations ls ctanrwd.

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0.3 ~ crserla for 1.1nsed semor Reactor peerators moved from Es.lol.

~i ES-204 Processing Waiver Request D.1.a Aretstte esnrtrwbcÃl lrlusltake place wclrt orw year of Ow date on which ow denial ofow or9rwl apptcaoon lwcame rrwt, D.1.9 The re9iorl may waive Ole lequvemerss foren e semination 9 the eppicanl was prevrousry lcensed at ow same faqsty, Must have termewted psncipaton n requal less own two years a9o.

0.t.h Tl>> re9itn may accept apptcatons and atann'ster seams to appacsnts vrno fwve nol completed owr &e reactnrry man'truratcns due lo estended SnutOOwa A COld Or refuetrt9 teenae vrie be iSSued.

ES-205 Generic Fundamentals Examination Program l

C.l.a Facihty lcensees should notifyow NRR operator ricens'st9 pro9rarn office if owy add or oelete an tdivrduat from owv previously submeed rely'stratcn lacer for tne GF ES oerbre ow esamrwtan rs atsniestered.

I Ath'ed GFES is pose@le lt2000. october 1999. Febnrary 2000, s June 2000 are steely dates.

The GFES cram date iS a4rayS OW WetSWSday oner OW rear Sunday Oflne

TRAININGMANAGER CONFERENCE REGION II OFFICES AUGUST 12, 1999 BRUCE A. BOGER, DIRECTOR DIVISION OF INSPECTION PROGRAM MANAGEMENT OFFICE OF NUCLEAR REACTOR REGULATION

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REGULATORY FRAMEWORK

'RC's Overall Safety Msslon PUBLIC HEALTHANDSAFETY AS A RESULT OF CIVILIAN NUCLKARRKACTOR OPERATION Strategic Pert'orlnnnce Areas REACTOR SAFETY RADIATION SAFETY SAFEGUARDS Cornerstoncs INITIATINC EVENTS MITICATIO SYSTEMS UARRIER INTECRITY EMERCENCY PREPAREDNESS PUBLIC OCCUPATIONAl Pl l YSICAI PROTECTION IIUMAN

" SAFETY CONSCIOUS WORK PERFORIMNCE ENV1RONMENT t

PROBLEM IDENTIFICATIONAND RESOLUTION

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Plant Oversight Process Management Meeting Licensee Action

- - < NRC Inspection, Regulatory Action Assessment Report Public Assessment Meeting

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8.85II'~I,"Ii'valuation ofFindings

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Operator/Technician Fatigue "Policy on Factor Causing'Fatigue of Operating Personnel at Nuclear Power Plants" (GL 82-12)

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Policy implemented through technical specifications

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Recent allegations and Congressional interest

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Use of overtime at some plants not consistent with policy. guidelines

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NRC to reassess policy statement

'i 0 CFR 55.31(a)(5)

Reactivity Manipulations Current Rule I

Requires 5 significant control manipulations that affect reactivity or power to be performed by each license applicant Must be performed on the actual plant Proposed Rule Would continue to accept use of the actual plant -or-Would allow use of the simulation facility-if-Control manipulations are evolutions that are part of the SAT-based, Commission-approved training program,

- and-core and thermal-hydraulic models reflect the actual core that exists or will be loaded at the time of the applicant's operator's license examination, - and - simulator fidelityhas been assured by testing Related Regulatory Activity,'egulatory Guide 1.149 is being revised to endorse ANSI/ANS 3.5-1998, 10 CFR 55.45 is being revised to reduce unnecessary regulatory burden.'

ES-30't Final Rev 8 Change Overview Purpose A

Attsop4cants for reactor operator (RO) snd senior reactor operator (SRO) liceriscs st power reactor faciaties src fcqubcd to take sn optrstirig test. unless Ilhas beth waived in accoldanccvnth 10 cFR 55.47 (rcftrto Es-204). The specÃic content of thc operating teal dt panda on the type of acense for which the applicant has

applied, This standard describes the procedure for developing operating tests that meet the requvements of 10 CFR 55.45. inducing the use of reactor plant simutstion facilsies snd the conduct of multi unit evaluations.

Background

B To the extent sppbcablc,the operating test willrequire the op p4cant to demonstrate sn understanding of. and the abilityto pcrfonn, the scdons necessary to sccom pl)eh s representative sam pang from the 13 items identified in 10 CF R 55,45(a) (all 18 lrtms do not n<<d to be sampled on awry opcrsdnp test).

IfiaddCion, tht conttllt Ofthc operating test wia bc Idtrltlfitd,ln part, from learning objectives contained in the facilitylicensee's training program and fnom bdormadon in the final safety analysis report. system description manuals snd operating procedures. the facitcy license and lieenae amendmentS, 4Ctnxee event re pcrtS. and Other materialS requested from the facility4censee by thc Commission.

Category "B" Control Room Systems and Facility Wai)t-through (B.2)

II Category B is divided into two subcategories.

The fiat snd larger subcategory IB.l. control Room systems

) focuses onthose systems with wtuch licensed operators sre most involved (i.e.. those having conuots snd hdications kt the main control room). The second subcategory IB.2. Facitxy wstk Through ) ensures that the applicant it familiarwrth tne design and operation ol systems located outside the main control room.

The applicant's knovriedge snd abiiiries relative to each system are evaiusted by admfnlstennp JPMs and, when necessary, specific follow.

up rfuestions based on the applicant s performance ofeach JPM.

I Category "C" Integrated Plant Operations (8.3)

Each spprcant must demonstrate proficiency on every competency a ppbCabte tO hix Or her geense level. The Only eXCebbcn iS that SRO Competency Number 5. Control Board Operations.

is optional for SRO.

upgrade applicants (fe., SR~pgrade appiicants do not have to tliiaposirion that rerfufreS COn bur bOard OPera tiOnxihOwe Ver, Ifthey dO rutate inrO such a position, they willbe graded on this competency even though they may not be individuallyobserved by an HRC examiner, as discussed In ES.202].

INSTRUCTIONS General Guidelines (0.1.a)

To minimize predictsbitriy and maintain test integrity. vened subjects.

SyxtCmx. and OperatiOnx ShaN be eValuated wnh op pbCSntx that are nOl being exsmrncd at the same time, unless measures src token to preclude interaction among the applicants.

The same JPMs and simuiator scenarios shall not be repeated on successive days.

General Guidelines (D.1.a) cont operating tests wltacn by the fsorrty licensee may not duplicate test items (slmulator scenarios or JparsJ from the applicants'audit test (or tests Ifthe applicant Is retrain p the examination J given st or near the end of the license training crass.

simulator events and Jpars thai sre sider to those that werc tested oilthe sulfa exsfMlation sfc pcrrnirrcd provided thc

~ctions required to mitigate the transient or complete the task (e.p., usinp an CINrnare path as,discussed In Appendix cJ are significantly different fnom those required during the audit examination. The*cillrylicensee shall Idendfyforthe HkC chief esaminer thOSe SimulatOr eventa and Jpata that are Similar tu thOSC that were tested on the sudlr examination.

General Guidelines (D.1.d)

When selecting and developing msteriais (JPMs. scenarios. Cnd questions) tor the opcfabng 'test. ensure 'that the rllatcriais contnbutc to thc tears overaa capacity to Nfercnuste between those a pp4cants who arc corn peient to safety operate thc ptsnt and those who sre not.

Addirionally,~liofthe test items should Include the three facets of test vslldhy(ie

~ content, operational, anddlscrimlnao'onJ discussed i

In Appendix A.

I I

Any test acms that. when missed, would raise question regarding

~oequatc iustrficstion for denying the applicant's tcense should noi be induced on the operating test.

General Guidelines (D.1.i)

Every facet ofthe operating teat. Includinp the prescrlpred Caregory A questions and answers, the Jpafs for Categories A and B, and the Caragory C simulamr scenanos, should be planned, resesrchcd, validated. and documented to the maximum extent possible before the test is adfllinixtered.

