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Ack Receipt of & Expresses Appreciation for Opportunity to Address Professional Reactor Operator Society Meeting on 900721
	ML20062F023
Person / Time
Issue date:	11/16/1990
From:	Carr K; NRC COMMISSION (OCM)
To:	Gray C; PROFESSIONAL REACTOR OPERATOR SOCIETY
Shared Package
ML20062F029	List: ML20062F023; ML20062F031;
References
	NUDOCS 9011270046
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UNITED $TATES

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NUCLEAR REGULATORY COMMISSION l

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W ASHING ton, D. C. 20566 o

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November 16. 1990 CHAIRMAN Mr. Carl M. Gray, President Professional Poactor Operator Society 1015 Nucicar Road Mishicot, Wisconsin 54228

Dear Mr. Gray:

I am writing to acknowledge receipt of your letter of September

20. 1990, and to thank you for the opportunity to addrett your organization.

I found the experience of speaking to the Prof essional Reactor Operator Society (PROS) very enjoyable.

In that regard. I have atteched supplemental responses to specific questions asked at the July 21, 1990 meeting (as reported in your recent newsletter) and other information relevant to those ques-tions.

In addition, I have enclosed a copy of the Chernobyl Hotebook referred to during the meeting.

The Commission appreciates the concerns you conveyed in ycur letter regarding the administration of requalification examina-tions.

I know y:u recognize that a certain amount of stress can be expected f rom any testing process or emergency operational situation.

Nevertheless, our headquarters Operator Licensing Branch is continuing to work with our regional offices and the industry to eliminate any unnecessary pressure that might be placed on reactor operators during the examination process.

The Nuclear Regulatory Commission (NRC) staff is also committed to the identification and resolution of inconsistencies in the operator licensing examination process and appreciates the f_eedback that facility representatives and operators have provided'in this area.

You also expressed a desire to establish a._ working relationship between your organization and the NRC.

We agre9 that continuing communication would be mutuelly beneficial, and.have requested L

Mr. Jack Roe, the Director of the Division of Licensee Performance l

and Quality Evaluation, to contact you to discuss impra ing l

communication channels.

Your comments ~have helped to focus attention on the importance of stability and consistency in the examination process to eliminate unnecessary stress experienced by reactor operators during-examinations.

The NRC staff appreciates your constructive feed-back and will follow up to both correct inconsistent examination practices and improve the quality of the NRC requalification

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i I want to commend the Society for the significant contribution:it j

is making toward' promoting professionalism in reactor operators t

and look forward to future interactions with PROS..

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e Sincerely,

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Kenneth M. Carr i

Enclosures:

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J Responses to Questions to Chairman Carr at the l

Professional Reactor Operator Society (PROS) liceting Boston, Massachusetts July 21, 1990 Ouestion:

In 1984, the NRC did a study on ways of getting direct operator feedback. Apparently, this study did not go very far because utilities did not want that kind of relationship between the operators and the Comission.

What happened to that study?

Answer: The NRC conducted three Operator feedback Workshops in Chicago, Boston, and Atlanta during the period December 1981 to May 1982. A fourth workshop was planned, but was never held for several reasons.

Participation was limited (a total of 60 attendees, representing about 38 plant sites), and a mail survey technique had been developed that provided a more cost-effective method o' receiving operator feedback.

The reports of both feedback efforts are enciosed.

(NUREG/CR-3730, "The Operator Feedback Workshop: A Technique for Obtairing Feedback from 0)erations Personnel," and NUREG/CR-4139, "The Mailed Surve/: ATechniquefor0)tainingfeedcackFromOperationsPersonnel.").

In 1989, a broad-based Regulatomy impact Survey was conducted by NRC teams going to 13 utilities and talking with operators, engineers, managers, and CEOs about their perceptions of the NRC.

A draft report on the results of the survey was published as NUREG-1395.

