ML18151A630
| ML18151A630 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 09/01/1999 |
| From: | Christensen H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 9909150195 | |
| Download: ML18151A630 (85) | |
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e September 1, 1999 Virginia Electric and Power Company ATTN:
Mr. J.P. O'Hanlon Senior Vice President--Nuclear Innsbrook Technical Center
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5000 Dominion Boulevard Glen Allen, VA 23060
SUBJECT:
TRAINING MANAGERS CONFERENCE MEETING*
SUMMARY
Dear Mr. O'Hanlon:
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. is the list of attendee~ and Enclosure 2 is a copy of the slide presentations.1 is a list of questions received from the participants. These questions will be reviewed and addressed at a future date.
If you have any questions concerning the conference, please contact me at 404-562-4638.
Sincerely, Original signed by Harold 0. Christensen Harold 0. Christensen, Chief Operator Licensing and Human Performance Branch Division of Reactor Safety Docket Nos. 50-338, 50-339, 50-280,50281 License Nos. NPF-4, NP.F-7, DRR-32, DRP-37
Enclosures:
- 1.
List of Attendees
- 2.
- 3.
Licensee Presentation Handouts Participants Questions cc w/encl: (See Page 2) 9909150195 990901 PDR ADDCK 05000280 V
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LIST OF ATTENDEES U.S. NUCLEAR REGULATORY COMMISSION Luis A. Reyes, Regional Administrator Victor McCree, Deputy Director, Division of Reactor Safety (DRS)
Harold Christensen, Chief, Operator Licensing & Human Performance Branch, (OLHP), DRS Fred Guenther, Senior Reactor EngineerL 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
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Marvin Skyes, Reactor Engineer, OLHP, DRS Hironori Peterson, Senior Examiner, Region Ill LICENSEE CAROLINA POWER AND LIGHT COMPANY 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 Veller, 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
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FLORIDA POWER AND LIGHT COMPANY 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 Dela, 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 Ma~ager, Vogtle SOUTH CAROLINA ELECTRIC AND GAS COMPANY Albert Koon, Operations Training Manager, Summer Perry Ramicone, Lead Instructor Exam Development, Summer James Callicott, Training Evaluation Coordinator, Summer TENNESSEE VALLEY AUTHORITY 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 VIRGINIA ELECTRIC 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
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WELCOlVIE TO U.. S. NUCLEAR REGULATORY COMMISSION REGION II TRAINING MANAGER'S CONFERENCE AUGUST 12-13, 1999 SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH SW, SUITE 23T85 ATLANTA, GA 30303 ENCLOSURE 2
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e REGION II TRAINING MANAGER CONFERENCE AGENDA Sam Nunn Atlanta Federal Center Thursday,August12,1999 8:30 - 9:00 a.m.
9:00-10:00 a.m.
10:00-10:15 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 -*4:00 p.m.
4:00 - 5:00 p.m.
Friday, August 13, 1999 8:00- 8:15 a.m.
8:15-9:45 a.m.
- 9:45 - 10:00 a.m.
10:00-11:00 a.m.
11 :DO a.m. - 12:00 p.m.
12:00 - 1 :00 p.m.
1 :00 - 2:00 p.m.
2:00 - 3:00 p.m.
(Bridge Conference Room B)
Introduction Summary of Significant NUREG 1021 Changes Break ES-200 Series {Exam Process)
Lunch Changes in the NRC Break ES-300 Series (Operating Test)
Break New Inspection Program Day 2 Opening Remarks ES-400 Series {Written Exams)
Break L. Reyes V. Mccree C. Christensen C. Christensen M. Ernstes B. Boger R. Aiello C. Christensen C. Christensen R. Baldwin ES-500 Series.
- C. Payne
{Post-Exam Process)
Recent Training Program Issues G. Hopper Lunch ES-600 Series {Requa! Program)
M. Sykes G. Hopper Closing Remarks L. Reyes V. Mccree C. Christensen
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TRAINING MANAGERS CONFERENCE August 12 -13, 1999 TRAINING MANAGERS CONFERENCE INTRODUCTION Luis Reyes Victor McCree Chris Christensen TRAINING MANAGERS CONFERENCE
.. 8:30 a.m.
.. 9:00 a.m.
- 10:00 a.m.
- 10:15 a.m.
- 11:45a.m.
- 1:00 p.m.
- 2:00 p.m.
.. 2:15 p.m.
.. 3:45 p.m.
- 4:00p.m.
.. 5:00 p.m.
AGENDA-DAY ONE Introduction NUREG 1021 Changes Break Exam Process Lunch Changes in the NRC Break Operating Test Break
- New Inspection Program End Day One e
TRAINING MANAGERS CONFERENCE VICTOR M. McCREE Deputy Director, Division of Reactor Safety Region II August 12
- 13, 1999 REGULATORY TRENDS*
- BACKGROUND
- DESCRIBE THE CHALLENGE FACING NRR
- £.XPLAIS HOW NRR IS l\\1££TING TH£ CHALLENGE
- DISCUSS HOW NRR IS DEFINING SUCCESS
- DISCUSS STATUS OF HIGH PRIORITY AREAS FOR AcnON
- THEl'i, SOW AND TH£ FUTURE r:,.
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. BA,CKGROUND
- U.S. Nuclear Reactor Industry Anraz* Saf*ty P*rformanc* Has lmprowed 5'ndily Numll*r of Accident Sequence Pra:unon Declin*d Significantly Since 19&~
- Fin of Th* NRC Tncked Pcnormanc* Indicators Show Siznilican1 Jmpro*ement Since 1985 (automatic scrams. safety tystcm actuations.
siznilicant..-.,us, equipment forc*d outal!G and collectiwe ndia1ion Hposur*)
Challmc* Is to Deline Prognms (in Rapidly Chancing Business And Rei:ulatory £nwironments) at a.Le,,el Which:
- Maintain Safety
- Reduee Unnecessary Reiulatory Burden
- Jncrasc Public Confidence
- I mprowe Efficiency And Effectiw*ness e
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AREASOFNRC STAKEHOLDER CONCERN
- Senate&. House Comminee Reporu on NRC Appropriations -£arty June, 1998
- Commission Meeting With Stakeholden -July 17 & Nov. JJ; 1998
- NRC Ovenighl H~ring Witb Senate Subcomminee..July 30, 1998
- Regulatory Framework Needs 10 Be Predictable, Objective, And Timely
- Coneern 'E.zisu Thal Some NRC Regulations And Regulator Practice Pose Unnecessary Burden on Licensees
- In Deregulated Electric U1ili1y Environment, Unnecessary Re:ulalory Burden Is of Significant Concem to Licensees
- Need For Continuous Improvement in Regulatory Effectiveness And Efficiency
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\\¥.i POST-HEARING TASKING MEMO
- Memo From Chairman to EDO-Augast 7, 1998
- ldentirtes Commission Proposed Hich Priority Areas For Action
- Tasking Memo Response - August 25, 1998 -Contains Shorl And Lone Term Aclions (Updued l\\lontbly)
- l\\laintaininc Safety Remains Hi:hest Priority
- ManyTuks Previously Identified And in Operating Plan; Remaining Tasks Added
- Some Existing Tuks May Be Appropriate 10 Slow, Defer, Cancel, Other 10 Accelenle
- Challenge Is lo !\\laintain Safety While Reducin: Unnecessary Burden
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PERFORMANCE GOALS FOCUS A TTE!'"TIO:-i TO MEASURE lliUCLEAR REACTOR SAFETY PROGRAM OUTCOMES:
- MAl!'"TAIS SAFETY
- REDUCE UNNECESSARY REGULA TORY BURDE:-!
- ISCREASE PUBLIC COSFIDEl"iCE
- JSCREASE EFF1CIE1'"CY/EFFECTIVEN£SS Of KEY !'iRC PROCESSES Determined by l"iRC Nuclear Reactor Regulation Team Working With Contractor 10 Deline And Implement *Planning, Budgeting, And Performance 1\\lanagement Process (PBPM) e
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(¥,.i PRIMARY AREAS. OF AGENCY FOCUS
- Risk*lnforined And Performance-Based Regulation
- Reactor lnspeczion And Enforcement
- Reactor Licensee Performance Assessment
- Reactor Licensin& And 0Yersighl
- NRC Orzanizational Szruc1ure And Resources
- Other Agency Proirarns And Areas or Focus (I.e. License Transfers, Dry Cask Storage, Decommiuionin::)
- Uranium Recovery Issues
- Cban&a to NRC's Hearing Process REACTOR OVERSIGHT PROCESS IMPROVEMENTS ASSESSMENT, L'-SPECTION AND ENFORCEMENT
- Performance Results Will Be £Yalua&ed 10 Derermine When Enhanced NRC Diagnosis of LiCfflSff Performance Is Warranred. A Risk-Informed Baseline lnspecrion Pn11:ram Will Be Performed For All Sires..
- Framework: Performance Indicators And Risk-Informed Inspection Resula Will Be Used lo Measure Licensee Safetv Performance. Results Will Be Enluared Usini: £quinlenr Risk-Informed Scala. fThraholds)
- lnspecrions \\\\'ill Become !\\lore Risk-lnrormed and Results Will Be Evaluared For Tlmr Risk Significance l/sini: Rules-Based (£samples)
Scale.
- Assessment: a Streamlined, Strucrured Re,*iew Process *Will Be l/sed. An Action !\\latrix Will Provide Consistency in Makini: Response Decisions.
REGULATORY FRAMEWORK Please See Handout i
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ACTION MATRIX Please See Handout I
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TRAINING MANAGERS CONFERENCE
- 8:00 a.m.
- 8:15 a.m.
- 9:45 a.m.
- 10:00 a.m.
- 11:00 a.m.
- 12:00 p.m.
- 1:00 p.m.
- 2:00 p.m.
AGENDA - DAY lWO 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
- Neep to stay flexible on exam schedule and do not wait until the last minute to accept the criteri~ from licensee. Suggested method was to accept the criteria early in process of the prep week. Would prefer to have 30-45 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 NRG should publish the exam schedule early. Suggestion was to publish at least 1 year in advance.
.. An Operator Licensing WEB page will be coming soon and it will have the exam schedules.
Additionally, we have been sending confirmation letters to each licensee on the exam schedule.
- Recommend the NRC tum 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.
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Last Conference Questions
- The issue of written exams and limited staff in NRC create a Mde 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 if you want a given date.
- The issue of tying up exam writers.
- The security requirements are like Requa! exam requirements now.
