ML19249E716
| ML19249E716 | |
| Person / Time | |
|---|---|
| Issue date: | 07/30/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19209A091 | List: |
| References | |
| FOIA-81-131, REF-10CFR9.7 SECY-79-330E, NUDOCS 7910020256 | |
| Download: ML19249E716 (74) | |
Text
,
s T,
COMMISSIONER ACTION July 30, 1979 For:
The Commissioners From:
Harold R. Denton, Director Office of Nuclear Reactor Regulation 1
Thru:
Executive Director for Operations
Subject:
QUALIFICATIONS OF REACTOR OPERATORS Purcose:
To obtain Commission action regarding improvements in the Operator Licensing Program.
Category:
This paper covers a major policy matter.
Resource estimates, Category 1, preliminary.
==
Introduction:==
In a memorandum from Samuel J. Chilk to Lee V. Gossick
~
dated April 30, 1979, NRR was requested to conduct a thorough review of current NRC requirements and guidance to licensees for qualification of reactor operators.
It was further requested that their training and qualifi-cations for off-normal and accident conditions should be particularly addressed.
Finally, the staff was requested to review licensee practices for training and testing of operators.
The memorandum also requested information on seven specific items.
This information has been provided in separate information papers, SECY 79-330 through SECY 79-3300 and in a memorandum from H. K. Shapar to Comissioner Bradford dated April 24, 1979.
On May 15, 1979, GA0 issued a report to Senator Schweiker regarding the Operator Licensing Program.
Tha report did not make any recommendations for changes to tr,e prcgram, but raised several questions regarding tae program.
This paper will also address those questions.
Discussion:
We have conducted a detailed review of the Operatcr Licensing Program.
The results of the review, answers to tne questions raised on the GA0 report and options to the present program S
r9,
are addressed in Enclosure 1.
The purpose of tnis paper b
is to summarize the results and present our recommendations j
Y for your consideration.
Mbk""
N sh g
s The Commissioners.
Eligibility and Training Eligibility to sit for a license examination consists of education, experience, and training requirements.
ANSI N18.1-1971 entitled, " Selection and Training of Nuclear Plant Personnel," and Regulatory Guide 1.8,
" Selection and Training of Personnel," provide guidance regarding education, experience, and training for appli-cants for operator and senior operator licenses.
A revised ANSI N18.1 was issued as ANSI /ANS 3.1-1978.
A revised Regulatory Guide 1.8 endorsing the standard has been issued for comment.
The ANS-3 Subcommittee is revising ANSI /ANS 3.1-1978 based on recent events.
The NRC has requested additional public comment on Regulatory Guide 1.8 and the endorsed standard.
In addition, NUREG-0094, "NRC Operator Licensing Guide," provides additional guidance regarding the operator licensing program.
We believe that programmatic changes, as indicated belcw should be made:
Recommendations 1.
The experience requirements regarding power plant operations for senior operator applicants should be increased.
Adoption of Option 1 is recommended to achieve this.
2.
Establish requirements for applicants for senior operator licenses after the plant achieves criticality to be licensed as an operator for six months.
Option 2 is recommended to achieve this.
3.
Establish requirements for participation in plant shift coerations prior to licensing.
Option 3 is recommended to achieve this.
4.
Establish requirements that simulators be used in training programs for hot applicants.
Option 6 is recommended to achieve this.
5.
NRC should audit training programs more closely, in-cluding administration of certification examinations.
Option 5 that specifies acministering some of the certification examinations is recommenced ratner tnan Option 4 that specifies acministration of all the certification examinations.
6.
Develop el dbility recuirements for instructors.
Option 7 is recommended as a first step to achieve this.
1075 102
The Commissioners Ooerator Recualification Procram Our review of the Licensed Operator Requalification Programs results in the following recommendations:
Recommendations 7.
In addition to the cresent operator requalification program requirements, all licensees should be required to participate in periodic retraining and recertifica-tion on a full scope simulator representative of their facility.
Adoption of Options 8 and 9 are recommended to achieve this.
8.
Establish more explicit requirements regarding exercises to be included in simulator requalification programs.
Adoption of Option 10 is recommended to achieve this.
9.
An increased level of confidence in the effectiveness of requalification programs should be provided by NRC examiners administering annual requalification examina-tions. We recommend Option 12 that provides for administering some, rather than all requalification examinations as indicated in Option 11.
NRC Examinations The NRC examiners administer both written examinations and oral / operating tests to evaluate the knowledge and under-standing of applicants.
The written examination for the operator consists of seven categories.
An individual passes the examination if he receives an overall grade of 70%.
A grade of less than 70% in a category is not grounds for failure.
The written examination for the senior operator ccnsists of the above seven operator categories plus an additional five category written examination.
An individual passes the examination if he receives an overall grade of 70%.
The oral / operating test at nuclear pcwer stations consists of both an oral examination during a plant walk-through and an actual defnonstration at the reactor console during a reactor startup, if the applicant has not been to a simulator.
Most applicants have attended simulator courses.
Therefore, NRC examiners do not normally witness accli-cants nanipulating the controls.
10/b 105
The Commissioners The scope of the oral and operating test consists of testing the applicants' ability to (1) read and interpret the control instrumentation, (2) manipulate the control equipment, (3) operate other facility equipment, and (4) determine his knowledge and understanding of radiological safety practices and radiation monitoring equipment.
We have given reconsideration to the passing grade.
In addition, we have conductad a survey of the written exams given during the. period of January 1977 through March 1979.
The purpose of the survey was to assess the impact of revised criteria for passing the examination as applied to those examination results.
Our recommendations are as follows:
Recommendations 10.
The scope of the written examinations should provide increased emphasis on understanding of thermodynamics, hydraulics, and related matters.
Adoption of Option 13 will accomplish this without changing the format of our examinations and is recommended rather than Options 14 and 15 that change the format.
- 11. Applicants for operator and senior operator license should be examined at a nuclear power plant simulatcc.
Option 16 is recommended to achieve this.
12.
Senior operator applicants who hold operator licenses should be required to take an oral test as well as the written examination.
Adoption of Option 17 will achieve this.
13.
The passing grade of written examination should be increased to 30% or greater overall and 70% or greater in each category.
Adoption of Option 18 will achieve this.
14.
NRC should inform facility management of the results of each examination so that remedi M training may be instituted, as applicable.
Adoption of Option 19 will achieve this.
1075 104
The Commissioners Nuclear Power Plant Simulators We reviewed the requirement regarding simulators and their use in training programs.
We recommend the following:
15.
ANSI /ANS 3.5-1979, " Nuclear Power Plant Simulators,"
should be reviewed and revised and a Regulatory Guide reflecting NRC endorsement be developed.
Adoption of Option 20 will achieve this.
OLB Examiners We reviewed the present staffing and training of the Operator Licensing Branch personnel.
The Operator Licensing Branch employs nine full-time examiners and 22 part-time examiners.
The primary function of an examiner is to develop, prepare, and administer written, oral, and practical examinations to operator and senior operator applicants for critical, research, production, and utilization facilities.
In addition, he reviews safety analysis reports as to a facility license applicant's proposed method of training, requalifying, and evaluating plant staff members, and proposed methoc of procedural control of operations.
The examiner also audits the requalification program examinations at the operating facilities.
Individuals seiected as full-time NRC examiners have many years of nuclear operating experience at National Laboratory reactors, commercial power plants, or military reactors.
Several years of this experience has involved training of operators.
Individuals selected as part-time examiners have back-grounds similar to the full-time examiners, except that several have had actual operating experience only at research reactors; although all have studied power reactor design and characteristics.
The staffing objective of OLB has been to provide per-manent personnel to accommodate about 80% of the expected workload and part-time personnel for the rest.
Thus, the availability of part-time talent has permitted the program to efficiently and expeditiously meet workload fluctua-tions between 30% ar.d 120% of normal while keeping permar.ent staff active.
Also, the impact of loss of permanent staff members can be eased by use of part-time examiners.
However, during the past several years, part-time examiners have been administering uo to 40% of the examinations.
10/5 10b
,3 gQh b
s The Commissioners Recommendation 16.
The present part-time examiners should be augmented by utility and vendor training personnel and formal training programs should be instituted for examiners.
Adoption of Options 21 and 23 will achieve this.
We also considered eliminating all part-time examiners.
We believe this would be detrimental to our program.
We recommend that Option 22 not be adopted.
Resources Estimates:
The present resources for the Operator Licensing Branch consists of one Branch Chief, nine full-time examiners and 22 part-time examiners.
Two secretaries complete the branch complement.
We expect that there will be 12 full-time examiners and 22 part-time examiners at the start of FY 1980.
Our forecasted manpower requirements are based on the following assumpticis:
1.
Full-time examiners will administer 80% of the examinations.
2.
Operating tests will be administered at simulators.
3.
NRC examiners will administer some of the certi-fication examinations and requalification examinations.
'J 4.
NRC will administer examinations to instructors.
~
5.
Examiners participate in additional retraining programs.
During FY 1980, it will be necessary to recruit four additional full-time examiners bringing the total number 3
}
of examiners to 16 at the start of FY 1981.
The OLS i
full-time examiners will increase by one to two examiners i..
until 23 full-time examiners are employed in FY 1985.
During this same period, we will require about two years of technical professional r:n years of private consultant 3'i manpower each year and contractor consultant costs from
, ?.
the National Laboratories will increase from 5170K to
.e 5300K.
We will also require that an administrative
~
assistant position be provided and an additional clerk typist be added to the staff. provides the manpower requirement details.
10/5 106
The Comissioners Coordination:
The Office of the Executive Legal Director has no legal objection to this paper.
The TMI-2 Lessons Learned Task Force has concurred in this paper.
Scheduling:
This paper should be scheduled at an open agenda session.
