ML18153B051
| ML18153B051 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 08/30/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Gallo R Office of Nuclear Reactor Regulation |
| References | |
| 94-493, NUDOCS 9409080292 | |
| Download: ML18153B051 (6) | |
Text
r i.
I e
e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA. 23261 Mr. Robert M. Gallo Chief, Operator Licensing Branch Mail Stop OWFN 10 D-22 August 30, 1994 United States Nuclear Regulatory Commission.
Washington, D. C. 20555
Dear Mr. Gallo:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 Serial No.
NL&P/ETS Docket Nos.
License Nos.94-493 50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 UTILITY DEVELOPMENT OF INITIAL LICENSING EXAMINATIONS PROPOSAL On June 29, 1994, Dr. Terry M. Williams of my staff met with the Operator Licensing Branch in Region II to informally discuss a proposal for utility developed initial license examinations. The attachment to this letter provides a description of our initial license development proposal along with a justification.
I would like to offer Surry and/or North Anna Power Station as pilot sites for the purposes of implementing this proposal. Surry is conducting an initial licensing class
'*J!-'.',-r-1d'.1 ~';'~~**,1." j-i IJl;-"~I,.. "' '4 n0i::,..+ **1~i,-.h +in°!~ t~l:' ~*qc is S!"h~rfr 11~,i tQ ad,nini!=;fer
,./, -- * ***'"'*-* - initi~l *Ax::imin~tion!;.
- North Anna will commence an initial lict:::nsing class in..1anuary, 1995, with a scheduled compiet1on date or January, i ~36. i, yuu \\;ui1(,Ji' livit;, vu; proposal, I will designate members of my staff to work closely with the assigned Chief Examiner to develop and refine this process.
This action is being submitted as part of our Cost Beneficial Licensing Actions {CBLA) program and complies with the NRC guidelines for consideration as a CBLA.
Should you have any additional questions or concerns, please contact Dr. Terry M. Williams at (804) 273-2701.
Very truly yours,
(_;~-~ r?0~..I~~
7, ____ n f""\\'L.-~"'."'~*,.....
Senior Vice President - Nuclear Attachment t I '! '
., e."\\
(
'"' ~1*,.., r,
) r:: \\) \\J -l-l,J, 9409080292 940830 PDR ADDCK 05000280 V
cc:
'(""tJnite{fSlates]~JucleafRe-gplatory-Commission-7 Attention: Document Control Desk*
Washington, D. C. 20555 United States Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. Thomas Peebles, Chief Operator Licensing Branch United States Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. Eugene V. lmbro, Director Regulator Review Group/CBLA Programs United States Nuclear Regulatory Commission Washington, D. C. 20555 Mr. M. W. Branch Senior Resident Inspector Surry Power Station Mr. R D ~fl.~W~o--tAr
---*,.. * *** -* * *SeniorHesident*lnsoector i>Jorth Anna Power Siacion
".... : -, :.~.
PROPOSED REVISIONS TO THE PROCESS FOR NRC INITIAL LICENSE EXAMINATIONS Virginia Power recommends the following changes to the NRC initial license examination process:
- 1.
The utility will be responsible for developing the Operating Test [Job Performance Measures (JPM) in support of Plant Walkthrough and Simulator Scenarios] and Written Test in accordance with NUREG-1021 &
BR-0122 requirements.
- 2.
Facility representatives who acquire specific knowledge of the initial license examination material will be required to comply with the "Examination Security Agreement" as described in NURE(3-1021, Section ES-201.
- 3.
The NRC's Chief Examiner will review and approve the Operating Tests and Written Test at least 4 weeks prior to examination administration.
- 4.
- The NRC will administer the examination (Operating and Written) to each licensee with minimum utility interface. The utility will provide support during the simulator scenarios by initial simulator setup, running of the simulator for each scenario and responding as outside plant operators as described in NUREG-1021, Section ES-302.
- 5.
The NRC will grade each area and make the ultimate pass/fail determination as described in NUREG-1021, Section ES-303 & 403.
Recommendation 1:
Standard:
The utility will develop initial exam material.
IAW ES-301 (Operating Test) and ES-401 (Written Test) &
BR-0122 (Examiner's Handbook) Criteria Operating Test Development The operating test to the extent applicable, will require the applicant to demonstrate an understanding of, and ability to perform, the actions necessary to accomplish a representative sample from among the 13 items identified in 10 CFR 55.45(a).
These examination materials will be developed in accordance with the criteria
_..,.,;,"*-.. * :~ r-:~ "'""' r:::>-~---:",.. I ;,...,_...,...--..:-'."'t T.,f"",+.,. I~* f :""",--,....,..,..--.li,..~-.*t"!' ~* p.,...,.,",..
..l
... ;*. ~:-,*. '.::.,* *.:.:.. ~.:.:::.~-.i..~.. :,..,,:,:.:.'!...:,'.**:*~-=-*-* !.:.:}.... _:. -.:*.
.. 1 *: '.
- Reactor Faciiitie$:; which captures the requirements of 1 O CFR 55.45(a) & (b).
