ML20137M111
| ML20137M111 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1985 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1471, NUDOCS 8512030616 | |
| Download: ML20137M111 (199) | |
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UN11ED STATES "o
NUCLEAR REGULATORY COM1\USSION IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON HUMAN FACTORS O
?.OCATION: WASHINGTON, D. C. PAGES: 1 - 181 DATE: MONDAY, NOVEMBER 25, 1985
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UNITED STATES OF AMERICA
,i y k-) 2 NUCLEAR REGULATORY COMMISSION 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 SUBCOMMITTEE ON HUMAN FACTORS 5 Nuclear Regulatory Commission Room 1046 6 1717 H Street, N.W.
Washington, D. C.
7 M nday, November 25, 1985 8
9 The subcommittee meeting convened at 11:00 a.m., Mr.
10 David A. Ward, chairman of the subcommittee, presiding.
ACRS MEMBERS PRESENT I
12
(} MR. DAVID A. WARD MR. CARLYLE MICHELSON 14 DR. FORREST J. REMICK 15 ;
MR. CHARLES J. WYLIE '
i 16 i
17 KRIS GIMMY, ACRS Consultant 18 JOHN SCHIFFGENS, Assigned ACRS Staff Member 19 20 21 22 23 C) 24 b Federsi Coporters, Inc.
25
l PUBLIC NOTICE BY THE
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UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ,
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MONDAY, NOVEMBER 25, 1985 The contents of this stenographic transcript.of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards .
(ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at
() this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
0 50 01 01 2 MPBeb 1 PROCEEDINGS 2 MR. WARD: The meeting will now come to order.
3 This is a meeting of the ACRS Subcommittee on 4 Human Factors.
5 I am David Ward , the Subcommittee Chairman.
6 Other ACnS members today are Carlyle Michelson, 7 Forrest Remick, and Charles Wylie.
8 Also present is ACRS consultant Kris Gimmy.
9 John Schiffgens, on my right, is the assigned 10 ACRS Staff member for this meeting.
11 The purpose of the meeting is to complete our
(~) 12 review of current reactor operator requalification U
13 procedures, and to initiate review of proposed final 14 rulemaking on 10 CFR Parts 55 and 50, and three related 15 Regulatory Guides, 1.134, 1.149 and 1.8.
16 The meeting will begin with a Subcommittee 17 discussion of reactor operator requalification.
18 Later today and tomorrow, the Subcommittee and 19 the NRC Staff will discuss a proposed rule for revision of:
20 10 CFR 55, " Operators' Licenses;"
21 10 CFR 50, " Domestic Licensing of Production and 22 Utilization Facilities;"
23 Reg. Guide 1.134, " Medical Evaluation of Licensed 24 Personnel for Nuclear Power Plants;"
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25 Reg. Guide 1.149, " Nuclear Power Plant Simulation ACE. FEDERAL REPORTERS, INC.
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0150 01 02 3 1 MPBeb 1 Facilities for Use in Operator License Examinations;"
I \
\"# 2 And Reg. Guide 1.8, " Qualification and Training 3 of Personnel for Nuclear Power Plants."
4 A transcript is being kept of the entire meeting, 5 and I request that each speaker first identify himself or 6 herself and speak with sufficient clarity and volume so that 7 he or she can be readily heard.
8 We have received no written statements from 9 members of the public, nor have we received requests for
, 10 members of the public for time to make oral statements.
2 11 During the first two and a half hours of the 12 meeting, I propose that we have a general discussion among 13 the Subcommittee members and consultant of the operator 14 requalification program. We have had two or three meetings 15 in the past months to gather information on the program.
16 The Staff or some representatives of the Staff are here to 17 answer any questions that we may have, and perhaps to help 18 us with our discussion and understanding.
19 But I don' t propose to have any presentations 20 from the Staff this morning, except I think they will be 21 willing to answer particular questions we may put to them.
22 Our goal is to develop a subcommittee position on the 23 questions that have been raised about operator 24 requalifications. And in fact hopefully at the end of the
() 25 day today, we will spend some time rather specifically ACE FEDERAL REPORTERS, INC.
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0150 01 03 4 MPBeb 1 thinking about what an ACRS letter might look like on the 2 subject.
3 If we do decide that we want to write a letter --
4 and I think we should, I think we owe the Staf f and the 5 Commissioners a report on the topic -- at the December full 6 Committee meeting, we have allotted I think two hours, an 7 hour8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and a half or two hours to this topic, plus 8 letter-writing time.
9 So we will also want to decide today I think 10 during this morning's session what we think the agenda for 11 that one and a half or two hour session for the full 12 Committee should consist of relating to the Staf f, or what 13 it is we would like to have the full Committee hear in order
(' })
14 to bring the full Committee along in understanding, 15 hopefully to support whatever position on requalification 16 the Subcommittee develops.
17 Af ter this time we spend on the requalification 18 program, this afternoon and tomorrow morning we will hear 19 from the Staff at some length on the related subject of the 20 revised rules and the revised Regulatory Guides and some 21 other associated matters related to operator licensing.
22 Some of that will touch on the recualification 23 question, but it is a broader-- The rule changes and 24 Reg. Guides touch on things, operator licensing, more (m
() 25 broadly than this particular requalification question that ACE FEDERAL REPORTERS, INC 202 347-3700 Nationwide Coverage 800 336-6646
0150 01 04 5 MPBeb 1 we want to grapple with this morning. So we have heard a 2 good bit about it in previous meetings.
3 Also since our last meeting on the topic which 4 was -- when? -- in June, I guess, John,--
5 MR. SCHIFFGENS: The 20th.
6 MR. WARD: -- June 20th, I think each of us has 7 had an opportunity to hear a little bit more about 8 requalification. For example, last week when we were at 9 Millstone, we questioned the people at Millstone relative to 10 their experience with the new requalification practices.
11 And I think each of you may have had the opportunity to do 12 that sort of thing.
13 So probably there is some new information we have
(' )
14 since the June meeting.
- 15) DR. REMICK: Can you summarize basically what 16! their response was, Dave? I assume this was to the NRC 17 Administrator.
18 MR. WARD: Yes.
19 DR. REMICK: What kind of reaction was it?
20 MR. WARD: It turns out they have had only fairly 21 limited-- We were up there really to talk about the 22 Millstone 1 permanent license. They haven't had any NRC 23 administrative exams from Millstone 1 but they have had some 24 Millstone 2. It sounds like there haven' t been many, but
() 25 their experience has been, as I say, just fine.
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0150 01 05 6 MPBeb 1 Everything went very well; they experienced no problems, no 2 particular negatives about the program that they expressed 3 to us.
4 MR. MICHELSON: Is the Staff going to be prepared 5 this morning to talk about Crystal River and their 6 requalification program and what went wrong, and what the 7 problem is? They had a very, very high flunkout rate.
8 MR. WARD: Yes. Well, I think that can be one of 9 the questions we can address to the Staf f.
10 MR. MICHELSON: I had asked that they come i
11 prepared to talk about it some time ago. They did get the 12 message that we wanted to talk about Crystal River 3. Maybe 13 it got lost through a crack. It was about a month or so ago
(~')
us .
14 when we talked about it. I remember I came in and pointed 15 out that the real problem -- their flunkout rate was almost 16 100 percent, so I thought it was a good case to look at as 17 at least one extreme where the utility must be having a real 18 problem.
19 MR. WYLIE: Was this NRC-administered?
l 20 MR. MICHELSON: Yes.
21 MR. WARD: Well, I think i got an indication they 22 are prepared to say something about it.
23 MR. MICHELSON: Okay.
24 MR. WARD: As a focus, I think we have got two or rs
) 25 three ways we can focus the--
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0150 01 06 7 1 MPBeb 1 MR. MICHELSON: Before we got started, also,
() 2 Dave, I would at least like to thank John for putting 3 together what I thought was a very fine condensation of this 4 information along with plenty of material to read for the 5 details. I certainly appreciated the effort, and it was 6 extremely helpful. When I didn' t have a whole lot of time 7 to look at it, it really allowed me to focus.
8 DR. REMICK: I already told John that this 9 morning. I appreciate it very much.
10 MR. WARD: For the typical lazy ACRS member it 11 was of great assistance. It really was.
12 Well, there are a couple of ways we can focuc the r- 13 discussion. One is in this splendid write-up that
(_3 /
14 Mr. Schif fgens has provided he has given us some questions 15 to consider. In addition to that we have the questions or 16 the requests from Commissioner Asselstine way back in 17 February, and I think John's questions cover a couple of the 18 points that Ccamissioner Asaelstine raised.
19 I would paraphrase Asselstine's comments or 20 questions in the four questions, and I think the most 21 important two perhaps are covered by John's, but I think two 22 others are not.
- 23 MR. MICHELSON
- Right.
24 MR. WARD: In addition to that, I think we havo l () 25 got -- each of us has some questions, specific questions ACE. FEDERAL REPORTERS, INC.
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0150 01 07 8 1 MPBeb 1 which we might want to raise, and I have some.
9 2 So I would ask you if anybody has any strong 3 views about how you would like to proceed. We have got two 4 and a hal f hours to talk about it. I suspect it will be a 5 somewhat disorderly process, but that is probably all 6 right.
7 MR. MICHELSON: Well, if we go through John's 8 questions first, I think they kind of bring out a number of 9 the points. It would be better I think to do that and then 10 go to Asselstine and pick up those things that aren' t yet 11 covered.
12 MR. WARD: Okay.
^
13 MR. MICHELSON: But John' a seemed to bring out a
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14 number of things that I had wondered about, and that might 15 be a useful starting point.
16 MR. WARD: Yes. I think they are in a more 17 appropriate order than are Asselstine's.
18 Any other?
19 (No respo'ase.)