That ls 8 E F 0 R E

General Guidelines (D.1.j)

Examiners who wiN bc admkdstenny the opersdny tests but wife nol involved kt their developmenl sre expeaed to research and study the topics snd systems to be examined on the opersliny test so that they sre prepared lo ssk whatever performance-based toUow.up questiionx miyhl be necessary to determine lithe appiicsrll is compelerll in those areas.

I As stated In 10 CFR 5$A$(af, the operatlnp test requires the applicant to demonstrate in understanding otand the abilityto perform the l

scdons necessary ro accomplish s representadve sample from among 1$ items listed In the rule.

General Guidelines (D.1.j) cont lfthe applicant cone ctlyperforms ~ JpM (including both crfticaland noncrtdcal stepsi and demonstrates familiaritywirh the equipment

~nd procedures, ttis not necessity to ask any followwpquestions.

t However, Ifthe ipplicant falls to accomplish the cask standard forthe Jptrt or demonstrates

~ lickofunderstanding regarding the

~qvlpment snd pmcedures such as hiving dNiculrylociting Intonnadon, control board Indicadons, or comrols, the examiner mvst be prepared to ask perfonnance based followup questions, as necessary, to clarity or congrm the applicant's understanding ofthe system as Itrelates to the taslr that was perfonnid.

General Guidelines (D.1.I)

The presaipled questions tor Category ftsnd the perfom>>nce based follow up questions for Catipory B n>>y include a combinadon ot open.

~nd closed-reference Items. Open.rclerence cams that require spp6csnts lo apply their knowledge ot the plant to postulated normal, abnormal. snd emergency situations are preferred.

Closed-reference items msy be used to evaluate the immediate saions of emergency snd other procedures, certain aulomalic saions. operstxty CharaaeriadCS.

intertOCka. SCt POintS. and rOutine SdmintxtratiVe aCtivirieS, ss appropn'ate to the facility.

Referto Attachment1 formore pvidtnce regarding the developmentand l

use ofprescripted open reference questions tor Category A ot the walk-through test.

To the extent possible, the concepts ln the anachment should iiso be applied to perforn>>nce-based follow vp questions.

l II

Cata gory "A" Administrative Topics (D.2.b)

For each administrative subject. detenninethe best method for evaluating the a pplicsnt's knowled ge or abidty inthat ares. Almough a performance.

based evahrsdon. using a single administrative JpM is generally preferrerl.

two prescripted questions msy be used lo conduct the evatusdon in each Speetrro SubjeCl area Setested fOr eVahradcn.

The quesdons msy be associated wfrh category B Jpafs or they msy be administered separately.

I Administrative Topics (D.2.9)

Forward the completed outline to the NRC cSef exanwtel so that ItIs received by the date agreed upon withthe NRc regional orrce st the time the examination arrsngemems were conrxmed: the outkne is normally due rpproximstefy Td dhys belore the scheduled examination date. Refer lo E5 20 I for add ldona I urstru coons legardiflg the review and submrttal ofthe examination ouuine.

Administrative Topics (D.2.h)

Atter the NRc chief examiner approves the operadng test outsne, prepare the final Category Atesl materials in accordance wrth the general Opemting teat gurdednex in Seaian 0.1. the Openreferenee quextiOn guidelines in Appendix B. and the JPM guxfeenes in Appendix C.

ff,e., the JPMs, prescrlpred questions. end answers)

Control Room Systems and

. Facility Walk-Through Specific Instructions For Category B (D.3)

This category ofthe operating test evalwtes the applicant on systems-related @les by having the rpplicant perform selected tasks and, when t>>cessary, based on the rpplicrnt's performance, probing his or her knowledge ofthe trek md its associated system with specific follo~p tfuesdons.

Thc Category B tasks ate in rdtkffon to and should bc tNfetcnf hom the events and evolutions conducted during Category C. Integrated Plant Opetations.

Specific Instructions For Category 8 (D.3.a) cont The 10 systems and eotutions seiected for RO and SRO-I applicants shoukl

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evaluate a! least 7 dNercnt safety functions. Att ofthe systems and

~volulions in each subcategory ofthe test should be seleaed from dNerent safety funcdon lists. and the same system or evolution should nol be used to

~valuate more than one safety funcuon in each subcategory.

For PWR operating tests, the prfmary and secondary systems listed under Safety Functions, Heat Removal From Rerctor Core,"in Section 1.9 ol HllREC 1122 mrybe treated as sepr rate artery functional l.e., two systems, one primary end one secondary, n>>y be selected fmm Safety Function 4.

S pecific Instructions For Category B (D.3.a) cont The 10 systems and evotutktns selected for RO and SRO-I applicants should evaluate al least 7 dNerent safety functions. Allof thc systems and evolutions in each subcategory of the test should be sekcted from dNerenl safety func&xlLsts. and thc same Sys'em oi evolution should nol be used to evatuate more lhan one safely function kt each subcategory.

For PWR operating tests, the pnmaryand secondary systems listed under SrfrtyFunction/,

Heat Removal From Reactor Core, In Section 1g ofHflREG-1122 mry bc treated as separate safety functional l e.I two systems, one primaryrnd one secondary, mry be selected from Safety Function 4,

Specific Instructions For Category B'D.3.b)

For each system seleaed for evaluation, seiecl from the s pprcsbie K/A catalog or the facilitylicensee's ske-sperdrrc task kxt one task for which a JPM exists or can be developed.

Review the associated bnutsto outane IfIt hss already been prepared (reler to section DA).snd avoid those tasks that have already been seleaed for evstusdon on tne dynainic simrsator test.

I The JPQs should, individuallyand as s pmup, have meaningful performance requirements that willprovide ~ leplrlmste basis for

~valuating the applicsnt's understsndinp ofand ebilhy to safely operate the assoclsredsystems snd the plant (ss required by 10 CFR SSAS).

Specific Instructions For Category B (D.3.b) cont Atleast one ofthe tasks shsa be related to s shutdown or low power condsion. snd sg percent ofthe tasks (l.e., srf0 forRos snd instant SROs and 2rS forupgrade SROs) shall require the sppkcsnt to execute alternate paths whhin tne fsckhyb operating procedures.

In addition, s't least one ofthe tasks conducted In the plant (Le.,

subcategory 8.2) shall evaluate the applicanrs abkity to implement actions requved during sn emergency or abnormal condaion, snd another snail requve the spprcsnt to eruct the RCA.

r This provides an exceaent op ponunity forthe applicant to discuss or demonxuste the radiation control subjects descnbed in Admiruxlrative Topic A.3.

Specific Instructions For Category B (D.3.c)

Forwanl the compieted walk.through test outdne to the NRC chief examiner so that it Is recelvedbythe date agreed upon wnh the NRC regional ctree at the time lhe examination arrangements were confsmed; the outlines are normally due approximately Ts days before the scheduled examitation date. Refer to Ks.201 forsdrabonal ktxtructians regarding the review and submatsl of exslTlinstion outtktcs.

Spe'cific Instructions For Category B (D.3.e)

Submit the entire operabng test package to the designated facitxy reviewer or the NRC chief examiner, as appropriate. for review and appmval in accordance with secdon E. The test must be received by the NRC chief examiner approximately 4$ days before the scheduled review date, unless other arrangemeiris have been made.

integrated Plant Operations Specific Instructions For Category C (D.4.d)

Each scenario set must, at a minimum. require each applicant to respond to the types ot evouiions. failures. and transients in the quantxies identified for the applicant's license level on Form ES-Sot-5.

Transient and Event checkhst An applicant should only be given ciedx for those events that require the applicant to perform venf~bte aaions that provide insight to the a ppticanrs competence.

The required instrument and component failures should normally be completed before starting the major uansientl those that are initiated

~rter the majOr tranxient Shauld be Carefully reviewed OeCaua ~ they may require littleapplicant anion and provide lirr/e insipht repardinp rheir performance.

Specificlnstructions For Categoty C (D.4.d) cont Each event should only be counted once per a ppbcsnc For example: a power change can be counted as a normal evolution OR as a reactnnty manipulation.