[
Harold R. Denton; Director Office of Nuclear Reactor Regulation Enclosures.
1.
Review of the Operator Licensing Program 2.
OLB Manpower Requirements Comissioners' coments should be provided directly to the Office of the Secretary by c.o.b. Friday, Aucust 10, 1979.
Comission Staff Office coments, if any, should be submitted to the Ccmissioners NLT August 6,1979, with an information copy to the Office of the Secretary.
If tne paper is of such a nature that it requires additional time for analytical review and corrent, the Comissioners and the Secretariat should be apprised of when cocrents may be expected.
DISTRIBUTION:
Comissioners Comission Staff Offices Exec. Dir, for Opers.
Secretariat 10/5 107
ENCLOSURE 1 RESULTS OF A REVIEW OF CURRENT NRC REQUIREMENTS AND GUIDANCE TO LICENSEES FOR QUALIFICATION OF REACTOR OPERATORS 4
The requirements that reactor operators must demonstrate their qual-ifications and receive licenses from the NRC to perform their functions were established as a statutory requirement by the U. S. Atomic Energy Act of 1954.
Further, pursuant to the Act, the Code of Federal Reg-ulations, Part 50, Chapter 10, " Licensing of Production and L*tilization Facilities," provides that the controls of any reactor licensed under Part 50 shall not ce manipulated by anyone who is not a licensed operator or senior operator as provided in 10 CFR Part 55, " Operators' Licenses." Part 55 estastishes the procedures and criteria for the issuance of licenses to operators and senior operators and therefore governs the regulatory program of operating licensing.
A.
Types of' Licenses The Commission presently issues two types of licenses.
In general, anyone who manipulates reactor controls must be licensed as a reactor operator, and those who direct the activities of licensed operators must be licensed as senior reactor operators.
Practically speaking, the reactor operator in a power station would be the control room operator, ano One shif t supervisor would normally be the senior reactor operator. Herein, the two types will be referred to as
" operator" and " senior ocerator."
10/S I08
. B.
License Application and Eligibility Applicants for operator and senior operator licenses must submit a signed application to the Conaission pursuant to Section 55.10(a) of 10 CFR Part 55.
In addition, an authorized representative of the facility at which the applicant will be working must certify that the applicant has a need for the license, has completed a training program (supplying the details of such), and has learned to operate the reactor controls competently and safely. A report of medical examination of the applicant on an NRC form must also be submitted.
Eligibility of an applicant for examination is determined after receipt of the application.
However, in order to provide utility management with guidance regarding eligibility to be administered an examination, Subcommittee ANS-3, Reactor Operations, of the American ?bclear Standards Committee prepared a standard, ANSI N18.1-1971 entitled, " Selection and Training of Nuclear Power Plant Per-sonnel."
The standard has been endorsed by Regulatory Guide 1.8,
" Selection and Training of Personnel."
These documents provide guidance regarding edu ation, ex;erience and training for appli-cants.
In addition, Regulatory Guide 1. 70, " Standard Format and Content of Safety Analysis Peports for Nuclear Power Plants," provides guidance regarding information required in SAR submittals for training programs for the plant staff, including cperator and senior operator applicants. These plans are reviewed by the CL3 10/S 109
. staff using the criteria contained in NUREG-75/087, Standard Review Pl an, Section 13. 2, " Training."
Fi nally, NUREG-0094, "NRC Operator Licensing Geide," provides additional guidance regarding the operator licensing program.
The present operator licensing eligibility requirements include the following:
1.
Education a.
Operator: Higtr$chool graduate or equivalent.
b.
Senior Operator:
High-School graduate or equivalent.
There is presently no definition of " equivalent."
2.
Experience a.
Operator: Two years of power plant experience or its equivalent, provided that a minimtm of 1 year is at a nuclear power plant.
b.
Senior operator: Four years of respcnsible power plant experience, of which a minimum of 1 year must be nuclear power pl ant ex;erience. A maximta of 2 years of the remaining 3 years of power plant experience can be ful filled by academic or related tecnnical training on a one-forwone basis.
There is no definition for "respcnsible power pl ant experience."
iU/5 110
. C.
Minimtm Training for Applicants for Li:enses Prior to Fuel Loading (Cold Applicants)
Section 55.25(b) of 10 CFR Part 55 requires that individuals who apply for licenses prior to initial criticality must have extensive actual operating experience at a comparable reactor, as one requirement to be administered a cold examination.
An applicant meets the requirements of Section 35.25(b) provided:
(1) he has, or had, an operator's license at a comparable facility; (2) he has a certification of the necessary experience if the comparable facility was not subject to licensing (e.g., reactor operated by the Departnent of Defense); or (3 ) he has successfully canpleted an NRC approved training program that utilizes a nuclear power plant simulator.
It should be stressed that most trainees receive expericnce in excess of the simulator programs outlined herein to acquire the desired competence. Hewever, examinations are administered to individuals who meet these requirements.
Applicants with no previous nuclear experience are required to ccmclete the entire training program as indicated below:
Ind i v-icuals who have previous nuclear experience are factored into these programs as apprcpriate.
10/5 111 4
a
. Phase I - This phase is a basic fundamental course, including a 2-week laboratory course at a research reactor during which a trainee performs at least 10 reactor startups.
The time required to complete this phase is normally 12 weeks.
Phase II - This phase of the training consists of a design lecture series that is intended to faniliarize the trainee with the general design features of the NSSS and then that of F ' :. facility.
The time required is normally 6 weeks.
Phase III - This phase consists of observation of the day-to-day operation of a nuclear power plant and operation of a nuclear power plant simulator. The observation is under the direction of knowledgeable individuals and the trainee is required to observe a minimLm of opera-tions, surveillance testing, and radiation procedures as evidenced by a completed, previously approved chec kli st.
The time required varies from 1 to 2 months based on the overall training program that has been approved.
The cceratien of a nuclear power pl ant simulator must be conducted on one similar in design to the facility for wnicn the trainee will be seeking a license. The 10/5 112
. time for these programs varies from 2 to 3 months based on the overall training program that has been approved.
Approximately 3C% cf the simulator programs is devoted to abnormal and emergency procedures.
However, the NRC does not require that each individual be required to cope with a minimum ntaber of abnormal and/or emergency pro-cedures.
The minimtm Phase III time is 4 nonths of combined pour plant and simulator training in all cases.
The training must be administered consecutively and by one organization.
Phase IV - This phase consists of a combination of on-the-job training and classroom study at the site. The applicants participate in construction check-out activities, preoperational testing, procedure and technical specification writing and study of facility oriented reactor theory, core parameters and specific operating characteristics.
Usually the minimum time in Phase IV is 1 year. Approximately 2 aonths prior to fuel loading, the applicants return to the simulator for a 1-week refresher course.
~hese crograms are presently offered by the fcur principal vendors.
Utiiities that have or will purc' ase their own simulators will conduct these programs for individuals who will sit for " cold" examinations at future f acilities within their systems.
1(17S i15
. A unique feature of these programs is tiiat the vendors, training firms and utilities administer examinations at the completion of Phase III, that cert'ify that applicants have " extensive" attual operating experience. NRC examiners have conducted some certifica-tion exaninations for the first few classes to assure that the training programs were appropriate.
D.
Actual Licensee Training Programs for Applicants for Licensing Prior to Fuel Loading All cold training progams exceed the minimLm programs described above.
Many key staff personnel receive additional observation
~
training at operating stations to witness items such as fuel Icading and major maintenance activities.
Frequently, individuals with previous nuclear experience attend Phases II and III, even though there is no requirement that they do so.
Finally, almost all applicants attend Phase III, regardless of their previous nuclear experience.
Throughout the course of the training program, the trainees are administered quizzes and examinations.
Ceficiencies in their knowledge and understanding are corrected through special tutoring.
Individuals whose progress is consistently unsatisfactory are dropped frcm the program.
iU/b i14
. All trainees receive a final examination at the conclusion of the offsite training and again at the conclusion of the final onsite training program.
These examinations are similar in scope to the NRC examinations. The results of the first examinations are used to establish that the individuals have " extensive actual operating ex peri ence."
The results of the second examination are used to support management's certification regarding the ccmpetency of the applicants.
E.
Minimum Training for Applicants for Licenses After Fuel Loading (Hot Applicants)
In or. der to be eligible to sit for an examination after a facility achieves criticality, an individual must receive formal classroom training and on-the-job training. Training programs for hot applicants that utilize simulators are described below:
Individuals who participate in these programs have been enployed at the facility as auxiliary operators or as staff personnel.
The classrocm training consists of lectures on reactor theory, facility design, operating characteristics, normal and emergency procedures commensurate with the type of license for which the applicants will apply.
The mi n im um time required fcr this training is 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br />.
10/S 115
9_
~
The on-the-job training consists of training on shift during which time the applicants manipulate controls through five reactivity changes under the direct supervision of a licensed operator or senior operator.
Two of these manioulations may be reactor startups. However, the applicants usually perform the reactor startups on the simulators.
Tie on-the-job training must be at least 3 months dura-tion.
There are no specific NRC requirements regarding tasks to be performed other than the control manipulations.
The simulator course includes training in abnormal and emer-gency operations, as well as performing reactor startups.
The minimum time for this training is 1 week.
The final portion of the training program consists of a 40-hour review, including a written examination and oral test similar in scope to an NRC examination.
F.
Actual Licensee Training Prograns for Applicants fcr Licensing After Criticality All of the Utility Training Procrams meet these recuiremeHt~. -
s However, there are many variations on how the training programs are conducted.
10/b ii6
. The maximum time devoted to classroom training is 600 hours0.00694 days <br />0.167 hours <br />9.920635e-4 weeks <br />2.283e-4 months <br />.