20 MR. WARD: Well, we will proceed.
21 Forrest, do you have any questions?
22 DR. R2 MICK: What is our ultimate purpose? Is it 23 to respond to Asselstine's request, or is it broader than 24 that?
/'N 25 MR. WARD: Well, I think somewhat broader. I
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0150 01 08 9 l_ MPBeb 1 think we need to respond to Asselstine's request but I think
'k 2 we also need to develop, you know, perhaps what we consider 3 to be a well-rounded position on the requalification program 4 in general, if we can do that. To the extent Asselstine's 5 questions define a well-rounded, you know, look at the 6 program, maybe they are the same thing.
- 7. DR. 'EMICK: Okay. Because I thought John's 8 questions were broader than necessarily Asselstine's.
9 MR. WARD: Yes.
10 DR. REMICK: Could I ask Staff one quick 11 question which would help me in my own thinking on 12 requalification? I think it could be a short one.
r- 13 If 10 CFR 55 as changed would go through, would
(-)/
14 the Staff still intend on the 20 percent of 50 percent 15 administered requal exams? Would they still anticipate 16 continuing that procedure if the new Part 55 went through?
17 MR. BOGER: This is Bruce Boger from the Staff.
18 The answer is Yes.
19 DR. REMICK: Okay.
20 MR. WARD: Okay.
21 Well, let's go ahead, and we will use John 22 Schiffgens' questions as the focus for discussion. The 23 questions have several parts, but let me just read the 24 general question and then we will start with the first part p 25 of it.
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i 0130 01 09 10 MPBeb 1 The first approach is-- The general question is:
2 Is the NRC requalification program philosophy 3 appropriate, and the first question is what are the NRC 4 objectives?
5 And I think of course we could ask the Staff 6 that, but I think they have told us. But I would like to 7 get an idea of what we believe the NRC objectives are.
8 MR. MICHELSON: Before we get into that, I think 9 at the June meeting which I wasn' t able to attend, I think 10 you searched out whether there are comparable 11 requalification processes geing on in this country in the 12 medical profession and elsewhere. Was that a part of your 13 June meeting?
(~)/
\_
14 MR. WARD: Yes, it was.
15 MR. MICHELSON: And could you tell me just real 16 briefly is there anything even comparable to this level of 17 requalification requirement?
18 MR. WARD: Yes, I think there is. First of all, 19 we didn' t hear from the FAA at that time. We were scheduled 20 to, and we didn' t, and we haven' t had any further input from 21 the FAA other than written material that we had--
22 MR. MICHELSON: Is this relative to pilot 23 requalification?
24 MR. WARD: Yes, pilot requalification, and
() 25 particularly, you know, the use of check pilots because ACE FEDERAL REPORTERS, INC.
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0150 01 10 11 MPBeb 1 that is a part of this expression.
2 We also heard from -- I forget what it is called, 3 bu the American Board of Medical Examiners or something. I 4 found that to be kind of an interesting presentation.
5 MR. MICHELSON: How of ten do they require 6 requalification by examination?
7 MR. WARD: Well, it is quite scattered. It 8 depends on, you know, the segment of the medical profeosion 9 that you are talking about. For some it's zero; for others 10 it's-- I think five years might have been a more typical 11 number. -
12 MR. MICHELSON: And that is by examination?
) 13 MR. WAFD Yes , by ex amination.
v 14 MR. MICHELSON: Wi-itten examina tion?
15 MR. WARD: In some cases it is a rather 16 comprehensive written exam, but at the present time, zero 17 might be more typical.
18 MR. MICHELSON: I think it is in the medical 19 profession. There aren' t too many that require f requent 20 requalification.
21 MR. WARD: Yes. But some do. And if there was a 22 trend, my impression of the trend was that the trend was to 23 begin to require it more and more. This might have been 24 just the view of the Board of Medical Examiners.
25 MR. MICHELSON: And that came closest, bes ides
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0150 01 11 12 MPBeb 1 the FAA which you didn' t get the inf ormation on.
2 MR. WARD: Le t's see. What else did we hear 3 f rom at tha t-- Do you remember what other groups we heard 4 f rom at that meeting, John?
5 MR. SCHIFFGENS: The medical examiner.
6 MR. WARD: Yes, the medical examiners.
7 MR. SCHIFFGENS: The FAA didn' t come.
8 MR. WARD: Yes.
9 MR. SCHIFFGENS: We had the region 10 representatives.
11 MR. WARD: Yes, but we didn' t hear from any 12 other--
(~) 13 MR. SCHIFFGENS: -- outside group.
C/
14 MR. WARD: -- outside group, did we?
15 MR. SCHIFFGENS: No.
16 MR. WYLIE: But as I recall the basic general 17 practitioners' retraining quite often was just staying 18 abreast of the current training literature, as I recall. He 19 read certain documents periodically.
20 MR. MICHELSON: Yes. It is not very organized.
21 DR. REMICK: Dave, on the question before us, I 22 was licensed before the time that there were requirements 23 or requalification programs and was licensed at the time 24 that requalification programs came into effect. In my mind 25 there is just no question that the concept of
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0150 01 12 13 2 MPBeb 1 requalification is a good one. I think it definitely O 2 improves the status of operators.
3 The annual exam can sometimes be traumatic, but I 4 think the overall philosophy and the concept of 5 requalification training in my mind is a good one. And I 6 have a feeling that that's a general feeling out there 7 amongst operators. I think the thing that has changed that 8 has caused so much dif ficulty was a couple of years ago when 9 the Commission basically ordered the Staf f to start 10 administering some of those annual examinations, but I think 11 the overall--
12 And I think that's a question before us, the 13 philosophy, the concept. From my perspective, there is just
^}
14 ao question in my mind that it is a good one and that people 15 need to be continually training to keep up to date.
16 When we talk about requalification training for 17 operators it is more than just theory, it is making sure 18 that you get experience on the simulator, that you are 19 updated on changes. You get a plant walk-around to make 20 sure you're familiar with the plant; a whole series of 21 things.
22 And I just think that is very good concept that 23 people are continually being trained, and it is not 24 necessarily limited to what you learned before. It is fj 25 learing new things, too, and I think this is always good.
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0150 01 13 14
['S MPBeb 1 I think the fact that people are continuing to learn more, V
2 it contributes to professionalism. They aren' t stagnant, 3 just relearning what they learned before, although for 4 operator licensing, continuing training or requalification 5 training, much of it is relearning things that you learned 6 before, but there is the opportunity there to be learning 7 new things also.
8 So I come out-- I think the philosophy is a good 9 one.
10 MR. MICHELSON: Well, I haven' t made up my mind 11 yet. The philosophy is a good philosophy, but we certainly 12 have apparently picked up the nuclear industry for an
() 13 inordinant amount of this retraining and requalification as 14 opposed to other high-impact industries -- occupations like 15 doc tors , for instance, where certainly the public health and 16 safety must be heavily involved with them, and yet we do not 17 have that kind of a rigorous requalification process there.
18 DR. REMICK: Maybe we should.
19 MR. MICHELSON: Maybe we should.
20 MR. WARD: There is in-- You know, some of the l
21 segments of the medical profession had I think rather 22 rigorous requalification departments.
23 MR. MICHELSON: But others like general f amily 24 practice, there is no requirement to ever requalify. And a
() 25 lot of other licensed occupations in this country--
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0150 01 14 15 MPBeb 1 Engineers don' t have to requalify. Why shouldn' t an 2 angineer have to requalify every year to prove he is still 3 an engineer? You take the license exam once, and that's 4 it.
5 MR. WARC: Well, you know, to me that raises an 6 interesting question. You know, the purpose of 7 requalification -- or the purpose of professional licenses 8 in the first place, is the purpose to, you know, assure the 9 general competence of a profession, or is it to protect the 10 public against individual charlatans?
11 MR. MICHELSON: I thought it was just the 12 latter. I thought that was the basis for, you know, making
(~) 13 it legal, to protect the public health and safety. There U
14 are certain occupations in this country that require 15 licensing. I am not authority on it by any means. In my 16 mind, that's what I thought the basis was.
17 MR. WARD: For example, the engineering license.
18 In most cases people hire engineers or engineering firms 19 because of the reputation of the engineer in the marketplace 20 or, more usually, the reputation of the institution that 21 engineer works for, I mean the corporation or the laboratory 22 or something else.
23 It seems to me that the general competence of the 24 engineering work in the country isn' t af fected too much by
( w,) 25 the fact that they have a state licensing.
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l 0150 01 15 16 MPBeb 1 MR. MICHELSON: Well, it's hard to tell because 2 it has been in existence for a long time.
3 MR. WARD: Yes.
4 MR. MICHELSON: But there are a number of small, 5 independent practitioners who build small buildings and 6 small bridges and whatever, and the public wants to be 7 assured that those are not going to jeopardize their health l
8' and safety.
9 MR. WARD: Yes. So you're saying that it's 10 because the engineer or the medical doctor can practice as 11 an individual rather than as part of a kind of a visible 12 institution that the public needs the licensing of it.
(~} 13 Well, if you think about it,--
L.)
14 MR. MICHELSON: Well, I think that's the basis 15 because there was a time when it was much more prevalent 16 than it is now to see small practitioners.
17 MR. WARD: But if you think about it in those 18 terms, the parallel with licensing nuclear power plant 19 operators kind of breaks down somewhat.
20 MR. MICHELSON: Because they are not individual 21 practitioners. The operators are not operating as 22 individual practitioners but, rather, as a member of a large 23 corporate group which has organized checks and balances that 24 protect the public. You could argue that way.
t
() 25 MR. WARD: Yes.
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0150 01 16 17 1 MPBeb 1 MR. MICHELSON: But if you argue that way, then O 2 what is the purpose of licensing? There is this big 3 operation with its billions of dollars invested. It is to 4 them a very important self-interest to be sure of 5 operations even beyond public health and safety. So perhaps 6 you shouldn' t have to have any special requirement, but we 7 do, and now the question is how much.