I Sinvtsrty. a component failure that immediately resutts in a major transient counts as one or 'tile other>> but nol both

Specific Instructions For Category C (D.4.d) cont Any normal evolution, component failure, or abnormal event (other then ~

reactor trip or other stnomsdc power reduction J thar reqvires the operator to perform s controlled power or resctivhy chsnpe willssdsfythe requirement for ~ resctivlry msnipulsdon.

i I

This Includes events such ss sn emergency boration, a dmpped rod recovery, s sipnillcsnt rod bank realignment. ors manual reactor power reduction In response to s secondary system upset. Such events msy produce s more timely operator snd plant response then s normal power i

chsnpe.

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I Specificlnstructions ForCategory C (D.4.d) cont lfthe fscllhylicensee normally operates with and is required by its technical specifrcsdons to have more than two Ros In the control room, the chiefexaminer msy suthorfxe the use ofadditional sunogstss to tillovt the crews.

I In such cases, take care ln planning the scenarios to ensure that the

~dditionsl operators do not reduce the examiners'ability to evaluate

~ach applicant on the required number of events snd on every competency and rating factor.

Specific Instructions For Category C (D.4.e)

When thc procoscd simulator operabng text ouuines are complete. forward them to the NRC chief examiner so they sre received by the date agreed upon wrth the NRC tegionai olfce at the time the examutsbon ansngemenis were confxmed: the oudincs arc normally duc

~pproximstely 75 days before the scheduled examination date. Refer to Es-201 forsddiiionsiinsuuctions regardiny the review and suomctal of the exsnxnstion outlines.

Specific Instructions For Category C (0.4.g)

Subme the entre operating test package to the designated facilrtyreviewer or the NRC chief examiner. as appropnate. for review and approval in accontance with Section E.

I The test must be received by the NRC chief examiner approrimareiy 4S days before the pcheduted administration date, unless omar arrangements have been made.

QUALlTYREVlEWS Facility Management Review (E.1)

Ifthe operating test was prepared by the facility scensee. the preliminary outline and the proposed rest shall be independently reviewed by a su penrisor or manager before they are submlned to the NRc regional africa for review and approval et acconlance with ES-201.

The revieWer ShOuld eValuate the Outline and text uxing the Criteria On FOrma ES.201.2. ES-301.3, and ES.30tH and etcfude the signed forms {foreach I

deferent operating test) xt the examination package subnvtted to the NRc in accordance wxh ES 201.

I ATACHMENTS (F)

"Open-Reference Question Guidelines"

Open-Reference Question Guidelines

1. The most appmpriate Sonnet is the shortwnswer question, which requires the applicant to compose ~ response rather than select from among a set ofahernadve responses, as is the case whh multiplechoice, matching, and true/false questions.

2. Provide cfear, explicitdirecdonsrguldelines foranswering the tiuesdon so that the applicant understands what constitutes ~ tully correct response.

Choose words carefully to ensure that the sdpuladons and requiramemsof the quesdon are appropriately conveyed.

IVordssuchas

evaluate, outline, and

explain, csn invite ~ lot ofdetail that Is not necessarily relevanc.

Open-Reference Question Guidelines (cont)

$. Make sure that the expected response matches (and Is limhed tol the requirements posed in the question.

Consider the amount of pardal credit to be granted foran incomplete answer. For questions requlnng computadon, specify the degree ofprecision expected.

Tryto metic the answer turn out to be whole numbers.

4. Avoidgivingaway pan oreg ofthe answer by the way the question Is worded. For example:

lfthe letdown line became obstructed, could bors tlon ofthe plant be accomplished shordy atter a reactor trip to put the plant in cold shutdown y Ifso. howy 4 testwris ~

applicant can realize that the answer has to be yes, or else the second part ofthe question would have read something like IfnoL why noty Open-Reference Question Guidelines (cont)

5. 4 void what could be considered ufck questions in which the espeCted anawer dOeS nOt preCISely matCh the queStiOn.

FOr eXample, asking Howidol the Sl teniunation criteria change followingan Sl reinhiadonT implies that the termination ctiteifa willchange, when In

~ctuality they do not.

d. Do not use direcf look~p questions that onlyrequhe the applicant to recall where to findthe answer to the quesuon.

The operational orientation required of questions on the walk-through test and the

~pplicant s access to reference documents, argue against the use of questions that test forrecall and memoritation. Anyquestions that do not require anyanalysls, synthesis. orapplication ofinfonnation by the applicant should be answerable whhout the aid of reference materials.

Refer to Es-d02, Attachment t, fora more detailed discussion ofdirect lo'ok up quesdons.

Open-Reference Question Guidelines (cont)

T. Questions should also adhere co the generfc Item construction principles and guidelines in Appendix S. Moreover, Form FS.402.1, HRC Checklist for Open.Reference Test Items, contains a listof questions that can be used to evaluate the suitability ofthe questions forthe walk.through portion ofthe operating test.

Although the checklist was developed foruse In evaluating re qualification written examinations, all ofthe crherfa except 0, 10, 11, and the ltiArating on item T are genencally applicable.

602-1 Excerpt Items 9, 10, and 11 g.

is the question appcotxiate tor the wceen examination and the

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selected format Ie.g.. short answer or mueipte choice)?

10. Do questions in Section Atake advantage ot the simutator control room seaing?

I 1 t. Does any question have the potential of being a dou~pacdy quelion?

ES FORlNS ES-301-1,2, 3,4, 5, and 6

Examples of LONfdiscrimination JPMs

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1.

Reset the Turbine Orinn AFWPump Trip Throttle Vshfe (PWR) 2.

Actuate AOS (single critical slap) (BWR)

I 5.

Start the kydfogen Recombiner (whhout a fault)

Locally borate the RCS with the emergency manual boration vaNC (PWR)

Examples of DISCRIMlNATORY JPNs.

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Q~ ++++

1.

Ofoppcd fod recovery (dfop a second rod durltlg fccoccfy fcftuifslg reaaor tnp) 2.

Local start ol eftuipmcnt with fsdures requiring the use ol atfemste pfoccdures.

, ~

~

ES-302 Final Rev 8 Change Overview Purpose A

I

'This standard descnbes how to administer operating tests to fntdal license applicants in accordance withthe requirements of 10 CFR 55 45. It indudes polcies and guide4nes for admirustering both the walk-through and the integrated plant operations categones of the operatinp test. It Is assumed thai the operating test was prepared In accordance with ES 301.

Background

B As noted in ES.201. facilitylicensees willgenerally prepare proposed operatinp tests in accordance wnh ES.30t and submn them to the res pon sible NRC regional otfice for review and a pproval.

Regardless ofwhether h was prepared by the facilitylicensee or the frRC.

every operating test wid be inde pendently administered and graded by an fIRC dcensinp examiner in accordance wrth the instructions contained herein and in ES 303.

I I

Res ponsibilities "C" Facility Licensee (C.1.b)

~

Safeguard the intcgdty and security ofthe opersdng tests in accordance with facilityprocedures established pursuant to 10 CFR 5SA0(bf(2J and the guiderines rhscussed in Attactunent t of ES-20t.

I I

Responsibilities "C" NRC Regional Office (C2.a)

Worh withthe facllhycomact ro coordinate the operating test

'dminhtrao'on schedule In a manner that maslmizes efficiencyand maintains security.

i Normally, the operating tests should be administered wfthlnJO days before or after the wrlnen esa mlnadons.

The region shall obtain concurrence from the HRR operator licensing program otYice Ifthe

~semination da tes diverge by more than JO days. (Refer to ES.201 fora ddhlonal guidance raga nfing examinadons that have to be rescheduled to achieve an acceptable product]

Test Administration Instructions and Policies (D)

General (D.1.d)

Honnally, an HRC esaminer willbe assigned to individuallyevaluate

<<ch a ppli cant during the simu4tor operating test. However, Ila three-person operating crew consists entirely ofsenior reactor operator (SRo) upgrade applicants (who do not have to be evaluated on the control boards), the chief examiner may assign only two eraminers to observe the crew.