On-the-job training varies up to 4 months.
The trainees at most plants are assigned to the training group for this training with no other concurrent duties.
These training programs normally require between 6 months and 8 months.
About 10 percent of the plants do not assign their people to full-time training. These people are trained concurrently with their normal shift work.
Normally, they will receive the lectures as they rotate on to the day shift and receive the on-the-job portion of the training on the back shifts.
Thei r training may be interrupted at any time for any reason. Con-sequently, some individuals wi'l require 2 years to complete the programs. As part of the training programs at tne facil-ity, and at the different vendor training centers, our review found the trainee spends about 25% cf his time on the off-normal, emergency and accident conditions that could occue at the plant.
The + raining programs are normally administered by the utility staf-However, utilities utilize the services of training organizations to conduct parts of the training.
In a few cases, utilities have contracted to have an entire class of trainees trained by a training organization.
i()/S II/
. Typically, 80% of the training is administered by the utility staff, and the other 20% is by the training organization.
At the conclusion of all training programs, each trainee is administered written examinations and oral tests similar in scope to the NRC examinations. Frequently, utilities will request training organizations to conduct these examinations to assure impartiality.
The training staff members are normally licensed senior operators.
If they do not have a current license, they have previously been l'icensed. However, there are not specific criteria regarding instructor qualifications.
G.
Medical Requirements Section 55.10(a)(7 ) of 10 CFR Part 55, "Cperators' Licenses,"
requires an applicant for an cperator license to submit a report of a medical examination by a licensed medical prac-titioner.
Section 55.11 lists the physical and mental conditions that may constitute sufficient cause for denial of an application.
American National Standard, ANSI N546, " Medical Certification and Monitoring of Personnel Requiring Cperator Licenses for iU/S 118
. Nuclear Powr Plants," was issued in 1976.
The standard was developed by Working Group ANS-3.4 of the American Nuclear Society Standards Committee. The Working Group consisted of three industry physicians, an ERDA physician, a National Laboratory physician, a tRC representative and an industry representative.
This standard provides the minimun requirements necessary for an examining physician to determine that the physical condi-tion and general health of the operators are not such as might cause operational errors.
This standard was endorsed i.n 1979 by Regul atory Guide 1.134, " Medical Eval uation of Nuclear Power Plant Personnel Requiring Operator Licenses."
10 CFR Part 73, " Physical Protection of Plants and Materials,"
requires that facility management have employee screening procedures. ANSI N18. 7-1976 entitled, " Industrial Security for Nuclear Power Plants," requires examinations by a licensed psychiatrist or physician or other person professionally trained to identify aberrant behavior.
In addition, Re g-ulatory Guide 1.134 and ANSI N546-1975 address mental condi-tions that could be disoualifying conditions.
Form fRC-396, " Certificate of Medical History," has not been revised since the issuanca of Regulatory Guide 1.134 1075 ll9
. GAC Questions on Eligibility, Including Training Q1.
The Commission has no minimtm eligibility requirements, but endorses recommendations made by the American Nuclear Society.
Should the Cornission have minimtm eligibility requirements?
If so, what should those requirements be?
A 1.
The regulatory guides provide one method for the utilities to provide reasonable assurance that safe and competent individuals will operate nuclear power plants. If util-ities do not wish to follow the guidance then they must provide an acceptable alternative that would have to
-be approved by NRC.
In order to be approved, the educa-tion, experience and prograns would be comparable to those described above.
The guidance is sufficient with-out the need to cast it in concrete in a regulation.
Q 2.
Is a person with a high school education suited to operate the cc.nrols of a nuclear power plant?
91ould that person be better educated?
A 2.
The American itclear Society Standards Subccamittee ANS-3 is reviewing and recommending changes to the ANSI /ANS Standards for which they are responsible. One of the standards is ANSI /ANS 3.1-1978, that addresses the selection and training of nuclear power plant perscnnel. One area to be reviewed 1q7E
- 9o lViJ I LU
. will be the education requirements for operators and senior operators.
However, individuals who presently operate nuclear power plants, because of their participation in the training programs, have more education than a high school education.
The extensive evaluations of the operator's competency by the facility management during training and by NRC examiners after training are much more significant than the formal education requirements for selection into training.
Q3.
The term " equivalent" high school education is not defit.ed.
Should it have a specific meaning?
A 3.
This item will be reviewed by ANS-3. During our review of the revised ANSI /ANS 3.1, we will assure that " equivalent" is defined.
Q4.
" Power plant experience" can pertain to that experience acquired during any stage of a power plant's life including the design and the construction. Should " power pl ant expe-rience" be more specifically defined?
A4 In the definiticn of power plant experience, the standard provides that experience during cesign and construction may be given credit for scme positions.
It would not normally be given creoit for operating positions, except when it incl uded conducting preccerational test ;rograms.
However,/ b_I 1
IU 2
. for a position such as reactor engineer, experience in design of nuclear power plants may be highly relevant.
For a position such as maintenance manager or mechanic, experience in power plant construction may be very valuable.
The standard is structured to permit credit for this exper-ience when applicable and we believe that this approach is correct.
However, we will review, and ask ANS-3 to review, the definition to see if it needs sharpening.
QS.
The term " responsible power plant experience," when referring to a senior operator, is not defined. Should it have a specific meaning?
A S.
This question is addressed in Option 1.
We reconnend that responsible power plant experience be defined better than at present.
Q 6.
- hould medical examinations fo,.1uclear power plant operators be more stringent?
Should psychological profiles be developed for these operators, analyzing their response capabilities in stress situations?
A 6.
The medical requirements enunerated in the documents listed above are sufficiently stringent for us to have reasonable assurance that the physical condition and the general health of the applicant are not such as might cause operational errors endangering public health and safety. A review of LERs,
10/5 122
t abnormal occurrence reports, information contained in individual dockets and inspection reports involving personnel errors do not reveal any instances where undue stress was a contributing factor.
Further, the training programs in which the applicants participate are demanding. This subjects the applicants to stressful situations.
Also, the NRC written and oral examina-tions place an individual in a stressful situation. Finally, the requirements of the requalification programs are such as to place the operator in stressful situations and we are insti-tuting changes to increase the variety and complexity of casualty situations encountered at simulator training centers. Th ere-fore, we believe that explicit psychological testing for stress is not warranted.
Q 7.
The Commission basically performs a paper-review of a utility' <
training program.
Should the Commission. establish its awn minimtm training requirements?
S1ould the Commission have its staff personally inspect the training program?
A 7.
The staff
. been very involved in developing the scope, content a.id times allotted for the cold training programs.
The " cold" training programs were developed by the vendors and reviewed in detail by the staff to assure tnat the sub-jects enwnerated in Sections 55.20 through 55.23 of 10 CFR Part 55 were adequately addressed.
Indeed, many of the items spelled out in training programs are the direct 1075 123 result of NRC input.
These programs have, over the years,
. been changed due to technological changs and as safety concerns have changed.
Each change in the programs has been reviewed and approved by the staff prior to its im pl ementation. Hence, we do, in effect, have minimun requirements, although not spelled out in a regulation.
However, NUREG-0094, "NRC Operator Licensing Guide," indicates the acte table expected qualifications for applicants.
D D
NRC examiners conduct audits of the training progrcms by oo D
g
}
administering examinations to all the graduates of the O
j O rogram and informing the trainers of any weak areas in o
p their programs, based on the examination results. The same technique is employed to 2valua.e a utility cold training
,prcgram. We do not beliave the e would be any specific benefit in developing mc re dete. led regulations.
The s ub-ject of tr iining progrars for hot applicants is further addressed in Option ?
Q 8.
The. plant operating organization is very much involved in training operator applicants.
Should the Conmission re-review and approve the individuuls who give this training?
A 8.
Most of the utility instructors and simulator training instructors have senior operator licenses; we hai2 advocated this approach as a demcnstration M ccmcetence but have not made it a requirement. We believe that the subject of instructor qualifications and 3.monstrated competence deserves further investigaticn ard pssible change. One 1075 124
. aspect of this question is addressed in Option 7.
Even beyond that aspect, we are exploring the matter with the Subcommittee ANS-3 and the newly formed Nuclear Operations Institute of the Atomic Industrial Forum.
Q 9.
Replacement applicants do not necessarily participate in the simulator training program. Should it be a require-ment that they do so?
A 9.
This question is addressed in Option 6.
Cptions to the present eligibility requirements are val uated as follows:
Optien 1 Require the following experience for senior operator applicants:
Applicants for senior operator licenses shalf Have 4 years of responsible power,. ant experience. Responsible power plant experience should be that obtained as a control room operator (fossil or nuclear) or as a power plant staff engineer involved in the day-to-day activities of the facility, ccmmencing with the final year of construction. A maximtm of 2 years power plant experience may be fulfilled by academic or related technical training, on a ane-for-cne time basis. Two years shall be nuclear power plant experience. At least 6 months of the nuclear power plant experience shall be at the plant for which he seeks a license.
1U/5 125
. (Note: The ANS-3 is currently considering changes in the experience requirements; the results of this effort should be considered as an alternative to the above.)
PR0: a) Have more assurance regarding the qualifications of indi-viduals selected for senior operators, by requiring that experience is truly relevant.
b) Prevent auxiliary operators from applying for senior operator licenses without lilving relevant experience.
CON:
a)
May restrict the advancement opportunity of some i ndiv idual s.
b)
May result in some valuable experience gained in construction and design not receiving snple credit.
Oction 2 Modify the hot training progrsns so that the training concentrates on the responsibilities and functions of the operator, rather than the senior cperator. All individuals who satisfactorily complete this hot training prcgram will be allowed to apply for an operator license, but must have at least 6 months experience as a licensed operator before applying for a senior operator license.