8 And I am wondering. What I am concerned with in 9 my own mind is have we gone too far with this kind of 10 requalification program. And I j ust don' t have that 11 answer. And I am trying to hear the information that 12 assures me that we haven' t gone too far.
r3 13 MR. WARD: Yes. Well,'it seems to me that the C/
14 purpose of licensing and maybe even of requalification --
15 that strikes me as pretty much the same thing -- is more to 16 give the NRC one handle on or one means of sampling the 17 competence of the overall organization rather than the 18 competenece of individual practitioners. And if that is 19 really the purpose, then it seems to me that that influences 20 the sort of thing you're saying.
21 You know, why should the--
22 MR. WYLIE: It is really a question of who does 23 the examination, who administers the examination. That is 24 what it boils down to. Like Forrest, I think that the
() 25 general philo+ophy of requalificatica is sound for many ACE-FEDERAL REPORTERS, INC. I 2 @ 347-3700 Nationwide Coverage 800-336-6M6
0150 01 17 18 MPBeb 1 reasons. And the parallel that you mentioned earlier, the 2 FAA and the testing of the pilots to ensure that they are 3 still competent to fly an airplane, because again it is sort 4 of like-- The kind of business like that, if they are not 5 you'll crash a plane and it is catastrophic.
6 And the same problem oxists in the nuclear 7 industry. So I guess it is a close parallel between the two 8 from that standpoint.
9 The thing I have a little bit of a problem with, 10 though, is that we go through the process of reviewing 11 applications for construction permits and revicw the designs 12 from a programmatic standpoint as to how well they meet I
13 criteria in Reg. Guides and this sort of thing, but that is
(-)
V 14 more of an auditing process, a review and auditing process 15 to see that the program is working.
16 If you were on the other side of the coin, and 17 where we get most of the objections from the utilities is 18 that the NRC goes further with this program in that they are 19 administering the examination of the individuals, and that 20 is a little different. I fail to see why there is a 21 difference.
22 MR. WARD: Yes. Well, the fact that they are 23 only administering 10 percent of them means that--
24 MR. WYLIE: 20 percent.
^
25 MR. WARD: Well, 15 or 20 percent means that that (V i i
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0150 02 01 19 MPBeb 1 is really kind of an auditing process, and I think that is n 2 good question. Why have they chosen to audit in that way?
3 Why not just audit the requalification in the more 4 traditional way?
5 MR. WYLIE: Why not audit to see that the program 6 has been accepted or is actually being enforced and 7 administered? It seems like to me that's the question.
8 The other one has to do with the thing we've 9 mentioned earlier about-- Forrest mentioned the 10 examinations and the content of the examinations. And most 11 of the criticism that I have neard from operators has to do 12 with the -- and it is not what we hear all the time -- the
(] 13 highly academic questions that they get on the examinations.
LJ 14 And I think that maybe t!;a staf f will speak more to this 15 later.
16 But the program that they have proposed and the 17 changes are based on job task analysis, and how much that is 18 going to change this type of question I would like to hear.
19 I think that's the right approach. And obviously there are 20 some basics that maybe need to be refreshed. Just like 21 engineers' licenses, you have to pass certain basics in 22 order to get that license, but that is a one--time 23 proposition and not an every-two-year proposition.
24 MR. WARD: Does that make sense, though?
I'd wJ 25 MR. WYLIE: Wha t?
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0150 02 02 20 MPBeb 1 MR. WARD: I mean if there was something you need 2 to know in the first year, don' t you need to know that in 3 the tenth year?
4 MR. WYLIE: Well, engineering is a little 5 different I think. There are a lot of checke and balances 6 in engineering. It is hard to get a bad design through, for 7 one thing. Being an electrical engineer, if it is not 8 designed right it is not going to work right, generally.
9 There are a lot of checks and balances in the process, and 10 you can always checx on each other, you know, and there is a 11 lot of that.
12 And QA programs assure that they are checked, and
(^)
%J 13 this kind of thing, so I think it is a little dif ferent.
14 MR. MICHELSON: The medical profession doesn' t 15 necessarily have all these checks and balances, but it 16 doesn' t get the re-examination either.
17 MR. WYLIE: No, that's true.
18 MR. MICHELSON: And it certainly is dealing with 19 public health and safety in the very closest sense.
20 MR. WYLIE: And I think you don' t have to go very 21 far until you also find glaring examples of malpractice, 22 too.
23 MR. MICHELSON: Oh, yes. And with engineering 24 you get malpractice also. You may not call it that.
25 DR. REMICK: c;rl, you had asked a question,
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0150 02 03 21 MPBeb 1 have we gone too far. I guess I don' t feel we have gone too 2 far if the requalification is aimed at what it is the 3 operators need to know to safely operate the plant, plus 4 learn new things related to that.
5 If it goes back and it is just theory, some of 6 which might not be needed, then I think perhaps it is going 7 too far. But if it really is a performance-based type of 8 thing, then I think it contributes to esprit de corps. If 9 it contributes to people being able to respond and so forth, 10 then I don' t think it has gone too f ar.
11 I would like to respond to Chuck's comment about 12 the theory, and I realize I used to examine people for a
~
13 license, so you do get into those discussions of what theory (v}
14 is necessary. And I remember -- and this is pre-TMI --
15 getting into an argument at a plant in Pennsylvania, not 16 Three Mile Island, in which I had a question on there, what 17 was the approximate melting point of UO2. And I thought 18 operators -- This was a senior operator exam -- should know 19 that. And I got into an argument with management that that 20 was an inappropriate question.
21 And then I thought later af ter TMI, with 22 hind sig ht , that that is a good question. And I wasn' t 23 looking for the exact temperature, but I thought people 24 ought to know approximately at what temperature fuel would f') 25 melt. And I think they surely needed to know that during v
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1 0150 02 04 22 l MPBob 1 the TMI accident. ;
1 I
2 But you do get into these types of 3 discussions about what theory is needed, and what isn't.
4 You get into reactivity coefficients which-- My personal 5 view is that operators should have some kind of feeling what 6 things like temperatures and poisons and boron dilution and 7 all these things have on reactivity. There are people who 8 dif fer; well, yes, but we never really see those things in 9 the plant. Some of you do and some of you don' t. So it is 10 a subjective type of judgment on what theory is 11 appropriate.
12 MR. WYLIE: Maybe, Forrest, you and the Staff can
^
13 enlighten me some, but the complaints that I have heard from (v]
14 older operators is what they call highly academic, 15 mathematical type questions and as to what that really --
16 how useful that is to the operator and whether, you know, it 17 really buys anything, and those type of questions. And it 18 depends on whether or not his job task analysis requires 19 that he have a knowledge of that.
20 If in truth the objective of the Staff's program 21 here is to take job task analysis and to analyze those, to 22 the extent you then can say Yes, these are the things he 23 ought to know and be able to calculate if he has to 24 calculate these things, then that is a good question, but if 25 it is not, then it shouldn' t be in there.
(O~)
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0150 02 05 23 l_ MPBeb 1 MR. WARD: But it seems to me that if it depends O 2 on -- the base, the training, and then maybe the requal 3 examination only on the job task analysis then that puts the 4 burden on the job task analysis to really be complete.
5 MR. WYLIE: Well, I personally feel that is where 6 you ought to put your emphasis.
7 MR. WARD: Okay. Then that is a good point.
8 But I mean, for example, on of Asselstine's 9 questions was something to the effect of is the 10 requalification program fostering a gradual increase in the 11 level of engineering expertise on shift? We might ask 12 "Should it?"
13 Well, some of those-- I mean if the job task
{~}
14 analysis is just dealing with the stuff the operator does 15 every day, I don' t think that's enough. I mean you could 16 almost say the operator doesn' t need the training in the 17 routine duties.
18 MR. WYLIE: Oh, no.
19 MR. WARD: What he needs training and hence 20 examination is in the rare things that he never encounters.
21 MR. WYLIE: Oh, yes. And as I look at this 22 program, that is part of the training program. Well, the 23 INPO program has the unusual event training, the emergency 24 procedure training, you know, and those types of things.
() 25 The knowledge that goes with that as to what is happening ACE-FEDERAL REPORTERS, INC.
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0150 02 06 24 MPBeb 1 should be there. That would be my thought.
2 MR. MICHELSON: The question of course is the 3 depth of that knowledge. Even in such simple-minded 4 questions as asking him at what temperature UO2 will melt, 5 that is a very complex question when it is placed in the 6 matrix of fuel. And with all of the other funny things that 7 happens then it gets to be very complicated, and it can melt 8 way below what UO2 itself would melt.
9 MR. WYLIE: But in a mix like that there is a 10 cutof f below which he really doesn' t need to know what is 11 going on as far as the nuclear physics part of it goes. I'm 12 talking about an operator. So it is really how far you go
(~} 13 with what the level of the questions is.
U 14 MR. MICHELSON: Yes, I think an airplane pilot 15 has to understand the thrust characteristics of his engines, 16 for instance, in pretty good detail.
17 MR. WYLIE: Sure.
18 MR. MICHELSON: But as far as the bearing design 19 is concerned, he ought not to worry about that.
20 MR. WYLIE: Well, I'm not so sure about that.
21 MR. MICHELSON: Well, he is not going to be able 22 to do anything about it.
23 MR. WYLIE: For example, I think a TMI operator 24 could have benefitted by the fact that centrifugal pumps --
p) g 25 that you can' t overpressure a system with a centrifugal ACE-FEDERAL REPORTERS, INC.
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0150 02 07 25 MPBeb 1 pump. And that's a knowledge of pwmps.
2 MR. MICHELSON: Yes, I think that's the kind of 3 knowledge you do need. But I looked at some of these 4 examinations that are being given, the requalification 5 exams. We were sent a sample of I think five or six, and in 6 the theory part they asked very detailed theory questions I 7 tho ug ht.
