ML19322C742
| ML19322C742 | |
| Person / Time | |
|---|---|
| Site: | Crane |
| Issue date: | 04/04/1977 |
| From: | METROPOLITAN EDISON CO. |
| To: | |
| References | |
| 1006-02, 1006-2, NUDOCS 8001220696 | |
| Download: ML19322C742 (17) | |
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.':. I.;I 04/11/77 THREE M:LE ISLAND NUCLTAR S.TATION ,hi u . um e" y houm coison c7mron umanation enocunCENTRAL Fil 4 ' 7 musmtm noame ioos x. s i7 w. or et,a,e.w a CONTROLLED COPY f-4. g p.. Revhton M M R edston Pace Date -Revist: g;, K,; 1.0 04/11/77 2 26.0 E1.0 h p'g --4 3.0 04/11/77 2 28.0 53.0-2.0 04/11/77 2 27.0 - 52.0 mc-h"? e,.%A 4.0 04/11/77 2 29.0 54.0 ik.' '.- 7.0 04/11/77 2 32.0 57.0 X'" I 5.0 04/11/77 2 30.0 55.0 I 8.0 04/11/77 2 31.0 56.0 MS pjJ. 8.0 04/11/77 2 33.0 58.0 Ji " 9.0 04/11/77 2 34.0 59.0 S 10.0 04/11/77 2 35.0 60.0 I* 11.0 04/11/77 2 36.0 61.0 M '; M.. 12.0 04/11/77 2 37.0 62.0 P""M.. Or ' 13.0 04/11/77 2 38.0 63.0 rW ' 14.0 04/11/77 2 39.0 64.0 7l " k. 16.0 04/11/77 2 40.0 65.0
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. P ,,b. ,,w.gg ~ n-p' 1006 Revision 2. 04/11/77 i', THREE MILE ISLAND huCLEAR STATION ADHINISTRATIVE PROCEDURE #1006 Metropolitan EJf son Operator Requalification Program CAUTION: Prior to changing attached procedure - FSAR submittal must be 1 made since Admin.1006 has been submitted as a portion of the FSAR. Table of Contents 5.; i f.a_gg 1.0 GENERAL 2.0 1.1 Purpose 2.0 h[.~. 1.2 Scope 2.0 1.3 Program Schedule e 2.0 2.0 REQUIREMENTS h 4.0 2.1 Operational Review (OR) Lecture series 4.0 2.2 Fundamentals and System Review (FSR) Program 6.0 2.3 On-The-Job-Training 7.0 2.4 Annual Evaluation Examination .. 10.0 r# 2.5 Records ~ 13.0 f, 2.6 Accelerated Requalification Program 14.0 2.7 Four Month Absence Program 14.0 2.8 Newly Licensed Operator 15.0 3.0 RESPONSIBILITIES 15.0 3.1 Supervisor of Training and His Staff 15.0 3.2 j Operations Supervisor. Supervisor of Training, or Other } Suitable Qualified Person Designated by the Station w.m,. W ' Superintendent 16.0 h p s O Ei-
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10% ', p Revision 2 , 04/11/77 THREE MILE ISLAND NUCLEAR STATION ' Y ADMINISTRATIVE PROCEDURE #1006 Metropolitan Edison Operator Requalification Program h.+r 1.0 GENERAL. i 1.1 Purpose ymm : [f* - T~ The Metropolitan Edison Requalification Program, as set forth in r this document, applies to the Three Mile Island Nuclear Generating Ef My Station. All licensed personnel will-participate in the applicable portion of the requalification program. The basis of the requalift-cation program is the need to maintain operator competence and f proficiency in the quest for continued safe operation. The guidelines' ~ i fwr the requalification program are found in 10CFR55 Appendix A. In addition the implementation of this program conforms to 10CFR50. ) 1.2 Scope' a The following section of the requalification program covers: Program Schedule ) II. Pre-planned Lectures i III. On-the-job-training IV. Annual Evaluation Examination V. Records . 1 VI. Accelerated Requalification Program f VII. Four Month Absence Program VI!!. Newly Licensed Operators -1 IX. Requalificatfor. Program A&iinistration . v. 1.3 Program Schedule i . jyp l' The requalification program described herein will be implemented at a specified date within 90 days after receipt of an operating 'i 2.0 7 ja. 'Wd: [. ' { W ""- $ kg s- --= ir VFF ,m W
rr2:9. - 1.v ' WA 4-p.e 3ng ,f Revision 2 04/11/77 ticanse. March 1. and subsequent anniversaries of this d&te will ~ be considered to be the starting date of each annual cycle of p requalification program operation. h The Mstropolitan Edison Requalification Program consists of four f interrelated segments which run concurrently. These segments are: 1) 0,,arational Review Lecture Series (OR) { 2) Fundamentals and Systen Review Program (FSR) ) 3) On-the-job-training I
- 4) Annual Evaluation Examinations t