Questions for last Conference
- There is inconsistency in the examiner
- standards and the KIA manual. 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 following the 10 CFR for an SAT program rather than following the guidance 4n the memo once issued by the Director of NRR.
- You can follow your SAT based program, however if you have a Tech Spec or FSAR requirement you need to follow those 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 limit on 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 />.
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SUMMARY
OF SIGNIFICANT CHANGES OR CLARIFICATIONS Chris Christensen
SUMMARY
OF SIGNIFICANT CHANGES OR CLARIFICATIONS
- Changes to 1 O CFR 55
- New 10 CFR 55.40
- Exams Prepared Using NUREG-1021
- Licensees may Prepare, Proctor and Grade Written 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, Prodor and Grade Examinations Upon Licensee's Writtfi!n Request
SUMMARY
OF SIGNIFICANT CHANGES OR CLARIFICATIONS
- Changes to 10 CFR 55
- Was Revised to Clarify Compromise and Security Expectations
- Changes to NUREG 1021
- ES 200 Series: Examination Process
- Due dates for Exam Outline and Draft Exam Advanced
- Personnel Restrictions are Like Requa!
- The Region May Approve Separating the Written Exam and Operating Test By up to 30 Days e
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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 follow-up questions for Cause Allemate path JPMs Increased to 40'.4
- No Reuse of Material on Subsequent Days
- STA Use OK per Licensee Pra_ctice
SUMMARY
OF SIGNIFICANT CHANGES OR CLARIFICATIONS
- Changes to NUREG 1021
.. ES 400 Seri!=!s: Written Examination
- Systematic Sampling Required for Outline Construction
- Leaming 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 of Answer Sheet Required
.. ES 500 Series: Post Examination
- May Hold License for 80-81 % Passes
- Administrative Review Process Streamlined Licensee May be Requested to Provide Reference Material and Tedlnical Information
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SUMMARY
OF SIGNIFICANT CHANGE OR CLARIFICATIONS
- Changes to NUREG 1.!)21
- ES 600 Series: Requalification
- Test Item Duplication Expectations Clarified
- Licensed Operators Detailed Off-site Clarified
- Proficiency Watch Expedations Clarified
- 50 Question Written Examination
- Appendices
- Guidance for Developing Multiple Choice Questions in App. B
- App. E - Clarified Making Assumptions
- App. F - Defined:
- Responsible Power Plant Experience
- Tedlnical Specifications as a Reference
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Examination Process ES-200 Series Mike Ernstes ES-201 Examination Process
- e. Facility~ *..,..,.lions must meet lhe following:
(1 I mrnpty with NUREG-1 D21 (2)--.iish. inpenen1 end manlain -.ity pracac1ures (3) eum l&lbmillals must be appn,wed by an aU!llanZed represen:tative
(*) NRC must appn,,,e Ille papaMd IIUfflirlalil>ns.
C. t.a ~s fat NRC -.inistralicn cl e..,.irlalians must be in writing in accarC1ance _, 1C CFR 5S.4C (C).
Respond IC NRC arnual actninisntive leller and keep region a:,praised or any cllianges. ConlaCI Region II OLB Branch Chier by pllcne IC negotiate exam dates and development opticns. Panial de.elcpment may be negotiated.
ES-201 Examination Process C.1.b The agency e1lucatn.ent policy applies to exam compromise.
Allaclvnent 1 has a HClion called "Olher Considerations" wllicn was not in Interim Rev. B which...,.marizu IIGffle *um secunty and integrity issues C. t.e The amount of reference malerial requested from the facility licensee wiU be adjusted basacl on Ille NRC"s level or invoh,ement.., tne eumr,ation development process. The Chier examiner will discuss re!erenoe material cantent and lkll! dates d..-ing the pllOne can prier to tne 120-day letler.
. The licensee is requested to subm~ ttvee =i,es al the O&lllines and auminalians. Only one r:1JP'f al u,e references is Mquftd. (Region II Nquesl)
C.1.1 A facilily supenrisor or manager shall independently review tne aumirlation outhnas and lhe proposed exams before tney are sut>mitled to Ille NRC.
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e ES-201 Examination Process C.1.g An authorized repruenialive of the facility lic:ensN shall approve !he aubmillals before Hnding !hem ID the NRC for n,view. The IIUlhoriZed representative is not the same person as the facil~y n,viewe;::--n;e-aumonzea repn,sentative will be tne me person inat tne l;zO.day lotter is Hnl to. He does nol -
to....,;.w 111e test ~ems nor be on lhe sea,ity agrNmenL C.1.j Facility is ~
to c:ammunicate aignifoc:ant -
with the content for di!ricufty of the NRC.,,...,..CS eum of the c:llanges tnat Ille NRC has drectad for its ptOpCIHd uam.
C. 1.k Facility will make any -ry cnanges to Ille examinations as agreed upon willl lhe NRC.
C.2.c About fD4I months befDre Ille ezaminalicn, the Chief Examiner win can !he facility to discuss the nne items listed. Negotiation of cleli¥ery dalas may be made to elbw most effocient review.
C.2.f Eum.,..s have Ille option 1o not panicipate in the prap -k visit ES-201 Examination Process C.2.h The wnnen and operemg portions ot lhe exams mey be aplit by up to 30 days.
C.2.i llrench Chief will sign Ille OA slwels -
tw is ulisflM! lhlll lhe esaminalions ere.-y for-inisnlicn.
C.3.f "Sampling Re,,;,,..t of the written._,,.,.I.ion lllaP lie c:amplated wilhin of recaomg Ille....,,Nlion and the -
of the review canpleled in lwO -
after recaipL C.3.j SRO ~s filling an RO or BOP position do not Med to be evaated individually.
ES-201 Examination Process 0.2.a FIICitity should Im~ aaoes.s lo only lhoH portions which the individual beats responsibi~ly.
0.2.b Gives enmples of "pn,hibud aaivilies" for individuals an the Sec,ity Agreement.
Supenrilors and managers on the SeQ,rity Agreement may continue !heir general 0¥erSight cf !he !raining pragram including review of euminations and remedial lraning. They may not provide individual applicant feedback.
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ES-202 Preparing and Review Operator Licensing Applications C.1.a rr more than six months ""..., passed since an applicant's rnec!GI examination. 1"" tacihty shall callify that lhe applicanl has not ~
.,y.. panable CDndltion.
D.3 Eligit,ility cneria fer Lin~ed Senior Rucior Operators mooed tram ES-701.
ES-204 Processing Waiver Request 0.1.a A retake *xaniratian mus1ta1teplace Wlllwl _,.. of llledat* en which Ille denial of 1M or;nal applicatian -
fnal.
0.1.g The ra;ian may....., the __.,,,.em, fer an *.-ninatian r Illa applicant was pre,,iousty licensad at tne same facit~y. Must,...,. lelfflinated panicipatian in._.., 1ns 111an two,...-sago.
D. 1.ri The region may accept applications and aoninister exans to applicants wrio t,a.., not completed their,_ ructivl!y m~tions due to *lllended Sllulmwn. A COid or iefu*hng license will De issued.
ES-205 Generic Fundamentals Examination Program C.1.a Facility licansees st,culd notify the NRR operator licensing program otric:e if llley acid or delete an individual from their previously sutmilled registration lellerfor Ille GFES before Ille examination is administered.
A !Md GFES is -- in 2000. OCIDIII!!' 1999. f'etlnla,y 2000. & Ja.s,e 2000 are lik*ty dates.
The GFES *aam dale is always the WednesOay after the fil'sl So.nday of Ille mont/1.
TRAINING MANAGER CONFERENCE REGION II OFFICES AUGUST 12, 1999 BRUCE A. BOGER, DIRECTOR DIVISION OF INSPECTION PROGRAM MANAGEMENT OFFICE OF NUCLEAR REACTOR REGULATION
Office of Nuclear I
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Reactor Regulation Aoency All9111tlon1 Advlaor Director Deputy Director
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I A11ocl1te Director for ProfKI Llc1n1lng & Technlcal An1ly1l1 I
I Dlvl1lon Director for Dlvl1lon Director for Dlvl1lon Dlrtclor for Sy1t,m1 Safety & Analy1l1 Engineering llcenslna and ProJect Deputy Director Deputy Director M1n1gement Deputy Director I
I Reactor Syslema Branch Mech11nlc1I & Clvll POI Engineering Branch Plant Syslema Branch Materlala & Chemical Pon Engineering Branch Prob. S11lely Eleclrlc11I and POHi As111ssmenl Branch lnstrumenl1tlon & Controls Br11nch I
I PD IV/Decomml11lonlng Auoclite Director for Inspection & Proarama I
Dlvltlon Director for ln1pectlon Proaram Management Deputy Director I
Inspection Progr11m Branch CA, Vendor Inspection, Malnlen11nct1 & Allegallons Branch Oper1to~ Licensing, Hum11n Perform1n.ce & Plant Support Br11nch Program Management, Poll cy rr Development & An11lysl~ Sl11 I
RHOUrce Management Branch lnlorm1 Hon menl ch Man11ge Br11n Enlor cement Coor dlnator A
I Dlvl1lon Director for Rtgul1tory Improvement Proar11m1 Deputy Director I
Tech Speclfic11tlon1 Bnanch License Renewot &
S111nd11diz11tlon Branch Evenl1 Assessment, Generic Communlcetlon1 &
Non-Power Re1clor11 Branch Generic lssu111, Environ.,
Finan. & Rulemaklng Branch
PERFORMANCE GOALS FOCUS ON ACHIEVING OUTCOMES
Strategic Pcrformnncc Areas INITIATING Cornerstones EVENTS NRC's OvcNtll Snfety Mission REACTOR SAFETY MITIGATION SYSTEMS REGULATORYFRAMEWOR~*
PUBLIC HEALTH AND SAFETY AS A RESULT OF CIVILIAN NUCLEAR REACTOR OPERATION UARIUER INTEGRITY RADIATION SAFETY EM ERG ENC\\'
PREPAREDNESS PUBLIC SAFEGUARDS OCCUPATIONAi PHYSICAL PROTECJ'ION HUMAN ---------- SAFETY CONSCIOUS WORK---------------
PROBLEM---------
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- urmm. INFORMATION SOURCES
- DECISION THRESHOLDS RESOLUTION
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>5.<P/o Sciety ~em Ftn::ti<:Irl Falures (CNeJ µ-eviru; fcu
>5.0 NIA qtmas)
Table I - PERFORMANCE INDICATORS Cont'd Cornerstone lmtka,lot Thresholds Increased Required Regulatory Re1ulatory Response Band Response Band*
Battlers <ft Reactor Coolant System (RCS) Speclnc Activity (maximum
>50.0%
>100%
4 Fuel Cladding <t monthly values, percent or Tech. Spec limit, during.
p~evious four quarters) 4 Reactor Coolant RCS ldentined Leak Rate (maximum monthly value~,
>50.0%
>100%
System <ft percent of Tech. Spec. lirni~ during previous rour quarters) 4 Containment Cont~inment Leakage (maximum monthly values,
>60.0%
N/A percentage of LA over U1e previous four quarters)
Emergency Drill/Exercise Performance (over previous eight.quarters)
<90.0%
<70.0%
Preparedness ERO Drill Participation (percentage of Key ERO personnel
< 80. 0% (.