8 MR. WARD: But are they appropriate or not?
9 MR. MICHELSON: No, I didn' t think they related 10 to what he needed to know to respond in a reasonable time.
11 Now he isn' t going to have six days to think about an 12 accident. He is going to have a few minutes. And what is r~N 13 the kind of knowledge that he needs in those few minutes L.)
14 that would be helpful in responding?
15 I fully agree he needs to understand the 16 knowledge needed for performance of his tasks. He doesn' t 17 need to understand the theory involved. That would be nice 18 to know but he isn' t going to make engineering evaluations 19 of designs and so forth. He hasn' t got that kind of time ,
20 you know, when he is in an accident situation.
21 TMI was unusually long, and they fiddled around a 22 long time there. But even two hours is not long to think 23 about a lot of theory.
24 MR. WARD: Yes, but didn' t this whole question
() 25 arise from the TMI experience where the people on shift ACE-FEDERAL REPORTERS, INC.
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0150 02 08 26 MPBeb 1 apparently didn' t understand the steam table?
2 MR. MICHELSON: Yes, but it doesn' t take all of 3 what we are doing now to understand steam tables, or even 4 the other fundamentals of thermodyna.nics that they need to 5 know. But the questions seem to be far beyond that, into 6 areas on which they are not going to be making calculations.
7 MR. WARD: Okay. So it seems to me like the 8 question isn' t so much whether the exam should include 9 theory, but exactly what aspects of theory and what level of 10 theory--
11 MR. MICHELSON: That's right. I think the theory 12 associated with the short-term performance of their machino,
(~'s 13l but not with the fundamental design because they are not
(>
14 going to have time to deal with fundamental design, 15 MR. WARD: It seems to me they have to understand 16 fundamental concepts.
17 MR. MICHELSON: Sure. There's a dif ference.
18 MR. WARD: I mean the UO2 melting may be -- that 19 can be--
20 MR. MICHELSON: I'm not sure that that is going 21 to be helpful to them at all.
22 MR. WYLIE: That question I would say is one that 23 is on the original examination. It should have been on the 24 original examination, but maybe it shouldn' t have been on
()
25 the requal.
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0150 02 09 27 MPBeb 1 MR. MICHELSON: Tha t's it. It is a good 2 question. The original examination should examine his 3 understanding of all these theories, but not ask him the 4 same questions again every year.
5 MR. WARD: You think he doesn' t need to 6 understand the theories the second year?
7 MR. MICHELSON: The second year he needs to 8 understand that aspect of the theory that relates to the 9 perfor. nance of his job, as opposed to a lot of other 10 theories that it might be nice to be sure he understood at 11 least once in his mind, and perhaps can still recall it.
12 And that's the way doctors are examined, except
~'s 13 they assume there that they never need to be rechecked on (d
14 practice.
15 MR. WARD: I have a little trouble with the 16 argument that a person needs to know certain things for the 17 original license but he doesn' t need to retain that 18 knowledge, unless you are just using it as an ability test 19 in the beginning.
20 MR. MICHELSON: No, the whole busines2 is when 21 you store information that you can recall a fraction of it, 22 so you like to store a lot of information initially and 23 hopefully he can apply some of it later in an emergency.
24 But no one can recall 100 percent of what he has learned, or 25 you could never take the examination today that you passed
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0150 02 10 28 P'gMPBeb 1 when you were in college because you don' t remember all that b
2 kind of detail. But you remember a lot of things that are 3 important, but not all of the detail.
4 MR. WYLIE: It is sort of like, Dave, the 5 engineers' examinations, and the trend, and I think most 6 states are doing this now. You know there's two parts now.
7 There's the EIT, the engineering and training exam, where 8 it's a very broad exam and it covers many, many fields or 9 subjects. And then the later exam is more specific to that 10 particular degree.
11 MR. MICHELSON: But the thought is that the 12 student can' t retain all of that detail for four or five
() 13 years of practice when he takes the final exam.
14 MR. WYLIE: The fact that he was trained in that 15 area, he can fall back on it.
16 MR. MICHELSON: Oh, yes.
17 MR. WARD: You seem to be making the argument 18 that he can fall back on it for the operator, he can fall 19 back on it in an emergency on Saturday night but he can' t 20 fall back on it in an exam.
21 MR. MICHELSON: No, no, it is the other way 22 around. Just like an engineer, years later you will fall 23 back on it by pulling your book off the shelf and thinking 24 about it. In an emergency I don' t have time to pull those fm
's_) 25 textbooks off the shelf and start thinking about it again.
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0150 02 11 29 MPBeb 1 Engineers do.
2 DR. REMICK: Carl, I differ that you should only 3 be teaching him what he is going to need in the case of an 4 emergency. Most of the time they are doing things that are 5 not emergency situations. He has to have judgment arid he 6 has to know what the impact of doing this or that should 7 be. So I don' t think that the requalification or the theory 8 that he gets should be restricted to what he is going to 9 remember at the time of the transient.
10 Every day they are making decisions. If they do 11 this or do that, what effect on reactivity or on releases 12 and the importance of them and so forth are. So I think you 13 are going too far towards being able to respond to (v~]
14 emergencies.
15 MR. MICHELSON: Well, we haven' t, hopefully, 16 crystalized that narrowly. I was just trying to point out 17 that there is quite a dif ference between the kind of theory 18 he ought to be taught initially and the kind of theory he 19 ought to be expected to feed back ten years later.
20 MR. WARD: Is one of the differences that too 21 many of the exams-- I mean it seems to me the operator 22 should have some understanding of concepts, but it is less 23 important that he be able to make mathematical manipulations 24 which an engineer might have to make in designing or
() 25 analyzing something to deal with or make use of those ACE FEDERAL REPORTERS, INC.
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.O 2 MR. MICHELSON: As an example, that is right, 3 because he not going to have time during any kind of 4 normal emergency situation to do it, and his routine job 5 doesn' t require it.
6 DR. REMICK: But once again, see, I disagree.
7 There are some things he has to know for routine. An 8 operator talks about a reactor period. He has got to have 9 some idea what a reactor period is so he has to have some 10 understanding of exponentials, and so forth, 11 Many operators have to do -- have to calculate 12 expected critical positions and so forth, so there are 13 things that operators have to do that require some
/(])
14 understanding. They're not doing them under these crisis 15 situations; they are doing them under routine, but they have 16 to do them right.
17 And so you can' t scratch things away, and the 18 only things they need to know are--
19 MR. MICHELSON: And presumably he was trained and 20 examined on that basis initially. He demonstrated that he 21 understood how to do the calculations, and he was capable of 22 making such calculations. I think the question is whether 23 or not he has to redemonstrate that sort of thing on a 24 yearly basis.
() 25 DR. REMICK: Maybe not calculate a period. You ACE-FEDERAL REPORTERS, INC.
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0150 02 13 31 MPBeb 1 would hope that he would have some feeling, but I would 2 expect your critical position-- That's something he has to 3 do every time he goes critical, and I would expect an 4 occasional check to see that he knows how to do that would 5 be appropriate for requalification training from my 6 s tand point.
7 MR. MICHELSON: Well, generally the nuclear 8 engineer does most of the calculations, not necessarily the 9 . reactor operator.
10 DR. REMICK: It is a requirement of the operator, 11 an SRO.
12 MR. MICHELSON: It is a requirement to know what
) 13 to do and how to do it.
(~J L
14 DR. REMICK: Right.
15 MR. MICHELSON: But not to do it. The SRO 16 doesn' t necessarily do that.
17 DR. REMICK: In some plants they do.
18 MR. MICHELSON: In some plants.
19 I think the differences we have are, you know, 20 what sorts of things need to be reexamined. Is the 21 requalification examination just a sample out of the 22 original set of questions, or is it a directed sample based 23 on what he really needs to know now in terms of operation as 24 opposed to the kind of theory he ought to have been trained
() 25 in initially?
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0150 02 14 32
(~'sMPBeb 1 I think there is a lot that needs to be put into V
2 his head initially that doesn' t need to be reverified 3 because it is an unreaonable request I think of an operator 4 unless it really is needed. If it is really needed--
5 MR. WARD: Why is it needed, though, in the first 6 place?
7 MR. MICHELSON: Well, why does an engineer learn 8 all these good things that he learns when he goes to 9 college? Years later he asks why did I ever take surveying, 10 for instance? Well, there was a time when surveying was a 11 required course. There are a lot of things you take that 12 you don' t necessarily use, and not knowing what you are em
(_) 13 going to go into--
14 MR. WARD: Well, you gain an appreciation for the 15 concepts.
16 MR. MICHELSON: Sure.
17 MR. WARD: And I think you retain that 18 appreciation even on a exam.
19 MR. WYLIE: It is a matter of degree, though.
20 For example, like Carl says, I took surveying.
21 MR. MICHELSON: I did, too.
22 MR. WYLIE: But I would be hard-pressed right 23 today to do some calculations on surveying without boning up 24 on it.
( 25 MR. WARD: Okay.
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0120 02 15 33 MPBeb 1 MR. WYLIE: But if I don' t use surveying, and I 2 very seldom use surveying, then I have that knowledge and I 3 have got the textbooks over here. I can go look at them if 4 I want to, if I need to. And I have that broadened 5 experience so that I can read layouts and plans and this 6 kind of thing.
7 MR. WARD: Okay.
8 MR. WYLIE: But if I had to lay out a road and do 9 this kind of thing, I couldn' t make that calculation without 10 sitting down and boning up.
11 MR. iICHELSON: And it wouldn' t be needed for 12 ,
your job.
13 MR. WYLIE: It goes back to the job task analysis
(^}
'w/
14 I think of what the operator needs to know.
i 15 ~ MR. MICHELSCN: But that was on the EIT exam, by 16 the way.
