ML20128G617

Discusses Evaluation of Requalification Program & Licensed Personnel Scheduled for Wk of 930607.Ref Matls Encl

ML20128G617
Person / Time
Site:	Byron
Issue date:	02/08/1993
From:	Ring M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Delgeorge L COMMONWEALTH EDISON CO.
References
NUDOCS 9302160059
Download: ML20128G617 (13)

Text

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EEB - 81993 Docket No. 50-454.

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Docket No. 50-455

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Commonwealth Edison Company I

ATTN:

Mr. L.

O.

DelGeorge, Vice President-l Nuclear Oversight and Regulatory Services Executive Towers West III 1400 Opus Place, suite 300 Downers Grove, IL 60515

SUBJECT:

REQUALIFICATION PROGRAM EVALUATION In a telephone conversation on February 3, 1993, Mr.

L. Bunner and Mr-J.

Lennartz arranged to evaluate the requalification program and licensed personnel at the Byron Nuclear Station.

The evaluation is scheduled for the week of June 7,.1993.

NP' examiners 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 ersminees are familiar with these standards.

For the NRC to adequately prepare for this evaluation, the facility licensee will need to furnish the NRC the_approvedlitems listed in Enclosure 1, " Reference Material Guidelines." -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-L described in this letter.

Please review the guidance promulgated 'in Revision 7: to t

NUREG-1021 on the content and scope of simulator examination L

scenarios.

The scenario examination bank'should cover the entire L

spectrum.of' emergency operating procedures (EOPs), including 1 l

alternative decision paths within_the EOPs,:and:it should

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incorporate a range of failures with various degrees-of severity.

i for.the same type of event.

Each' scenario-should contain simultaneous events that' require the senior reactor operator (SRO)Lto prioritize his/her actions and to assign other crew members particulae tasks.- Each scenario should_also require the

.SRO to decide whenLto transition between EOPs and decide which actions to take within EOPs.

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FEB - 8 $33 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 oy 10 CFR 55.53 (e) or (f) from the Byron Nuclear Station operations department.

You sre encouraged t; designate _a second-employee from the training stSff to be a member of the examination team.

This employee should also be a licensed SRO, but may be a certified ins ructor.

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 of these indi=lduals will be subject to the examination security agreement.

The NRC restricts any facility 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 (s) will be present.

These restrictions apply from the day that the facility licensee representative signs the examination security agreement indicating that the representative understands that he or she has specialized knowledge of the examination.

The chief examiner will 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; he*ever, 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 licensees, including crew composition, for the examination.

The facility licensee training staff should send this information.

directly to the NRC's chief examiner.

The facility licensee may request that the NRC chief examiner or another NRC representative meet with the licensees.to be_ examined and the~ licensee managers during the examination preparation week, normally 2 weeks-before the examination.

However, if the

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FEB - 8 893 schedulu does not allow them to meet during the preparation week, they may meet at any mutually agreeable time.

The NRC examiner-will explain the examination and grading processes and will respond to any questions that licensees may have about NRC's examlnation procedures.

The facility licensee training staff should cchedule 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.

The NRC requests that this feedback form be

,1 completed by all operators, evaluators, and facility licensee

!f representatives participating in the NRC requalification-H examination, 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.,

" 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 simulator examination process at the site.

The request for requalification examination materjal is covered by Office of Management and Budget Clearance Number 3150-0101, which expires October 31, 1995.

The estimated average burden is g

7.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per response, including 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, DC 20555; and to the Paperwork Reduction Project (3150-0101), Office of Information and Regulatory Affairs, NEOB-3019, Office of Management and Budget, Washington, DC 20503.

The request for responses to the Requalification Feedback Form is

.f covered by Office of Management and Budget Clearance Number 31'0-0159, 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.

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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, NFOB-3019, Office of'Managementfand Budget ~

Washington,-DC 20503.

1 Thank you for your cooperation in this matter.

Mr. Dunner has' i

been advised of the NRC guidelines and policies-addressed in this letter.

If you have any questions on the evaluation process, please contact Mr. C. Osterholtz at (708) 790-5293 or me at (708) 790-5602.

Sincerely, Original signed by Mark A _ Ring-l Mark A.

Ring, Chief Operations Branch 1

Division of Reactor Safety i

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Enclosures:

1 1.

Reference' Material Guidelines a

2.

Administration of'Requalification

Examinations

'3.

-Requalification Examination Feedbacki Form See Attached Distribution

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FEB - 8193 Distribution cc w/ enclosures:

K. Graesser, Site Vice President PWR Operationn K. Schwartz, Station Manager D. Brindle, Regulatory Assurance Supervisor _

D.

Farrar, Nuclear Regulatory Services Manager DCD/DCB (RIDS)

OC/LFDCB Resident Inspectors, Byron, Braidwood, Zion Richard Hubbard J. W. McCaffroy, Chief, Public.

Utilities Division Diane Chavez, DAARE/ SAFE Robert Newmann, Office of.Public Counsel, State of1 Illinois Center Robert M. Thompson, Administrator Wisconsin Division of Emergency Government State Liaison Officer A. Chernick, Training Manager cc w/o enclosures:

- R. M. Gallo, Branch Chief, OLB J.

