ML20058C185
| ML20058C185 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 11/22/1993 |
| From: | Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cottle W HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 9312020373 | |
| Download: ML20058C185 (11) | |
See also: IR 05000498/1994002
Text
UNIT E D STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DRIVE, SUIT E 400
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AR LINGT ON, T EXAS 76011-8064
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Dockets:
50-498
50-499
Licenses:
NPF-80
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Houston Lighting & Power Company
ATTN: William T. Cottle, Group
Vice President, Nuclear
P.O. Box 289
Wadsworth, Texas 77483
SUBJECT: REQUALIFICATION PROGRAM EVALUATION AT SOUTH TEXAS PROJECT STEAM
ELECTRIC STATION NRC INSPECTION REPORT NO. 50-498/94-02;
50-499/94-02
In a telephone conversation on October 26, 1993, Mr. J. Pellet and
Mr. G. Weldon arranged to evaluate the requalification program a.nd licensed
personnel at the South Texas Project Steam Electric Station. The evaluation
is scheduled for the weeks of March 21 and 28, 1994. NRC examinars and
evaluators from your facility will conduct requalification examinations, and
the NRC will evaluate the facility licensee's requalification program in
accordance with Sections ES-601 through ES-604 of NUREG-1021, " Operator
Licensing Examiner Standards," Revision 7.
You are encouraged to ensure that
your training staff and proposed examinees are familiar with these standards.
If 10 CFR 55 is revised before the start of the requalification examinations
such that individuals are no longer required to pass an NRC administered
examination as a condition of license renewal, then these examinations may be
cancelled and the licensed operator requalification program would then be
evaluated by a training inspection.
For the NRC to adequately prepare for this evaluation, the facility licensee
will need to furnish the NRC the approved items listed in Enclosure 1,
" Reference Material Requirements." You are also requested to submit, at your
option, a proposed examination for use during the examination week; however,
if you do submit a proposed examination, the personnel participating in its
development may become subject to the security restrictions described in this
letter.
Please review the guidance promulgated in Revision 7 to NUREG-1021 on the
content and scope of simulator examination scenarios. The scenario
examination bank should cover the entire spectrum of emergency operating
procedures (EOPs), including alternative decision paths within the E0Ps, and
it should incorporate a range of failures with various degrees of severity for
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the same type of event.
Each scenario should contain simultaneous events that
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require the senior reactor operator (SRO) to prioritize their actions and to
assign other crew members particular tasks. Each scenario should also require
the SRO to decide when to transition between E0Ps and decide which actions to
take within E0Ps.
You are requested to designate at least one employee to be a member of a joint
NRC-facility examination team. The employee is expected to be an active
senior reactor operator (SRO) as defined by 10 CFR 55.53(e) or (f) from the
South Texas Project Steam Electric Station operations department. You are
encouraged to designate a second employee from the training staff to be a
member of the examination team. This employee should also be a licensed SRO,
but may be a certified instructor.
If desired and agreed to by the chief
examiner, you may designate one additional employee from the training staff
with appropriate qualifications to be a member of the examination team.
In
addition to these individuals, you will need to designate a simulator operator
for scenario preview and validation during the on-site examination preparation
week.
In some cases, you may need to designate a simulator operator during
the test item review period. All these individuals will be subject to the
examination security agreement.
The NRC restricts any facility licensee representatives under the security
agreement from knowingly communicating by any means the content or scope of
the examination to unauthorized persons and from participating in any facility
licensee programs such as instruction, examination, or tutoring in which an
identified requalification examinee will be present.
These restrictions apply
from the day that the facility licensee representative signs the examination
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security agreement indicating that the representative understands that he or
she has specialized knowledge of the examination. The chief examiner will
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determine when a facility licensee representative has received specialized
knowledge concerning the examination and will execute an examination security
agreement.
In most cases, the examination team members will not be required
to enter into an examination security agreement more than 60 days before the
examination week. The simulator operator will normally become subject to the
security restrictions during the examination preparation and validation week;
however, this may occur as much as 45 days before the examination week.