17 MR. WARD: But it seems to me you are putting a 18 lot into the original licensing exam that isn' t on the job 19 task analysis -- I mean that doesn' t derive from the job 20 task analysis.
21 MR. WYLIE: Well, I think there ought to be more 22 than just what he needs to know to operate daily in response 23 to emergencies. I think he needs to have a broader 24 knowledge of the plant and the hoact. I mean that is like
() 25 an engineer needs to know many things. Even an electrical ACE FEDERAL REPORIERS, INC.
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l 0150 02 16 34 MPCeb 1 engineer has to know chemistry.
2 MR. WARD: Well, I am trying to be a devil's 3 advocate in a way, I guess. For some reason I am 4 comfortable with that idea but intellectually I'm having 5 trouble reconciling it. I'm not sure it makes--
6 MR. WYLIE: He needs to be broader than--
7 MR. WARD: I'm not sure I could explain that to a 8 Martian, why it makes sense.
9 MR. MICHELSON: Well, you are an engineer. You 10 don' t get requalified every year. Why does that make sense?
11 Why shouldn' t I-- As a member of the public, if you are 12 dealing with a public health and safety occupation, why 13 shouldn' t I insist that somebody check you every year to
( })
14 make sure you are still smart enough?
15 DR. REMICK: I have no trouble, Dave, because in 16 my view I want operators to be professionals, and by 17 professionals, I think that they have to be inquisitive; 18 they want to be learning; they want to be cross-trained. It 19 is not just their narrow field. They want to learn more, 20 than to have blinders on and just how to onerate.
21 So I have no problem with that. A lot of people 22 differ. They think you sFould train them just exactly what 23 they have to do, and no more, and if you train them more, 24 you are going to lose them to somebody else or to some other n
() 25 field.
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l 0150 02 17 35 l MPBeb 1 I liave no problem because I just think the type 2 of person that I would want to see in the control room is 3 one who would be interested in learning more.
4 MR. WARD: Yes.
5 DR. REMICK: That is a personal viewpoint.
6 MR. WARD: But why wouldn' t he be interested in 7 maintaining that on a continuing basis?
8 DR. REMICK: Well, there I am torn, I guess. I 9 would say Yes, he would want to, but how important is some 10 of it to his day-to-day operation? That I am not sure. I 11 mean I don' t know. If he has learned a lot, I think it is 12 unreasonable to expect that he is going to be able to 13 regurgitate that every year in exams. So somehow you have
(~)N
\.
14 to narrow it down to what is he responsible for.
15 At the same time I would hope that every year he 16 is interested in learning new things that he hasn' t learned 17 before, either about the broad plant or about his company or 18 the world. That is just the type of person I would want to 19 see.
20 MR. MICHELSON: As a practical matter, one has to 21 remember, though, we are not dealing with intellectuals 22 necessarily. We are dealing with a cross-section of the 23 operators which generally are high school graduates, not 24 necessarily any college exposure at all. They have a little
(~\
c) 25 dif ferent way of approaching it; this is a requirement of ACE-FEDERAL REPORTERS, INC.
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0150 03 01 36 MPBeb 1 the job so they do it becauce it is a requirement of the 2 job.
3 They didn' t get the job because they had an i
4 intellectual curiosity. They got the job because they were 5 interested in getting it. And they were able to retain it 6 as long as they were able to receive enough training and 7 regurgitate it in the form of passing exams and whatever to 8 do the job. But that doesn' t make them intellectually 9 curious.
10 DR. REMICK: I'm just saying that's the type of 11 person I would want.
12 MR. MICHELSON: Yes, but there is nothing-- Then
(~T 13 you had better have a different selection process--
N-]
14 MR. WARD: Or a dif feren't requalification 15 process.
16 MR. MICHELSON: -- in some way because 17 intellectual curiosity is not a requirement of this job.
18 DR. REMICK: Not an NRC requirement.
19 MR. MICHELSON: Not a corporate requirement 20 either. How do they know he is intellectually curious?
21 DR. REMICK: Some plant managers would say that 22 that is--
23 MR. MICHELSON: You would always like to have 24 intellectually curious people, I guess.
("i 25 DR. REMICK: There are people who like to keep G
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0150 03 02 37 MPBeb 1 their intellectual operators barefoot and pregnant, not 2 encouraging them to learn at all because they might lose 3 them. I personally think that's a mistake.
4 MR. MICHELSON: But we do have to be practical 5 at this whole matter, too. I can't believe we should 6 approach this from the viewpoint that we are dealing with 7 intellectually curious people because I don' t think we 8 necessarily are. We are dealing with good, honest, 9 hard-working people, but not necessarily lixe they are 10 anxious to learn all there is to learn about the world 11 because I don' t think that's--
12 I have had a pretty fair amount of axposure to r~~'s 13 operators, and I have never gotten that impression, by and V
14 large, that they were that curious about the world.
15 MR. WARD: But I think Forrest is suggesting that 16 might be a problem.
17 DR. REMICK: It might be.
18 Kris, did you want to say something?
19 MR. GIMMY: Yes, I would like to expand on a 20 point that Carlyle raised about time.
21 Requalification is by definition a very limited 22 time sort of thing. You have limited time to get ready, 23 limited time to take it. And for instance on the initial 24 license they have got all the time in the world for that,
("N, 25 and usually they do it before the plant starts up, and if
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MPBeb 1 the plant starts up late, they have even got another year to 1
2 get ready for it sometimes.
3 But on requal you are talking about pulling 4 people off a shift., relieving them, and all that sort of 5 thing. And it is a very tight thing.
6 I know at the June meeting one of the comments 7 that we got from several of the people that were here was 8 that they have limited time and they spend it all learning 9 to pass the exam. And so I'm getting back to your question 10 now:
11 Should the requal be just a mini-versien of the 12 original thing? For instance, should it have all seven or 13 eight of the original categories, and should it be sprinkled (J~)
14 out equal.ly, as it was in the original exam or, for 15l instance, should the theory and principles of operation, the 16 part that they complained the most about, should that indeed 17 be quite a bit watered down now?
18 Now in other organizations that do give requal, 19 namely, FAA which I am a little familiar with, when the 20 pilot comes up for his annual requal, it is primarily about 21 a 90 percent of flying thing, to see that he can handle 22 unusual attitudes, fires and atof f that he doesn' t see every 23 day, and also they sper.d some time pointing out the tricky 24 parts of the new airplanes, like the 737 that likes to go 25 into a nose high stall, and they make sure to take him
({ )
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f 0150 03 04 39
- 1. MPBeb 1 through that, or any modifications that they have made to I'J 2 the plane recently, or any changes in the de-icing 3 procedures and stuff.
4 They don' t go back and retest him on the 5 Bernoulli's theorum. Even though he had to have it to get 6 that first license, they don' t make him do a Bernoulli 7 calculation on the wing cord or anything. They don' t do any 8 of that.
9 On the medical thing, I would like to say 10 something there.
11 I have a good friend who is a doctor and I went 12 through school with him, and when he got over in med school, 13 one of the things they made him do -- you all know this --
(-)
'w/
14 was memorize the names of all the bones in Latin, and in 15 particular the foot bones. They gave him a hard time 16 because there are a lot of bones in the feet, more than 17 anyplace else, and he had to know every joint in Latin.
18 And of course he couldn' t name hardly any of those today.
19 Now the question is would you want him to name 10 20 percent of the foot bones in Latin today, and the answer is 21 No.
22 And the reason they went through that I think was 23 that so in an emergency, he would renember hey, the foot has 24 got a lot of bones in it. And if there is an emergency and your main leg bone is broken, you can strap it up with
(} 25 ACE-FEDERAL REPORTERS, INC.
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I 0150 03 05 40 MPBeb 1 belts and newspapers and stuff and you can walk out of 2 there. You can' t wrap the foot in newspapers and walk,out 3 of there. And I think that's about all they wanted him to 4 remember.
5 Now whether that is relevant or not, I don' t 6 know. But I really want to get back to your question that 7 you raised but didn' t follow, and thac is giving limited 8 time for requal, should the requal be just a mini-version of 9 the original exam with 10 percent of it being theory 10 questions and 10 percent of it being this and 10 percent 11 being that, or should it be more over into problems peculiar 12 to this type of plant that we have uncovered, recent
(}
v 13 backfits to this plant, new changes in how we operate, new 14 environmental regulations?
15 I don' t know the answer. I would just like to 16 raise the question, given limited time.
17 DR. REMICK: And then you can subdivide that 18 further into the question-- You could say Well, are you 19 talking about requalification cenducted at the plant, the 20 training program and their testing of it, versus if the NRC 21 comes in and gives a requal exam, thculd they be asking 22 questions on theory or should they restrict themselves to 23 making sure that the person can demonstrate that he can 24 operate the plant, say on a simulator?
() 25 In other words, you could subdivide that, ACE-FEDERAL REPORTERS, INC.
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.0150 03 06 41 1 MPBeb 1 depending on who is going to administer the exam.
O 2 MR. GIMMY: One of the comments that we got last 3 June was very strong on that, and that was that the outside 4 person tends to ask and check the theory questions because 5 those are the ones-- They are easier. And to ask anything 6 about the plant in great detail or to even observe a guy on 7 a simulator, you have really got to know the nuts and bolts 8 of that plant.
9 So by definition the outsider, whether he be a 10 consultant or from NRC, is going to tend to lean toward the 11 book-type question I would think. And the question I think 12 before us would be should there be the same representation (m 13 or even more, heaven forbid, of that type question in the
'us) 14 requal than there is in the original. I think it is the mix 15 that is important.
16 We heard the people testify last time they were 17 here. One guy just said flat out that they spent all their 18 time getting ready for the book questions, and that's a 19 shame.