Although the applicants in the r<<ctor operator and ba4nce ofplant positions may not beindivldually evaluated, they willbe held accountable forany errors that occur as a result oftheir action(s) or inacdon(sI and graded on theirabflhy to "Operate the Control Boartfs" (i.e., SRO Competency JJ. SROInstant applicants wfll

~lways be individuallyevaluated by en HRC examiner regardl<<s what operating pOSIO'on they are fillingcfuring a given scenario.

General (D.1.j)

Although the simulation facikty operator willnormagy assume the role of the other personnel that the sppkcsnts diect or nobfy regarding plant operations, the chief examiner msy permit other members of the fscikty training or operadons staff (e.ga shift technical advisor (STA)I to

~upment the opera Vnp shiftfoam Ifnecessary.

The chief examiner shaN fusy brief those individuals regarding their i

responsibghies, reponing requirements. duties. and level of participation before the operating test begins. The examiners must not restrict the surrogate operators' cdvities to such an scient thai the applicants being evaluated sre requksd to assume les ponstbtkties beyond the scope of their poaUon.

The sunogate operators wiN be expected to assume the fugresponsibigtles of the roles they take in the operating test. Consuhadons wfth sn STA l

shillbe conducted In accordance wfrh thi facilitylicensee's normal control room pracd eel e.p., sn STA shall nof be stationed In the simulator IIthey are on+ail at the sha Walk-Through (Categories A and B) (D.2.b)

To the extent possible, the examiner should have the a pplicant perlonn the control room J PM5 on the simulator, rather than asking the s pplicsnt to describe how he or she would accomplish the task.

Ifthe examiner observes a discrepancy between the slmulirorsetup

~nd the condhions specified in a JPM, then the examiner shall stop the JPM snd conect the shuidon, as necessary.

Ifthe Caulk can be completed whh different viluas (e.p., wind direction when determining a pro tecdve iction recommendation during an

~merpency), then the examiner shilldocumint thi differences and coonrinate with the ficilhycontact and the kRc chief examiner to validate the applicant's response under the actual condidons.

Walk-Through (Categories A and 8) (D.2.()

I r As stated In 00 CFR 55'(a], the opersdng test requhes the applicant to demonstrate an understanding ofand the abilityto perform the

~ccions necessary to accomplish a reprasinta tive sample from among f5 Items listed In the rule.

Ifthe applicant conectly performs ~ JPM (including bcnh crfticaland noncritical steps) and demonstrates famlliimywhh the equipment and procedure, the eximiner should infer that the applicant's understanding offhe sysremrrask Is adequate snd refrain from asking foNovwup questions.

However, lithe applicant falls to accomplish the task standard forthe JPM, exhibits behavior that demonstrates s lack offamiliad~ with the

~quipment ind procedures, oris unable to locate information, control board Indications, or controls, the ixaminershould ask perfbnnanca-based followup quesrions as necessary ro clarifyor confirm the

~p pli cant's understanding ofthe system ss Itrelates to the task that wss performed.

Walk-Through (Categories A and B) (D.2.f) cont Simikrfy,Ifthe applicant gives sn ambiguous answer to a prescriptad

~dmlnistradve question In Category A, the examiner Is expected to ask probing questions to ensure that the applicant understood tha original quesdon snd the applicable knowledge or ability.

The examiner shall document sllperformance. based questIons snd answers forlater evaluadon.

lfsn applicant volunteers addldonal or corrected information oner having completed a task or question, the examiner shall offer the

~pplicant the opportunhy to take whatever actions would be required In a similarsitusdon In the pknt.

The examiner willrecord any revisions to previously performed tasks oranswers forconsldaradon when grading the opersvng test per Es-dgd.

Walk-Through (Categories A and B) (D.2.g)

The examiner should prscbce other goodwalk~ evalua0'on techniques ss discussed in secoon D ofApperusx C.

Walk-Through (Categories Aand B) (D.2.o) ttthe simulation tacky should become inoperable snd cause excessive delay or thc opefsdng tests, the shier examiner shoUld dkcuss the scustion with the fsctetyscensee and the responsible regional supenrisor so that management can make s decision regarding the conduct of the operating tests.

tt may be necessary to reschedule the simulator examinsdons tor ~ tater date.

The simulator should be considemd inoperable under any ofthe followingcondhionsl The simulator exhibits a massienergy imbalance. ensue logic, or inexplicable panel indications dunng model execution.

- The simulator exhibits unpknned snd unexplained events or malfunctions that cause the applicants to divert from the expected responses and success path ofthe planned scenano.

Walk-Through (Categories A and 8) (D.2.o) cont l

The simulator automatically goes to the freeze state duKng s scenado ors beyondsimulatedlimlts slannis received on the Instructor station.

The simulator Instructor Informs the examination team that s sohwere module hes halted or kicked out.

Occurrence ofsny ofthese abnormal simulator operadng condidons dutfng an examination constitutes s&icient cause to stop the scene do. &slusdons ofthe applicants'erformance dun'ng sny of these simulator malfunction condfdons msy be unreliable.

Wlwn the simulator hss been restored to fulloperability, the chief examiner willdetermine Ifthe scenario reriuires re pie cern enb msy be resumed In progress, or msy be restarted from the beginning.

Finai Rev 8 Change Overview Purpose A

This standard describes the procedures for documendng att categories o<

the operating test. coaatsig the data to arrive al a pass or lail recommendation, and~g the documentation to ensure quality.

Background

B This standard assumea that the operating test was prepared and administered in accordance wtth 6&501 and ES-302. respectively.

4 The procedures corltaiflcd herein require thc csaminel to evaluate each applicant's perfonnance on the operating lest and maire a judgement as to whether the applicant's revet ol knowledge and understanding meet the minimum requirementa to safely operate the faciety for which the license is sought.

The examiner evafuates each noted deficiency in right ofthe tots'I breadth Of knowledge and a barry demOnauated by the a ppaoanl ln that SubjeCt ates.

Responsibilities "C" NRC Examiner of Record (C.2)

I As soon ss possible atter sdminittering the test. the examiner ol record chal!review. evaluate, snd finaate each applicant's operating test documentation bt accordance withthe instructions in Section D.

Iten applicant made an error with serfoua safety consequences, the examiner may recommend an operating test failure even Ifthe grading Insrrucdons In Sacdon 0 would normally result In ~ passing grade. tindersuch circumstances, the examiner shall thoroughly justifyand document the basis forthe failure In acconfance wfrh Secdon D>.b.

Mo!eever, the HRC regional oflice shall obtain wrfrren concurrence s

from the HRR operaror licensing program office before completing the Iicenslng action.

Grading and Documentation Instructions "D" Evaluate the Applicant's Performance Form ES-303-1

~ Category B (D.2.b) r I

To detemine a grade forthe systems/JPMs listed on Form ES.303 t, evstuate each deficiency coded in the rough notes for Category B. Ifthe toaowtng c!Naris sre met, assign a sstisfacto!y grade by piecing sn S st the Evaluation cotumnforthstsystemrJpM:otherwiseenters Ly:

~ Time crnicat JPMs must be completed wchin the asoaed time.

Evaluate the Applicant's Performance Form ES-303-1, Category B (D.2.b) cont The task standard forthe JPM must be accomplished by correaly co!op!sung ail ofthe cntical step5.

- tfthe op picant inkiaay missed s crtdcst ste p. but tater performed it correctly snd accomplished the task standard without degrading the condcion ofthe system or the plant. the applicant's performance on that JPM should be graded ss satisfactory.

HOwever, the SPP!iCSnt'S enbr Shag be dOCumented in a CCOldanCe with Section D.3.

~ Evaluate the Applicant's Performance Form ES-303-1, Category B (D.2.b) cont

- The responses to inyperforman~sed forrowwp questions

~skid pursuant to Section D&fofESJ02 must confirm that the applicant's understanding ofthe syst emiJPM is satisfactory.

lfthe follo~p truesdons reveal thitthe applicant's understanding ofthe system/JPM is seriously deficient. the esaminer miyrecommend in unsatisfactory grade forthe sys>>m even though the ipplicintsuccessfully completed the task standard forthe JPM. The bails forthe recommendatlon shillbe thoroughly jusdfied and docun>>nted ln accordance with Section DA.