Sixty days before the examination administration date, please provide the NRC
Regional Office with a list of proposed examinees, including crew composition,
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for the examination and the current mailing address for each proposed
licensee, if different from that listed on the most recent Form 398 submitted
to the NRC. The facility licensee training staff should send this information
directly to th NRC's chief examiner, ensuring that each licensee address is
sent in a manv 7
9 ensure privacy.
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The facility licen..ee may request that the NRC chief examiner or another NRC
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representative meet with the licensees to be examined and the licensee
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managers during the examination preparation week, normally 2 weeks before the
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examination. However, if the schedule does not allow them to meet during the
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preparation week, they may meet at any mutually agreeable time. The NRC
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examiner will explain the examination and grading processes and will respond
to any questions that licensees may have about the NRC's examination
procedures. The facility licensee training staff should schedule this
meeting, if it is desired, with the NRC chief examiner.
The facility licensee is requested to distribute the "Requalification
Examination Feedback Form," attached as Enclosure 3.
The NRC requests that
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this feedback be completed by all operators, evaluators and facility licensee
representatives participating in the NRC requalification examination,
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including facility licensee managers.
The results from this survey will be
used to measure the success of the NRC and facility licensee's efforts to
reduce undue stress during the requalification examination.
The facility licensee staff is responsible for providing adequate space and
accommodations to properly develop and conduct the examinations. Enclosure 2,
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" Administration of Requalification Examinations," describes our requirements
for developing and conducting the examinations. Also, a facility operations
management representative above a shift supervisor level should observe the
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simulator examination process at the site.
The request for requalification examination material is covered by Office of
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Management and Budget (0MB) Clearance Number 3150-0101, which expires October
31, 1995.
The astimated average burden is 7.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per response, including
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gathering, copying and mailing the required material. Send comments regarding
this burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, to the Information and Records
Management Branch, MNBB-7714, Division of Information Support Services, Office
of Information Resources Management, U.S. Nuclear Regulatory Commission,
Washington, D.C. 20555; and to the Paperwork Reduction Project (3150-0101),
Office of Information and Regulatory Affairs, NE0B-3019, Office of Management
and Budget, Washington, D.C. 20503.
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The request for responses to the Requalification Feedback Form is covered by
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Office of Management and Budget Clearance Number 3150-0159, which expired
February 28, 1992. A request for a clearance revision has been submitted to
OMB and is expected to be granted. The estimated average burden is 30 minutes
per response, including copying, and mailing the completed responses.
Send
comments about this burden estimate or any other aspect of this collection of
information, including suggestions for reducing this burden, to the Records
and Reports Management Branch, MNBB-7714, Division of Information Support
Services, Office of Information Resources Management, U.S. Nuclear Regulatory
Commission, Washington,'DC 20555; and to the Paperwork Reduction Project
(3150-0159), Office of Information and Regulatory Affairs, NE08-3019, Office
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of Management and Budget, Washington, DC 20503.
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Thank you for your cooperation in this matter. Mr. Weldon has been ' advised of
the NRC guidelines and policies addressed in this letter.
If you have any
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Houston Lighting & Power Company
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questions on the evaluation process, please contact Mr. J. Pellet, Chief,
Operations Section.
Sincerely,
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Division of Reactor Safety
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Enclosures:
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Reference Materials Required
2.
Administration of Requalification Examinations
3.
Requalification Feedback Form
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Houston Lighting & Power Company
ATTN: Mark Ludwig, Manager
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Nuclear Training
P.O. Box 1700
Houston, Texas 77251
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DRS (J. L. Pellet).
Projc:t Engineer.(DRP/0)
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Lisa Shea, RM/ALF, MS: MNBB 4503
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Enclosure 1
Reference Material Guidelines
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1.
Provide test items to support all aspects of the requalification
examination to the NRC 60 days before the examination date.
2.
The following reference material:
A minimum of 700 test items for use in the written examination equally
divided between the two sections of the written examination and which
cover all safety-related elements of the facility job-task analysis (JTA).