20 MR. MICHELSON: Yes, that's right.
21 DR. REMICK: Yes, even that concerns me a little 22 bit because the whole philosophy of the annual exam 23 originally -- and it is still in Part 55 -- as written, the 24 purpose of the annual exam was to see basically whether 25 you -- well, I shouldn' t say it this way -- was to assure (a')
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0150 03 07 42 MPBeb 1 that you knew everything at that point, and was to identify 2 the things you didn' t know so that you could direct the 3 requalification training over the next two years'to fill 4 those voids.
5 That was the purpose, and then the individual 6 exams that people take-- For example, let me go back.
7 Suppose you take the annual requal exam and you 8 found out that shielding was an area that you were weak.
9 The idea was that some time over that next two-year 10 requalification program you would cover shielding and then 11 at the end of those shielding lectures or whatever it was, 12 you would take the examination, and it was important then 13' that you passed that examination.
(v~')
14 But the whole concept of the annual requal exam 15 was to identify those areas where your group was weak, or 16 individuals were weak and they needed requalification. Now 17 it has gotten around to be more like you are talking about, 18 that they are boning up ahead of time to pass that annual 19 exam, and I think that is putting the cart before the horse 20 on at least what was the original philosophy. And it is 21 still the written philosophy in Part 55.
22 MR. MICHELSON: So I think it kind of boils down, 23 doesn' t it, to whether the requalification process should be 24 worrying too much about the old br. sic theory that was taught
(, ,) 25 to the stadent before he passed his first err ~, or whether ACE-FEDERAL REPORTERS, IN. .
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0150 03 08 43 1 it should focus on the kind of things he ought to be aware
/l_')MPBe b 2 of and make sure he is aware of it. And that's the purposa 3 of giving the exam.
4 So you don' t really go back and re-examine him on 5 all those fundamentals but, rather, you examine him now to 6 make sure that he understands how the plant is currently 7 configured, what changes might have been made, or if an 8 unusual safety problem has appeared, make sure by 9 examination that he is aware of that problem and what it 10 means to his plant.
11 That's the sort of exam I thought was going to be 12 involved in requalification, but that is not what I see when 4>
~
13 I read these questions.
14 MR. WARD: Yes, but that isn' t quite what Forrest 15 said, and that is I think what is in 10 CFR 50 or 55 now is 16 a little contradictory, but that is the argument that the 17 exam should-- I mean it seems to me you would have to 18 conclude that the exam should test the operator broadly 19 enough.
20 It isn' t really a question of academic or 21 non-academic or practical, but broadly enough so you can 22 determine where the training should be concentrated in the 23 future. And if the weakness is in academic areas, you would 24 say the training should be concentrated in those areas. Now
() 25 whether that was supposed to apply to the individual or to ACE-FEDERAL REPOP.TERS, INC.
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0150 03 09 44 1 MPBeb 1 the group isn' t clear to me. I don' t know if that was the 2 intent.
3 MR. MICHELSON: Well, related to that, it is not 4 clear to me what happens if a person f ails the 5 requalification examination. Is he immediately ineligible 6 for further duty for instance, or has he got two years in 7 which to -- or six months or some other time period in which 8 to you know, take the exam again, or what happens to him if 9 he fails in terms of his allowable duties?
10 MR. WARD: Well, I guess as John said in his 11 letter, it is not clear. I think one thing that is clear is 12 that the NRC does not revoke licenses based on the results 13 of the requalification exam. I think that's a principle.
14 But in practice there seems to be a more variable response 15 in that it seems to me there have been cases where the NRC 16 has requested that the utility remove from shif t duty 17 operators who have performed unsatisfactorily on the exams.
18 Now maybe that it not taking away their license 19 but it sounds pretty close to me.
20 MR. MICHELSON: Yes, in terms of their allowable 21 duties. I was hoping maybe the NRC Staff could tell us what 22 happens to an individual if he f ails to pass the exam, how 23 soon can he be re-examined or what can he do in the 24 meantime, and so forth. It is just not clear.
(} 25 MR. WARD: Can you tell us what the practices ACE-FEDERAL REPORTERS, INC.
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OMPBeb 2 MR. BOGER: Basically what we try to do is 3 implement whatever the facilities' requal program told them 4 to do. Each facility has the requal program where it 5 identifies what they have to do to qualify. Included among 6 that is the written examination, and inside of that are the 7 criteria for what to do with somebody that fails.
8 Basically what happens is it depends on the 9 degree of failure. If it is-- Say if it looks like a small 10 deficiency in someone's knowledge, then typically they are 11 allowed to have an oral exam by somebody else who evaluates 12 whether that person has sufficient knowledge to remain on 13 shift.
O,.
14 If it is a big deficiency based on the written 15 ex amina tion , the person is typically taken off shift until 16 they have had time to review that material and then be 17 re-ex am ined . That is typically by the facility.
18 MR. MICHELSON: Now there are no regulations 19 requiring him to be removed from duty then?
20 MR. BOGER: No. It is typically what we have 21 required in a requalification program. The people have to 22 be taking the NRC requal program.
23 MR. MICHELSON: You are saying as a part of the 24 requal program words are put in as to how the failures are
{} 25 handled? l i
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0150 03 11 46 1 ,MPBeb 1 MR. BOGER: Tha t's correct.
/ ')
2 MR. WARD: Is that consistent from one utility to 3 another, or are there cases where--
4 MR. BOGER: We found out there are some 5 inconsistencies in the requal programs that were approved 6 through the years, and so some had that requirement, some 7 d id n' t.
8 DR. REMICK: It might help you, Carl. In 9 Appendix A to Part 55 this it what it says about the annual 10 exam. It is under 4, " Evaluation."
11 "The requalification program shall 12 include (a), annual written examinations which gg 13 determine areas in which retraining is needed V
14 to upgrade licensed operator and senior operator 15 knowledge."
16 So that is the purpose, to determine where they 17 need retraining.
18 Now later on in that, in Section (e) under 4, it 19 says:
20 " Provisions for each licensed operator 21 and senior operator to participate in an 22 accelerated requalification program where 23 performance evaluations conducted pursuant to 24 Paragraph 4(a) through 4(d)...."
{} 25 And I j ust read 4( a)--
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0150 03 12 47
' l _s MPBeb 1 . . . . clearly ind icate the need . "
b 2, So they are supposed to have something, but I ;
3 think at least initially each licensee proposed sanothing.
4 The Staff had a chance to review these and accept or not 5 accept.
6 MR. MICHELSON: None of these rules ever told me, 7 though, whether he was relieved from duty until he passed, 8 for instance.
9 DR. REMICK: That depends I think on the 10 individual licensee and what he proposed on requal and what 11 the Staff accepted at that time.
12 MR. MICHELSON: That is apparently where 1.t is
,/ 13 iden tified .
14 DR. REMICK: Am I correct on that, Bruce?
15 MR. BOGER: Yes.
16 MR. WARD: That's what Bruce just said, and that 17 although the regulation doesn' t require it.
18 DR. REMICK: No, it doesn' t.
19 MR. MICHELSON: The regulation doesn' t read too 20 badly to me because it doesn' t say what the examination 21 shall really contain, and it doesn' t say what happens if you 22 don' t pass them, and so forth. It is pretty clean.
23 DR. REMICK: Under " Lectures" it tells you what 24 should be in it.
() 25 MR. MICHELSON: Well, it just gives you the ACE-FEDERAL REPORTERS, INC.
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0150 03 13 48 MPBeb 1 reference. What section are you referring to? ;
2 DR. REMICK: Section Number 2. See it on the 3 left-hand -- over here. ( Ind ica ting . )
4 MR. MICHELSON: Oh, yes.
5 DR. REMICK: That is basically the same thing as 6 the initial test, roughly, if I recalle 7 MR. MICHELSO!!: Well, yes, but these are very 8 general words .
9 DR. REMICK: Yes, but you see theory and 10 principle of operation. Now Appendix A is all 11 requalification, but I think the fact that now the Staff is 12 coming in and administering requal exams, by administering The
{} 13 annual exams you have taken what was initially--
14 purpose of the annual exam was to identify areas where 15 people need training.
16 Now the Staff is coming in-- And I realize this 17 was Commission dictum that you are doing it, at least 18 initially. You are coming in and evaluating, and if people 19 don' t pass that, or a certain number, you are judging the 20 requalification program. And I think you have distorted the 21 whole purpose of that annual exam, which was to identify 22 areas where people are weak and they needed training. So it 23 is a philosophic shift.
24 MR. WARD: It sure has been. I agree with that,
[')
\s 25 but le t's see.
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0150 03 14 49 1 MPBeb 1 What guidance does the rule give to the Staff on kl. l
- 2 how it should judge a requalification program if it is not g[d 3 on the basis of performance and exams? It doesn' t really 4 give any.
5 DR. REMICK: No, because it originally was not 6 the intent that the Commission come in and do what they are 7 doing. That was just started in 1982, I believe, or a 8 little bit later when the Staff had resources to do it.
9 Before, remember, the licensee administered all of the 10 requalification exams.
11 MR. WARD: Yes. And with-the intent supposedly 12 of following the regulations, I mean the purpose of the
(~ 13 regulation,--
(_)/
14 DR. REMICK: Yes.
15 MR. WARD: -- which was to determine where 16 retrained needed to be emphasized. Is that right?
17 DR. REMICK: Correct.
18 MR. WARD: Bruce?
19 MR. BOGER: I think there is a piece that is l 20 missing here and that is basically what we do to identify 21 which plants receive requalification exams at a given time.
22 In our Examiner Standards we consider things like 23 events that happened at that plant, whether the resident l
24 inspectors have seen indications that the operators didn' t know something, whether there were other clues that perhaps j{]) 25 l
l l
r ACE-FEDERAL REPORTERS, INC.
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0150 03 15 50 MPBeb 1 the operators were not being trained.