1075 126
. PRO:
a)
The requirement to have licensed operator experience prior to applying for a senior operator license will result in more experienced people applying for senior operator licenses.
b)
Improved training programs will result if the delineation between an operators' and senior operators' duties is stressed and training is conducted appropriate to these duties.
c) Utility management will be able to better select senior operator caniidates if they observe their personnel in a licensed operator capacity prior to making the selec:f on.
CON:
a)
Increased OLB examiner workloac to administer examinations if the present one step senior operator examinations are eliminated.
b) There would be no guarantee that the individual would be perfanning licensed duties full time because of excess of operators.
c)
Could create severe management - bargaining unit problems if control room operators were supplemented with profes-sional staff personnel, c)
May delay highly qualified personnel
.n obtaining senior operator licenses.
1075 127
. Option 3 Require that the 3-month continuous on-the-job training for hot operator applicants be as an extra man on shift in the control room. Require the hot senior operator applicants to have 3 months continuous on-the-job training as an extra man nn shift in training.
PR0:
Provide more formal and complete training for operators and senior operators by exposure to, and participation in, day-to-day operational experiences and problems at the facility under application.
CON:
a) Require increasing plant staffs.
b) Tr aining could be diluted for large groups of people due to control room restrictions.
Ootion 4 NRC examiners should administer all the cold certification examinations at the simulator training centers.
PRO:
a) NRC examiners would be unbiased in their evaluations.
b) Provide for immeciate feedback to the trainers regarding deficiencies in the training progrsns.
10/S 128
- 22 ~
c) Have an opportur,ity to observe applicants manipulate controls.
d) Previde a method to assure that the latest operating experi-ence has been programmed into the simulators.
CON:
a) Substartial additional NRC manpower would be required.
b) To a very large extent, previous certifications from training centers have been validated by subsequent NRC exam inationr.
Option 5
.RC examiners should routinely administer some (approximately 10%)
af the certification examinations at the simulator training center.
PRO:
a) All of those listed in Cption 4.
b) To a very large ex'ent, previous certifications from training centers have been validated by subsequent NRC ex ami nations.
CO.'i :
Additional tRC manpover would be required, but not as many as in Option 4.
1075 129 O ptien 6 In accicn to the presently approved training programs, require that all replacement applicants participate in simulator training programs, as applicable for their f acility. Exception may be
. made for licentaes at older facilities whose facility features and operating characteristics are not similar to present facili-ties, providing suitable alternatives are substituted.
PRO: Assure all applicants observe and demonstrate this abilit" to cope with abnormal and emergency conditions.
CON:
Individuals from some older plants may not receive much benefit from training at the simulators that presently exist or are planned; in some cases, requiring such training could be counterproductive.
Option 7 Require that Phase II, III and IV cold training program instructors and all hot training program instructors that provide instruction in nuclear power plant operations hold senior operator licenses and be required to successfully carticipate in applicable requalification programs to maintain their ir.structor status.
PR0:
a)
Initially assure a competent staff at the training centers and facilities.
b) Assure that the instructors review the latest appli:able operating experiences, LERs and abnormal occurences to factor into the programs.
10/5 130 c) Provide a cadre of backup personnel to assist a facility in an emergency.
' ~
CON:
Increased NRC manpower to administer examinations.
H.
Licensee Practices Regarding Requalification Programs Licensed Operator Requalification Programs are conducted at all nuclear power plants pursuant to Appendix A to 10 CFR Part 55.
These training programs require annual written examinations and systematic evaluations of actions taken by licensed personnel.
Based on the results of these exaninations, individuals are required to attend lectures and/cr participate in accelerated programs.
The requalification programs also require each licensee to manip-ulate the controls through a minimtm number of reactivity changes every 2 years. Other requirements include systematic review of procedures, technical specifications and design fea-tures, incl uding changes thereto.
The programs are administered by the facility and audited by NRC.
At present, 85% of the facilities surveyed have sent some of their operating staff to a simulator for refresher training. Simul ator training is not a requirement of the requalification programs and the frequency and number of individuals receiving simulator training varies at each plant.
Normally, the personnel assigned to shift work do not go to a simulator, because they perform their required reactiv-ity changes at the plant.
Consequently, staff personnel who hold licenses may receive simulator training in abnormal and emergency situations, while many of the control cperators only walk-through their abnormal and emergency procedures at the f acility.
10/S 131
. The requalification programs are jointly audited by IE and OLB.
IE reviews the record of accomplishment to determine that the facility is conducting their program in accordance with the approved progran. OLB audits the annual examina-tions to assure that they are comparable to the NRC examina-tions in depth and content, and to ensure that the grading is also comparable. OLB also audits the quizzes administered as part of the lecture series.
GA0 Questions Q1.
The Commission requires that a nuclear power plant operator under-go exanination once a year.
Is one year, or a much shorter period, appropriate?
For example, the Federal Aviation Administration requires that airlines pilots be exanined every 6 months.
A 1.
The annual examination is followed up by lectures in subjects in which the individual scored below 80%.
The lecture series is preplanned and scheduled throughout the year. The licensees are required to be administered quizzes at the conclusion of each lecture. In addition, continuous evaluation of on-the-job performance is required.
Therefore, training arid evaluations are continuous, rather than once a year. We believe that an annual overall written examination is sufficient but that strengthening the means of on-the-job evaluation merits attention.
'ne have discussed this with ANS-3 and they are considering a standards revision of this ty;e.
1U75 132
. Q2. To a large extent, the Comission relies on utility management to certify that an operator should have his license renewed.
Should the Comission independently check this certification?
A2.
This question is discussed in Options 11 and 12.
Options to the present requalification programs are evaluated as follows:
Option 8 In addition to the present operator requaltriuation program requirements, we shall require that all licenses participate in periodic retraining and recertification on a full scope simulator representative of their facility.
The frequency of training should be on an annual basis.
Exceptions may be made for licensees at old facilities, whose facility features and operating characteristics are not similar to present f acilities, providing suitable alternatives are substituted.
PRO:
a)
Increased assurance that licensees are maintaining their competency regarding the handling of abnormal and emergency situations.
b) Permit licensees the opportunity to perform normal evolutions that they have not performed recently at their facility.
CON:
a)
Increased cost to the utilities.
b) Apprcpriate simulators do not exist for a few older facilities.
1075 133
. Option 9 Presently, individuals who have not been performing licensed duties for 4 months or longer, are required to participate in an accelerated requalification program and receive our approval, prior to resuming licensed duties.
In addition to the present requirements, these individuals should be required to be recertified on a full scope simulator, represer.tative of his facility.
Licensees at older facilities may be excepted, providing suitable alternatives are provided.
PRO:
Increased assurance that the licensee will be able to perform
. his licensed duties in a safe and competent manner as soon as he reports back to work.
CON:
Increased operating expenses to the utility.
Opticn 10 Establish more explicit require. neats regarding exercises to be incl uded in s imulator training programs.
These requirements should assure performance of exercises in a broad spectrum of normal and abncrmal operations and response to transients and emergencies and shall include consideration of multiple failures, compound abnormal-ities and imperfect initializaticn.
The requirements should not be rigid so that the flexibility and spontaneity in training programs are precl uded.
We, and ANS. 3, have initiated effort in this direction.
1075 134
. PR0:
a)
Increased assurance that those items considered important to safety by NRC are covered in each training program.
b)
Increase scope of training to assure that the scope of evolutions performed is sufficiently broad and that realistic considerations are included.
CON:
If the requirements are structured too rigidly, the resultant training could be too standardized and thereby decrease emphasis on response to unexpected events.
O ption 11 NRC to administer and grade all the annual written examinations and adninister all the oral evaluations associated with requali-fication progrsas.
PR0:
a) The administration of examinations would be more uniform and assure that NRC concerns were addressed.
b) The examinations w'ould be separated from the training program and serve as a measure of the training program's effectiveness as well as individual ccmpetency.
CON:
Substantial additional OLB personnel will be necessary fcr NRC to assume the responsibility for administering these examinations.
O otion 12 NRC administer scme (approximately 10%) of the requalification examinations and oral evaluations, rather than all of the examina-tions, as indicated in Cption 11.
. PRO:
a)
Serve as a check on requalification program effectiveness.
b)
Form a basis for administration of complete examination of the individuals.
c)
Continue to emphasize that facility management has the responsibility to assure effective administration of the program.
CON: Additional CLB personnel will be required.
I.
NRC Exaninations The NRC examiners administer both written examinations and oral tests to evaluate the knowledge and understanding of applicants.
The written examination for the operator consists of the following seven categories:
A.
principles of Reactor Operation, B.
Features of Facility Cesign, C.
General Cperating Characteristics, D.
Instrumentation and Controls, E.
Safety and Emergency Systems, F.
Standard and Emergency Operating Procedures, and G.
Radiation Control and Safety.
The examination is designed so that the average applicant can complete the exanination in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
However, no time limit is imposed.
An individual passes the examination if he receives an overall grade of 70t.
He may receive less than 7C". in any category.
The wricten examination for the senior operator consists of the above seven categories plus t.he following:
10/S 136
. H.
Reactor Theory; I.
Radioactive Materials Handling, Disposal, and Pazards; J.
Specific Operating Characteristics; K.
Fuel Handling and Core Parameters; and L.
Administrative Procedures, Conditions, and Limitations.
The examination is designed to be completed in 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> by the average applicant.
However, no time limit is imposed.
An individual passes the examination if he receives an overall grade of 70%.
He may receive less than 707. in any category.
The operating test at a nuclear power station normally consists of bo.th an oral exanination during a plant walk-through and an actual demonstration at the reactor console during a reactor startup if the applicant has not been to a simulator.
Most applicants attend the simulator. Therefore, NRC examiners do not normally witness applicants manipulating the controls.