The OR Series is a classroom lecture cresentation which provides the licensed personnel with the details of operational information k related to the Three Mile Island Station. As part of the OR Series, k selected FSR topics are presented. FSR topics are selected in areas where annual operator and senior operator written examinations indicate that emphasis in scope and depth of coverage is needed. OR lectures are scheduled for a minimum of 60 hours per year. On-the-job-training is designed to insure that all ifcensed personnel. operate reactor controls and participate in major plant evolutions. I Records of all on-shift performance are maintained and periodically reviewed by snoervisory personnel. The annual evaluation examinations simulate the written and oral examinations administered by the Nuclear Regulatory Connission. Performance on these annual evaluation examinations detemine the extent of the FSR program during the following tweN month requalirication period. h. k-Each license holder will complete all OR and FSR requirements on an 4 j. annual cycle. The On-the-job-training is conducted throughout the - E g two year term of the individual's license. All required on-the-1 b t job-training will be completed prior to ifcense renewal. ~ i M 3.0 M~-- "? y, g,;r7. ara,%TJiee3m4 o - ~ ~ - - - = l
i _ _. ~ ~ p - ?s;.'*{ *.. 4 f.s3d g e MyT,+. ~ j .p. kc.?' 1006 Revision 2 04/11/n ~ A statement of Requalification program participation will be submitted 'W1 with each license renewal application. The requalification program h is designed with fixed performance standards and specified remedf al actions. The program results and records are fully auditable. 2.0 ILEQUIRENENTS 2.1 Operation 31 Review (OR) Lectures Series I During each year, personnel shall attend the Operational Review ^ i (OR) Lecture 5erfes on the following bests: I (a) Licensed station administrative and technical personnel will participate in the OR Lecture Series as either students or ( instructors, except to the extent that their normal dutfes preclude the need for specific retraining in particular
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(b) OR Lecture Series attendance is required of all licensed b-operators and senior operators who are normally on. shift assipments. ~ L The following topics shall be covered as a minimum during the OR . $;j Lecture Series each year: (a) Reportable Occurrences (b) Unit Modifications (c) Operating History and Problems l (d) Procedure Changes LFw., c,. (e) Abnormal and Emergency Procedure Review ' " O^~ j (f) Technical Spectfications (g) Major Operational Evolutions (such as refueling) d" (h) Applicable portions of Title 10. Chapter I. Code of Federal ,3 y. Regulations 'l ); a 4.0 w w., t\\ l MN@f g; [$ w % ___m_ ~~
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Revision 2 >J ~ i -04/11/77 lf I (1) FSA Program Material jp' p Additional toples which may be presented includes (but are not " -i 1tattedto) V F w (a) Operettonal Q/A 9:,. i .% m g-v (b) Standing Orders r, m y% h (c) Operating Experiences - Reactor Safety and other pertinent NRC pubitcations ~.'.7. [f Lectures shall be held on a continuing basis and consist of a ' " ~ alntmum of 60 scheduled hours per requalification program cycle. l,. The program for each session will be determined by unit operations 5 ' '- o, or projected operations. Records of the toples covered in each _:deff' i .;&-6 session will be maintained by the Training Department. Attendance s I,M of all ifcensed personnel will be recorded. Absences will be made 6, up by reviewing lecture materials and/or discussions with on-shift f supervisory personnel or the technical staff. Periodic evaluation t(W quizzes covering the content of the OR lecture series will bc kj administered. The quizzes may be administered in either the closed b h _., book or open book format. as class room, or on-shift quizzes. If - p _.- an unsatisfactory grade (less than 801) is received, makeup sessions l' wtth assigned instructors will be ecnducted. The makeup session N-4:3 vp 3 will conclude when an oral evaluation is satisfactorily completed. gp The content of the quiz will be different for R0 and SRO license ) du holders and will reficct the topic areas and degrees of responsibility .: b;. O. I pyynt * - needed by the Itcense 1. older. Examples of the