2 And so we rely en that, SALP inputs, resident 3 inspectors' comments, recent events, LERs, things like that 4 before we ever even go to a plant. And that's what we try 5 and focus on, where we may have programmatic problems rather 6 than individual problems.
7 MR. MICHELSON: But then what do you do to tailor 8 the examination to make sure that the operators have what 9 they need for proper performance as opposed to perhaps all 10 the nice-to-know things that they might have originally been 11 trained in? Because a poor performance on a given event 12 doesn' t necessarily mean that you have to go back now and 13 re-review all the theory; it means you had better have-- If r~)N 14 you messed up on the theory that is associated with that 15' event, tnat you had better go back and retrain them on 16 the theory on that event.
17 Do you make the assumption because they missed on 18 one event then they are weak in theory and go through all of 19 it, or do you focus on the event?
20 MR. BOGER: I think we would look more at whether 21 that was a procedural deficiency or whether that could be an 22 overall problem with all operators. We don' t try to go in 23 an pick on the particular shift that was there, but it may 24 be an indication that others on other shif ts also have a 25 similar weakness.
(~)
~.
l -
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0150 03 16 51 1 MPBeb 1 MR. WARD: Bruce, it seems to me what you just 2 said was you used the requalification exam -- I mean the 3 NRC-administered requalification exam as kind of a constant 4 trade audit tool where you have indications that there is a 5 problem with the training program or retraining program, I 6 guess, in that if you find problems with it, as indicated by
- 7. low operator test scores, you know one reaction would be to 8 regard that as only sof tness in the program and then develop 9 some plan with the licensee to improve the program.
10 But part of your reaction I mean is sort of 11 codified in your approval of the requalification program.
12 It indicates softness in the ability of a particular s 13 individual operator and that that operator is in f act gJ 14 removed from his job until he is upgraded. That seems to be 15 two different things, and the second thing dealing with the 16 individual operator does not seem to have any basis in the 17 regulation or in the original philosophy of 18 requalification.
19 Where did that come from?
20 MR. BOGER: I think the problem is if we have 21 done an inspection or, in this case, an examination and l
22 found a potential weakness, we feel we have the 23 responsibility to do something about it. And in many cases, 24 in the case or requal in particular, that is why we said if i
25 we identify a weakness that person should have additional
}
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0150 03'17 52 1 MPBeb 1 training and reassessment.
O ss 2 We have thrown NRC in there as the assessor.
3 Where the f acility used to have 100 percent of the 4 requirement, now they, you know, have 80 percent and we have 5 20 percent in a particular year.
6 MR. WARD: No, but the weakness is the weakness 7 in the program or in the individual? It seems that the 8 regulation and the original philosophy was to use this sort 9 of examination to identify weakness in the program, and the 10 individuals were just samples of the program and you weren' t 11 to conclude anything about the performance of the 12 ind ivid ual .
13 But somewhere there was a change made. You've O 14 crossed over some boundary where you decided to use the 15 requalification exam scores as an indication of the 16 performance of the individual, not of the program. And 17 where did the justification or where did the drive for doing 18 that come from?
19 MR. BOGER: I am going to have to fall back to I 20 think that if we identify a potential flow in an individual 21 and that individual holds a license that we have got to 22 assure ourselves that that person still has the minimum 23 level of knowledge or competence to hold a license.
24 MR. MICHELSON: How do you do that?
25 MR. BOGER: That's where we go back through the
)
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c150 03 01 53 MPBeb 1 exam, or additional training.
2 MR. MICHELSON: You go back and check his high 3 school chemistry and make sure that he still understands it 4 in order to continue to be an operator?
5 MR. BOGER: No, sir.
6 MR. MICHELSON: Well, that's what the examination 7 does. It goes back and tests all these basic theories 8 again.
9 10 11 12
()
es 13 14 15 16 17j 18 19 20 21 22 23 24
('\ 25 x _./
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i 0150 04 01 54 MPBwrb 1 MR. BOGER: If I could just talk about--
2 MR. MICHELSON: At least the exams I looked at 3 talked about that. My sample wasn' t too great. I looked at 4 several plants--
5 MR. WARD: You mean all the questions dealt with 6 that sort of thing, or just some?
7 MR. MICHELSON: No, not all, some of them. Some 8 of them, not all of them.
9 Some of them were very good questions that, if an 10 operator didn' t know, he ought not to be an operator. And I 11 think he ought to be able to sort out that kiad of 12 information and test on it.
r~) 13 There are certain things that if he doe'sn' t V
14 understand, he ought not to operate until his mind is 15 refreshed, on perhaps a yearly basis. But there is a smell 16 set of those, and there is a much bigger set that is covered 17 by the original exam, and it seems to be a fairly big set 18 covered by the requalification exam.
19 MR. WARD: Well, I think there might be some 20 dif ference of opinion about what exactly should be included 21 in that first set.
22 MR. MICHELSON: Yes, I know.
23 Well, I think the real dif ference of opinion is 24 what ought to be included on the requalification set. I
(",) 25 think the first set, I never heard anybody really say that
~
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i 0150 04 02 55 l 1 MPBwrh 1 the original operator exams were unfair, and so forth. Has O 2 that been an issue?
3 MR. BOGER: I have heard that before.
4 MR. WARD: A time or two.
5 MR. MICHELSON: But I didn' t look at it. My 6 assemption was that the original exam was fine.
7 MR. REMICK: The thing that has been said for 8 years, partly true and partly untrue, is the fact that you 9 have got to teach them to pass the NRC exam and then you 10 have got to teach them to operate the plant. There is some 11 true in that, and there is some overlap. That claim has 12 been going on for quite some time.
r~N 13 MR. MICHELSON: But sooner or later you get them
's_ /
14 taught, and you have presumably plenty of time to do it.
15 And the fellow finally did learn it and he passed his 16 examination.
17 MR. WARD: Maybe that is why--
18 MR. MICHELSON Why does he have to continue to 19 retain that kind of knowledge?
20 MR. WARD: That's the point Kris was making:
21 maybe that's why there isn' t as much unhappiness about the 22 original exam as there is about the requal, because you've 23 got plenty of time to deal with the original.
24 MR. GIMMY: Dave, on your question of what is the f)
a 25 purpose of the thing anyway, is it to find a bad training ACE-FEDERAL REPORTERS, INC.
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P 0150 04 03 56 1 MPBwrb 1 program or to find a bad individual: well, in most requal n
'- 2 things it is both. But the only thing you can test is the 3 ind ivid uals. I won' t say the only thing you can, the only 4 thing they are testing is the individuals.
5 You could test the program maybe if you had a 6 really smart bunch of people and a good job task analysis, 7 you could sit down ar.d say okay, now what kind of test 8 should these guys make up; is this really representative of 9 this plant or isn' t it?
10 But the way it's really done, both for pilots and 11 for operators, is you test the individual, first because you 12 may have an individual who is really slipping, the pilot who
-m 13 really isn't with it any more, has poor reactions, staff U 14 that hasn' t shown up, or the operator has got so many home 15 problems and other problems that he can' t think about his 16 job long enough to do anything.
17 So you do want to catch the bad egg.
18 I would submit, though, that where you have a 19 case where a lot of the operators are having trouble, like 20 the Crystal River thing, then that tells you there's 21 something wrong with the program; either that, or they've 22 gotten a really poor sample of operators.
23 In practice, all you can do is test the 24 ind ivid ual .
(~3 25 MR. MICHELSON: As long as Crystal River was LJ ACE-FEDERAL REPORTERS, INC.
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0150 04 04 57 l l
MPBwrb brought up, maybe you can tell us a little bit about that, '
1 2 and why so many operators have failed. Was there anything 3 wrong with the original examination process, or was it only 4 with the requalification process?
5 MR. GIMMY: That tells me there is something 6 wrong with their program. Before he answers, my guess is 7 there is something wrong with the program; either they are 8 not teaching it, or there is one other extreme: they have 9 made the test so hard that their own guys can' t pass it.
10 MR. MICHELSON: Or a third possible extreme is 11 that the original test wasn' t very darn good to begin with.
12 MR. GIMMY: Right.
(3 13 MR. REMICK: This was an NRC administered requal, G'
14 wasn' t it?
15 MR. BOGER: Do you want me to go through the 16 whole thing?
17 MR. MICHELSON: Yes.
18 MR. BOGER: Okay.
19 Basically, at Crystal River the NRC did 20 administer an examination where there were a lot of 21 failures. The company also--
22 MR. MICHELSON: How many is a lot, now?
23 MR. BOGER: It was on the order of 60 percent.
24 MR. MICHCLSON: I thought it was 70, but I will
[~'t v
25 give or take. That's a lot.
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0150 04 05 58 MPBwrb 1 MR. BOGER: Yes, sir.
2 MR. MICHELSON: Yes.
3 MR. BOGER: The company also administered an 4 examination that also had high failure rates. They weren' t 5 quite as high as the NRC's, but they were within the area 6 that we would have classified that program as marginal by 7 their own standards.
8 As a result of that, the NRC had a lot of 9 meetings with the management of tha facility, and the 10 management -- or the facility conducted an evaluation, their 11 own evaluation of the requalification program, and they 12 found about four major items. One of them was inefficient
{} 13 and inadequate management review of the training program; 14 another was training and administrative procedures with 15 vague and unclear requirements. A third was insuf ficient 16 indoctrination and training of training department 17 personnel. And a fourth was inadequate methods of showing 18 compliance with NRC requirements.
19 So I think what was found was that there were 20 programmatic problems at that facility, and the way we 21 identified it was--
22 MR. MICHELSON: Well, let me ask: How did they 23 do on their original examinations, which was the basis for 24 giving them a license t'o begin with? All these people
() 25 passed, of course; they must have passed an original exam.
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0150 04 06 59 MPBwrb 1 Did you go back to look to see if there was 2 something wrong with their original training program and 3 somehow these people all just slipped through the 4 examination process; which I assume was totally NRC 5 administered?