The scope of both portions of the operating test is the same for both operators and senior operators, except that the senior operator is expected to answer questions as if he were the operator's superviscr.
The scope of the oral and operating test consists of testing the applicant's ability to (1) read and interpret the control instrurentation, (2) manipulate the control equipment, (3 ) cperate other facility equignent, and (4) his knowledge and understanding of radiological safety practices and radiation monitoring equi; ment. The tests do not have a numerical grade, but rather each answer received 10/5 137
. in response to a question is considered satisfactory or unsatisfactory.
The examiner evaluates the overall performance and recommends passing or f ailing the individual.
J.
Adninistration of Examinations Approximately 2 months prior to fuel loading, NRC written examinations are adninistered to the cold applicants.
The operator and senior oper-ator examinations are administered on consecutive days. Approximately 1 month prior to fuel loading, the oral exaninations are administered.
This practice has the advantage of permitting the chief examiner to receive an orientation tour of the facility at the time of the written and t,o become fsniliar with the equipment and its location and to permit the examiner to personally assess when the facility will be sufficiently complete for the conduct of the oral examinations.
Also, it permits the examiner time to grade the written examinations so that those who fail the examination will be issued a denial letter e.,d the number of oral exaninations will be reduced.
After a facility is operating, written and oral examinations are admin-istered consecutively on the same visit to the facility.
This reduces the number of visits to a facility.
- ndividuals who do not hold an operator's license for that f acility, whc apply for senior operator licenses and fail the senior portion of the examination are issued operator licenses if they pass the operator pcrticr.
10/5 138
. Individuals who hold an operator license who apply for a senior operator license normally are granted a waiver of the oral por-tion of the examination and are administered only the five part senior operator written examination.
Individuals who pass only the written examination or the oral test my request a waiver of that part of the examination when he reapplies.
This request for waiver is usually granted.
K.
Written Examination Crades We have conducted a survey of the written exams given during the period January 1977 through March 1979.
The purpose of the survey was to determine the impact of changing the passing grade on the written examination from the present 70%.
We recognize that the full impact that is indicated would probably not have actually occurred if the postulated criteria had been in effect, since the training and evaluations by facility management would have been altered.
We reviewed the results of 508 cperators and 484 senior operator written examinations.
The following is a sumary of what the effects would be for those applicants if various criteria had been in effect. The percent denied include those that were denied based on present passing grades o# 70% cverall.
10/b 159
S Lupact of increasing overall total grade, expressed as % denied.
PRESENT 70%
75%
80%
85%
90%
Operators 5.7%
6.3%
31.5%
57.4%
88.6%
Senior Operators 4.1%
8.2%
28.9%
59.2%
89.0%
Impact of requiring a minimLm grade in each category, expressed as
% denied.
70%
75%
80%
Cperators 43.7%
57.7%
81.2%
Senior Operators
- 32. 9%
43.6%
69.4%
hapact of maintaining the overall passing grade at 70% with no more than one category below 70%, expressed as % denied.
Operators 20.7%
Senior Operators
- 9. 9%
Impact of increasing the overall passing grade to 75% with one cate-gory below 70%, expressed as % denied.
Operators 15.0%
Senior Operators 11.4%
Impact of increasing the overall passing grade to 75% with one category belcw 75%, expressed as % denied.
perator:
34.4%
Senior Cperators 19.4%
10/b 140
. Impact of increasing the overall passing grade to 75% with two categories below 75%, expressed as % denied.
Operators 21.0%
Senior Operators 8.2%
Impact of increasing the overall grade to 80% with no more than one category below 75%, expressed as % denied.
Operators 38.6%
Senior Operators 32.2%
Impact of increasing the overall grade to 80% with no more than two categories below 75%, expressed as % denied.
Operators 31.9%
Senior Operators 28.9%
Impact of increasing the overall grade to 8.0% with no category below 70%, expressed as % denied.
Operators 49.0%
Senior Operators 40.3%
The following two items were indicated during our review:
The review indicated that operators with an overall grade as high as
- 38. 7% received less than 70% in one category.
The review also indicated that senior operators with an overall grade as high as 90% had less than /0% in one category.
If we had required a grade of 7C% in every category, 22 instant seniors would have passed the senior portion of the examination, but would have f ailed the operator portion.
01 b
}!l f.
. GA0 Questions Q1. The difference between the examination given to the senior operator and the operator appears ill-defined. Questions asked of an applicant for a senior operator's license supposedly are more difficult and mor,e indepth. Should specific criteria be developed addressing the difference in degree of the difficulty and complexity?
A1. The scope of the examinaticns are enumerated in Sections 55.21, 55.22 and appropriate sections of NUREG-0094, "NRC Operator Licensing Guide." These documents define the differences between operator and senior operator questions.
However, NUREG-0094 will be revised to more clearly define the responsibilities of the senior operator.
Q2. An average score ai 70 percent overall is passing on the written examination. However, a person could fail one or more categories and still pass overall.
Is this appropriate?
i0/5 142
' A 2.
This question is addressed in Option 18.
Q3.
A person who fails one or more parts of the written examination but passes overall does not have to receive additional training on those parts that he failed. Is this approp-iate?
A 3.
This question is addressed in Option 19.
Q4. Approximately 90 percent of those persons who take the written exam-ination pass on the first try.
Is the examination too easy and should it be revised?
A4.
A review, of tRC examination results at nuclear powr plants from 1960 to 1978, indicates that t e denial rate for applicants
~
for operator licenses had decreasec from 16. 6% to 11. 5% and for applicants for senior operator licenses from 21.1% to 11.2%.
We believe that the decrease in the denial rate is due to:
(1) the developnent of better screening procedures by the utilf tles when selecting trainees; (2) the formalizing of training programs con-tent, particularly those involving the use of nuclear power plant simulatcrs; (3) the weeding out of the trainees, based on interim evaluations during the course of the training program; and (4 ) wi t h-drawal of applicants, based on the results of utility administered final written examinations and c al/cserating tests.
1075 143 Further, when a group of applicant at a f acility do poorly on an exanination that indicates a breaxco m in the training program, we take immediate corrective action to improve the training ::rogram and avoid a repetition of accr results.
- Therefore, it is not surprising the 89% of the applicants who are administered NRC examinations are successful and receive licenses; this high rate of success is indicative of careful selection and meaningful evaluations during training and at the completion of training.
Options as re'ated to this issue are evaluated as folicws:
Option 13 The content of the existing written examination should be expanded to include more selective essay type questions on tfiermodymamics, hydraulics, fluid flow, and heat transfer.
This should ba dcne using the same categories that now exist for the R0 and SR0 examina-tions.
The length and complexity of the written examinations will increase from the present requirements.
PR0:
a) Will provide added assurance of understanding of phenomena associated with. unexpected events.
b) Can be accomplished rapidly without a change to the regulations, c) Will provide for examination in these technical disciplines in the same manner as other disciplines.
d)
Is consistent with published guidance, NUREG-0094, regarding the Operator Licensing Program.
e)
The analysis of category-grade acceptance criteria will still be meaningful.
CON:
a) Oces not provide high visibility regarding this change in emchasis in our examinations.
b) May require depth of understanding of technology that the operator will never encounter in practice.
10/5 144
- Option 14 The content of the existing written examination should be expanded to include more selective essay type questions on thermodynamics, hydrau-lics, fluid flow, and heat transfer. This should be done by creating new categories for the R0 and SR0 examinations as appropricte. The length and complexity of the written examinations will increase.
PRO:
a) Will provide added assurance of understanding of phenomona associated with unexpected events.
b) Can be accomplished rapidly without a change to the regulations.
c) Provides high visibility to this change in examination emphasis.
CON:
a) Would result in overemphasis on this subject, in order to provide sufficient content in a category of the exams.
b) Would lengthen the examination time unnecessarily.
c) Will moot the result of the analysis of category-grade criteria, d)
Is not consistent with published regulatory guidance, NUREG-0094, concerning the Operator Licensing Program.
e) May require depth of understanding of technology that the operator will never encounter in practice.
Cotion 15 NRC should adopt a different approach to the written examination, such as one that would relate to only elemental questions and leave the exploratory questions to the oral examination.
Such an examinati0n could be restructured to include multiple choice and true and false type questions.
PR0:
a) The multiple choice - true-false question type examination has the ability to cover a greater variety of questions within a given time franie.
1075 145
. b) This type of examination could be prepared from standard questions and graded by overlays or automatic grader thus reducing the present man-hours to prepare and grade a essay-type exanination.
CON:
a) This type of examination would be generic in nature.
Hence, the oral exanination would be the only way to explore plant specifics.
b) The confirmation aspect of the written and the oral-operating test' would be greatly reduced.
c) Development would require time and expense to compile a sufficient bank of questions.
d)
Inherent disadvantages of these types of tests would be introduced (e. o.,
subtle senantical distinctions, importance of guessing) which would tend to alter the purpose of the exanination.
0 0 tion 16 Require part of the oral / operating test to be administered using existing nuclear power plant simulators.
PR0:
a)
Evaluation of applicants would be made, based on their demonstrated ability to manipulate controls and diagnose and respond to abnormal and emergency situations.
b)
Indicate that actual response to acnormal situations is as important as knowledge and uncerstanding of the situations.
) [,} 7 C l /. 4, J
e
. CON:
a)
Increased NRC examiner manpower to administer the examinations, b) Most applicants would have to learn two facilities, their own and that for which the simulator is modeled, in order to be evaluated properly. The validity of that portion conducted at a non-identical simulator could be questioned.
c)
Increased cost to the utilities.
d) Difficulty of scheduling the examinations at simulators.
e) Probably would not include individuals from some of the older plants.