B. Hickman, Project Manager, NRR M. J.

Farber, Section Chief, DRP i:

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l ENCLOSURE 1 Reference Material Guidelines 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 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 E5-603.

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.

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 appilcable industry 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 examination am program evaluation visits, the facility shall:

Submit an Examination Sample Plan which meets the requirements of ES-601, Attachment 2; L-__-__-_-_-____

ENCLOSURE 1 (Cont'd)

Provide the associated examination banks (written, simulator and JPM) and associated reference material.-

At a minimum, the reference material.should include Technical Specifications, abnormal and emergenny.

operating procedures, and emergency plan procedures utilized in.the requalification training; and Provide additional reference material as requested by e

the NRC chief examiner.

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.m ENCLOSURE 2 Administration'of Requall'fication 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.examinationLis 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' development.

The chief _ examiner and the facility representatives will agree on the dates and duration of time needed-to develop the examinations.

3.

The chief examiner vill review the reference material used in the simulator.-

The NRC will not authorize the'use ofz reference material that is not normally used for plant operation in the control room to be used-during the simulator test 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 faciliti'es will be located to prevent the examinees from contacting al]

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other facility and contractor personnel during_the examination.

5.

The chief examiner will inspect the examination room ~to see-that it-meets tho' minimum standard that will ensure examinationfintegrity..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 examinea forESection.B of thel written examination.

The material shouldiinclude documents that are normally_available to the. licensees in the control-room-such-as the technical. spec.ifications, operating and abnormal' procedures,-administrative procedures, and the-emergency plans..

The chief-examiner will review the reference material before-the examination begins.

7.

The NRC requalification examination-will_ attempt _to distinguish-between'RO' and SRO knowledge and abilities to

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' tent that the facility training materialsEallow'the deve.cpers to make these' distinctions.

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' ENCLOSURE 2 (Cont'd)-

8.

Prudent scheduling of examination week activities is important to help al)eviate undue stress on the. licensees.

The facility training staff and the NRC chief examiner-should attempt to. formulate a schedule that will minimize delays while conducting the examination.

The following are some suggestions for structuring the-examination activities to achieve.this objective:

Bring in~ licensees in accordance with their scheduled examination times.

It is better to segregate the group.of licensces completing their examination,_instead of the group of licensees that-are scheduled to start their examination.

Following simulator scenarios, the facility evaluatcrs 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 scenarios.

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 examinaticns.

If the facility licensee. requests to videotape the examination,-any use of the tape must be completed before the NB2 leaves the site at the end of the examination. LIf a disatceement over.the grading of a licensee still exists at the end of the

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examination week, the facility licensee may retain-the tape for the purpose of subml.tting it.to support a request for regrade by the NRC.

Dur,4 ng the regrade, thn LNRC vill 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 licensco is expected to erase-all video _ tapes-made.during the examination.

ENCLOSURE 3 REOUALIFICATIQ1{ EXAMINATION FEEDBACK FORM Introduction Tlus 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 facilityLlicensee's efforts tol 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."

Jnstructions 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 administerea by Region III at J. facility licensee)'during (exam dates); however, comparisons ~with previous examinations may be appropriate.

Any examinee or individual involved in the development'or--

e-administration of this-examination-in encouraged toicomplete-this form.

Mail completed forms to:-

U.S. Nuclear Regulatory Commission

-e Region _III ATTN: -Mark A.

Ring, Chief Operations Branch 799 Roosevelt-Road Glen Ellyn, Illinoi's.-60137 Your Backcround Please check the boxes that describe your' involvement in this

' examination.

I was:

-an' examinee involved in developing'the examination

-involved in~ administering the examination-int examination observer 4

other:

l ENCLOSURE 3 (Cont'd)

Please check the boxes that describe your current position.

(Check all that apply)

RO SRO operating crew member training department operations department other:

Strqns vs. Undue Stress The following q'lestions 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, dndue stress is unnecessary or inappropriate stress which can be practically eliminated without compromising the validity of the examination.

The distinction between strecs 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 Aliminate the cause of the stress without compromising the validity of the examination?

If your answer in no, then no undue stress was present.

(See point #1 on the rating scale 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.

(See point #2 on the rating scale below.)

The alternative is that the source may be unnecessary and also of sufficient magnitude to be likely to affect an individual's performance in the examination.

(Sec.

point #2 on the rating scale below.)

Ratina Scale:

1.

No undue stress 2.

Some undue stress Inappropriate stress was present t?.at could have been practically avoided but would,nct likely affect an individual's examination performance.

f 3.

Significant undue stress Inappropriate stress was present that could have been practically avoided, and it would likely affect an individual's examination performance.

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." 7 ENCLOSURE.3 (Cont'd)

ExamiDallon Feedback Ratings:

Please use the rating scale described on the preceding page to indicate your judgme.it of-the degree of undue stress that.was present in each aspect.of the..

examination identified below.

Write the number-(1, 2,

or 3) 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 ~

additional sheets if necessary.

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ENCLOSURE 3 '(Cont'd)

Pre-examination Interactions with NRC Comments:

Written Examination:

Administrative Controls / Procedural-

-Limits Comments:

Dynamic Simulator comments:

r Job Performance Measures comments:

i; Please comment on any practices which you believed were successful:in reducing undue stress.

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Your cooperation in completing this-form is appreciated.

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