Recommendation 1 : {continued)
Written Test Development The content of the written licensing examinations for ROs and SROs is dictated by 1 O CFR 55.41 and 55.43. Each examination shall contain a representative selection of questions on knowledge and abilities (K/As) needed to perform the duties at the desired license level.
The written exams will be constructed in accordance with the criteria stated in NUREG/BR-0122, "Examiner's Handbook for Developing Operator Licensing Written Examinations."
Recommendation 2:
Standard:
Security Agreement Examination security requirem~nts will be complied with.
IAW ES-201, Preexamination Activities for Initial Examinations at Power Reactors Criteria The training staff who develop the proposed NRC examination must meet the requirements of the security agreement as stated in Form ES-201-2, Examination Security Agreement.
Recommendation 3:
.: -". --~.***/-..e. ***t,:-µ~,"<J..A<'>-,," t.. **_ -~...-*~ * ****-'-" *t" ~.. "c*-,i. *) **,, -~* *_,,.*....
,.~--~
Examination Approval The NRC will review and approve examination material. 4 weeks prior to administration.
fri!"'. !ni+i?.!
The chief examiner will make arrangements with the facility licensee to review the initial licensing examination before they are administered. This review will normally be conducted 4 weeks before the week in which the examinations are scheduled and should include all sections of the licensing examination (Le., the written examination(s), the simulator scenarios, and the walkthrough JPMs).
The NRC chief examiner or his designee will review the examination material and make his recommended changes and/or comments to facility representatives.
The examination material will be revised accordingly based on a mutual consensus betvyeen the chief examiner and facility representative.
~. :;.,~,
e e
Recommendation 4:
The NRC will administer the initial licensing examination.
IAW ES-302, Administering Operating Tests to License Applicants at Power Reactors, & ES-402, Administering Written Examinations at Power Reactors Criteria Standard:
Examjnatjon Admioistratjon Initial licensing examinations will continue to be administered to license applicants by NRC personnel in accordance with NUREG-1021, Section ES-302 (Operating Test) & 402 (Written Test). The facility will continue to provide facility operators in support of the simulator portion of the operating test.
Recommendation s:*
The NRC will grade examinations and make pass/fail determination.
Standard:
IAW ES-303, Documenting and Grading Operating Tests Administered at Power Reactors, & ES-403, Grading Written Examinations at Power Reactors Criteria Examination Grading The chief examiner shall evaluate and grade the applicant performance during the Operating Test portion of the license examination in accordance with NUREG-1021, Section ES-303. The written portion of the examination will be graded in accordance with NUREG-1021, Section ES-403.
Any inaccurate or ambiguous examination material (simulator scenario,
__ '.'.""" ~-:
'.~:- *.-.. ~'.f:--i:: tqt~--~...i=--:'.".'*.*ered ~~~:-;~,,, tr~ ar?_~inQ,:,f the
- .,,,._;,::,,,..,.* -.co:a,-; '
0
' 'dY'~*n,ir,qti'fyrf'tVill'h~'ftl'rl-*h'l=!*~k: to':thA* I 1ti1"1fi fnr-'COrre/f1on" S:..,,,-_._ ****- -
. I' \\* 1
e e
JUSTIFICATION FOR REVISING THE PROCESS FOR NRC INITIAL LICENSE EXAMINATIONS
- 1.
The same justification used for utility administered requalification examinations (Federal Register Vol. 59 No. 27 dated February 9, 1994) can be used to justify utility developed and NRC administered initial examinations. Existing regulations have established a high standard of licensee performance. NRC examiners are duplicating tasks that are already required of, and routinely performed by, facility licensees.
- 2.
Operator training programs have been developed over the years utilizing the SAT approach. These programs are maintained up-to-date and must undergo INPO accreditation every four years. Surry and North Anna have just completed the third round of Accreditation Review with no findings for all of the Operations Training Programs.
- 3.
Virginia Power has been developing similar license examinations (audit examinations) as a means of screening potential license candidates prior to NRC examination. The quality of our examination and screening process is evident based on our results in recent NRC administered exams. (1991 through 1993 the number of candidates and the number licensed - NAPS 38/38 and SPS 34/31)
.14.
Ti...~ C!.'r'."-?~.t "'rl'.':~"'"'.'.~ f.~!' 1'."'"~l~-,1~,: in)ti?I !icpn~o o"'.'~"linati()n~ is
c.,.......,.,, *.,....... * --~
,,. '"inefficienHor both the-utilitv..,and the NRC.. The-use of c0ntractu(s:oy the,,,. __ ". -
NRG to deveiop exc:tmir,atiom:i is nui c;ot;t t:1r1t:,Ciive. *r,*;t# uidii.f (;Bi'i c.1*ea~~
an equivalent quality examination at lower cost. Furthermore, this change in the initial license examination development process is administrative in nature and will not impact nuclear safety.
- 5.
The proposal represents a Cost Beneficial Licensing Action consistent with NRC guidelines. In 1993, actual NRC contractor charges to support initial examinations at North Anna was $104,165 and $87,472 at Surry for a total of $191,637. We estimate that an average of $67,500 per station could be saved for each initial license class by implementing the proposed approach to initial licensing examinations.