Ootion 17 Require senior applicants who hold an operator's license to take an oral test in addition to the senior portion of the written examination.
PR0:
a) Obtain better evaluation of the individual's ability as a senior operator, b) Provides for emphasis of managerial responsibilities of the senior operator (i.e., command and control).
CON:
- ncreased examination time with resultant increase in NRC man-ocwer needs.
10~/S 14/
. Ootion 18 Increase the overall passing grade for operator and senior oper-ator written examinations to 80% and require at least 70% in each category.
PRO:
Prevent individuals from obtaining licenses who have a lack of knowledge in specific areas.
CON:
a) Deny individuals for minor lack of knowledge that could be addressed in requalification programs.
b)
Each category consists of six or seven questions.
Receiving a grade less than 70% in categories may not be statistically significant.
Ootion 19 OLS should provide facility management with the detailed results of NRC initial examinations so that individuals may be immediately enrolled in the requalification programs.
PRO:
a)
The facility training department can administer training to the individual in weak areas.
1075 148
. b) Provide feedback to utilities regarding general weaknesses in trair.ing programs.
CON:
The privacy act may preclude divulging this information without the individuals' pennission.
L.
Nuclear Power Plant Simulators In the late 1960's, the General Electric Company proposed that a nuclear power plant simulator be incorporated in a training program to provide trainees with the necessary control manipulations to meet our eligibility requirements.
The simulator was built and becane operational in 1970.
Since that time, we have reviewed and approved training programs incorporating nuclear prwer plant simulators for Combustion Engineering, Babcock and Wilcox and Westinghouse and for five utilities which have purchased their own simulators. An additional five utility-owned simulators are under construction and four more are proposed.
Our decision to accept a training program using a nuclear power plant simulator was based upon several pertinent considerations, including:
a)
The ccmpleteness and accuracy with which the simulator is constructed, b)
The extent to which the simulator provices various types of control room experience to the trainee, includino the ability to simulate normal startup and shutdown operations, as well as a multitude of casualty drill situations.
10/S 149
c)
The extent of operating experience of the simulator instructors.
To determine that the simulator meets the requirements of (a) and (b) above, we compare the proposed simulator to the information con-tained in the Final Safety Analysis Report of the facility after which it is modeled and detailed drawings of the facility's control rocm.
Our comparison includes the nteber of systems simulated, the degree of simulation, and the fidelity of simulation.
In addition,we determine that the nutber and types of malfunctions are adequate for the intended training purposes. Our final acceptance of the nuclear power plant simulator depends upon the comparison of the simulator's response to various transients to that of the plant's response as determined during the startup testing program.
An industry standard was issued early in 1979, which specified minimum functional requirements for nuclear power plant simulators.
This standard is ANSI /MS-3. 5-1979, "?bclear Dower Pl ant Simul a-tors for Use in Operator Training."
(Note:
Subcocmittee ANS-3, that developed this standard, has met and initiated a revision _to the standard in light of the TMI-2 experience.)
The four phase training program described previously was designed for applicants with no previous experience.
Simulator trair.ing, per se, is not required #cr those applicants with previous nuclear ex perience.
It is strongly encouraged, however, by the NRC.
NUREG-0094, " A Guide for the Licensing of Facility Operators, Including Senior Cperators," contains the folicwing statements:
107S 150
. "Howver, it is highly desirable that previously licensed individ-uals participate in a short course utilizing a nuclear power plant simulator similar to the facility for which the applicant will be seeking a license.
This training should take place as close to fuel loading as practicable."
"In addition, it is highly desirable that ex-military personnel participate in a short course utilizing a nuclear power plant simulator to the facility for which the applicant will be seeking a license."
"4plicants who have been certified at ERDA-owned reactors and lack power plant experience are required to attend an appropriate nuclear power simulator course or participate in the day-to-day operations of a plant similar to the one for which he seeks a license for a period of two months."
Several years ago, we modified our programmatic requirements to permit an individual to be licensed without having to perform a reactor startup on the exanination in certain circunstances.
Basically, the training program substitutes a certification of competency in the area of reactor startup for the actual startup demonstration witnessed by an IRC examiner. An applicant would be eligible for examination withcut a reactor startup if, among other training requirements, "The applicant has satisfactorily completed an NRC approved training program that includes at least one week at a nuclear powr plant simulator. The applica-tion shall contain a certification from the simulator training center."
At the present time, many use this startup certification program for hot applicants.
lil/S ibl
Nuclear power plant simulators are used in many of the licensed operator requalification programs. Howver, the tRC position has been to strongly encourage their use but has not required them.
Many utilities routinely incorporate simulator training in their requalification programs.
They send all personnel to a simulator on an annual or biennial cycle. At the simulator, emphasis is placed on non-routine activities and casualty drills.
Other utilities use simulators only where it is obvious that certain of their operators will not meet the 10 reactivity manipul a-tions requirements of the requalification program at the plant.
The few remaining utilities do not use simulators because they make special effort to meet all requalification program require-ments at the facility or they make the determination that there is no applicable simulator for their facility.
Several years ago, General Electric Company proposed an " advanced" control room (Nuclenet) which represented a major departure from tha existing control room.
The Nucienet control room makes extensive use of CRT displays for providing information to the operators.
Instead of the hardwired instrtrents presently in use, the Nuclenet relies heavily on computer-generated information.
OLB performed a review of the physical features and intended uses of the !bclenet and compared this with the features of the exist-ing simulators.
Our conclusion was that no existing simulator nould lend itself to the training of fOclenet operators - GE would have to provide a Nucienet simulator. OLS has maintained this 10/5 l,.,x
. position. As each of the other reactor vendors have proposed advanced control rooms, we have specified, where necessary, that a simulator must be constructed to provide the required training.
Ootion 20 Establish requirements that ensure that simulators, in order to receive credit in operator training and licensing activities, have the capa-bility to acconnodate a sufficient number and variety of abnormal and emergency conditions. This can be accomplished by appropriate revision to the 'itandard ANSI /ANS 3.5-1979 or by separate NRC requirements.
PR0:
A::ure lessons learned from TMI-2 are incorporated in existing and future simulators and that operating personnel are afforded this training capability.
CON:
Reprogramming of existing simulators and possible hardware changes.
M.
Operator License Examiners, Including Part-Time Examiners The Operator Licensing 3 ranch employs nine full-time examiners and 22 part-time examiners. The primary function of an examiner is to develop, prepare and administer written, oral and practical examinations to operator and senior operator applicants, for critical, research, ::ro-duction and utilization fac.lities.
In additicn, he reviews safety analysis reports as to applicant's proposed method of training, requal-ifying and evaluating plant staff members and proposed method of procedural control of opertions. The examiner also audits the requal-ification program examinatior.s at the operating facilities.
10/b 155
Individuals selected as full-time NRC examiners have many years of nuclear operating _xperience at National Laboratory Reactors, commercial power plants or military reactors.
Several years of this experience has involved training of operators.
New exminers to the staff are processed through an orientation and training program comensurate with their experience prior to assuming the.fr responsibilities.
This consists of the new examiner observing an experienced senior (LB member prepare and administer written and oral ex minations at research reactors.
The new examiner then pre-pares and administers an examination on a similar reactor under the specific guidance of the senior OLB member.
This procedure is followd at a nuclear powr plant until the examiner is fully f amiliar with OLB procedures and practices.
Following orientation, he is assigned to administer examinations under the general guidance of a senior exminer.
Cnly after demonstration of his capabilities is he assigned as a solo examiner; even then, his activities are subject to audi.t by the group leader and branch chief.
Examiners attend nuclear powr plant technology courses conducted by the IE Career Management Branch to increase their knowledge of pome plant systems of facilities that they have not operated.
Individuals selected as part-time examiners have backgrounds similar to the full-time examiners, except that several have had actual operating experience only at research reactors, although they have studied powr reactor design and characteristics. In the latter cases, the individuals are facility di ectors.
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4 t.
New part-time examiners are provided crientation and training in the same manner as new headquarters examiners, except that they do not attend IE courses. Their training also requires a longer period of time due to the need to accommodate their principal job d uti es. Af ter their initial orientation and training, part-time examiners participate in continuous training programs, albeit mostly informal. Their written examinations are reviewd and critiqued by a senior OLB examiner, usually a group leader, prior to their administration. Periodic audits of their performance are conducted by senior OLB members, either by accompanying them dur-ing the administration of an oral examination, or observing their performance during the course of an examination conducted on a simul ator. Their evaluations of individuals are reviewd by senior OLB members to assure conformance with OLB examining standards.
Simulator training is provided when it can be accommodated in conjunction with the administration of examinations.
The staffing objective of CLB has been to provide permanent personnel to accommodate about 30% of the expected workload and part-time per-sonnel for the rest. Thus, the availability of part-time talent has permitted the program to efficiently and expeditiously meet workload fl uctuations between 805 and 120" of normal, while keeping permanent staff active.
Also, the impact of loss of permanent staff members can be eased by use of part-time examiners.
Each year, O'_B conducts a conference f ar all examiners where 2 or 3 days are devoted to training relative to acministering 1075 155
written and oral examinations.
Conferences are held at simulator training centers when possible so that demonstration and hanas-on training may be conducted using the simulator.
GA0 Questions Q1.
The examiners who prepare, give, and evaluate the examina-tions are not all Commission employees--they are often part-time consultants who work full-time for the national l aboratories.
Often these part-time examiners themselves have not taken cormiercial power plant licensing examinations, and do not hold licenses.
Many have not had experience in cormiercial nuclear powr plants. Many have not been through simulator training for nuclear power plants.
Is this appropriate?
Can this lead to examination problems?
A1.
Individuals that are selected as part-time examiners have many years of reactor operating experience and are extremely knowledgeable regarding reactor theory, core parameters, operating characteristics and radiation protection and con-trol, nuclear instrumentation and safety and emergency systems.