<60.0% 1 that have participated in a drill or exercise in the previous eight quarters)
Alert and Nolincalion System Relia bilily (percentage
<9'1.0%
<90.0%
reliability during previous rour quarters)
Occupatlonal 1 Occupational r~posure Control Effectiveness (occurrences >5
> It RndlaUon Safety during previous 12 quarters)
Public IMlbtlon R ETSiODCM Radiological Emuen.t Occurrence
>I
>3 Safety (occurrences durinR previous rour quarters)
Phys.k:al Protection Protected Area Security Equipment Performance Index
>0.05
>0.15 (over a four quarter period)
Personnel Screening Program Performance (reportable
>2
>5 events durinR the previous rour quarters)
Filness-ror-Duty (FFD)/Personnel Reliability Program
>2
>5 Perrormance (reportable events during Ute previous rour
Plant Oversight Process Management Meeting Licensee Action ca.-
1-
~ NRC Inspection 1 I. -
t Regulatory Action Assessment Report Public Assessment Meeting Evaluation of Findings
ACTION MATRIX DI LICENSEE PERFORMANCE I
INCREASING SAFETY §fQNlflCANcE -** >
~
All Assessment One or Two While Inputs One Degraded Repellllve Degraded Overall Unacceptable Inputs (Performance (In different Cornerstone (2 White Cornerstone, Multiple Perfonnance; Planls Nol
.J lndldtlors (Pis) and cornerstones) In a Inputs or 1 Yellow Input)
Degraded Cornerstones, Permitted lo Operate U)
Inspection Findings)
Strategic Performance or any 3 White Inputs In Mulllple Yellow Inputs, Within this Band, w
Green: Cornerstone Area: Cornerstone a Strategic Performance or 1 Red lnput1; Unacceptable Margin lo er Objectives Fully Mel Objectives Fully Mel Area: Cornerstone Cornerstone Objectives Safety e I I
Objectives Mel wllh Met wilh Longstanding Mlnlmal Reduction In Issues or Significant Safely Margin Reduction In Safely Margin Regulatory Routine Senior Branch Chief (BC) or DD or Reglonal EDO (or Commlsslo!1)
Commlsslc,n meeting with Conference Resident Inspector Division Director (DD)
Administrator (RA) Meet Meet with Senior Senior Licensee (SRI) Interaction Meet wllh Licensee with Licensee Licensee Management*
Management Licensee Action Licensee Corrective Licensee Corrective Licensee Self Licensee Performance Action Acllon with NRC Assessment wllh NRC Improvement Plan with w
Oversight Oversight NRC Oversight U) 2 NRC Inspection Risk-Informed Basellne"and Inspection Baseline and Inspection Baseline end Team 0
Baseline Inspection Follow-up Focused on Cause of Inspection Focused on
- n.
Program (Baseline)
Degrodatlon Cause of Degradation en w er Regulatory Nono
'- Document Response lo Docket Response lo
-10 CFR 2.204 DFI Order lo Modify, Suspend, Actions Degrading Area In Degrading Condition
-10 CFR 50.54(f) Leiter or Revoke Licensed ln*narllon Reoort
Report assessmentreport assessment report assessment report assessment report 0 I=
(w/ Inspection plan)
(w/ Inspection plan)
(w/ Inspection plan)
(w/ Inspection plan) 5 z
I Commission Informed
- E
Commission Meeting with 0
Assessment Licensee Licensee Performance wllh Discuss Performance Senior Licensee u
Meeting Licensee wllh Senior Licensee anagemenl Management D
""I Review I An@ncv Review **
Operator/Technician* Fatigue I
"Policy on Factors Causing'Fatigue of Operating Personnel at Nuclear Power Plants" (QL 82-12)
Policy implemented through technical specifications Recent allegations and.Congressional interest Use of overtime at some plants not consistent with policy guidelines NRC to reassess policy statement I
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1 O 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 fidelity has been assured by testing
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Related Regulatory Activity...
Regulatory Guide 1.149 is being revised to endorse ANSI/ANS 3.5-1998..
1 o CFR 55.45 is being revised to reduce unnecessary regulatory burden.
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ES-301 Final Rev 8 Change Overview Purpose "A" All applicants fOf' reador operator (RO) and senior reactor operator (SRO) ticenses at power reador facilities are required to take an operating test, unless it has been waived in ac:orc:lance-with 10 CFR 55,47 (refer to ES-204). The specific content of the operating test depends on the type or ticense for whieh the applicant has applied.
This standard desaibes the procedure for developing operating tests that meet the requirernems or 10 CFR 55.45, including the use or reador plant simulation facilities and the conduct of mutti-unit evaluations.
Background *s*
To the extent applicable, the operating test will require the applicant to demonstrate an understanding or. and the ability to perform, the adions nec:essary to acccmplish a representative sampling from the 13 items identified in 10 CFR 55.45(a) (*1113 irems do nor nMlrfro be sampled on every operaring rest).
In addition, the content of the operating test will be identified. in part, from learning objedives contained in the facility licensee's training program and from information in the final safety analysis report, system desaiption manuals and opera!ing procedures, the facility license and license amendrnems, tic:ensee event reports, and other materials requested from the facility licensee by the Commission.
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Category "8" Control Room Systems and Facility Walk-through (B.2) category B is divided into two sui,ca1egories. The first and larger subcategory (B.1. "Control Room Systems") focuses on 1hose systems with which licensed operators are most involved (Le.* fflcse having contrcis anct indications in the main control room). The se=nd subcategory (B.2. "Faciltty Walk-Through") ensures that the applicant is familiar with the design and operation of systems IOcated oUISide the main comrol room.
The applicant's knowledge and allllit~ ra/ative to uclt system are
..,_,uated tiy administering JPMs and, wllen necessary, specific follow-up qu..Uon:s tiased on the app/ic:ant':s perfurmanr:e of nch JPM.
Category "C" Integrated Plant Operations (B.3)
Each applicant must demonstrate proficiency on every competency applicable to his or her license level. The only exception is that SRO Competency Number 5. "Control Board Operations," is optional for SRO-upgrade apptic:ants (i.e., SR~pgrade applir:anrs do not hat/fl to fl/I a position that raqui~ control board operations; 110-wer, If they do rotate into such a position, they will be graded on fhis competency enn though rlley may nor be individually otise,-d by an NRC ezaminer, as discussed in ES-302).
INSTRUCTIONS General Guidelines (0.1.a)
To minimize predidabitity and maintain test integrity. varied subjects.
systems. and operations shall be evaluated with applicants that are net being examined at tne same time. unless measures are taken to preclude interadicn amcng the applicants.
The same JPMs and slmulatar scenarios shall not be repeated on successive days.
General Guidelines (D.1.a) cont Operating tests wrillen by the facility licensee may not duplicate test items (simulator scenarios or JPMs) from the applicanrs
- audit rest (or tests ff the applicant is retaking th* examination) given at or near the end of the license training class. Simulator events and JPMs that are similar to those that were tested on the audit examination are permitted provided the actions required to mitigate the transient or complete the task (e.g., using an alNTMte path as discussed In Appendix CJ are significantly different from those required during the audit examination. The facility licensee shall Identify for the NHC chief uaminarthose simulator -*nts and JPMs thatare simllar to those that wwre tested on rhe audit *nm/nation.
General Guidelines (D.1.d)
When setecling and developing materials (JPMs. scenarios, and questions) for the operating test. ensure that the materials contribute to the test*s overall capacity to differentiate between those applicants who are competent to safely operate the plant and those who are nol Additionally, all of the r.st /rems should include the thrft faceu of tast "8/idlty (i.e., content. operational, and discrimination) discussed in Appendix A.
Any test items that. when missed. -uld iaise questions regarding adequate justification for denying the applicant's ticense should not be included on the operating tesl General Guidelines (D.1.i)
Every facet of the operating tesl, lnt:luding the prescripted Category A questions and anstft1$, the JPMs for Categories A and B, and the Category C simulator scenarios, should be planned, researehed.
validated. and documented to the maximum extent possible before the test is edministered.
Thatis -eeFORE-
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General Guidelines (D.1.j)
Examiners Wllo will be administering the operating tests but were not involved in their development are expected to rese.rcn and study the topics and systems to be examined on the operating test so that 11\\ey are prepared to ask whatever performance-based follow-up questions might be necessary to determine if the applicant is competent in those are.as.
As stated In 10 CFR 55.45(aJ, the operating resr requires the applicant ro amonstrare an understanding of and the ability ro perform the at:tions necessary ro accomplish a representative sample from among 13 irams listed in the rule.
General Guidelines (D.1.j) cont trtlte app/icanr comicrly performs a JPM (including borh r:mica/ and nonr:ririr:al steps) and demonsrrares familiarity with the equipment and procedures, It is nor necessary co aslc any fol/ow-up questions.
However, trfhe applicant fails ro accomplish the raslc standard tor the JPM or demonstrates a /aclc of underst11nding regarding the equipment and procedures such as having difficulty locating information, r:onrro/ board indications, or controls, rtte eraminer must be prepared ro aslc performance-based fo//o.,...up questions, as necessary, ro clarify or confirm the applicant's under.nanding of the system as if re/ares ro the task that was performed.
General Guidelines (D.1.1)
The prescripted questions for Category~ and the performance-based fo/lo.,...up questions for Category B may include a combination of open*
and c/oseG-r-eferenr:e irems. Open-reference items that require applicants to apply their knowtedge DI the plant to postulated nonnal, abnonnal, and emergency situations are preferred.
Closed-reference items may be used to evaluate the immediate actions of emergency and other procedures, certain automatic actions, operating characteristics, interlocks, set points, and routine administrative ar:riviries, as appropriate ro the faci/iry.