- materials to be used
> q Y. i,+ ' .g during the OR lecture series are: Y i; g :; ;, i s.0 y;y "o, m2 > g -1E SQI2f nn c we a ' n. - x q, p ' ~.;g ' Tl ** py; -- ~ y LY
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l +,m .., T..y. n:+ 1006 {;} Revision 2 04/11/77 ~g: (a) Unit Records ar.d Logs ~ (b) Pertinent Connunications to and from the IRC a ~ihji (c) Unit Procedures and Changes
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(d) Test Results g .w (e) Applicable Training Program Materials W 2.2 Fundamentals and System Review (FSR) Program {.;;. During each year, licensed personnel shall participate in the Fur.damentals and Systems Review (FSR) Program based on the'f r annual written examination scores as identified in Section IV - Evaluations. Lh 4 i The F5R Program may consist of pre-planned lecture series, self study assignments, possible tutorial sessions with designated technical instructors and evaluation quizzes. The study assignments and pre-planned lectures will be in keeping with the license level
- of the individual license holder. Indiviifual study assignments, f
films, and video tapes will censtst of no more than 50% of the F5R r Program. Pre-planned F5R lectures shall be scheduled in those areas where + annual operator and senior operator written exan.inations indicate rM that emphasis in scope and depth of coverage is needed. Any or all of the following topics may be included in a particular i' I, year's F5R Program: (a) Principles of Operation \\ (b) Features of Facility Design 7,x %f (c) General Operating Characteristics j";l* (d) Instrumentation and Control (e) Safety and F.mergency Systems including Unit / Station Protection '.a.,,, Systems kbh 3 s,.uw. 6.0 n-m l p ff! F - ps - Q. .:. ~n x ~ ~ ...,.1 ::ntL ~
4 - ~ - i f-g km ,4W p 1006 gg % 4 Revision 2 3' g'* e.* 04/11/77 174 - i gy (f) Normal and Emergency Operating Procedures a 's (g) Radiation Control and $afety n g. 4 For Senfor Operators the FSR Program will alsr. include. + g 9 je (h) Reactor Theory h2.((, .fr Q. (1) Radioactive Material Handling. Otsposal, and" Hazards A -M.gyop,.. (j) Specific Operating Characteristics w.- ~ Ag..ree (k) Fuel Handling and Co9 Parameters p m9-m.n (1) Administrative Pr 4edures, Conditions, and Limitations Performance of F5R aufgnments will be determined through written ^ y s,. t .. e. W. ,un, evaluation quizzes gy (-- These quizzes will be specifically directed swa h toward RO or $R0 mowl. edge requirements. The quizzes may be administered a-in either the '.losed book, or open book for' mat, as classroom or on-5 y,. We shf f t quizzr. A satisfactory grade on the F5R evaluation quiz will be 801. If a i. grade below 801 is achieved by a Ifcense holder, a' deffetercy is assigned and the Itcense holder will be assigned an accelerat'ed ma requalification program as per Section 2.6. k.n 2.3 _~. ": *rO On-the-job-training 43 Fl m MA. rp M ' - pidea) During the two-year term of his ifcense, each licensed operator
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guls: u.h t .w j (a) ' $%y Each Itcensed reactor ortrator or senior operator shall participate ru u {0@%~ in a minimum of 10 reactivity manipulations as defined in this 'M d '-
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e,: s, ~y F-section of the requalification program. n,r l D Y' kb....iU% $hU (b) Each licensed reacto, operator'or senior operator shall participate x s t as appropriate. In appitcable surveillance testing system M i .4.
