ML20062E909
| ML20062E909 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/03/1990 |
| From: | Curtiss J NRC COMMISSION (OCM) |
| To: | Holmes K GEORGIA POWER CO. |
| Shared Package | |
| ML20062E904 | List: |
| References | |
| NUDOCS 9011260184 | |
| Download: ML20062E909 (3) | |
Text
-
TD
$M%jM ki.
c ' *. ? f"#
UNITED STATES
%D NUCLEAR REGULATORY COMMISSION JL - -
y W ASHINGTON, D.C. 20665 f
j f
October 3, 1990 OF FICE OF THE to n. g%
{p p
COMMISSIONE R 4~,
- V (g och -d W
Cui ( 7 Kenneth R. Holmes uo Manager
'T Plant Training and Emergency Preparedness l
Georgia Power Company P.
O.
1600 Waynesboro, GA 30830 Dear Ken When I was at the Vogtle site on August 21, 1990, you-and various members of your staff expressed concerns about the NRC's operator requalification examination process and, specifically, the frequency with which NRC's operator licensing examiner standards contained-in NUFG-1021 were being revised, including " pen and ink" changes to the standards made by NRC examiners.
You indicated that frequent revisions to the standards were extremely frustrating to your organization, because incorporation;of the revised standards into the requalification training program and the preparation of examinations requires considerable lead-time l4 and-effort.
You specifically noted that at a recent NRC/ industry workshop =in the spring of 1990, which was held to discuss
. Revision 6 of the examiner standards, the staff indicated that Revision 7-to.the standards was " waiting in the wings".
This announcement, I understand, added to your concern, since my return from Vogtle, I have checked further-on'the
- concerns that you raised to determine what, if anything, needs to be done to ensure that licensees are given ample time to comment on,..and implement, revisions to the examiner standards.
I. share-the following with you:
=As with any new endeavor of this magnitude, early on in the
+
implementation-.of the revised requalification process the NRC-learned a nutber of lessons'about how to go about most effectively implementing this process.
Accordingly, substantial
' changes,were made to the examiner-standards, incorporating these various lessons.
In each case, the revisions were preceded by an opportunity for.the industry to comment.
Between revisions 5 and
-6:of the examiner standards, however, the NRC headquarters operator licensing organization issued two errata sheets to the NRC regional offices and to all licensees.
The errata sheets were not subject to industry review and comment and did not specify implementation dates.
As a result, implementation in_the 9011260tBf 901114 PDP ADDCP 05000424
\\
PNU 1
s Kenneth R. Holmes October 3, 1990 Page 2 of 3 field by NRC examiners occurred at various times -- much to the surprise of some licensees.
The NRC staff recognizes that this caused considerable confusion and frustration with licensees and NRC examiners and I have been advised that because of this problem, such informal revisions to the examiner standards will not be issued in the future.
Currently, it is expected that the examiner standards will be revised on an 18-month cycle, based upon lessons learned during the actual administration of exams and industry comment.
The 18-month frequency has been established to ensure that improvements identified by both the NRC and industry are incorporated in a timely manner and, at the same time, provide sufficient time for licensees to implement the revisions.
When the staff initially issues a revision to the examiner standards in draft form, it will be subject to industry comment and then revised and reissued in final form.
This part of the process will take anywhere from three to six months.
When the re"ision is reissued in final form, an implementation date will be established, typically about 3 months later.
Licensees who, after the implementation date, roccive the usual 90-day letter announcing the NRC's intent to administer requalification examina-ions will be required to comply with the revised standards.
Thus, the time from final issuance of the revised standards to administration of the first exams where compliance with the revised standards will be mandatory will be approximately 6 months.
Licensees may, of course, implement revised standards earl!cr on a voluntary basis.
With respect to revision 7 of the examiner standards, it is my understanding that this revision will primarily address changes to the initial examination process and Dat the requalification process.
The initial examination process will employ job performance measures similar to those that have been tried and proven successful in requalification exams.
I understand that the industry has been highly supportive of this initiative.
Revision 7 will be subjected to the review and comment process described above.
Additionally, in parallel with review and comment, revision 7 will be implemented on a pilot basis, similar to the way that revision of the requalification examination process was handled.
Consistent with the 18-month revision cycle, revision 7 is not scheduled to be issued in final form until January 1992, at the earliest.
I trust that this information responds to the concerns that you raised.
I appreciate your bringing this matter to my attention.
If you have any further thoughts or questions, please feel free to contact me or the staff.
I firmly believe that with continued
.o
.n 9
Kenneth R. Holmes October 3, 1990 Page 3 of 3 dialogue on this most important subject, we can continue to improve the process for administering operator licensing examinations, in a manner that will provide the necesr,ary stability for the industry while, at the same time, perritting continued refinement and improvement in the process.
Most sincerely, t
L s
mes R.
Curtiss