Refer to. Amchmenr 1 for mor-e guidance regarding the deve/opmenr and use of prescripred open refer-ence questions for Caregory A of the wallc-through test To rite ertenr possible, the concepzs in the artachmenr should also be applied ro performanc*based follo.,...up questions.
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Catagory "A" Administrative Topics (D.2.b)
Fer each administrative subject, determine the best method fer e11aluating the applicant's knowledge er ability in that area. Although a performance-based evaluation, using a single administrati11e JPM is generally preferred, two prescripted questions may be used to concluct the e11alu11tion in eaeh specific subjed area seleded fer evaluation.
The questions may be associated with Category B JPMs or they may be administered separately.
Administrative Topics (D.2.g)
Forward the completed outline to tne NRC chief examiner so th.rt ii is rec~d by the date agreecl upon wilh the NRC regional office at the time the examination am1ngements were confirmed: the outttne is normally due appro1titr111tely 75 days before the scheduled examination elate. Refer le ES-201 for aclditicnal instrudicns regarding the review and submittal of the examination outline.
Administrative Topics (D.2.h)
After the NRC Chief examiner approves the operating test outline. prepare the final Category A test materials in accordance wilh the general operating test guiclelines in Sedion 0. 1, the open-reference question guidelines in Appendix B. and the JPM guidettnes in Appendix C.
(i.e., the JPMs, prescripted questions, and *ns-r:.J
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Control Room Systems and Facility Walk-Through Specific Instructions For Category *s* (0.3)
This r:negory of the operating rest evaluates the applicant on system.related Kllu by having the applicant perform selected tasks and, when nec-ry, based on the appliclint's performance, probing his or her knowledge of the task and /rs associated system with specific follo-p questions.
The Category B tasks are In addition to and should be different fn:>m Ille events and evolutions ClllldUCled during Category C. "Integrated Plant Operations.*
Specific Instructions For Category *s* (0.3.a) cont lhe 1 o systems and eVOlulions selecled for RO and SRO.I applicants sllould evaluate at least 7 different safety funelions. AU of 1he systems and
- evolutions in eaell subcategory of tlle test should be seleCled from different safety funCliDn lists, and Ille same system or evolution should not be used to evaluate more tllan one safety funelicm in each subcategory. For PWR operating resu, the primary and secondary systems listed under Safety Function 4, *Heet Remove/ From Reactor Core,* in Section 1.9 of NUREG-1122 may be treated es separate safety functions; i.e., 1WO systems, one primary and one secondary, may be selected from Safety Function 4.
l Specific Instructions For Category *s* (0.3.a) cont TIie 1 D systems and evolutions seteCled for RO and SRO-I applicants
. should e.raluate ill least 7 different safety functions. All of Ille systems and evolutions in eac:11 subcategory of tlle test should be seteCled from different safety funClion lists, and tlle same system or evolution should not be used to evaluate more than one safety function in eac:11 subcategory.
For PWR operating rasu, the primary and secondary systems listed under Safety Function 4, *Hut Remove/ From Reactor Core,* in Section 1.9 of NUREG-1122 may be uuted es separate safely functions; i.e., 1WO systems, one primary and one secondary, may be selected from Safllty Function 4. **
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Specific Instructions For Category *s* (D.3.b)
For each system seleded for evaluation. select from the applicable KJA catalog or the facility licensee*s site-specific task fist one task for which_a JPM exists or can be developed. Review the associated simulator outline if it has already been prepared (refer to Sedion 0.4), and avoid those tasks that have already been seleded for evaluation on the dynamic simulator tesL Th* JPll/s should, Individually and as a group, haw, muningful perform.nee requiramenrs that will provide a legftimate basis for evaluating the applicant's understanding of and abilfty to safely operfle the assoc/ate_d systems and the plant (as required by 10 CFR 55... 5).
Specific Instructions For Category *e* (D.3.b) cont At least one of the tasks shall be related to a shutdown or low-power condition, and 40 percent of the tasks (i.e., "'10 for ROs and insranr SROs and VS for upgrade SROs} shaft require the applicant to uecute an.mare paths within the fac//fty's operating proceduru.
In addition, at least one of the tasks conduded in the plant (i.e.,
Subcategory B.2) shall evaluate the applicam*s ability t.o implement actions required during an emergency or abnormal condition. and another shall require the appln::am to enter the RCA.
This provides an e,rcellent opponunity for the applicant to discuss or demonstrate the radiation control subjeds described in Administrative TopicA.3.
Specific Instructions For Category *e* (D.3.c)
Forward the completed walk-through test outfine to the NRC chief examiner so that it is re~ved by the date agreed upon witll the NRC regional ot'f'n:e at the time the examination arrangements were confirmed; the outlines are normally due approrimate/y 75 days before the scheduled examination date. Refer to ES-201 for additional instrvdions regarding the review and submittal or examination autlines.
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Specific Instructions For Category *s* (D.3.e)
Submit the entire operating test package to 1lte designated facility reviewer or the NRC chief examiner. as appropriate, for re,new and approval in accordance with SeClion E. The test must be received by the NRC chier examiner approrlmataly 45 days before the scttadu/ad rwview date, unless Olher arrangements hllve 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 of evolulions, failures, and transients in the quantities identified for the applicant's ticense level on Form ES-301-5. "Transient and Event Checklist.* An applicant should only be given credit for those events that require the applicant to perform verifiable aClions that provide insight~ the applicant's competence.
The. required insrrument and component fa/lures sttou/d normally be comp/etad before starting rite major transient; tttose thar are initiated atrer the major transienr sttou/d be carefully reviewed because they may require little applicant action and provide /m/e insight regarding their performance.
Specific Instructions For Category *c* (0.4.d) cont Each event should only be counted once per applicant.
For example: a power change can be counted as a normal evolution OR as a reaClivity manipulation.
Similar1y. a component failure that immediately resulls in a major tlansient counts es one or the ather, but not both.
e Specific Instructions For Category "C" (D.4.d) cont Any normal evolution, component failure, or abnormal event (other titan a reactor trip or other automatic power reduction) that requires rite operator to perform a controlled power or reactivtry cttange will satisfy rite requirement tor a reat:tivfry manipulation.
This includes e"9nts suctt as an emergency boration, a dropped rod reco.,.ry, a significant rod bank realignment, or a manual,..ctor power reduction in NSponse to a secondary system upset. Such evenzs may produce a more timely operator and plant NSpo,ue titan a normal power change.
Specific Instructions For Category *c* (D.4.d) cont ff th* faciltry licensN normally operates wtth and is required by iu technical specifications ro ltilve more rttan rwo ROs in rite comrol room, the chief enminer may authorize Ute use of additional surrogates ro fill our the craws.
In such cases, talle ca,e in planning the scenarios to ensure that rhe additional operators do not reduce the era miners' ability to evaluate
- ch applicant on rhe required number of *.,.ms and on every competency and raring factor.
Specific Instructions For Category *c* (D.4.e)
When the proposed simulator operating test outlines are complete. forward them to the NRC chief examiner so they are received by the dale agreed upon with the NRC regional office at the time the examination arrangements were confirmed; the outlines are normally due approximately 75 days before the scheduled examination date. Refer to ES-20t for addttional instructions regarding the review and submittal of the examinalion outlines.
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Specific Instructions For Category *c* (D.4.g)
Submtt the entire operating test package to the designated facilily reviewer or the NRC Chief examiner, as appropriate, for review and approval in accordance willl Seclion E.
The test must be received by the NRC chief examiner appro:icirnarely 45 days before the scheduled administration dale, unless other arrangements have been made.
QUALITY REVIEWS Facility Management Review (E.1)
If tlle operating test was prepared by the facility,censee, the preliminary ourline and th* proposed rest shall be independenuy reviewed by a supervisor or manager~ they are submitted tattle NRC regional otrice for review and approval in accordance with ES-201.
The rewiewer Should evaluate the outline and test using the criteria on Forms ES-201*2, ES-301*3. and ES-301-4 and inctude the signed forms (for eaeh different operaling test) in the examination pacltage submifled to tlle NRC in accordance with ES-201.
ATACHMENTS (F)
"Open-Reference Question Guidelines"
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- I Open-Reference Question Guidelines
- 1. The most appropriate format is the sllort.. nswer question, which
,equires rlle applicant ro compose
- response rather than select from among* ser of alremative responses, as is the case wtrll mulripie-clloice, matching, and true/false questions.
- 2. Provide clur, erpliclr dirwt:tio~guidelines for ans-ring the question so that the applicant understands what cansrtrures
- fully ca,,.ct response. Choose worr:s ca,efully to ensure that the stipullltions and,equirwments of th* question arw appropriately conveyed. Wonts such as *evaluate,* *outline,* and "uplain,
- can invite
- lot of deUlil that Is not necessarily rw/evant.
Open-Reference Question Guidelines (cont)
- 3. Make sure that die expected response marches (and Is limited to) the requirwmenu posed in the question. Consider the amount of panial credit to be granted for an incamp/ete *-r. For questions requiring computation, specify the deg,.. of p,ecision upecred. Try to make the answer rum our to tJe whole numbers.
- 4. Avoid giving *-Y part or all of the answer t,y the -Y the question is worded. Forenmple: "tfthe letdown line became obstructed, could t>oration of the plant be accomplished shortly after* rwacror trip to pur the plant in cold shutdown? ff so: how?* A test-lse applicant can rulize tllar the answer has to tie yes, or else the second part oft/le question would have,ead something like *tt nor, why not?
Open-Reference Question Guidelines (cont)
- 5. Avoid what could tie considered *fric~ questions in which the upecred answer does not precisely match the question. For enmple, asking *How {do} the SI termination criteria change following an ~I
,eintriation?" implies that the termination criteria will change, when In actuality they do not.
- 15. Do not use direct look-up questions that only,equire t/te applicant to recall where to find the answer to the question. The operational orientation required of questions on the -lk*through test and the applicant's access to reference documents, argue against the use of questions that rest for recall and memorization. Any questions that do not require any anelysis, synthesis, or application of information t,y the applicant should tie answerable without the aid of referwnce materials.
Refer to ES-102, Attachment 1, for* more detailed discussion of direct lo'oll-up questions.