Evaluate the Applicant's Performance Form ES-303-1

~ Category B (D.2.b) cont Conversely, lfthe ipplicant did not accomplish the task standard and follooewp truestioning revealed that tl>> failure wis caused by a detrciency in the procedure orcome other factor beyond the

~pplicant's control, the esamlner may sdll recommends sausfactory grade forthe sys>>mfJPM.

Once again. the basis forthe recommendation shall be thoroughly justifiedand documented In accordance with Section D.0.

Evaluate the Applicant's Performance Form ES-303-1, Category B (DZ.b) cont Atter grading the applicant's perfonnance with respect to allthi Category B sys>>ms, determine an overall grade for Category 8 by calculating the percentage ofsatisfactory system grades.

lfthe ipplicant has in S on at least 40 percent ofthe systems

~samlned, the applicant passes Ca>>gory Band receives in S overall. Iftheipplicanthasan S onfewerthan40percentofthe systems, the applicant fails Category B and receives a U overall.

Documenttheipplicant'sgridebyplicmgan S ora tl InblockB, Control Room Systems and Facility Walk-Through, in the Operating Test Summary on page t ofForm ES402-t. En>>r HIE lfthis category was waivedin accordance with Es-204. Document

~ndjusdfyevery deficiency in accordance with Section D.2.

Evaluate the Applicant's Performance Form ES-303-1. Category C (D.2.c)

Using Form Es-303-3 or Es-303-4. de pendiny on the applicant's Lcense kvet. evaluate sny deficiencies coded for Category C. Circle the integrsi rating value (1 through 3) cones ponding to the behavioral anchor that most accurately regrets the applicant's performance.

A rating of 1 would be justiYied ilthe a ppiicsnt missed a critical task (i.e.. by omksion or incorrect perfonnance) or comnvtted mukipk errors ol lesser siglicence that have a bearing on the rsdng fsttor.

Missin one or more crtticsl tasks does not necesssni mean that the s

ni wia sit the simulator ieu nor does success on eve craica task event tne examiner tiom iecominendin s taxure itthr a icant nad oinerde iciencies that inthe s re ate st tne sdure base onine corn ien evaiuations.

As discussed in

Jut, ompetency ts op ona ror vpgrsdeapplfcants.

However,theesamlnershall

~valuate Comprtency 6 Ifthe applicant rotated Into an operating err w posidon that rerrulred the applicant to manipulate the controls.

Docvn>>nt and jvsdfyevery degiclencyin scconfancr with Secdon D.3.

Finalize the Documentation (D.3.b)

Deficiencies that do not comrlbutr to an opera ung test Category failure shall also be documented.

HOweVer, ~ briefStatement deasribfng rhr rnur and the eaproted

~cu'on or response fs generally suNcient.

Braminrrs should keep in mind that their licensing rucomn>>nda cion

~nd the associated docun>>ntation sm subject to review by the chief examiner and NRC regional office management.

Tr>>reforr. thr documrntadon should contain suNcirnt detail so that the independent reviewer, responsible supervisor, snd licensing oflicialcsn mskr u logical decision in suppon of the examiner's recommendau'onto drny orissue the licrnse.

Finalize the Documentation (D.3.b) cont Retain rough documentation untilthe chief examiner snd NRC regional otlice management have reviewed the examiner's recommendations snd concurred in the resutts(refer to Es-Sot).

Examiners shall retain allapplicable notes and documentation

~ssoclated with proposed denials vntllthe denials become final.

Examiners are advised that svch notes would be subject to disclosure lfrrrrvested under the Freedom ofInformation Act.

Individual Examination Report ES 303-1

Appendix C Final Rev 8 Change Overview Purpose "A"

'I This Appendix provides a framewortc for preparing and eva4atxtg lob performance measures (JPMs) to ensure they are of appropriate substance and format for et)tlat operator Ecensing and requattrcation examinauons.

The fottcrrnng elements afe discussed el delail or attached for infortnation:

a basic procedure for developing new JPMs (Section B). lnc4ding forms to document the JPM and to assess the quatrty of the procluct (Form ES.

i C-t and ES-C-2)

- guidd'nes forthe development and use of alternate-path JPMs (Section C)

- a discussion of walk-through evaluation techniques (Secxion D)

THE PRESCRIPTED QUESTIDH BULI.'ETWAS DELETED Development and Reviewing JPMs 'B ALLPRESCRIPTED QVESTION DEVELOPMENTPARAGRAPHS WERE DELETED

Attachments/Forms ATTACHMENT1, PRESCRIPTED QUES TION SAMPLES WERE DELETED

TRAlNINGMANAGERS CONFERENCE NEW INSPECTION PROGRAM NEW INSPECTION PROGRAM I

~ The New Program WillEstablish Baseline Inspections Common to AllPlants

~ Inspection Beyond the Baseline WillBe Performed at Plants Below a Specified Threshold

- Predicated on Performance Indicators

- Inspection Findings

Response

to Specific Events or Probiems

~ Baseline Inspections willBe Grounded on "Cornerstone" Areas

~ Focused on Risk Significant Activities and Systems

~ Focused on How Utilities Find and Fix Problems

~ Focused on How Utilities Accept and Encourage Em lo ees to Raise Safe Issues NEW INSPECTtON PROGRAM

~ Major Parts of the Baseline Inspection Program i Inspect Areas Not Covered By Performance Indicators Inspect to Verifythe Performance Indicators

~ Inspect/Review Effectiveness of Finding and Resolving Problems (Corrective Action Program)

~ CORNERSTONES Monitor Performance in Three Areas:

>> Reactor Safety Radiation Safety Security

NEW INSPECTION PROGRAM Comerstones l

e Reactor Safety Initiating Events

~ Mitigation Systems

~ Barrier Integrity Emergency Preparedness

~ Radiation Safety

'lant Worker General Public e Security

~ Physical Protection New Inspection Program Cornerstone Cross-Cutting Elements

~ Cross-Cutting Elements

- Element that Effect Each Cornerstone Human Performance Abilityto Raise Safety Issues Finding and Fixing Problems I

NEW INSPECTION PROGRAM I

Major Elements of the Baseline Program

~ The Program is Indicative and Not Diagnostic Program Delineates Specific Inspection Activities

~ Inspection Findings are Evaluated for Significance

~ DiagnosticjRoot Cause Determinations Done By Supplemental Inspection Program

NEW INSPECTION PROGRAM i

'ajor Element of Baseline Program

~ Baseline Program is Risk Informed lnspectable Areas Selected based on Significance from a Risk Perspective Risk Factor in to Program Four Ways Inspectable Areas are Based on importance to Measuring Cornerstone Objective I

i

- Inspecbon Frequency and Number of Activi!iesand Time Spend Inspecting Based on Risk Selection of Inspection Activities in Each Inspectable I

Area Based on a Risk Matrix Modified by Plant Specific Information I

- Inspectors Are Trained in the Use of Risk Information

~ Baseline Program is the Minimum Program NEW!NSPECTION PROGRAM Cornerstone linkto Inspectable Areas

~jg~~

R5 I

NEW INSPECTION PROGRAM PERFORMANCE INDICATORS

~ Initiating Events:

Unplanned Reactor Shutdown

~ Loss of Normal Rx Cooling Sys Following Unplanned Shutdown Transients - Unplanned Events that result in Rx Power Change

~ Mitigating Systems:

Safety Systems Not Available Specific ECCS Emergency Power Systems

~ Safety System Failures

NEW INSPECTION PROGRAM Performance Indicators

~ Integrity of Barriers:

Fuel Cladding (coolant activity)

Rx Cooling System Leak Rate

~

Rx Containment Leak Rate

~ Emergency Preparedness:

Emergency Response Organization Drill Performance Readiness of Emergency Response Organization Availabilityof Notification System NEW INSPECTION PROGRAM Perfonnance Indicators

~ Occupational Radiation Safety:

Compliance with Regulations for Controlling Access to Radiation Areas in Plant Uncontrolled Radiation Exposures to Workers Greater than 10'!o of Regulatory Limit

~ Public Radiation Safety:

~ Effluent Releases Requiring Reporting Under NRC Regulations and License Conditions NEW INSPECTION PROGRAM Performance Indicators I

~ Physical Protection:

~ Security System Equipment Availability

~ Personnel Screening Program Performance

~ Employee Fitness-for-Duty Program Effectiveness

I NEW INSPECTION PROGRAM Inspection Findings / Performance Indicator Data I

~ Inspection Findings:

~ Inspector Observations are Evaluated to Determine Significance Use Defined Process: Significance Determination Process

~ Performance Indicators:

Thresholds Set Regulatory Response

- Example:

I

- OrgtfExercfse performance The percentage of sD Orgl. exercise.