Consequently, they need only apply their knowledge and under-standing to the specific design of power plants, as applicable to their assignments. OLS orientation and training programs are designed to assist in making this transition.
Al so, f ul l-time examiners conduct thorough reviews of their work. We believe that the use of individuals with this background is app ropri at e. We have not had problems egarding examination validity due to the use cf these individuals, probably because 10/5 iS6
. we have recognized that special attention is needed.
Addi-tional training and retraining of examiners is discussed below.
In addition, the part-time examiners from universities provide val-uable input into the program by providing the lastest thinking regard-ing teaching and testing. However, reconsideration of the need for specialized training of these persons is addressed in Option 21.
Options relative to this issue are evaluated as follows:
Ootion 21 The present part-time examiners will continue to be recruited from universities and national laboratories. Formal training
~
and ' retraining programs shall be developed for all OLB exam-i ners. The training programs will be prepared and ccnducted by OLB with assistance from the IE Career Management Branch.
Training shall also be provided at simulator training centers.
In order to remain as a part-time examiner, the individual must make himself available for this training, in addition to the time previously required for the normal examining workload; thus, a commitment of about 55 days per year will become a requirement.
PRO:
a) Provide for more competent examiners, particularly in those areas involving system transients and thereby provide for better evaluations during examinations.
b)
Senior staff members can conduct more c:mprehensive evaluations of the examiners by caserving their performance during training sessions.
10/5 15/
~
e
, c) Part-time examiners recruited from universities and national laboratories are unbiased and have no apparent conflicts of interest.
CON:
a) Will require additional manpcwer to adequately staff and maintain the Operator Licensing Program.
b) Will require special authorization to provide training to part-time examiners (e.g., consultants).
c) Will require additional time for part-time examiners; this will result in the immediate loss of some personnel that cannot commit to the requisite time.
d) Additional ~ funds will be requirsd to purchase simulator time.
Ootion 22 Eliminate all part-time examiners and increase OLS manpower to meet all operator licensing requirements. Manpower hiring requirements should restrict hiring to those individuals who have held or currently hold a senior operator license or equivalent for a nuclear power plant. Examinersshouldbeassignedtoadministerexahtinationsat
~
specific types of reactors. Only after proper training should they be assigned to examine on other types of facilities.
PRO:
a)
Increasing the headquarters staff to conduct all licensing functions would provide an independent, unbiased cadre of highly qualified examiners, b) Would increase specialization within CL3 to better carry out the resconsibilities of the branen.
CON:
a) Elimination of the part-time examiners would require in-creased staffing of headquarters personnel, with additional cost to maintain.
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. b) Loss of part-time examiners would eliminate the cushion to accommodate large short-term increase in workload and the impact of loss of permanent staff, c) Would result in loss of independent perspective the part-time examiners introduce into the program.
Option 23 Augment the part-time examiners that are currently employed by OLB.
Obtain from the utility and vendor training staffs licensed SR0s to assist OLB in licensing activities. This select group of " Check Senior Operators" would be comparable to the FAAs " Check Airmen."
The " Check Airmen" are considered the elite among the airline pilots.
Usually they are selected from the better flight instructors and are given additional training. They are certified by the FAA as being qualified to evaluate other crew members. They assist FAA examiners in recertifying pilots. All initial FAA examinations are administered by FAA employees. Likewise, the " Check Senior Operators" would be the elite of nuclear plant training staffs. They would be used to admin-ister the requalification examinations, including that portion using simulators.
All initial examinations would be administered by headquarters examiners.
PRO:
a) The use of check examiners, such training coordinators and other SR0s, as examiners would increase the effectiveness of the recual-ification programs because of their intimate involvement with administering programs at their facilities with their asscciated understanding of items in wnich operators need retraining.
10/S 159
. b) A large pool of well-qualified experienced examiners would be available for conducting examinations.
c) Provide excellent operating experience expertise to 0.3.
CON:
a) The fact that a " Check Senior Operator" of one utility may be making a decision concerning the qualifications of per-sonnel from another utility raises questions of potential bias.
b) A full description of the responsibilities and qualifications of the Check Senior Operators will require rule changes to effect appropriate regulatory control over these persons and possibly to provide training and instruction.
c)
Examinations may become too manipulistic with' little emphasis on principles of reactor theory, hydraulics, tc.
d)
Part-time examiners from utilities could appear to cre :e conflict of interest problens.
N.
Acditional GA0 Questions The G40 report raised several questions that are indirectly related to the Operatcr Licensing Program, but not the direct responsibility of the Cperator Licensing Sranch. The appropriate organizations have supplied the following responses to the GA0 questions.
Ql.
Nuclear powr plant management, maintenance, and other t echnica:
perscnnel are not required to be licensed.
Cnly the operators are required to hold licenses to maniculate the controls of a powr plant.
Since virtually many, if not all, of the unif ensed personnel may critically affect pl ar.t operation, should other plant perscnnel also be required to holc licenses?
7g j
A 1.
Quality Assurance Branch Response We are currently assessing the need to upgrade the qualification requirements for all members of the plant staff. One of the means to upgrade qualifications that we are currently considering is the periodic determina-tion of continued qualification by the NRC of the following plant staff positions.
They are listed below as functional levels as described in ANSI /ANS 3. 1-1978:
Plant Manager - Section 4.2.1 Maintenance Manager - Section 4. 2. 3 Technical Manager - Section 4.2.4
, Supervisor Not Raquiring fRC License - Section 4.3.2 Reactor Engineering - Section 4.4.1 Instrunentation and Control - Section 4.4.2 Chenistry and Radiochenistc/ - Section 4.4.3 Technician - Section 4.5.2 Maintenance Personnel - Section 4. 5.3 Auxiliary Operator - Proposed Rev. 2, R.G.1.8 - Section C For the above noted positions, we currently require that the perscns filling these positions meet the ANSI N18.1 require-ments regarding, basically, education and experience.
'We also require (Section 5.1) that the entire plant staff be t rai ned.
The acceptance criteria is in the SRP reference Reg-ulatory GJide 1.8 which endorses ANSI N18.1.
However, Section 5.1 is very general and, therefore, the acceptance criteria 1075 161
. are very general.
It is recommended that the staff establish NRC accepted training programs for each of the above noted functional positions which should be keyed to the plant at which they are assigned and which would include special enphasis on systams affecting safety, plant procedures, and license require-ments.
Their continued qualification would be audited by the NRC through review and evaluation of the curricula for the required annual retraining programs.
The initial training and the retraining determination of qualifications could also be accanplished by the auditing of formal quizzes which would be required at the completion of training and retraining sessions, but would be administered by the licensee.
In addition, we have had discussions with the Subccanittee ANS-3 which is, in view of recent events, considering revisions to ANSI /
ANS 3.1-1978, " Selection and Training of tbclear Power Plant Per-sonnel."
In addition to consideration of the imposition of stricter standards regarding qualifications of personnel, we have initiated discussions with the newly formed Nuclear Operations Institute of the Atomic Industrial Forum concerning the certification of various categories of enployees.
Q2.
Commission regulations require that only one licensed oparator be in the control roon at all times.
Should the Commission amend its regulations and require that a senior operator pl us one or more additional operators be continually present?
)0/S i62
e J
. A 2.
QAB Response At this point in time, we do not consider that the number of personnel required in the controi room as a prime concern, since there is hardly ever only one person actually present. More relevantly, we see the need to upgrade the qualifications of the operating staff, to enhance the administrative controls that govern their operation and to ensure availability of specialized technical support to the operating staff. Comprehensive proposals regarding these activities are under consideration by the staff, the Sub-cecnittee ANS-3 and the ibclear Onerations Institute.
Q3.
Com'ssion regulations do not require that a nuclear engineer be on duty at a nuclear po;er plant at all times. If this were required, there would be one " key" individual available at all times to cope with an emergency situation that may require nuclear engineering knowledge.
Should this be required?
A 3.
QAB Response As indicated in the response to question 2 above, the need for a " nuclear engineer" to be on duty at a nuclear power plant or available on call at all times is under consideration.
Another alternative under consideration is to upgrade the qualifications of one or more persons on shift. This would provide a means for assuring that someone with training and/or qualifications in the field of thermal-hydraulics and systems will be available to provide guidance to operators during unusual events such as these related to pipe break analysis and natural O!b b
circula: ion modes for the react:r.
Q4 Licensee event reports identify errors or other problems that develop in reactor operations. hhen an operator makes an error, it has to be reported to the Comission through a licensee event repo rt.
However, the reports do not provide the names of operators who comit the errors. Therefore, it appears that the Commission cannot maintain operational error records based on what specific operators comitted the errors. How effective is this?
How can the Comission effectively monitor operator errors?
A4 IE Response IE does not maintain a file of operational errors, either
~
identified through the Licensee Event Report (LER) system or otherwise, that identify a specific operator to a specific
, error. LERs were not intended or designed to be used as a tool for evaluation of individual operator performance. Also,
" personnel errors," when identified as a cause for an LER occur-rence, do not always refer to errors by licensed operators.
LERs are reviewed at the IE regional offices for complete-ness, safety significance, appropriateness of licensee actions, and adequacy of the report.
Based on the inspector's j udg-ment and the safety significance of the event, onsite follow-up of aspects of the event may be conducted.
If IE followup of the event clearly indicates poor performance by a licensed operator, this information is reported to NRR:0L3 for informa-tion and action, if appropriate, as specified in tRR:CL3 pro-cedure, " Consideration of Performance of Licensed Operators and Senior Operators," that was forwarded to all the regions.
1075 164
In general, IE efforts are directed toward assuring that facility licensee management is taking adequate corrective action for operator.nitiated events.