The facility licensee is expected to maintain a dynamic bank by reviewing,
revising or generating at least 150 questions a year.
New questions
should cover equipment and system modifications and recent industry and
licensee events-and procedural changes.
JPMs to evaluate each reactor operator and senior reactor operator safety-
related task identified in the facility JTA, which meet the criteria in
ES-603. The JPM bank should expand at a rate of at least 10 JPMs per year
until this goal is reached. It is estimated that 125-150 JPMs will be the
final result.
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A bank of at least 30 simulator scenarios which reflect all abnormal and
emergency situations to which a licensee is expected to respond or
control.
At least 5 scenarios per year should be generated until all-
aspects of the emergency operating procedures are covered with sufficient
variation in the type and scope of initiating events- and level of
degradation.
Emphasis should be placed on scenarios that include
applicable incostry events.
These target levels are expected to be attained by the facility licensees
on 10/1/95, five years after the implementation of Revision 6 of NUREG-
1021 (10/1/90).
3.
For all licensee requalification enr ination and program evaluation
visits, the facility shall:
Submit an Examination Sample Plan which meets the requirements of
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ES-601, Attachment 2;
Provide the examination banks (written, simulator and JPM) and
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associated reference material. At a minimum the reference material
should include Technical Specifications, abnormal and emergency
operating procedures, and emergency plan procedures utilized in the
requalification training.
Provide additional reference material as requested by the NRC chief
examiner.
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Enclosure 2
Administration of Requalification
Examinations
1.
The NRC must evaluate at least 12 licensees to perform a program
evaluation. Normally, the decision to select a licensee or crew for the
requalification examination is based on license renewal needs.
The
requalification examination may also include other licensees who are not
routinely performing shift duties or are not maintaining an active license
as defined in 10 CFR 55.53(e).
The restrictions on crew composition in
the simulator are described in ES-601 Section C.2 and ES-604.
2.
The simulator and simulator operators need to be available for examination
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development.
The chief examiner and the facility representatives will
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agree on the dates and duration of time needed to develop the exami-
nations.
3.
The chief examiner will review the reference material used in the
simulator. The NRC will not authorize the use of reference material that
is not normally used for plant operation in the control room to be used
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during the simulator test.
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4.
The facility licensee will provide a single room for completing Section B
of the written examination. The examination room and the supporting rest
room facilities will be located to prevent the examinees from contacting
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all other facility and contractor personnel during the examination.
5.
The chief examiner will inspect the examination room to see that it meets
the minimum standard that will ensure examination integrity.
The minimum spacing standard consists of one examinee per table and a
3-foot space between tables.
No wall charts, models, or other training
materials are allowed in the examination room.
6.
The facility licensee is expected to provide a copy of each reference
document for each examinee for Section 8 of the written examination. The
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material should include documents that are normally available to the
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licensees in the control room such as the technical specifications,
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operating and abnormal procedures, administrative procedures, and the
The chief examiner will review the reference material
before the examination begins.
7.
The NRC requalification examination will attempt to distinguish between R0
and SR0 knowledge and abilities to the extent that the facility training
materials allow the developers to make these distinctions.
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Enclosure'2'
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Prudent scheduling of examination week activities- is important to help -
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alleviate undue stress on the licensees. The facility training' staff and
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the NRC chief examiner should attempt to formulate a schedule that will
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minimize delays while conducting the examination.-
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The following are some suggestions - for structuring the examination
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activities to achieve this objective:
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Bring in licensees in accordance with their scheduled examination -
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times.
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It is better to segregate the group of licensees completing their -
examination, instead of the group _of licensees that are scheduled.to
start their examination.
Following simulator scenarios, the facility evaluators and NRC
examiners should quickly determine whether follow-up questioning is
required so that the crew members may be . released .to talk -among
themselves about the scenario.
Ensure that time validation of JPMs, particularly those performed in
the ' simulator, is accurate.