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V gp 1006 3129 - v n'l Revision 2 'A M/- 04/11/77 ' W,' e - (c) Each licensed reactor operator or senior operator shall review 'S4 e procedure changes, unit modifications, technical specification 1sfr sb b L'f. b changes. reportable occurrences and incidents either on-the- ~ we job cr.iuring sessions of the OR Lecture 5e f r es. Each lfconsed reactor operator shall manipulate the unit controls L p ~~ g* m Rf'*: to effect reavanable reactivity changes. Each itcensed senior )& f~i H reactor operator.shall either manipulate or direct the manipulation ,t Tf ky.a.- of the unit controls to effect reasonable readwity changes. s,~ Reactivity manipulations which demonstrate skill and or fastlfarity g.-[ with reactivity control systems and which are credited to meeting h, Q, N^ on-the-job-training will include, but are not ilmited to: [ [*{ Power change of greater than 10% full power with the reactor, 1. e.4 # F' control station in manual. [ I d, c 2. Control rod manipulation from suberitical condition to point h" /' of adding nuclear heat. e,o E ~ ~.g 3. Scration and deboration maneuvers involving control rod mant-L f ( pulat1on. l+L - ";.,2; a 4. Turbine startup and shutdown. wm # vn;< d T -.M 5. Reactor trips and subsequent actions. The participation of ifcen.* d personnel in the on-the-job program yp $g, L'h will be reviewed quarterly by appropriate supervisors to insure 4#._. gl that operators participate in a variety of evolutions. y7 ? If diversity M;h -,, em of operations is lacking, specific assignments may be made to [ ,y j Qj ensure wide operator experience. a ..;c pt p., *. ? M( WMW - .y; Included in the following list are examples of additional operations which mey be considered in this categcry. These samples are not to lfh. ] be considered for reactivity manipulation credit. a-%m F WQ* Qf 8.0 we .~ ~ .?" M% m.3... . m..py. f?fS ..,.__,s 't % e as ~ - 4 " "
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s i .-{006 Y-- w Revision 2 04/11/77 k.. i 1. Survel11ance Testing Including: a. Containment Spray System b. Safety Injection .g c. Emergency Diesel Generators d. Chemical Addition System 2. Makeup and Purification System Operation 3. Decay Heat Removal System Operation 4. Feed ater System Operation 5. Reactor Coolant System m g ?? 6. Turbine Valve Testing 7. Pressurizer Operation L 8. Incere Monttoring System Operation 9. Control Room Calenlations Including: s. heat Balance b. Quadrant Tilt / Imbalance / Rod Withdrawal Index l c. Reactivity Balance 10. Portable HP Instrunent Use. '~ Licensed personnel, whose job assignmerts are not directly related to unit operations will actively participate in control room operation D- +w l an average of 4 hours per month. During this period these Itcensed personnel will participate in whatevec activities are in progress. l A simulator may be used in meeting the requiresnents of this section., .. g., The use of a simi.later to meet the on-the-job training section of I the program must be reviewed by the NRC prior to implenentation. f The following standards apply ec ".he evaluation of on-the-job J '. m'
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Quarterly review of operettons participation will be made by 9 F~ q
- the appropriate supervisors. The revtew must indicate a G-;3
+ diversity of expertence. ,. N;' 9-If this is not demonstrated. the h ( hq operator will be scheduled for additional operating expertence. &p 2. E Quarterly review of reactivity control mantpulation (RO) or + direction (SRO) sust shc4 satisfactory progress toward the
- g. s.c alnimum of 10 operations as defined in this section.
y.* < If \\ satisfactory progress is not indicated, an operator will be gf, .g pse-assigned additional control room operations or may accompitih e C, { c g' :,, _ '. j the required reactivity changes on a simulator. 1 3. Annuti review of licensed personnel whose job assignments are
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< * 'gy ~ not directly related to' unit operations must show a mintasm of m t, f..- 48 hours of unit esperation assQnments per year. If this is f not complete. per:ocr.1 wiil be assigned to active control ,N+ room duty untti the time is.made up. A simulator may be use"d to complete control room time. k n, b s 2.4 Annual Evaluation Examination ~ r Evaluations will be conducted on an annual basis as follows: ,_,0, w +,,n g (a) An annual written evaluation examination will be given to all- ~ g' i ~s : ] licensed operators nnd senior operators prior to the completion 7- ~ of each annual cycle. ^N~ @+ ~ ~
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(b) An annual oral evaluation will be administered to all Itcensel r m, operators and senior operators prior to completion of each v~W annual cycle. j,3 ^ p m,d The annual written evaluation examination will be administered to c O