Nevertheless, presently, if an operator comits a serious violation for actions for which he holds a license to per-form them, a full range of sanctions can be applied and will be applied as appropriate. Other licensing actions taken against individual licensed operators and senior operators include those initiated by NRR:0LB. To support these actions, IE has provided regional offices with guidance for providing OLB information regarding signi#icant information concerning individual operator performance.
IE plans to further evaluate the current methods fo assuring this information is adequately provided.
Q S.
In completing licensee event repcrts, the utilities have considerable discretion in how they classify each event.
Should the Comission require more specific details so that it can clearly distinguish hinan/ operator error from a tech-nical design problem?
A 5.
IE Response Guidance for filling out LERs is presented in NJREG-0161.
Scecific instructions for de:emining the cause code are provided in this doc: ment. While there is recm for subjec-tive j udgment, we censider that the guidance provided is 1075 le
sufficient. IE inspection procedures provide for regional review, and in some cases inspector followup of LERs, which includes a check of the cause code for accuracy.
If apparent discrepancies in cause code reporting are noted, practice has been to bring these discrepancies to the licensee's attention with the intent of providing better accuracy of future reports.
Recently, an tRC task force on Operational Cata Analysis and Evaluation, established at the request of the Executive Direc-tor for Operations, reported the results of their review to EDO.
This report, which includes consideraticn of GA0 recon >-
mendations in their January 26, 1979 mport, " Reporting Unsched-uled Events at Commercial Nuclear Facilities," specifies recocmendations for improvement of PRC's review and eval-uation of operating data.
Concurrently, operational report-ing requirements are under review by ACRS.
It is expected that these efforts will result in changes that will improve the reporting of operational data, of which LERs play.an important role, and NRC's review and evaluation of this i nformation. It is expected that these efforts will result in improvement in identification and accurate reporting of the cause of an event.
Q 6.
The Conmission has found it necessary to susoend one operator's license and require six other operators to be reexamined.
What criteria has the Connission established to determine if enforce-ment action must be taken against an operator?
10/S M6
A 6.
IE Response IE is currently developing more detailed criteria that apply specifically to enforcement actions as they apply to licensed reactor operators. The proposed criteria, which reflects past IE practice, establishes certain conditions under which a licensed operator would be cited. This criteria are currently being applied in determining if enforcement actions should be taken against licensed operators. Since the facility licensee is responsible for tr conduct of personnel in their employ, it has been IE practice to cite the facility licensee management for minor operator transgressions when the event resulted from inadequacies in the training program or unless
~ the operator knowingly or repeatedly comitted an act of potential significant safety consequences. We consider enforcement emphasis on the facility licensee program to be more effective than enforcement actions directed at the individual.
However, in light of the events at Three Mile Island Unit 2, the criteria for citing operator licensees are being further evaluated.
Nevertheless, presently, if an operator ccmits a serious violation for actions for which he holds a license to per-form a full range of sanctions can be applied and will be applied as appropriate.
Other licensing actions taken against individual licensed operators and senior coerators include those initiated by NRR:0LB.
To support these 10/5 16/
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actions, IE has provided regional offices with guidance for providing OLB information regarding significant infor-mation concerning individual operator performance. IE plans to further evaluate the current methods for assuring that this information is adequately provided.
Q7.
In 1Ight of the apparently low nunber of enforcement actions and high percentage of operator errors, should the Comission's criteria for enforcement actions be strengthened?
A 7.
IE Response As stated in previous responses, there are few enforce: ment actions directed toward individual operator licensees in relation to operator errrrs because enforcement emphasis is
~
directed more toward facility licensee management.
The numbers, homver, do not reflect enforcement actions taken against facility licensee: that are directly or indirectly related to personnel errors. We consider IE's present approach for use of enforcement actions as they relate to personnel errors to be the better approach. Homver, specific criteria for citing licensed cperators are presently being developed and should provide more definitive guidance.
Q 8.
Mcw effective are the utilities in self-enforcing ocerator violations?
10/b
.68
A 8.
IE Response Estimating the level of effectiveness for utilities in enforc-ing or correcting operator performance problems is a subjective matter. IE inspections are intended to verify that the licensee is complying with their approved operator qualification programs. IE review of these programs, LERs and licensee responses to noncompliance items has indicated that facility licensee programs and corrective actions are effective and adequate. As a result of the recent incident at TMI, further emphasis ir these areas may be required. Methods for deter-mining thk adequacy and effectiveness of the facility licensee's operator qualification program are subjects that warrant further IE review and consideration.
We plan to examine the licensee's actions and methods for selection, training, and retraining of
~
the plant f.taffs.
Q 9.
When a new nuclear powr plant becomes operational, the Com-mission has statistics which indicate that approximately 30 personnel are assigned to operate the facility. Ho mver, the statistics indicate that many times as few as six opera-tors have had actual comercial power plant operating exper-ience.
Is this a sufficient nir.ber?
A 9.
OLS & QAB Response The quoted numbers are not rep >: e n t c.,
.v.
The " cold" training programs described in the paper were 4 signed to provide individuals with " extensive actual operating experience."
They have been successful programs and 10/S 169
many the presently operating plaats have been loaded with fuel and have gone through successful startup testing with a majority of the licensed individuals having participated in these programs.
However, when the staff has believed that the licensed individuals required assistance during this phase of operations, we have assured that they have been supplemented
. th non-licensed startup engineers * 'th considerable nuclear power plant experience, including experience as a licensee at an operating plant.
Q10.
Control rooms in nuclear power plants are not standardized.
There are often considerable variations in the controls of
'5e facilities.
If the controls were standardized by the amnission, would this make operation easier for the
]perators?
Would there be less chance for error?
A10. OLB Response Individuals are licensed for a specific facility.
The licenses are nontransferable.
The transference of knowledge
- rom one control roca design to another is a legitimate concern, but is not considered to be a paramount problem.
lone'heless, the standardization of control rooms, incl uding displays, indicators, controls and alarms, has potential advantages in training although this aspect would be achieved only over a long term.
The concept deserves, and is receiv-i g, attention from the industry and the NRC. The obvious n
drawback, however, like all standardization, is the inhibition of val:
im provements.
1i)/S 1/0
ENCLOSURE 2 II b>
D D
l cv ;O OPERATOR LICENSING BRANCH
[ "D) 'Ih3
~
~y MANPOWER REOUIREMENTS M
FY80 FY81 FY82 FY83 FY84 FY85 Mancower. Man-Years Operator Licensing Examiners 16.0 18.0 19.0 20.5 21.3 23.0 Procram Suecort ($1,000)
Contractor 150 170 215 245 275 300 Consultants
~
In addition, 2 technical professional man years of private consultant operator licensing examiner manpower are required for each year during the period.
This includes a significant increase in operator licensing exam' scope which is required as a result of the Three Mile Island accident.
We expect that this increased scope will be started in FY79 and FY80 as supplemental effort and carried on as continuing effort for the period FY81-SS.
i0/S I/1
Enclovtre 2 2
There are four categories of. operator licensing examinations.
Cold exams are given 2 months before fuel loading.' Each such exam requires 78 san-days for an average group of 24 applicants.
As a result of THI, a supplemental simulator portion has been added to the basic exam.
This adds 16 man-days to the basic manpower if the simulator is offsite and 5.5 nan-days if the simulator is onsite.
The estimated number of cold exams each year is as follows:
FYSO FY81 FY82 FY83 FYS4 FY85 With Offsite 7
5 7
3 6
4 Simulators With Onsite 0
2 1
2 0
0 Simulators Initial hot exams are given 2 months after fuel loading.
Each such exam requires 61 man-days for an average group of 24 applicants.
As a result of TMI, a supplemental simulator portion has been added to the basic exam.
As with the cold exams, this adds 16 and 5.5 man-days, respectively, for offsite and onsite simulators. The estimated number of initial hot exams each year is as follows:
E8.0, FY81 FY82 FYS3 FYSA FY85 With Offsite 2
5 5
9 10 8
Simulators with Onsite 2
2 2
2 1
5 Simulators D' -
D C C./
~
~
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-e
mo D
0 d) o ))
3 ogg-
-r o
J(
a Power facility replacement exams and requalification audits are given at operating stations as needed.
The current average is 2.25 visits per year per operating station and five visits per year total to the simulator training centers. *Each visit requires an avarage of 14 man-days.
As a result of TMI, supplemental simulator portions have been added to the basic exams.
These add 4 mandays and 1.5 mandays, respectively, for offsite and onsite simulators.
Exams at second and third units at operating sites also are included.
The number of operating stations each year is as follows:
FY80 FY81 FY82 FY83 FY84 FY85 With Offsite 48 53 61 69 72 77 Simulators With Onsite 6
8 7
7 9
10 Simulators Nonpower exams are given at research and test reactors and critical facilities.
Each visit to such a facility requires 10 mandays and an average of 50 total visits per year is needed.
The final category of examination-related workload is auditing and is required as a ruult of the TMI accident.
Requalification programs are auditied at half of the operating sites once each year and each visit requires 5 man-days.
Similarly, half of the vender and utility operated training centers are audited once each year and each visit requires
'_0 man-days.
Six visits are required each year during the period of intarsst.
Auditing the
\\ols
\\15
4 administration of exams at the 12 training centers requires two visits per year to each center and each visit requires 8 man-days.
The total" examination workload is done by headquarters examiners in OLS, by contractor consultants in the 00E labs and industry, and by individual private consultants who are "special employees" of the NRC.
By definition, we plan for 20% of the exam workload to be done by consultants.
Of this 20%, a constant 2 man years per year will be assigned to the individual private consultants and the balance will be done under contract through the 00E labs.
T[eoT1 U
9 hb A
3
'L @ u i t 22 1m 1075 174