~

snd actual opportun5ea that were performed in s timely snd accurately during the previous eight quarters NEW INSPECTION PROGRAM Regulatory Response

~ Significance Determination Process Characterize the Risk Significance of Issue i

~ Each Issue is evaluated and assigned a color Using a Process Flow Chart GREEN: Licensee Response White: Increased Regulatory Response.

Yegovr. Required Regulatory Response Red: Pfant Not Permitted to Operated within this Band NEW INSPECTION PROCESS PILOT PROGRAM

<<Two Pilot Plants Per Region

~ Sequoyah Harris

~ Pilot Program Commenced June 1999

~ Full Implementation of New Inspection Program by April2000 I

I t

CiE.AR RE GUL~TO COMMISSIO

~pe>gG MAMAGEqS gOHFERENCE e" 45"vr c).

wp Span a

WPCA'ALQ%XW Training Managers Conference Changes & Clariftcations to ES-401, Part 1

PREPARING INITIALSITE-SPECIFIC WRIT)EN EXAMS

~ D.t.b The outtee must be systemsticahy seleaed.

Shalt nol use the she speaytc K/Acatalog The Plant VAde Generic IPWG) Tier 3 should StOT inaude system generic tasks, The topics forpwG Tier 1 a 2 and tne four K/Acategones for Tier 3 Shah be seleaed from seaion 2, GeneriC KnOwledge and Abititieaflem the K/ACatalOg.

~

~ D.t.c 10 she-specific K/As may replace 10 systematic sample horns.

for detahs or issues. wtth basis snd Chief Examiner s pprovat.

~ D.t.d Ensure outhne samples al least scary WAarea twice and the SRO samples topics required by 10 CFR 55A3(b).

~ blot>>

Dere of axe Fists ESeet 2 Tier 1.1 En erttency a Pent

&alamo Tier Toisii K

1 K

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2 A 0 Ptsnt1 Tocst 2s 1S 2.1 Piste 1 Srstene Twr Totsts

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Training Managers Conference Changes 8 Clarifications to E&401, Part II D2a i

~ Dd.c Use exisdng. modified or ntw questions.

Ifdeviation from subnxtted sample Is necessary discuss whh the.chief.

Be able to discuss why the change was necessary.

Document thoxe lessons.

The wntttn examinatkn MU57 be ~0'A higher cognxivt orderhcms. (NomofcHVkss)

~ D.2.d The SRO only questions on an exam must be at tht SRO level.

not just questions at the RO leveL These should be disuibuted ainongst thc 3 tkfs.

i Training Managers Conference Changes 8 Cjarificatjons to E&401 ~ Part III

~ D.2.f Retake examvtations may NOT have any overlap or reuse hams fnxntht fsikd scensc examination.

No overlap between NRC examination and audit unless independendy devtloped. Then only 5 questions asowed.

Repeat of ONLY25 questions from test 2 NRC examinadons arid <<trna used lflualniilg,

~ D.2.g Facility learning objective references are encouraged but not required.

Ifkaming objectives are not available. the does not invabdate the quesbon provided x has appropriate K/Aand technical refcfeilcc s.

Training Managers Conference Changes 8 Clariflcations to E&401, Part IV

~ D2.g Thc draft examination must bc fccctvcd a'I kast as days bcfoft the examination.

~ E.2.a NRC win review and gel supervisory review before discussing with bcenset.

~ E2.c The NRC WILLperform a 30 question sampk review, wgt review

~

all new plus moddied. quesdions. Ifrequved. The sample wia include 10 new and 20 modified questions.

(Atl 125 questions willundergo a review,)

l Ouestions previously reviewed and approved by the NRC for that ratittywillhaVe limned reVieW fOr unaCCeptablt naWS per EWot.g.

Training Managers Conference Changes 8 Clarifications to ES-401, Part V r

r

~ E.2.C Ifthe SamPIC ShOWS ICSS than 6 ltefflare unaCCePtable. det&ied revlcw ofthc fest or thc cxanwlatlofl WIQ contktuc. Ifgfcalcf

,than 6 items are found unacceptable, NRC MAYreturn the exanv'nation or we may complete fts review~evicw wia use Es-aot 9.

Ifthe examklation Is returned. we expect that the dcensee COfreet the identiraednaWS and thOSe ske kkldnaWS 1hat Were nOt

'peeafioaay idsnorted tO the feat Of the queatiOnS.

~ EXa The NRC Supevisor MUST review and appmve ag unacceptable Item comments.

~ Es.b The NRC supervisor WILLreview and approve each comment that woUld requife thc kcensce to rework a NRC validated question.

(Previously used test items.)

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Training Managers Conference Changes 6 Clarifications to E&401, Part Vl o E.a

~ AtL 1 Final validation of examination after incorporating changes is recoffvnended but NOT required.

I Describes an acceptable sampling methodology for systcmatio selection forthe wntten outline.

~ Form sot 7 Moddied version ofthis form provide blanks to record lest kern count for reuse from the last examinations, the source ofthe questions and the cognkwe level forthe qucstkfns forthe

~ Foun rtot g Wntten examinabon Review WorksheeL Used to keep track of sampled qua StiOns.

te Eseo) venue n Ecemneeettet FettnESeo) r Oeewr c)eccaknn cecttt Dote et rt>>

Se>>cewt ertceo

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etettwr Ctn Training Managers Conference Changes & ClanT)cations to E&402, Part I ADMINISTERINGINITIALWRfITEN EXAMINATIONS

~ c.t.s The licensee has to maintain securny of tne examinations.

~ C.t.e The Ecensee may use mschir)segradable sheets bul not requxed.

~ C.2.a The liCenSee ia SSOwed tO Sdminixter an NRC deVe)Oped examination.

~ C.2.b During s licensee sdmv)ixtered wrhen exam. the NRC MUST be on sse or svatlsb)e by phone.

II After NRC approval. me wrc)en exam may be administered sny II tifne wlthirlso days ofthe opefatir) g test, Training Managers Conference Changes & Clarif)cations to E&402, Part II ADMINISTERINGINITIAL~ITTENEXAMINATIONS

~ Dad Newtime Emit forthe wrmen is 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

It can be extended by 30 minute increments, with pRloR NRc approval. The new time limitshould not change me development process.

e E.S Licensee should submit formal comments within 5 woridng days after the wnnen examination is administered.

Training Managers Conference I

'hanges

& Clanflcatlons to ES-403 GRADING INITIALSITE-SPECIFIC WRITTEN EXAMS

~ C.1.b IfNRC developed. Scensee has responsibgrty to submk comments coricerhing cINnges 'to trNezsrnuistiorl.

I e C 2.b NRC may SSOW the ICensee tO maChine grade a NRC deVelOped wrinen examination.

I

~ D.1. ~ DO NOT delete Sny questinn Or Change Sn SnSWer Vdthaut a Varrd reference.

Unreasonable or unstated assumptions do not lustily s change.

I

~ D2.a Copy each applicant's answer sheet. snd set aside.

Do NOT mark ort the on'ginal unQ all comnNnts Sre fSNIised.

~ D.2.d Ifyou decide to share PRELIMINARYgrades do so with caution.

The NRC MAYNOT accept ss me scensee's changes.

Training Managers Conference Changes and Clarifications To Appendix 8 Written Examination Guidelines, Part I

~ C.1.s K/Areferences are ~re uired but Learning Obiettives are desired.

