ML20128N906

Discusses 930217 Telcon Re Arrangments to Evaluate Requalification Program & Licensed Personnel.Evaluation Scheduled for Wks of 930621 & 28

ML20128N906
Person / Time
Site:	Comanche Peak
Issue date:	02/18/1993
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9302240035
Download: ML20128N906 (12)

Text

.

• Q #f o UNIT E D ST AT ES

y. ?g NUCLEAR REGULATORY COMMISSION

, [ ir j ntoloN IV o 8 611 RYAN PLAZA DRIVE, SUITE 400 k s AR LINGT ON, T E XAS 76011 8064

"'* i FEB l 81993 Docket: 50-445 50-446 l Licenses: NPF-87 NPF-88 l

TU Electric I ATTN: W. J. Cahill, Jr., Group Vice President Nuclear Engineering and Operations Skyway Tower 400 North Olive Street, L.B. 81 Dallas, Texas 75201 Centlemer:

SUBJECT:

REQUALIflCATION PROGRAM EVALUATION In a telephone conversation on February 17, 1993, Messrs. John Pellet and Eric Schmidt arranged to evaluate the requalification program and licensed personnel at the Comanche Peak Steam Electric Station. The evaluation is scheduled for the weeks of June 21 and 28, 1993. NRC 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 examinees are familiar with these standards.

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, " Refer-ence Material Requirements." You are also requested te 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 simula'or examination. scenarios. Thc scenario

, ' examination bank shnuld cos e the entire spectrum of emergency operating _

procedures (E0Ps), including alternative decision paths within the E0Ps, and it should incorporate a range of failures with various degrees of severity for

.the same type of event. Each scenario should contain simultaneous events that require the senior reactor operator (SR0) to prioritize their actions and to assign other crew members particular-tasks. Each scenario should also require the SR0 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 SR0 9302240035 930210 7 w p

TO Electric as defined by 10 CFR 55.53(e) or (f) from the Comanche Peak 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

~

licenseo programs such as instruction, examination, or tutoring in which an a identified requalification examinee (s) will be present. These restrictions-apply from the day that the facility licensee re)resentative signs the examination security agreement indicating that tie representative understands j

.that he or she has specialized knowledge of the examination. -The chief examiner will determine when a facility licensee representative has received j specialized knowledge concerning the examination and will execute an i 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 ,t 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 4 regional office with a list of proposed licensees, including. crew composition, for_ the examination and the current mailing address for each proposed l 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-3 directly to the NRC's chief examiner, ensuring that each licensee . address is sent in a manner to ensure privacy. -3 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- a examination. llowever, if the schedule does not allow them to meet during the.  ;

preparation week, they may meet at any mutu' ally agreeable time. The NRC:

examiner will explain the, examination and grading processes and will respond-to any questions that licensees may h' ave about theLNRC's exa'mination

. procedures. The facility licensee training staff 1should schedule this

• meetingt if it is desired, with the NRC chief examint:r.

The facility licensee is requested to distribute the "Requalification

• Examination feedback form," attached as-Enclosure 3. The NRC requests that.

this feedback be completed by all operators, evaluators and facility licensee e

w ,~ m , , - -- - - ,,-~ ,,,,,e - , - -

TV Electric representatives participating in the NRC requalifisation examination, including faci.ity licensee managers, lhe 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,

" 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. ,

This request is covered by Office of Management and Budget (OMB)_ Clearance Number 3150-0101, which expires October 31, 1995. The estimated 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 gathering, xeroxing and mailing-  ;

the requird material. Send comments regarding this burden estimate or any 3 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, NE08-3019, Office of_ Management and-  :

Budget, Washington, D.C. 20503_.

The request.for responses to the Requalification-Feedback formLis covered by j' 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- i per response, including copying, and mail _ing 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 . ,

4 Services, Office of Information Resources Management, U.S. Nuclear Regulatory Commission, Washington, DC 20555; and to the Paperwork Reduction Project- 3 (3150-0159), Office of Information and Regulatory' Affairs, NE0B-3019, Office of Management and Budget, Washington, DC 20503.

Thank you for your cooperation in this matter. .Mr. Schmidt has been advised.

of the NRC guidelines and policies addressed in this letter. If you have any questions on the evaluation process, please contact John Pellet at (817) 860-8159. ..

Si $crely, -

)

Yn Samuel J.

90 ;lt yh*

llins, Direct 6r-  ;

Division f Reactor Safety'

Enclosures:

_(see next page)

i 5

. 3 , .;

. I i

-10 Electric '!

q i

l

Enclosures:

q

1. Reference Materials Required

2. Administration of Requalification i Examinations l

3. Requalification Icedback form cc w/ enclosures: .- :i 10 Electric AT1N: Jerry McMahon Director ,

Nuclear Training l P.O. Box 1002  ;

Glen Rose, Texas 76043-1147

' s.