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Open-Reference Question Guidelines (cont)
- 7. Quurioms should *lso *dhere to the generic h*m construction principles *nd guidelines in Appendix B. Moreover, Form ES-802-1,
- NRC Ctlecl<lisr for Open-Reference Tur /rems,* i:onr*in.s
- lisr of quesrioms r/Nlr can be used to *v*lu*te th* sutrabilhy of rhe questioms for me -11<-fhrough porrion of th* operaring resr.
Alrhough the cMcl<list -.s developed for us* in *.,.lu*ring Nqu*lificarion wrtrr*n *x*min*rioms, *II of the crir*ri* except 9, 10, 11, *ndfh* KIA rering on /rem 7 *N generic*lly*pplicable.
602-1 Excerpt Items 9, 10, and 11
- 9.
Is the question appropriate tor the written eumination and the selected format (e.g., Sllort answer or multiple Choice)?
- 10. Do questions in Section A take advantage of the simulator control room sening?
- 11. Does any question have the potential or being a "double-jeopardy'"
question?
ES FORMS ES-301-1, 2, 3, 4, 5, and 6
- 1)..
e Examples of LOW discrimination JPMs A
*\\C) ----
- 1.
Reset the Turbine Driven AFW Pump Trip Toronle Valve (PWR)
- 2.
Actuate AOS (single critical step) (BWR)
- 3.
Start the Hydrogen Recombiner (without a fault)
- 4.
Locally borate the RCS with the emergency manual boration valve (PWR)
Examples of DISCRIMINATORY JPMs
++++ © ++++
- 1.
Cropped rod recovery (drop a second rod during recovery requiring reaClortrip)
- 2.
Local start cf equipment with failures requiring the use of al!emate procedures.
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ES-302 Final Rev 8 Change Overview Purpose "A" This standard describes how to administer operating tests to initial ficense applicants in accordance with the requirements of 10 CFR 55.45. It indudes policies and guidelines for administering both the -lk-thrOugh and the integrated plant operations categories cf the operating test. II is assumed that the operating test was prepared in accordance with ES-301.
- Background *s*
As noted in ES-201, facility ticensees will generally prepare proposed operating tests in accordance will'I ES-301 and submit 11'1em to tile responsible NRC regional office for review and approval.
Regardless of whether ii was prepared by Ille facility licensee or the NRC, every operating test will be independently administered and graded by an NRC licensing examiner in accordance will'l the instructions contained herein and in ES-303.
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Responsibilities "C" Facility Licensee (C.1.b)
Safeguard the integrity and security of the operating tests in 11ccordance with f11cility procedures esti,b/ishod pursu11nt to 1 O CFR 55..,,0{b)(2) and the guidelines discussed in Attacnment 1 of ES-201.
Responsibilities "C" NRC Regional Office (C.2.a)
Wot* with th* facility contllct to coordin11re the operating rest administration schedule in" mllnner that marimizes efficiency 11nd maintllim; security.
Normally, the oper11ring tests should be adminisrered within 30 d11ys before or afler rhe wmren enmin11tiom;. The region sh11II obt11in concurrence from the NRR oper11tor licensing program office if the enmination dates diverge by more than 30 dlly:;. (Refer to ES-201 for 11ddirion11I guid11nce regarding er11minatiom; that h11ve to be rescheduled to 11chieve an aceeptllble product.)
Test Administration Instructions and Policies (D)
General (D.1.d)
Normally, an NRC examiner will be assigned to individually enluate uch appliCllnt during the simulator oper11ting test. However, if a three-person oper11ting crew consists entirely of senior raactor oper11tor (SRO) upgrade appliCllnts (who do not hllve to be evaluated on the conuol boards), the chief eraminer may assign only twO eraminers to obsen-e rtte crew.
Although tho applicants in rite reactor oper11ror and balance of plant positions may not be individually evaluated, they will be held accountable for any errors that occur a:." result of their 11ction(:.J or inaction(:.) 11nd graded on their ability to *operate rite Conuol Board:.* (i.e., SRO Competency 5). SRO-insunt applicants will al-ys be individually enluated by an NRC era miner regard/es:;
what operating position they are filling during a given scenario.
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<;;eneral (D.1.j)
Although the simulation facility operator will normally assume the rote or the other personnel that the applicants direct or notify regarding plant opennions, the chief examiner may permit other members of the facility
- training or operations staff (e.g., a shffl ter:hnir:al advisor (STA)) to
- ugmem th* o,,.rating shirt team If ner:essary.
The chief examiner shall fully brief those individuals regarding their responsibilities. reponing requirements, duties, and level of participation before the operating test begins. The examiners must not restrict the
- umigate operators' activities to such an extent that the applicants being evaluated are required to assume responsibilities beyond the sc:ope of their position.
The surrogate operators will be exi,ecled to assume the full responsibilities of the roles they take in the operating test Consutrations wfth an STA shall be r:ondur:ted in ar:r:ordanr:e with the far:fliry lir:ensee's normal r:onrrol tvom prar:tir:e; e.g., *n STA shaft not be srationed In the simulator If they *re on-call at the she.
Walk-Through (Categories A and B) (D.2.b)
To the extent possible, the examiner should have the applicant perform the control room JPMs on the simulator, rather than asking the applicant to describe h-he or she would accomplish the task.
tf the en miner obsel'V'eS a disr:repanr:y be,_.n the simulator setup
- nd the r:onditions specified in a JPM, then the eaminer shall stop rite JPM and correr:t the struation, as ner:essary.
tf the taslr can be completed with different values (e.g., wind direction wtten determining a ptvter:tive action rer:ommendation during an emergenr:y}, then the ez*miner shall dor:ument the differences and r:oordinare with the facility conrar:r and the HRC*chief ezaminer 10 validate the applicant's response under the *t:twl r:onriitions *
. Walk-Through (Categories A and B) (D.2.f)
As stared In 10 CFR 55.'5(aJ, the operating rest requires the *pplicant ro demonstrare an understanding of and the *biliry ro perform the ar:tions ner:assary to *r:r:omplish
- representative sample from among 13 hams listed in the rule.
tfthe applicant correr:tly,,.rrorms a JPM (inr:luding both critical and noncritical steps) and demonsrrares familiarity wfth the equipmenl and p,vr:edures, the ezaminer should infer that the applicant's understanding of the systemllaslr is adequate and refrain f,vm as/ring follow-up questions.
Ho-ver, If the appllcant falls to *r:r:ompllsh the raslr standard for the JPM, e:thlbirs behavior that demonstrares a tar:lr of familiarity wirh the equipment atid pror:edures, or is unable to lor:are information, r:onrrol board indications, or r:onrrols, the ezaminer should aslr performanr:f>.
based follow-up questions as ner:essary to clarify or confirm the applicant's understanding ofthe sysrem as it re/ares to the taslr t1r111
-.s performed.
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e Walk-Through (Categories A and 8) (D.2.f) cont Simi/arty, tf the app/icanr gives an ambiguous answer to
- prescripted administrative question In Category A, the examiner is expected to eslc probing questions to ensure that the applicant understood the original question end #le applicable knowledge or*abllity.
The examiner sM// document all perlormen-,.sed questions end
- nswer.s for later *lfllluation.
tf an applicant lfO/unteers additional or corrected Information mer having completed a taslc or question, th* examiner she// o"er the applicant th* opponunity to take whatever actions -uld be required
/n a similar 5/tuation In the plant The examiner will record any revisions to previously performed reslcs or ans-rs for consideration when grading the operating resr per ES-303.
Walk-Through (Categories A and 8) (0.2.g)
The e1taminer shoutd pradice orner !100d walk-through evaluation techniques as discussed in Section D ot Appendix C.
Walk-Through (Categories A and 8) (D.2.o) tr the simulation facility should become inoperable and cause excessive delay or the operating tests, the chief examiner Should discuss the situation with the facility ficensee and the responsible regional supervisor so that management can make a decision regarding the conduct or the operating tests. II may be necessary to reschedule the simulator examinations tor a later date.
The simulator 11hould be considered inoperable under any of the following conditions:
The 11imu/ator exhibits* mass/enerr.,y imbalance, erratic logic, or inexplicable pane/ indications during model execution.
The simulator exhibits unplanned and unexplairtea 9"!1115 or ma/functions that cause the applicants to divert from me expected reJSponses and 11uccass path of the planned scenario.
Walk-Through (Categories A and 8) (D.2.o) cont The simulator automatically goes to the *freeze* state during a scenario or a *beyond simulated limtts* a/arm is received on the instrut:tor station.
The simulator instrut:tor irrforms tire examination team that a srrtrware module has halted or *<<iclced out. -
OccurTence of any of these abnormal simulator operating conditions during an examination constitutes sufficient cause to stop the scenario. Evaluations of the applicants' performance during any of these simulator maHunt:tion conditions may be unreliable.
When the simulator has bHn restored to full operability, the chief examiner will determine ff the scenario requires rwplacement. may be resumed in progress, or may be resfllrted from the beginning.
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ES-303 Final Rev 8 Change Overview Purpose "A" This suindard desoibes the prccedures for documenting all categories or the operating lest, CDUating Ule data to arrive at a pass or fail recommendation, and reviewing the doc:urnentation 10 ensure quality.
Background *s*
This standard assumes that the operatiAg test was prepared and administered in accordance with ES-301 and ES-302, respectively.
The procedures contained herein require the examiner to evaluate each applicam*s performance on the operating I~ and make a judgement as to whether the applicant's level of knowledge and understanding meet Ille minimum requirements to safely operate the t.aci!ity for wnich the license is sought The examiner evaluates each noted deficiency in light Df the total breadth of knowledge and ability demonstrated by the applicant in that subject area.
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e Responsibilities "C" NRC Examiner of Record (C.2)
As soon as possible after administering the test. the examiner of record shall review, evaluate, and finalize eaeh applicant's operating test documentation In accordance with the instructions in Section 0.
If an applir:anr made an error with serious safery consequences, the examiner may recommend an operating r.sr failure e11en ff the grading instrucrions in Section D would normally result in a passing grade. Under such circumstances, the examiner shall thoroughly jusrHy and documem the IMsis tor the failure in accorrtance wfth Section D~.b.
Moreo"9r, the NRC regional office shall obtain writren concutn1nce from the NRR operator licensing program office before completing the 1/cens/ng acrjon.
Grading and Documentation Instructions "D" Evaluate the Applicant's Performance Form ES-30~1. Category 8 (D.2.b)
To determine II grade for the systernstJPMs listecfon Form ES-303-1, evaluate eaeh deficiency CDded in the rough notes for Category B. If the following criteria are met, assign a satisfactory grade by placing an *s* in the "Evaluation* column for that system/JPM; otherwise enter a "lT":
- Time-critical JPMs must be completed wilhin the allolled time.