Ttds is s check snd balance cn the fscilrues usining program.

I I

~ C.t.b Make sure dN quesdon matches the Intent ofthe K/A I

~ C.1.c Oiscnrrvnsdon vs%day is defvNd..the key purpose of any test item is to assess bnportant K/As at a level that distinguisies between safe and unsafe sp pkcsnts.'mplementstion requires subiective iudyemen) in construcdng the stem and distrsctors.

Training Managers Conference Changes and Clarifications To Appendix B Written Examination guidelines, Part II

~ C2. ~ Mukiple Choice quesbons which require the MOST CORREC1" answer are NOT allowed. Use a procedural reference!

~ Cd.f Allthe hformation bt the stem should be relevant. IDon'Iplay find the loci>.) Don'I sdd secondary pieces of information in the stem that sre not reievanl. in onier to make the question look more ddriCulL I

o C2.n Use of genericaay correct snsvers is saowed. but the stem needs to be wntten sucri that the Stela makes them rdesrly uICOrled.

I

ES-501

~ D.1 Facility management exam reviews.

~ Su ervisor or mana er shall confirm quality of grading is licensee graded written and sign QA check sheet.

Used to be "authorized facilityrepresentative."

~ Signed QA form represents facilitysenior

. management concurrence withindividual and collective exam results.

ES-501

~ D.2 Chief Examiner reviews.

~ No post-exam change willbe accepted without a valid lant reference.

Uncontrolled lesson plans are not acceptable.

~ Verifyanswer key used as template or to machine grade written exam is accurate.

~ Independently review every borderline written exam P8-82%).

ES-501

~ D.3 NRC management review.

~ Pass letters for applicants who passed exam but licenses are being withheld.

~ Ifpass written exam with 80-81% and another applicant fails, willhold license until assured pass/fail decision not affected.

~ For delayed licenses, shall ensure still medically fit within last 24 months, not developed permanent physical or mental condition, and up to date in requal.

~ If> 3 months pass, advise licensee to properly activate license per 10 CFR 55.53(f)..

~ E.1 and E.2 No significant changes.

<<Region still willretain EOPs, AOPs, E-Plan and Tech Specs for incident response.

~ E.3 Exam report documentation.

Some significant changes.

~ Previous revisions stated generic exam report content requirements.

Rev. 8 spells out specific types of issues to be included.

I ES-501

~ Factual description oftest item changes including type and number of psychometric enhancements made.

~ Conclusions regarding adequacy of facility l

only be considered ifhave a programmatic issue.

~ Any delay in administering the exam and the reason, and any extensions of the written exam time beyond five hours.

I

~

<<Any exam security issues/incidents.

ES-501

~ Allsimulator deficiencies encountered while preparing or conductirig-operating tests will be documented in Simulation Facility Report.

I

~ Generic comments submitted by licensee regarding exams or the process are welcome and willbe included in exam report. These do not require regional response or resolution.

~ Region willensure SRO upgrade applicants

~ that fail exam still comply with 10 CFR 55 before resuming RO duties.

i

INITIALPOST-EXAMINATIONACTIVITIES

~ gal Rgp~

o.

II p

4 l$.

44 D. Charles Payne August 13, 1999 ES-501

SUMMARY

OF CHANGES

~ Supervisor or manager shall confirm grading quality and sign QA sheet.

~ CE independent regrade for 78-82%.

~ Potentially hold passes 80-81%.

~ Exam report content more clearly defined.

~ PDR r'ecords defined.

~ New letter for delayed results.

ES-50't

~ C.1 No changes to facilityrequirements.

~ Note that clean copy of written exam answer sheet is expected to be provided.

~ C.2 No changes to regional requirements.

~ Note criteria for determining writte'n exam validityfollowing post-exam comments.

~ 5% changes/deletions w facilityexplanation.

~ 10% deletions ~ evaluate adequate sample.

I

~ PDR records willinclude the following:

- exam outlines

- draft and final written

- draft and final operating tests

- associated QA check sheets

- "Other documents"

~ Intermediate working copies not needed to be sent to PDR unless provided to facility licensee to facilitate communication.-

I

I PROCESSING REQUESTS FOR ADMINISTRATIVE REVIEWS AND HEARINGS AFTER INITIAL LICENSE DENIAL

~~ R~~

>>~a D. Charles Payne August 13, 1999 ES-602

SUMMARY

OF CHANGES

~ Reorganized to remove detailed sample letters and administrative review procedures.

~ New section noting expectation offacility licensee support during appeals.

~ New section to better define NRC responsibilities.

~ Administrative review process streamlined.

ES-502

~ C.1 Applicant responsibilities.

No changes.

~ Has 20 days to act on proposed denial. Has 3 options:

1. Do nothing.

2. Request reconsideration.

3. Request a hearing.

~ Ifapplication denied because oftraining or experience, can reapply when corrected.

ES-502

~ C.2 Facility licensee responsibilities.

New section.

t

~ Facility is expected to provide reference materials and technical support as necessary for NRC to evaluate and resolve concerns raised by applicant.

~ This includes organizationally supporting the response provided in the answer key.

ES-502

~ C.3 NRC responsibilities.

New section but no new responsibilities.

~ Splits out our responsibilities from mechanics ofthe review process.

~ Application denials willbe processed per D.1.

~Admin reviews willbe processed per D.2.

~ Hearings willbe conducted per 10 CFR 2, subpart L.

ES-502 I

~ D.1 Application denial admin review.

~ Not many have occurred in Region II. But be cautious of potential outcomes should one be required.

~ HQ generally willcomplete the review within 60 days.

1

~ Since draft applioations are not due until 30 days before exam, any issue with eligibility

.most likelywillresult in the applicant missing the scheduled exam.

ES-502 I

~ D.2 Exam failure. Some minor changes.

~ Detailed administrative review procedures and sample letters have been removed and incorporated into separate internal NRC documents.

~Added option to review the appeal internally at HQ.

~ HQ chooses how to process the appeal.

1. Can review internally

2. Can refer to affected region

3. Can convene an appeal panel

THE ISSUE Is itan acceptable practice to readmiiiister an identical examination to separate crews that have been separated m time over the finite testing period ofthe biennial wntten exam?

MAJORISSUES REVOLVING.

mome REPErrnVZUSEOF I

TEST XHMS TESTING EFFECTIVENESS W Do you have a testing practice that measures up to sound and accepted principles of testing?

W Are your examination conditions (size scope, discrimination quality) relatively uniform among crews.

DEHNlTIONS

~ The abilityto discriminate orto make sane distinction along a continuum ofexaminee perfonnance to determine whether or not your operators have sufBciently 'mastered" the

'nowledge, skills, abilities, and other attributes to perform theirjobs.

~ PREDICTABILGYOFATEST-I It

~ The abilityto forecast or anticipate the test items'r topics that willappear on an examination.

Previously administered test items reduce examination intemity because examination discrimination is reduced.

When the bank ofitems is laown or anticipated priorto the examination, the exam is highly praiictable. Discrimination is reduced use the cemitive level at which the examinees are tested could decrease to the simple recepition level.

I I

To assume that the capability for items within an examination to discriminate, over time, in the same manner as those items discriminated on the fust and second examinations is naive.

QUXSHON

+ How does excessive repetitive use of test items over a short inte'rvaI of time affect examination vaIidity?

~ Ifthe examinees liowor can anticipate the precise and limited pool 6am which the test items willbe drawn, they willtend to only study'&om that pool and may likelyexclude a iar er domain ofjob knowledge.

~ When h~ percentages oftest item duplication takes place (eg>SF/o), the discriminant validityofthe examination comes under question.

~ Successive administrations ofthe same or closely simihr examinations to different crews over the period covering the biennial written exam raises the potential for compromising examination integrity.

~ Achieve uniform testing conditions among crews as best as can reasonably be achieved so that the exam willbe a reliable tool for assessing operator competence.

ACCEPTABLE PRACTICE W To minimhe the potential ofreduced discriminant validity,a 50'/o portion ofany readministered examination should consist of replacement ofmodified or new items of like4ind content, psychometric attributes, and dif6culty levels. Moreover, when items are to be repeated among successive crews, they should be repeated in a distributed manner and approximately equaHy over aH previous exams so as to reduce predictability ofa disproportionately la'rge number ofitem coming form the most recent examination.