On page x::x of the report; the staff noted that " Operators had strong views on the need to further improve the quality of operator licensing examinations; the continuing changes to and stress asso-ciated with the operator licensing training and examination process; the complicating effects that continuing plant modifications have on operator performance; the burden resulting from the complexity and ambiguity of Technical Specifications; and the unnecessary burden of reporting events of marginal safety significance." The staff also noted in their initial assessment of the sumary (page xvi of NUREG-1395) that " licensees stated that operators are not permitted to function in the simulator examination process as they normally fbaction while on shift, examiner standards are continually char.ging and not uniformly implemented, and too many organizations are involved in tM requalification process " (Copy of NUREG-1395 and SECY-90-080, l

Farc:.3,1990, enclosed.)

in 1990, a specific survey of use of management time was-conducted via Generic Letter No. 90-01, January 18, 1990.

Forty-four out of fifty-four utilities responded. The results of this survey were reported to the Comission in SECY-90-205.

(Copy of Generic Letter and SECY-90-205, June 7,1990, enclosed.)

The Commission has considered the results obtained from these surveys, as well as from a companion survey of the NRC staff (SECY-90-250, July 16, 1990, 4

enclosed), and intends to issue the staff's recomended corrective actions for public comment.

A copy of the staff's recomendations, as contained in SECY-90-347, is enclosed, i

Question: Under Rev. 5, NUREG 1021, Examiner Standards, it was quite clear that any questions asked in the field by the NRC examiner or the facility had to be pre-approved by the exam team, which consisted of an operator, a trainer, and a NRC member.

The current revision, which you said takes effect in October, now gives the NRC team carte blanche to ask any question without this prior approval to make sure the exam stays operational oriented as it has in the past.

Based on your conenents, do you think this is the right way to go?

Answer:

In the area of examination ouestion reviews, the Examiner Standards Fnlit change significantly with Revision 6.

Written examination questions are selected mostly (or entirely) from the facility examination bank. Any questions that are changed by the NRC are reviewed by the facility representative on the Examination Team.

The Tetm, including the facility representative, then reviews the complete examinatinn before it is administered, in requalification examinations, tre NRC role is essentially passive during simulator and walk-through portions, which are conducted by the facility evaluator.

NRC examiners are only to ask clarifying questions.

Question: Earlier you mentioned teamwork among the crews. Opposed to that is the adversarial relationship between the operators and the NRC. There appears to be very little teamwork between the reactor operators and the Nuclear Regulatory Commission. We generally hear about NRC rules, desires, or needs in quite round about ways. My experience is that every time this information takes a circuitout path, the message gets changed.

Could there be more straight forward interaction between the operators and the NRC without the interference of management?

Answer:

NRC maintains a mailing list of home addresses for SR0 and R0 license holders. Mass mailings to operator licensees have been made about once per year. The Staff has been alerted to identify items of interest to operators in the future and to send such items to the mailing list. One recurring problem with this system has been a significant rate of undeliverable mail as a result of operators not keeping NRC informed of address changes.

This has become i

increasingly prevalent since the license term went to six years as opposed to two years, PROS could help by requesting operators to keep NRC informed of address changes.

Question: This is just a comment. The worst thin operators was regionalize the examination process.g the NRC did for the When the exam came from headquarters, there was more consistency. We had an exam team that included examiners from two different regions, and the perspective of what was supposed to be done was at opposite ends of the spectrum. This made getting the job done very difficult.

Having given exams before from headquarters was a much l

easier process.

Answer: On June 11, 1990, the Annual Examiners Conference was held in Region V.

All examiners were required to attend. They were brought up to date on Rev. 6 of the Examiner Standards, and minimizing inconsistencies was stressed.

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There is also a weekly conference call with all five NRC Regions to keep them current and to minimize inconsistencies. All examiners are requested to attend thete weekly conference calls. Also, minutes of these calls are published and sent to each examiner, in additien, there is e cuarterly counterpart meeting where Branch Chiefs and Section Chiefs from all NRC Regions got together with Headouarters Branch Chief s and Section Chief s to discuss program guidance and policy.

The Operator Licensing Branch at NRC Headquarters has a Qualification Journal, which contains study requirements end training and qualifications requirements for each new HRC examiner. This provides a consistent approach to train NRC examiners.

As a footnote, about 50% of all NRC examiners have been SR0s.