Evaluate the Applicant's Performance Form ES-30~1. Ca!egory 8 (D.2.b) cont
_The task standard tor the JPM must be accomplished by correctly completing all of the critical steps.
If the applicant initially missed a critical step, but later performed ii correctly and accomplished the task standard without degrading the condition of the system or the plant, the applicant's performance on that JPM should be graded as satisfactory.
However, the applicant's error shall be documented in ac:z:ordance with Section 0.3.
- Evaluate the Applicant's Performance Form ES-303-1, Category B (D.2.b) cont The responses to any performanc.-msed to/low-up questions uked pursuant to Ser:rion D.2.f of ES-302 must confirm that the applit:ant's understanding of the sysrem/JPM is safisfar:rory.
If th* follow-up quurions,..,.I that tlte app/1,:ant's undersianding of the system/JPM is seriously defi,:ient, the uamfner may,.,:ommend an unsafisfar:rory grade for the sy.stem ai,en rhough rha applit:ant su,:r:essful/y,:omplated the task standard for th* JPM. Th* basis for the rwi:ommendlltion shall be thoroughly justlrted and dot:umented in a,:,:ordllnt:e with Ser:tion D.3.
Evaluate the Applicant's Performance Fenn ES-303-1, Category B (0.2.b) cont Connr.sely, If the applit:ant did not accomplish the task siandan:t *nd follow-up questioning,wi,ealedthat the failurw was i:aused by a defit:ien,:y in the procedurw or some other tar:ror beyond the
- pplir:ant's t:ontrol, the uaminer may di/,w,:ommend
- satisfat:rDry grade for t/te sysrem/JPM.
Once *g*in, t/te basis for the recommendation shall be thoroughly justified *nd do,:umented in *ct:on:tan,:e with Set:rion D.3.
Evaluate the Applicant's Performance Form ES-303-1, Category B (D.2.b) cont After grading th* *ppiir:ant'$ perfo_rman,:e With resper:r to a// the Category B sy.stems, determine an overall grade for Category B by t:alt:ulating the perr:emage of satisfar:rory sy.stem grades.
If the applit:ant h*s *n -s* on *t least IJO pen:ent of the systems examined, the *pplit:ant puses Car.gory B *nd recei110S *n *s*
overall. If the *pplir:ant has *n *s* on,_r then /JO peri:ent of the systems, the *pplir:ant fails Category B and ret:eins a *u* owira//.
Dot:ument the applicant'$ g,ade by pi.t:ing *n *s* or a *u* in block B,
- control Room Systems and Facility W*lk-Through,
- in the "Operating Test Summary* on page 1 of Form ES-303-1. Enter *NfE" ff this category was waived in accordan,:e with ES-204. Oocumenr and justify *very defit:iency in accordllnce with Set:rion D.3.
Evaluate the Applicant's Performance Form ES-303-1, Category C (D.2.c)
Using Form ES-30~3 or ES-303-4, depending on the applicant's license level. evaluate any deficiencies coded for Category C. Circle the integral rating value (1 through 3) corresponding to the behavioral anchor that most accurately ~eds the applicant's performance. A rating of *1
- would lie justified if the applicant missed a.critical task (i.e.. by omission or incorrect performance) or committed multiple errors of lesser significance that have a bearing on the rating faClor.
Missing one or more critical tasks does not necessarily mean that the,
appllcanl w1111a11 the simulator tes1. nor does success on every crd1cal task prevent 1ne examiner from recommending a failure if the applicant had other def1crencies Iha!. m the aggregate, i!istifrhe failure based on tne competency evaluations. A$ discussed,n E 301, Competency 5,s optional for SRO upgrade app/icanu. Ho-nr, the examiner shell evaluate Competency 5 tfthe applicant rotated into an operating crew posttion that required the applicant"' manipulate Ute controls.
Document and justify enry dflficiency in accordance with Section D.3.
Finalize the Documentation (D.3.b)
Deficiencies that do nor contribute to an operating rest Category failure shall also be documented.
Ho-nr, a brief statement describing th* -,,.or and the expected action or response is generally sufficient.
Examiners should lrNp In mind that their licensing recommendation and the associated documenration are subject to review by the chief era miner and NRC regional office management.
Therefore, Ute documentation should contain sufficient detail so thar th* independent re.,;.-,. responsible supervisor, and licensing official can ma/re a logical decision in suppon of.the examiner's recommendation to deny or issue the license.
_)
Finalize the Documentation. (D.3.b) cont Retain rough documentation until the chief examiner and NRC regional office management ha"° reviewed the examiner's recommendations and concurred in the results (refer to ES-SO 1 ).
Examiners shall retain a// applicable notes and documenra.tion associated with proposed denials until the denials become final.
Examiners are arn,ised that such notes would be subject to disclosure If requested under the Freedom of/rrformation Act.
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e Form ES-303-1 Individual Examination Report ES 303-1
e Appendix C Final Rev 8 Change Overview Purpose "A" This Appendix provides a framework fer preparing and evaluating jab performance measures (JPMs) ta ensure they are cf appropriate substance and fcrmat fer initial operator licensing and requalilicaticn examinations. The fCllclwing elements are discussed in detail er attached for lnfcrmalicn:
- a basic procedure for developing n-JPMs (SeClion S). including forms ta document the JPM and ta assess the quality cf the produCI (Ferm ES-C* 1 and ES-C-2)
- guidelines fer the development and use cf atternate-path JPMs (SeClion CJ
- a discussion cf walk-through evaluation techniques (SeClicn 0)
-THE PRESCRIPTEO QUESTION BULLET WAS DELETED Development and Reviewing JPMs *s*
ALL PRESCRIPTED QUESTION DEVELOPMENT PARAGRAPHS WERE DELETED
e Attachments/Forms ATTACHMENT 1, PRESCRIPTED QUESTION SAMPLES WERE DELETED
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TRAINING MANAGERS CONFERENCE NEW INSPECTION PROGRAM NEW INSPECTION PROGRAM
- The New Program Will Establish Baseline Inspections Common to All Plants
- Inspection Beyond the Baseline Will Be Performed at Plants Below a Specified Threshold
- Predicatec! on Performance Indicators
- Inspection Findings
- Response to Specific Events or Problems
- Baseline Inspections will Be Grounded on "Cornerstone" Areas
- Fo~sed on *Risk Significant" Activities and Systems
- Focused on How Utilities Find and Fix Problems
- Focused on How Utilities Accept and Encourage Employees to Raise Safety Issues NEW INSPECTION PROGRAM
- Major Parts of the Baseline Inspection Program
- Inspect Areas Not Covered By Performance Indicators
- Inspect to Verify the Performance Indicators
- lnspe-ct/Review Effectiveness of Finding and Resolving Problems (Corrective Action Program) -
- CORNERSTONES
(
- Monitor Performance in Three Areas:
- Reactor Safety
- Radiation Safety
- Security e
NEW INSPECTION PROGRAM
- Reactor Safety
.. Initiating Events Cornerstones
.. Mitigation Systems
- Radiation Safety
.. Plant Worker
.. General Public
- Security
.. Physical Protection New Inspection Program Cornerstone Cross-Cutting Elements
- Cross-Cutting Elements
- Element that Effect Each Cornerstone
.. Human Performance
.. Ability to Raise Safety Issues
.. Finding and Fixing Problems NEW INSPECTION PROGRAM Major Elements of the Baseline Program
- The Program is Indicative and Not Diagnostic
.. Program Delineates Specific Inspection Activities
.. Inspection Findings are Evaluated for Significance
.. Diagnostic/Root Cause Determinations Done By
- Supplemental Inspection Program
NEW INSPECTION PROGRAM
- Major 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
- lnspedable Areas are Based on Importance to Measuring Cornerstone Objedive
- Inspection Frequency and Number of Activities and Time Spend Inspecting Based on Risk
- Selection of Inspection Activities in Each lnspedable Area Based on a Risk Matrix Modified by Plant Specific Information
- lnspedors Are Trained in the Use of Risk Information
- Baseline Program is the Minimum Program NEW INSPECTION PROGRAM Cornerstone link to lnspectable Areas 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
.. Availability of 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% of Regulatory Limit
- Public Radiation Safety:
.. Effluent Releases Requiring Reporting Under NRC Regulations and License Conditions NEW INSPECTION PROGRAM Perfonnance Indicators
- Physical Protection:
.. Security System Equipment Availability
.. Personnel Screening Program Performance
.. Employee Fitness-for-Duty Program Effectiveness
NEW INSPECTION PROGRAM Inspection Findings / Performance lndic:ator Data
- Inspection Findings:.
.. Inspector Observations are Evaluated to Determine' Significance
.. Use Defined Process: Significance Determination Process
- Performance Indicators:
.. Thresholds Set Regulatory Response
-Example:
- Dril11Exercise Performance - The percentage of all Drill, exercise,.
and actual opponunities tl'lat were performed in a timely and accurately during the previous eight quaners NEW INSPECTION PROGRAM
, Regulatory Response
.. Characterize the Risk Significance of Issue
.. Each Issue is evaluated and assigned a color Using a Process Flow Chart
- GREEN: Licensee Response
- White: Increased Regulatory Response
- Yellow: Required Regulatory Response
- Red: Plant 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 April 2000 r
e
\\)CLEAR REGULATOR
~
coMMISS/ON y
- /CK BAL'u~~
Training Managers Conference
. Changes & Clarifications to ES-401, Part 1 PREPARING INITIAL SITE-SPECIFIC WRITTEN EXAMS
- D.1.b The outline must be systematically selecled. Shall not use the aile specific KIA catalog The Plant llllide Generic (PWG) Tier 3 should NOT induele system generic tasks. The topics for PWG TterTl 2 and the four KIA categories for Tier 3 Shall be selected from section 2.
Generic KnOWledge and Atlililies from 1he KJA catalog. *
- D.1.c 10 site-specific K/As may replace 10 systematic sample items.
for ctetails or issues. with basis and Chief Examiner approval.
- 0.1.d Ensure outline samples at least every KIA area twice and the SRO samples topics required by 1 O CFR 55.43(b).
Form~S401*3 Date of &'I EamL-:
K/A~PDints Tier c;,,,.,p G*
Point*
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K K
K K " "I" "
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3 *-
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Training Managers Conference
'** 0.2.a
- 0.2.c
- 0.2.d Changes & Clarifications to Es-401, Part II Use existing. modified or new questions. If devialion from submitted sample is necessary discuss wilh the _Chief. Be able ID discuss why -tile Change was necessary. Oocumenl those reasons.