SUMMARY

~ Successive administrations ofthe same biennial requalification examination to different crews under oing the same requalification training is considered unacceptable.

This would seriously question the discriminant validityofthe exam.

~ W hen the content to be tested becomes hghty predictable, and the boundaries ofwhat will likelybe tested are lmown to the candidate, then the candidate willlikelyprepare ONLYto that level demanded by the examination.

~ Improper t practices willlikelylead to an erosion ofknow ge and long term decline in operator performance:

YOU MAYASK?

i

%%hen testing is diminished in level or ommitted in kind, knowlege degradation occurs.

> The subtle but important coercion implicitin preparation foran examination is lost.

> Attentionwillbe focused on what leads to visible success fora candidate.

a The loss ofspecific content area study can result in knowle e mps that cause operator errors.

ES-601/602 CONDUCTING NRC REQUALIFICATION j

EXAMINATIONS

~ NO SIGNIFICANTREV. 8 CHANGES

~ REACTIVE INSPECTION / EXAMINATION

~ SCOPE DETERMINATIONSBASED ON:

o PLANT PERFORMANCE o

INSPECTION PROGRAM RESULTS o

INiTIALAND REQUAL RESULTS o

OTHER FACTORS ES-601/602 CONDUCTING NRC REQUAL IFICATION EXAMINATIONS

~ NRC CONDUCTED OPERATOR REQUAL EXAMCOMPOSED OF THREE PARTS:

~

TWO SECTION OPEN-REFERENCE WRITTEN O

PLANTANO CONTROL SYSTEMS O

ADMINISTRATIVECONTROLSI PROCEDURAL LIMITS

~

WALK-THROUGHEVALUATION

~

DYNAMICSIMULATOR ES-601/602 CONDUCTING NRC REQUALIFICATION EXAMINATIONS

~ EVALUATIONOF REQUAL PROGRAM AND OPERATORS o

MINIMUM12 OPERATORS REQUIRED o

3/4 OF OPERATORS MUST PASS EXAM o

2/3 OF THE CREWS MUST PASS THE SIMULATOREXAM

gNRrg Licensed Operator Requalification Inspection Procedure 71111 REACTOR SAFETY-INITIATINGEVENTS, MITIGATINGSYSTEMS

~ BARRIER INTEGRITY 1 INSPECTION OBJECTIVE

~ To independently gather baseline inspection indicators to determine whether licensee performance meets the following cornerstone objectives:

~ Initiating Events: To limitthe frequency of those events that upset plant stability and challenge critical safety functions, during shutdown as well as power operations.

~ Mitigating Systems: To ensure the availability, reliability, and capability of systems that mitigate initiating events to prevent reactor accidents.

~ Barrier integrity: To ensure that physical barriers protect the public form radionuclide releases caused by accidents.

REQUALIFICATION CORNERSTONES

~ Mitigating systems P5%)

~ Barrier Integrity (25%)

~ Emergency Preparedness Inspection Bases

~ Inspection supports comerstones because it

~ can assess operator performance adequacy in responding to events.

This inspection evaluates operator performance in mitigating the consequences of events.

Poor operator performance results in increase risk due to the human performance factors terms, and assumed operator recovery rates and personnel induced common cause error rates assumed in the facilities IPEs.

INSPECTION AREA VERIFIES:

I

~ Procedure quality and human performance which are both key atTributes ofthe Mitigating Systems cornerstone for.which there are no performance indicators.

iHuman performance which is also a key attribute ofthe Barrier Integrity cornerstone for which there are no performance tndlcato rs.

PROCESS OLJTLINE AeAe ae eWael Qegaaa

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FY 2000 REGION IIEXAI~ATIONSCHEDULE Revised Aurust 6. 1999 W,p Date 9/27/99 10/4/99 10/18/99 11/I/98 11/8/99 11/6/99 11/29/99 11/29/99 12/6/99 12/13/99 I/10.2/14/00 I/10.2/7/00 ln4/00 1/31/00 Facility Docket No Catawba 50-413 Hatch 50-321 Hatch SO-321 Crystal River SO-302 Browns Ferry 50-260 Sequoyah 50-327 Vogde 50424 St. Luci>>

50.335 Vogde 5&424 Farley SO-348 Turkey Point 50-280 St Lucie 50-335 Brunswick SO-325 St Lucie SO-335 Number of Candidates 3RO 1 SROU 10 SROI 2 SROU I RO 3 SROI 2 SROU 5 RO I SROI 2 SROU Type of Activity Retake IniYial Prep Requal Inspection Requal Inspection Requal inspection IniYial Prep Requal Inspection Requal Inspecuon Requal Inspection IniYial Prep IniYial Prep Retake Chief Examiner R. Baldwin C. Payne C. Payne G. Hopper C. Payne L. Mellen R. Baldwin G. Hopper R. Baldwin TBD TBD TBD G. Hopper Examination Author Licensee NRC I Licensee NRC 2/ - 3/00 North Anna 50-338 Requal Inspecuon TBD 2/14/00 2/21/00 an4/00 ana/00 II 5/8/00 5ng/00 Brunswick

'50-325 Farley 50-348 McGuire 50-369 Farley S0.348 12 RO 4 SROI 6RO 6 SROI IniYial Prep IniYial Prep G. Hopper M. Ernstes C. Payne M. Ernstes NRC Licensee S/8/00 5 PHOO sn9/00 McGuire SO-369 Browns Ferry 50-259 6RO 2 SROI 5 SROU IniYial Prep C. Payne L. Mellen Licensee 6/12-7/14/00 McGuire 50-369

Requal Inspecrion TBD

Date 6/12/00 6/26/00 7/10/00 7/17/00 7/24/00 7/24/00 8/00 S/7/OO 8/14/00 Facility k

N Browns Ferry

. 50-259 Oconee o

Oconce 50.269 Summer 50-395 Sequoyah 50-327 Hatch Sumrn<<r 50-395 Sequoyah

'SO-327 Crystal River So-302 Number of nia 10 RO 3 SROI 3 SROU 8RO 2 SROI 3 SROU 8 SROU 5RO 4 SROU 3 SROI Type of Activity IniYial IniYial Prep Inidal IniYial Prep IniYial Prep Rc ual Ins ction lniYial IniYial IniYial Prep Chief Examiner L. Mellen G. Hopper G. Hopper M. Ernstes C. Payne M. Ernstes C. Payne Examinanon Author NRC Licensee NRC Licensee I NRC 8/28/00 9/11/00 S/2S/OO 8n8/00 9/18/00 9/25/00 Crystal River 3 RO So-302 3 SROI 3 SROU North Anna 50-338 Sorry 50.280 North Anna 7 RO 50-338 I SROI 3 SROU IniYial IniYial Prep IniYial Prep IniYial R. Aiello R. Baldwin R. Aiello Licensee Licensee I NRC 9/18/00 9/25/00 FY2ON 11/13/00 11/13/00 11/27/00 12/4/00 Surty 50-280 St. Lucie 50-335 Turkey Point 50.250 Hams 50400 St. Lucic 50.335 8 RO 2 SROI 3 SROU 4 SROI 5 SROU Initial IniYial Prep lniYial Prep IniYial Prep R. Baldwin C. Payne G. Hopper M. Ernstcs C. Payne Licensee I NRC Licensee 12/4/00 12/18/00 Turkey Point 16 50-250 InYiial G. Hopper NRC 12/11/00 3/26/01 Harris SINtoo Robinson 50-261 3 RO 2 SROI 3 SROU 7RO 5 SROU IniYial Ifu'ua1 M.-Ernstes Licensee

Date Facility oke No Number of Type ofActivity andidates Chief Examiner Examinauon Author 4/Ol Volttte

. 50424 16 lniYial TBD NRC 4/01 Catawba 50413 18 Licensee 5/OI Waus Bar 50-390 7RO 3 SROI 6 SROU 1lliYlal