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y all licensed persotinel as set forth in the following guidelines:
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1006 Revision 2 04/11/77 1. The examination will simulate the examination normally administered by the Nuclear Regulatory Coenission. 2. Reactor Operators will take Sections A through G of the examination while the Senior Reactor Operators will take Sections H through g L and answer selected questions in Sections A through G. 3. The examination, examination answers and a grading key will be l prepared in advance. 4. The examination results will be used to identify specific FSR lecture series topics to be covered by each licensed individual during the subsequent annual requalification program cycle. ( i i 5. The examination will be administered and graded by a member of 1 the station technical staff, station management staff, training ~* department supervisor, or consultant. I 6. The persons respecstble for the preparation of the examinations i and answers will be given credit for passing the examination. r The annual oral evaluation examination, using a checklist, will be administered to all licensed personnel. The oral examination will be. [ cover the following areas: (a) Action in event of abnonnal conditions "(; Q' ^'~ .n p' 1. :
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t (b) Action in event of emergency conditions (c) Response to unit transients -+ g (d) Instrumentation signal interpretation
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(e) Procedure modification } . g.i m.7 (f) Unit modifications (g) Technical specifications l L (h) Emergency plans yp 4 ! '- .; j 11.0 1mww- >+ .e :.; w ' N } " \\ %,I;,, } T/ } ]j{i fy,hf n ' e 9m ' m 1
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The following standards apply to the annual evaluation examinations: 'x ^ l. A license holder who scores higher than 801 in all sections of { the annual written evaluation will not be required to participate j l in the FSR program. 7- ~ 2. If a license holder scores less than 80% on any sections of the annual written examination, the license holder will attend ~ the FSR program related to failed sections. 3. If a license holder scored below S0% in two or a: ore sections t of the annual written examination, the license holder will be given an oral examination and evaluation by the Supervisor of Operations, Supervisor of Training, or other suitable qualif ted persons designated by the Unit Superintendent. This examiner will, based on the results of his examination, make a recom-lf stendation in writing to the Unit Superintendent, that the Operator either - (1) be relieved of his responsibilities and b !~< enter an accelerated training program or (2) be permitted to remain on shift while participating in the appropriate requalift-cation FSR program with suitable tutorial assistance. M p.. 4. An unsatisfactory evaluation on the annual oral examination .p P j will require that discussions of deficiencies take place between the license holder and either the Supervisor of Operations. [3 Superv. wor of Training, or other suitable qualified person designated by the Unit Superintendent. A second oral evaluation h' nu. examination will be adm.inistered. If performance is again y unsatisfactory, the license holder will be relieved of responst-gju u-bilities and placed into an accelerated requalification program. { ~ NN 12.0 R$ i qw
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~~~ ~ {',., [y% m 1006 p. Revistor 2 i ;. .s> w 04/11/77 $5 5. t.jE. . If an individual receives a grade of less than 70% overall on t s.x - 'i +F ,w the annual examination it will be mandatory that (1) he be nm ^' retteved of his licensed duties and (2) enter an accelerated - p a requaltftcation program. Upon (1) successfully passing s' second written and oral examination and (2) certificatfon of %g satisfactory rating being sent to the NRC, the individual will n;a r ^^ he returned to his Itcensed duties. 1 2.5 Records gjg, Records of Itcensed personne1' performance on all written evaluation -m sy ( examinations and quizzes shall be available for NRC examination for ->s W the two annual requaltftcation cycles prior to Ifeense renewal ,n Qifj appitcation. These records shall include: -w,- ,:p ..'"1 ~ Examination and quiz questions ' vi rf; %dge~t 1. La y 2. W, 3 Answer sheets and grade keys 9*"^'W-g w.w 3. Exastnation papers and work sheets _ 2+ :g ~ i ., as Records of participation in all OR lecture and FSR programs will be - $5- " - ^ ~ e , J n available for NRC review for the two annual requalification cycles - Meh <.ww ' m,, n prior to license renewal application. m 4!cy,a These records shall include: myp+ -