Establish a reasonable schedule to
prevent licensees from waiting _ for~ . simulator availability to
complete their JPMs.
9.
The NRC no longer requires the facility licensee to videotape dynamic
simulator examinations. .If the facility licensee'~ requests to videotape-
the examination, any use of the tape. must be completed before the NRC-
leaves the site at the end of the examination. If a disagreement over the
grading of a licensee still exists at the end of the examination week,-the
facility licensee may retain the tape for the purpose of submitting it to
support a request for regrade by the NRC. 'During.the regrade, the NRC.
will review only the portion of the videotape under contention.
After
all requalification examination grades are finalized, including the review
of any regrade requests, the facility licensee is expected to erase all
video tapes made during the examination.
Requalification Examination
Attachment 1
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Feedback Form
Enclosure 3
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Introduction
The NRC is requesting feedback regarding the conduct of requalification examinations. The
information provided will be used to monitor, on a generic basis, the effectiveness of the
NRC's and facility licensee's efforts to minimize undue stress in the examination process.
This form is not intended as a means of resolving technical or process concerns pertaining
to a specific examination.
Such concerns will be resolved using the guidance in NUREG-
1021, " Operator Licensing Examiner Standards ,
Instructions
Completion of this form is voluntary.
If you choose to provide feedback, please answer
the questions in accordance with these instructions:
The questions in this form regard the examination administered by Region IV at your
facility during the current examination set; however, comparisons with previous
examinations may be appropriate.
Any examinee or individual involved in the development or administration of this
examination is encouraged to complete this form.
Mail completed forms to:
U. S. Nuclear Regulatory Commission Region IV
ATTN: J. Pellet, Chief, Operations Section
611 Ryan Plaza Drive, Suite 400
Arlington, Texas 76011
Stress vs. Undue Stress
The questions require you to make a judgment of whether there was undue stress during the
examination.
Examinations are inherently stressful events and therefore it is important
that you make a distinction between stress and undue stress when making your judgments.
Undue stress is unnecessary or inappropriate stress which can be practically eliminated
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without compromising the validity of the examination. The distinction between stress and
undue stress is not a matter of whether the stress was extreme or mild. When making your
judgments you should follow these steps:
First, consider the cause of the stress. Would it have been possible and practical
to eliminate the cause of the stress without compromising the validity of the
examination? If your answer is no, then no undue stress was present (#1 below).
If your answer is yes, consider the magnitude of the stress. A source of stress may
be unnecessary but also sufficiently small in magnitude to be unlikely to affect an
individual's performance in the examination (#2 below).
The alternative is that the
source may be unnecessary and also of sufficient magnitude to be likely to affect an
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individual's performance in the examination (#3 below).
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Ratina Scale:
1.
No undue stress
2.
Some undue stress. That is, inappropriate stress was present that could have been
practically avoided but would not likely affect an individual's examination
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performance.
3.
Significant undue stress.
That is, inappropriate stress was present that could have
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been practically avoided and it would likely affect an individual's examination
performance.
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Your Backoround:
Please check the boxes that describe your involvement in this examination.
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I was:
an examinee
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involved in developing the examination
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involved in administering the examination
an examination observer
other:
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Please check the boxes that describe your current' position-(Check'all that apply):
R0
SR0
operating crew member
training department
operations department
other:
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Examination Feedback:
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Ratinos:
Please use the rating scale described on the preceding page to indicate your
judgment of the degree of undue stress that was- present .in each aspect of the
examination identified below.
Write = the number (1, 2, or13) in .the _ space-
preceding the section.
Comments:
Please comment about the source or cause of any undue stress, including who was
affected (e.g., examinees, examiners) and suggested practical solutions. Attach
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additional sheets if necessary.
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Preexamination Interactions with NRC
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comments:
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Written Examination: Administrative Controls / Procedural Limits
Written Examination: Plant and Control Systems
Comments:
Dynamic Simulator
Comments:
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comments:
Please comment on any practices which you believed were successful in ' reducing undue stress.
Your cooperation in completing this form is appreciated.
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