The written exarninalion MUST lie 50-60% higher cognilive Dnler ilems. (NO more N?riiss)
The SRO only questions on an exam must be at the SRO tevel.
not just queslions at 1he RO level. These should be dis1ribuled amongst the 3 tie~.
Training Managers Conference Changes & Clarifications to ES-401, Part Ill
- 0.2.f Relake examinations may NOT have any overlap or reuse items from the failed license examinalion.
No overlap between NRC ezaminatiOn and audil unless independenlly developed. Then onty 5 questions allowed.
Repeat of ONLY 25 questions from last 2 NRC examinllliDns and ilems used in !raining.
- 0.2.g Facilily teaming DbjeClive references are encouraged but not required.
If teaming objeClives are not available, this does not invalidate lhe question provided ii has appropriale KIA and lechnical references.
Training Managers Conference
.* 0.2.g
- E.2.a
- E.2.c Changes & Clarification_s to ES-401, Part IV The draft examination musl be received at least 45 days before the eurninatiDn.
NRC will review and get supervisory review before discussing witll ticensee.
The NRC WILL perform a 30 question sample review. will review all new plui"iiiodifoed, questions, if required. The sample will indude 10 new and 20 modified questions. (All 125 questions will undergo a review.)
Questions previously reviewed and approved by the NRC for thal facifily will have limited review for unacceptable flaws per ES-401-9.
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Training Managers Conference Changes & Clarifications to ES-401, Part V
- E.2.c If the sample shows less than 6 items are unacceptable. detailed review of the rest of the examination will continue. If greater 111an 6 items ane found unacceptable. NRC ~
mum the examination or -
may complete ils review. Review will use ES-
.C01*9.
If the examination is returned, we expect that the licensee caned the identified flaws and those like kind flaws that were not specifically identified to the rest of the questions.
- E.3.a The NRC Supenrisar MUST review and approve all unacceptable item comments.
- E.3.b The NRC supervisor WILL review and approve each comment that would require the ficensee ta rework a NRC-validated question. (Previously used test items.)
- es..a,-*
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Training Managers Conference
- E.4
- Att.1
- Farm 401-7
- Farm 401-9 Changes & Clarifications to ES-401, Part VI Final validation al examination after incorporating changes is recommended bUt t!Q! required.
Describes an acceptable sampling methodology far systematic selection far the written outline.
Modified version of this farm provides blanks ta record test item count far reuse from the last examinations, tile source of the questions and the cognitive level far the questions far the examination.
Written examination Review Waruheel. Used ta keep track al sampled questions.
e ES-.01-Fann Es-.01-7 II Qualily~'I iaca1cv*
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Training Managers Conference Changes & Clarifications to ES-402. Part I ADft.1IN1STERING INITIAL WRITTEN EXAMINATIONS
- C.1.a The licensee has to maintain sec:urily of the examinations.
- C.1.e The 6censee may use maelline-gradable sheets but not required.
- C.2.a The ticensee is aUowed to administer an NRC developed examination.
t!
- C.2.b During a licensee administered written exam, tl'le NRC MUST be on site or available by phone.
After NRC approval, tl'le wrillen exam may be administered any time within 30 days of Ille operating test.
Training Managers Conference Changes & Clarifications to ES-402, Part II ADMINISTERING INITIAL ~!TIEN EXAMINATIONS
- 0.4.d New time timit for the written 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 PRIOR NRC approval. TIie new time limit should not ctlangetiieoevelopment process.
- E.4 Licensee should submit formal comments within 5 working days aftertl'le wrillen examination is administered.
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Training Managers Conference
- Changes & Clarifications to ES-403 GRADING INITIAL SITE-SPECIFIC WRITTEN EXAMS
- C. 1.b If NRC developed, licensee nas responsibility to submit comments c:onceming changes to the examination.
- C.2.b NRC may allow the licensee to machine grade a NRC developed written examination.
- D. 1.a Do NOT delete any question or change an answer without a valid reference. Unreasonable or unstated assumptions do not justify a Change.
- 0.2.a Copy each applicant's answer sheet. and set aside. Do !!!QI mark on the original untU all comments are fmaliZed.
- D.2.d If you decide to share PRELIMINARY grades do so wi1h caution.
The NRC MAY NOT accept all the ticensee's changes.
Training Managers Conference Changes and Clarifications To Appendix 8 Written Examination Guidelines, Part I
- C.1.a KIA references are required but Leaming ObjeClives are~-
i This is II check and balance on the facilities training program.
- I
- C. 1.b Make sure the question matches the intent of the KIA.
- C.1.c Discrimination validity is defined. *_.the key purpose of any test item is to assess important K/As at a level that distinguishes between safe and unsafe applicants.*
Implementation requires subjeClive judgement in construcling the stem and distractors.
Training Managers Conference Changes and Clarifications To Appendix 8 Written Examination ~uidelines, Part II
- C.2.a Multiple Choice questions which require the "MOST CORRE Cr answer are !!!QI allowed. Use a procedural reference!
- C.2.f All the information in the stem should be relevant. {Don't play find the rock.) Don't add secondary pieces of information in the stem that are not relevant, in order to make the question took more difficult.
- C.2.n Use of generically correCI answers is allowed. but the stem needs to be written such that the stem makes them clearly incorreCI.
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ES-501 INITIAL POST-EXAMINATION ACTIVITIES
- 0. 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 records defined.
- New letter for delayed results.
- C.1 No changes to facility requirements.
- 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 written exam validity following post-exam comments.
- 5% changes/deletions-+ facility explanation.
- 10% deletions-+ evaluate adequate sample.
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e ES-501
- 0.1 Facility management exam reviews.
- Supervisor or manager shall confirm quality of grading is licensee graded written and sign QA check sheet. Used to be Mauthorized facility representative.n
- Signed QA form represents facility senior management concurrence with individual and collective exam results.
- 0.2 Chief Examiner reviews.
- No post-exam change will be accepted without a valid plant reference. Uncontrolled lesson plans are not acceptable.
- Verify answer key used as template or to machine grade written exam is accurate.
- Independently review every borderline written exam (78-82%).
- D.3 NRC management review.
- Pass letters for applicants y.,ho passed exam but licenses are being withheld.
- If pass written exam with BO-B1 % and another applicant fails, will hold 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 memal condition, and up to date in requal.
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- If > 3 months pass, advise licensee to properly activate license per 1 D CFR 55.53(f)..
- E.1 and E.2 No significant changes.
- 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.
- Factual description of test item changes including type and number of psychometric enhancements made.
- Conclusions regarding adequacy of facility proposed exams are not required and should only be considered if have a programmatic issue.
- Any delay in administering the exam and the reason, and any extensions of the written exam time beyond five hours.
- Any exam security issues/incidents.
- All simulator deficiencies encountered while preparing or conducting.operating tests will be documented in Simulation Facility Report.
- Generic comments submitted by licensee regarding exams or the process are welcome and will be included in exam report. These do not require regional response or resolution.
- Region will ensure SRO upgrade applicants lhat fail exam still comply with 10 CFR 55 before resuming RO duties.
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e ES-501
- PDR records will include 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.
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.t ES-502
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PROCESSING REQUESTS FOR ADMINISTRATIVE REVIEWS AND HEARINGS AFTER INITIAL LICENSE DENIAL D. Charles Payne August 13, 1999 ES-502
SUMMARY
OF CHANGES
- Reorganized to remove-detailed sample letters and administrative review procedures.
- New section noting expectation of facility licensee support during appeals.
- New section to better define NRC responsibilities.
- Administrative review process streamlined.
- C.1 Applicant responsi;>ilities. No changes.
- Has 20 days to act on proposed denial. Has 3 options:
- 1. Do nothing.
- 2. Request reconsideration.
- 3. Request a hearing.
- If application denied because of training or experience, can reapply when corrected.
e
- C.2 Facility licensee responsibilities. New section.
- 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.
- C.3 NRC responsibilities. New section but no new responsibilities.
- Splits out our responsibilities from mechanics of the review process.
- Application denials will be processed per 0.1.
- Admin reviews will be processed per 0.2.
- Hearings will be conducted per 1 O CFR 2, subpart L.
- 0. 1 Application denia! admin review.
- Not many have occurred in Region II. But be cautious of potential outcomes should one be required.
- HQ generally will complete the review within 60 days.
- Since draft applications are not due until 30 days before exam, any issue with eligibility JTIOSt likely will result in the applicant missing the scheduled exam.
- 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
e Is it an acceptable practice to readminister an identical examination to separate crews that have been separated in time over the finite testing period of the biennial written exam?
MAJOR ISSUES REVOLVING AROUND REPETITIVE USE OF TESTITEMS lESTING EFFECTIVENESS
> Do you have a testing practice that measures up to sound and accepted principles of testing?
> Are your examination conditions (size scope, discrimination quality) relatively uniform among crews.
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DEFINITIONS
- . DI:SCRIMINATION VALIDITY -
- The ability to discrirrrinate or to make sane
- 1 distinction along a continuum of examinee perfonrumce to detennine whether or not your operatozs have sufficiently 'mastered" the lmowledge, skills, abilities, and other attributes to perfonn their jobs.
- PREDICTABILITY OF A TEST -
- Toe ability to forecast or anticipate the test items*
- I or topics that will appear on an examination.
- Previously administered test items reduce examination integrity because examination discrimination is reduced.
- When the bank of items is known or anticipated prior to the examination, the exam is highly predictable. Discrimination is reduced because the a,gnitive level at which the examinees are tested oould decrease to the simple recognition level.
- To assume that the capability for items within an examination to discriminate, over time, in the same manner as those items discriminated on the first and second examinations is naive:
QUES;TION
-~ How does excessive repetitive use of test items over a short inte*rval of time affect examination validity ?
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- If the examinees know or can anticipate the precise and limited pool from which the test items will be drawn, they will tend to only study "from that pool and may likely exclude a larger domain of job knowledge.
- When high percentages of test item duplication takes place (e.g., >50°/o), the discriminant validity of the examination comes under question.
- Successive administrations of the same or closely similar'examinations to different crews over the period covering the biennial written exam raises the potential for compromising examination integrity.
GOAL
- Achieve uniform testing *conditions among crews as best as can reasonably be achieved so that the exam will be a reliable tool for assessi~g operator competence.