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.~,,.s f Ra. r &g 2. OR Lecture Content +4?-w; 1 np m.,. .mt 3. FSR Assignment e9 4. Absences and Makeup Sessions . ? l ,--e 5. Assignment Checkoff Lists hkE e e 'y" Og 6. Documer.t Review Lists YTc~- ' lT;sy-lt p y,d,; NC Records of annual oral. evaluation examinations shall be made available 6%hph -s 'for NRC review for the two ann al 'i *f v 3W requalification cycles prior to w. y, c license renewal appilcation. 2)f. ' + j W f.v.s.. 13 0 g;, M*' ( x"=:n y .gg.ie ' Fr S .;s }' ~ e w g . w,_ ... ~.... 2 AA,. -+aa*"" s
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review for the two annual requalification cycles pri ~ renewel applications. or to Ifcense These records shall include: 1. Rasctivity Control Manipulation 2. i.'I Equipment Operation 3. T $1mulator Participation A suncary record will be maintained on each li duration of his uployment. cense holder for the ~- 2.6 Accelerated Requalification Program G,a An operator who does not clear deficiencies assi below standards on eithe' r the annual written or gned due to performance s c oral evaluations will be relieved of responsibilities and enter a f ll \\ { F' requalifiestion program. time accelerated u The program duration and content will be dictated b the deficiency. y the nature of Program duration will be dete, mined by individ I' performance. ual When the license holder is (1) able to satisf ( pass an equivalent written or oral examination and (2) actorily g of his satisfactory rating is sent to the NRC, he shall certification on-shift responsibilities. resume his \\ 7.[ cation, attendance at the OR lecture series is requir license holder is off-shift for more than 4 months If the L . Section 2.7 dealing with lengthy absences applies. 2.7 Four Month Absence Program If a licensed person has not actively carried out th his ifcense for a period in excess of four month e functions of ' s he shall: (a) Review all, irrial presented or. scheduled to ha h. ve been presented in *he OR lecture series for the period of inactivit T1 y. 14.0 gg r wee I" t ~ ~ Ao \\
_7.,, 1005 Revision 2 Y j 04/il/77 p ( (b) Se given an oral examination on the applicable Section of the @r-y gy OR lecture series and current unit status, n_w y" no a '.c~ If performance nn the oral evaluation is unsatisfactory, the indivi@al M;$ g +b. N th will be placed in an Accelerated Requalification Program in accordance 5, with Section 2.6. "~ Upon receipt of a satisfactory rating the licensed person shall be p y, certti*ed by the Supervisor of Operations. Supervisor of Training a e- - ~ or other suitably qualtfled person designated by the Unit Superintendent. 7T v-e r - mu. The certification of satisfactory rating will. be transmitted to the. J'WRd MRC and only after approval by the NRC shall the operator be returned n 4:$ t WM-Y i to normal licensed duties. '":4 ,e fj 2.8 Newly Licensed Operators p 4.. w -s ttj j Newly licensed operators, upon receipt of their Itcense, shall + 7d. wzat enter the program and participate in the annual program cycle. W" "\\ New operators receiving their NRC license less than six months gy ,b FN [', 7 prior to the annual evaluation examination will be required to % ~' (rpifj attend the appropriate OR and FSR Programs but will be excused from k,_, -s tihjd,, * ' taking the current annual evaluation examination. However, he will i ,g ~
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be responsible for taking all other annual evaluation examinations. h ..:n - g g w,u i,'7#R-g r-3.0
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RESPONS!BILITIES - REQUALIFICATION PROGRAM ADMINISTRATION %a.. [c
- 8 m-s 3.1 The Supervisor of Training and his staff are responsible for:
g> K-1. Assigning instructors for the OR lectura series. 2. Determining FSR assignments for individual operators. h _,.# 3 3. Maintaining and reviewing all records. c. . meu 4c ( -4. Assigning deficiencies, determining appropriate action to M,;71 q., 34
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s ~+ k % % 4 1006 [ levision 2 04/11/77 i 5. Arranging accelerated requalf fication programs as may be yrp u,~- necessary. ?' 4. ~ Deffntng oral evaluation procedures. I I 7. Scheduling necessary simulator time. 8. Prepare license appiteations for Itcense renewal. g 3.2 The Supervisor of Operations, Supervisor of Training, or other ~ [: suitably quelfffed person designated by the Unit Superintendent is L p respensible for: F r 1. [ Evaluation of on-the. job pstformance of all license holdars. F 2. Meeting with Itcense holdars n.ho receive unsatisfactory annual y g evaluation exaatnatfor[ grades. b ,f 3. Certifying operator qualificattaa when returning from a four k month absence from operation. e 4. Constructing annual written evaluation e.xastnation, answers and grade key. 5. Grading of the annual written exarnination. 1-z;.. -7 y >,e ,v, " *g; e, mp 9 .,M 4 A
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