{

. _ . a _

l l

a E

e

+

' i

\:-

s.

i a

l l- t

l. ,

.lkh ,

e b 10 Electric bec w/ enclosures:

bcc to dist. by RIV:

J. L. Mil oan, RA Resident Office RIV file L. Miller, TTC DRS (J. L. Pellet) L. Hurley CPPD:0SP Reading (MS: 7-H-17) S. McCrory T. Bergman, NRR Project Manager (13-11-15) ,

B. Holian, NRR Project Manager (13-H-15)

Licensee & Debt Collection Branch, ATIN: Leah Tremper (MHBB 4503)-

(bccito DMBL(IE42)!

Chief Examiner Chief Examiner Reading file (C. Gordon)

RIV:C:05/4/ 7 D:DRP ,h , D:DRS rd j JPelleh[chgk ABBea k SJCollins'[ .

fJ'//93 / /93 k/)$/93 ,

230048 .

TV Electric bcc w/ enclosures:

bcc to dist, by RIV:

J. L. Milhoan, RA Resident Office RIV file L. Miller, 1TC DRS (J. L. Pellet) L. Hurley CPPD:0SP Reading (MS: 7-H-17) S. McCrory T. Bergman, NRR Project Manager (13-H-15)

8. Holian, NRR Project Manager (13-H-15)

Licensee & Debt Collection Branch, ATIN: Leah Tremper (MNBB 4503) bec to DMB (IE42)

Chief Examiner Chief Examiner Reading File (C. Gordon)

RIV:C:0524,/ ,0:DRP ,i\, D:DRSf ' d ,

JPelie[c$9k ABBea k SJCollins4

'l /l'l/93 / /93 k/If(/93 3

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 follnwing 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 R0 and SR0 operator safety-related task identified in the facility J1A, which meet the criteria.in E3-603.- The JPM bank should expand at a rate of at least 10 JPMs per yea = 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 app'licable industry events.

These target levels are expected to be attained by the facility licensees on October 1, 1995, 5 years after the implementation of Revisian 6 of NUREG-1021_ (October 1,1990).

3. For all licensee requalification examination and program evaluation visits, the facility shall: '

• Submit an Examination Sample Plan which meets the requirements of ES-601, Attachment 2;

• Provide the _examinat ion banks' (written, simulator and JPM) and -

associated reference material. At a minimum the reference material should includa Technical Specifications, abnormal and emergency operating procedures, and emergency plan procedures utilized in the requalification training; and

• Provide additional reference material as requested by the NRC-chief examiner.

. . . , . = - .,. - - , . . --

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 development. The chief examiner and the facility representatives will agree on the dates and duration ef time needed to develop the examinations.

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 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 restroom facilities will be . located to prevent the examinees from contacting all other f acility and contractor personnel during the examination.

4

5. The chief examiner will inspect the examination room-to see that it meets the minimum standard that will ensure examination inte -ity. 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 B of the written examination.

The material should include documents that- are normally available to the- 1 lice. sees in the control room such as the Technical Specifications,-

operating and abnormal procedures, administrative procedures, and'the energency plans. The chief examiner will review the reference material before the examination begins.

7. The NPC 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.

8. Prudent scheduling of examination week activities is important to help alleviate 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.

-c 2

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

• Bring in licensees in accordance with their scheduled examination times. 3

• 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 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 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.

.i l

L L

a

+

+* - , , - . - ,- ~ .- . _ , . . .. _ ~ .. w 4 ,,v., , , m.--- -, r.~, , , - <

ENCLOSURE 3 REQUALIFICATION EXAMINATION FEEDBACK FORM 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, "Operato Licensing Examiner Standards."

INSTRUCTIONS Completion of this form is voluntary. If you choose to provide feedback, please unswer the questions in accordance with these-instructions:-

• The questions in this form regard the examination administered by (Region) at (facility licenseel during (exam dates); 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: _(NRC Regional Office) '

Lc/o Operations Section Chief)

YOUR BACKGROUND 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 an examination observer other:

Please check the boxes that describe your current position..

(Check all that apply)

• I l

R0 SRO operating crew member l training department I operations depcrtment other:

= - - e , ...r-

STRESS VS. UNDUE STRESS The following 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 unduo stress when making your judgments. Undue stress is unnecessary or inappropriate stress which can be practically eliminated 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. 1 was present. (See point #1 on the rating scale below.)'

If your answer is yes, consider the magn;tude 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 i point #2 on the ratu.g 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. (See point #3 on'  :

the rating scale below.) ,

RATING SCALE:-

1. No undue stress

' 2. Some undue stress inappropriate stress was present that could have been practically avoided but would not likely affect an individual's examination performance. .

3, Significant undue stress ,

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

Examination feedback RATINGS: Please use the rat'ing 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, 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 solution . Attach additional sheets if necessary.

i

_r , m ,A. --.-,4- - - '-- . , . <w , , m-, _

~~# 4. . . _ . .

o

-r Preexamination Interactions with NRC Comments:  ;

Written Examination: Administrative Controls / Procedural Limits Comments: -l i

Written Examination: Plant and Control Systems  ;

r Comments:

Dynamic Simulator -

Comments:

Job Performance Measures Comments: _  ;

~

Please comment on any practices which you believed were successful in reducing undue' stress.

Your cooperation in completing this form is appreciated. '

i

+

L.

l:

1 .

I l:

. - . . , , . -. . , , . . . - - . . . . . . . . . . - . . . . . . . _ . _ _ . .