ACCEPTABLE PRACTICE
~ To minimize the potential of reduced discriminant validity, a50% portion of any readministered examination should consist of a replacement of modified or new items of like-kind content, psychometric attributes, and difficulty levels. Moreover, when items are to be repeated among successive crews, they should be repeated in a distributed manner and approximately equally over all previous exams so as to reduce predictability of a disproportionately large number of item coming form the most recent examination.
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SUMMARY
- Successive administrations of the same biennial requalification examination to different crews undergoing the~ requalification training is considered unacceptable. This would seriously question the discriminant validity of the exam.
- When the content to be tested becomes h~hly predictable, and the boundaries ofwhatwdl likely be tested are kn<M'll to the candidate, then the candidate will likely prepare ONLY to that level demanded by the examination.
- Improper testing practices will likely lead to an erosion of knowfecige and long tenn decline in operator performance; WHY YOUMAYASK?
>- When testing is diminished in level or ommitted in kind, knowlege degradation I
occurs.
,. >- The subtle but important coercion implicit in preparation for an examination is lost.
>- Attention will be focused on what leads to visible success for a candidate.
>- The loss of specific content area study can result in knowlege gaps that cause operator errors.
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ES-601/602 CONDUCTING NRC REQUALIFICATION EXAMINATIONS
- NO SIGNIFICANT REV. 8 CHANGES
- REACTIVE INSPECTION/ EXAMINATION
- SCOPE DETERMINATIONS BASED ON:
. o PLANT PERFORMANCE o INSPECTION PROGRAM RESULTS o INITIAL AND REQUAL RESULTS
~o~O_T_H_E_R_F_A_CT_O_R_S~~~~~~~~~. i ES-601/602 CONDUCTING NRC REQUAL IFICATION EXAMINATIONS
- NRC CONDUCTED OPERA TOR REQUAL EXAM COMPOSED OF THREE PARTS:
TWO SECTION OPEN-REFERENCE WRITIEN 0
PLANT ANO CONTROL SYSTEMS 0
ADMINISTRATIVE CONTROLS/ PROCEDURAL LIMITS.
WALK-THROUGH EVALUATION DYNAMIC SIMULATOR ES-601/602 CONDUCTING NRC REQUALIFICATION EXAMltijATIONS
- EVALUATION OF REQUAL PROGRAM AND OPERA TORS o MINIMUM 12 OPERATORS REQUIRED o 3/4 OF OPERATORS MUST PASS EXAM o 2/3 OF THE CREWS MUST PASS THE SIMULATOR EXAM i i v
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Licensed Operator Requalification Inspection Procedure 71111 REACTOR SAFETY-INITIATING EVENTS, MITIGATING SYSTEMS, BARRIER INTEGRITY 1 INSPECTION OBJECTIVE
.
- To independently gather baseline inspection indicators to determine whether licensee performance meets the following cornerstone objectives:
- Initiating Events: To limit the 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.
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e REQUALIFICATION CORNERSTONES
- Mitigating systems (75%)
- Barrier Integrity (25%)
- Emergency Preparedness Inspection Bases
- Inspection supports cornerstones 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 rjsk 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:
- Procedure quality and human performance which are both key atfrieutes of the Mitigating Systems cornerstone for which there are no performance indicators.
- Human performance which is also a key attribute of the Barrier Integrity cornerstone for which there are no performance indicators.
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FY 2000 REGION Il EXAMINATION SCHEDULE R
. d A 6 1999 ev1se Ul11JS[
Date Facility Number of Type of Activity Chief Examiner Examination Author Docket No.
Candidates Catawba 3 RO Retake R. Baldwin Licensee 9127/99 50-413 1 SROU 10/4/99 Hatch Initial Prep C. Payne 50-321 10/18/99 Hatch 10 SRO!
Initial C. Payne NRC / Licensee 11/1/98 50-321 2SROU 11/8/99 Crystal River Requa! Inspection G. Hopper 50-302 11/6/99 Browns Ferry Requa! Inspection.
C. Payne 50-260 11/29/99 Sequoyah Requa) Inspection L. Mellen 50-327 11/29/99 Vogtle I
Initial Prep R. Baldwin 50-424 12/6/99 Si. Lucie Requa! Inspection G. Hopper 50-335 12/13/99 Vogtle 1 RO Initial R. Baldwin NRC 50-424 3 SRO!
2SROU 1/10-2/14/00 Farley Requa! Inspection TBD 50-348 l/10-2nt00 Turkey Point Requal Inspection TBD 50-280 1/24/00 St Lucie Initial Prep TBD 50-335 1/31/00 Brunswick Initial Prep G. Hopper 50-325 2/7/00 St Lucie 5 RO Retake TBD 50-335 I SRO!
2SROU 2/ - 3/00 North Anna Requa! Inspection TBD 50-338 2/14/00 Brunswick 12RO Initial G. Hopper NRC 2/21/00 50-325 4 SRO!
- 4/24/00 Farley Initial Prep.
M. Ernstes 50-348 4/24/00 McGuire Initial Prep C. Payne 50-369 5/8/00 Farley 6RO Initial M. Ernstes Licensee 5122100 50-348 6SR0I 5/8/00 McGuire 6RO Initial C. Payne Licensee 5122100 50-369 2SROI 5SROU 5/29/00 Browns Ferry Initial Prep L. Mellen 50-259 6/12-7/14/00 McGuire
, Requa! Inspection TBD 50-369
.Pate Facility Number of Type of Activity Chief Examiner E:uminarion Author Doc:ket No.
Candidatei::
6/12/00 Browns Ferry lORO Initial L. Mellen NRC 6/26/00
.. 50,259 3 SRO!
3 SROU
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6/26/00 Oconee
<;O-"?'-Q Initial Prep G. Hopper 7110/00 Oconee SRO Initial G. Hopper Licensee 7/17/00 S0-269 2 SROI 3 SROU 7/24/00 Summer Initial Prep M. Ernstes S0-395 7/24/00 Sequoyah Initial Prep C. Payne 50-327 8/00 Hatch
- Reaual lnsoectiori TBD smoo Summer SSROU Initial M. Ernstes NRC 50-395 smoo Sequoyah SRO Initial C. Payne Licensee / NRC 50-327 4~ROU 3 SROI 8/14/00 Crystal River Initial Prep TBD 50-302 8/28/00 Crystal River 3RO Initial TBD Licensee 9/11/00 S0-302 3SROI
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3SROU 8/28/00 North Anna Initial Prep R. Aiello 50-338 8/28/00 Surry Initial Prep R. Baldwin S0-280,
9/18/00 North Anna 7RO Initial R. Aiello Licensee / NRC 9125/00 S0-338 1 SROI 3 SROU 9/18/00 Surry 8 RO Initial R. Baldwin Licensee / SRC 9/25/00 50-280 2SROI 3 SROU FY2001 11/13/00 St. Lucie Initial Prep C. Payne S0-335 1 i/13100 Turkey Point Initial Prep G. Hopper 50-250 11/27/00 Harris lnitia I Prep M. Ernstes 50-400 12/4/00 St. Lucie 4SROI Initial C. Payne Licensee 50-335 5SROU 12/4/00 Turkey Point 16 Initial G. Hopper NRC 12/18/00 50-250 12/11/00 Harris 3RO Initial M. Ernstes Licensee 50-400 2 SRO!
3SROU 3/26/0i Robinson 7RO Initial TBD TBD 50-261 5SROU
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V Date Facility Number of Type of Activity Chief Examiner Eumination Author Docket No.
Candidates 4/01 Vogtle 16 Initial TBD NRC
- . S0-424 4/01 Catawba 18 Initial TBD Licensee S0-413 S/01 Wans Bar 7RO Initial TBD Licensee S0-390 3SROI 6SROU
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TRAINING MANAGERS CONFERENCE August 12-13, 1999 COMMENTS/QUESTIONS Written Examination Questions:
- 1.
The most common issue raised by Hot License Candidates and Requa! license holders surround the issue of "trick questions" and operator written exams not being a fair test of. operator knowledge.
- 2.
If INPO creates a national initial licensed operator exam bank, will the NRC consider the INPO ba*nk 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 difficulty of 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 difficulty his gone beyond reason and is impacting the requal program.
People are not willing to 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 utility instructions 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.
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- 10.
If.the utility is 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 will not work.
- 11.
In 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 frciri, the bank {rather than 50% new questions), assuming the bank was an appropriate size and security concerns could be solved.
- 12.
The examination process** seems to be getting harder as com~ared to a few years ago.
- 13.
Once we use a comprehensive level question, does it become a knowledge base questions the next time we use it.
- 14.
We may want to have an exam writing workshop.
- 6.
Operating Examination Questions:
- 1.
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.
- 2.
Current subjectivity on what is a discriminatory JPM with the removal of the questions.
- 3.
Need region workshops to calibrate us on future JPM direction.
- 4.
Why can't the selection of JPM's for the license exam be driven by the SAT process and KIA value? "Low discriminatory valven is a euphemism for "too easy" and as a result, the difficulty of the exam is racheting up to an unreasonable level. This is contrary to the NRC stated goals.
- 5.
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.
- 6.
Operating Exam - Section "A" Admin. (Category): 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 error! 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.
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3 C.
Licensed Operator Experience Questions:
- 1.
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 if you have SAT based program?
- 4.
"Responsible" power plant experience 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 prior to them entering a license class.
D.
SAT Program Questions:
- 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 process? How familiar (knowledgeable) are the headquarters management on the SAT process? VVhat kind of training have they received?
E.
Reactivity Manipulation Questions:
- 1.
10 CFR 55.59-the use of SAT based program vice regulatory based programs. Why do you have to track individual control manipulations if you have a SAT based program?
- 2.
"Control Manipulations" in Requa! - 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.
4 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
- provided in 1989 by T. Peebles, S. Lawyer, and others who provides us guidance. It appears that we are returning to the middle to early BO'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 another?
What constitutes a large change? 2) For LOCT - INPO's policy for tracking manipulation seems to be in conflict w/NRC requirement (INPO doesn't require tracking on individual basis).
F.
GFES Questons or Concerns:
- 1.
2000 GFES Dates: Licensee have developed schedules and allocated resources to participate in a April GFES. 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. If implementation occurs in
- FY 2000 and exams are given in February, June, and October (as proposed),
unnecessary burden on these utilities could result.
G.
Miscellaneous Questions:
- 1.
ES-302 - General (D.1.j) - What determines if a 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 ~etter 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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