6 What happened to the people between the time that 7 they were qualified by your examination and the time that 8 they were attempting to be requalified? They lost some 9 knowledge or something? Because they passed to begin with.
10 MR. BOGER: That's right; they all had to pass an 11 initial exam.
12 MR. MICHELSON: And that was an NRC administered
,r w 13 examination. And it must have been a good one, or you L]
14 wouldn' t have given it. So what happened to the operators 15 that they can' t re-take it, or pieces of it?
16 MR. BOGER: Okay. We administered 100 percent of 17 the original examinations. I don' t know how many times some 18 of them took to pass it. I mean, it is not like everybody 19 passes the first time through.
20 I think what they found is that people were 21 allowed to slip through the program af ter they obtained a 22 license, they didn' t have to go to some of the 23 requalification lectures. The requalification program 24 didn' t f actor in some of the plant changes, things that had 25 happened to the plant, so that the operator would be made
(")
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0150 04 07 60 MPBwrb 1 aware of it. And so when they got tested on it they didn' t 2 know those things. And that's how we discovered it.
3 MR. MICHELSON: Did you go through a do a little 4 analysis to see what portions of the exam they were weak on 5 and which portions they were doing fine on?
6 In other words, was there a pinpointed weakness 7 that caused them to fail the exam, or was it 8 across-the-board?
9 MR. BOGER: I believe it was an overall weakness 10 across all categories.
11 MR. WYLIE: Let me ask you a question.
12 You said that they didn' t f actor in plant 13 changes. And principally, I guess, the NRC-administered (G')
14 exams picked that up. Or did the licensee's exam pick that 151 up?
I 16 MR. BGGER: I don' t know; I would assume that 17 ours did. We are the ones that identified the problem up 18 front. I don' t know what their examination was.
19 MR. WYLIE: But now from the failure rate the 20 company had, you said you would have considered that too 21 high to be an acceptable program.
22 MR. BOGER: Yes, sir. I 23 MR. WYLIE: Did that occur before you did yours? ]
24 MR. BOGER: I think it was af ter we conducted
~
25 ours.
(v)
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1 0150 04 08 7 xMPBwrb 1 DR. REMICK: Bruce, I have a question.
U 2 Why didn' t I&E catch the fact that people were 3 not attending requalification lectures? I&E used to come 4 around and audit requal programs to make sure that people 5 were attending. But the programs were being offered, and 6 the operator licensing branch used to come around and 7 actually pull out some requal exams and say "Does this have 8 the composition that we vould normally administer on an 9 initial exam? Are they the right level questions?" They 10 would actually even grade some of the answers to see if 11 there was approximately the same weight being given.
12 These types of things used to be done by I&E and
(} 13 NRR on an audit basis to be sure the requal programs were 14 reasonable.
15 Are they still being done? And why weren't they 16 caught at Crystal River?
17 MR. BOGER: Okay. In this case I believe that 18 the problems were identified earlier in the year, or in the 19 previous year. Roughly in December of that year a large 20 team went in to look at the Crystal River requalification 21 records and program, and determined that there were 22 deficiencies, and that some follow-up should occur.
23 That was one of the reasons why they conducted i
24 the requal exams at Crystal River.
() 25 DR. REMICK: I see. So they did pick it up.
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0150 04 09 62 MPBwrb 1 MR. BOGER: Yes, they did .
2 DR. REMICK: So the NRC-- The point I would like 3 to make, I guess, is the NRC administered annual 4 requalification exam is not the initial thing that caught 5 it?
6 MR. BOGER: In this instance it's not.
7 DR. REMICK: In this instance, yes. And I guess 8 one thing that still disturbs me is the bit of placing 9 emphasis that people don' t do well on that annual requal 10 exam, pointing out that that means that their program is 11 bad. Because, as I say, the original intent of that exam 12 was to identify areas where training was needed. It seems
(~N. 13 somehow we have got it distorted.
G 14 I guess I personally would like to rely on I&E 15 and operator licensing branch doing what they have done in 16 the past, and tha t is audit and make sure that those requal 17 programs are up *o speed.
18 MR. BOGER: Remember, we are auditing even in the 19 20 percent or 50 percent of the facilities.
20 MR. REMICK: I understand. But you are placing 21 completely dif ferent emphasis now on that annual exam.
22 MR. BOGER: Yes.
23 MR. REMICK: It is something we haven' t gone 24 into. It will have an impact on those operators.
() 25 MR. BOGER: And size is important. We recognize AcsFEDERAL REPORTERS, INC.
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0150 04 10 63 MPBwrb 1 that there are some things we have to think about when we go 2 on with the program.
3 MR. MICHELSON: It is a little hard for me to 4 come to grips with the idea that once you have a good 5 training program, presumably a good training program, at 6 least adequately good, to have the operators pass their 7 examinations, as all these operators did, they were all 8 qualified, and yet something is happening to their 9 knowledge, such that when they go to take the exam over 10 again -- and I don' t know the important factor of whether 11 this is one year later or ten years later or what; but, 12 whenever it was, they took the exams over again and there tT 13 was a large fraction of them failing.
%_.)
14 DR. REMICK: I think that stresses the importance 15 of the requalification training program: people do forget.
16 MR. MICHELSON: And I was wondering: did they 17 f ail because they didn' t remember all that good theory, or 18 did they f ail because they j ust didn' t -- weren' t properly 19 educated concerning changes and all the other important 20 f actors which they do need to have and do need to be tested 21 on?
22 Apparently it was across-the-board: they just 23 didn' t pay any more attention to training, or not much 24 attention, I guess, to training after the initial exam was n
25 passed.
(v)
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0150 04 11 64
'sMPBwrb 1 MR. WARD: Well, like Forrest says, if you accept
[d 2 it at face value, it is a demonstration of the importance of 3 requal training.
4 MR. MICHELSON: Or at least of the program.
5 MR. WARD: The other point Forrest made earlier, 6 it seems to me this gets back to something kind of 7 fundamental: the NRC has a responsibility to audit the 8 training, the requalification training, and it has done 9 that. You know, for many years they did it in several 10 ways. One is the sort of I&E inspector activity that 11 triggered you to select Crystal River for NRC requal exams 12 in the first place. And the other was what you just told
() 13 us, that you audit the performance of the operators under 14 the co.1oany's requalification exams. You have access to 15 that in fo rma tion .
16 MR. BOGER: Yes.
17 MR. WARD: So it just raises-- You know, the big 18 question to me is whether this 20 percent of 50 percent is 19 really necessary as an additional audit tool, which is 20 really what it is. Because you have got these other two 21 audit tools for determining the effectiveness of the 22 training program.
23 In the Crystal River example apparently there was 24 a problem, but both of the other audit tools detected the
() 25 problem.
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0150 04 12 65 2 1 Did the NRC administered requalification exam
( 4)MPBwrb 2 really change the picture? Did it give you a better 3 understanding of what the problem was, or did it give you a 4 better club to use in getting some corrective action taken, 5 or what?
6 Why was this additional audit tool, what I have 7 called an audit tool, necessary? How necessary? How was it 8 useful?
9 MR. BOGER: Well, I think that what some of the 10 other presenters in the previous maetings, the original 11 folks, particularly, said that there was a lack of 12 management attention on the requalification, and, in fact, a N 13 lot of them were emphasizing the initial licensing of (G
14 people, so that they really made sure that they did well, 15 and then kind of passed them off into this other requal 16 program where they did not have the same emphasis on 17 instruction and in making sure that people went to the 18 classes, and making sure that they were ready. And I think 19 that is what we are seeing now.
20 What we think we are seeing is, when we give 21 examinations, that the requalification program certainly has 22 more emphasis, and there is a lot more management attention.
23 MR. WARD: It seems to me that's what it is. If 24 you aren' t able-- I mean, you detect the problem from the i
{} 25 more traditf.onal audit methods. But then to get the l
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L 0150 04 13 66 1 MPBwrb 1 attention of the licensee management you hit them over the q
'/ ~
2 head with this club. And maybe that's necessary; I don' t 3 know. But it sounds to me like that's the single purpose of 4 the 20 percent of 50 percent requal exam.
5 MR. BOGER: Okay. I think that there are 6 instances where f ne audit itself doesn' t even require an 7 examination beyond that. It is not like we find the problem 8 and then go in and have to verify that the problem existed.
9 I think Region I indicated that it was Heddam Neuk where 10 they had to go back, and they found that their 11 requalification program wasn' t like the other 12 requalification programs for that company, and that the
,3 13 management were shocked to hear that, and so they changed
(
But I don' t believe that there was an examination 14 things.
15 associated with that one.
16 So there are occanions where the audit is 17 effective and does pick up things.
18 MR. WARD: Right.
19 MR. BOGER: And we may not always pick up things 20 in the audit.
21 MR. WARD: But I mean, you require the licensees 22 to use certain procedures and practices and in-service 23 inspection of primary system piping, for example. And 24 that's required. But the NRC doesn' t find i t-- And that is
,eN 25 aud ited ; it is a requirement, and the MRC audits it. But LI ACE-FEDERAL REPORTERS, INC.
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0150 04 14 67 MPBwrb 1 the NRC hasn' t found it necessary to go in, I don' t think, 2 and actually do in-service inspections of, you know, 20 3 percent of half the plants, or something like that.
4 And I kind of wonder why this area of operator 5 licensing requalifi =.lon has been singled out to be 6 different from all the other things the NRC requires of 7 audits for compliance. And I think one reason is because 8 the Commissioners told you to do it; bat I don' t know that 9 that's a very good reason.
10 You are supposed to-- You know, we were to have 11 technical scientific reasons for doing things that have some 12 sort of basis, and the Commission judgment may be a good 13 basis.
14 MR. BOGER: Unfortunately, any time there is a 15 transient or an event at the plant there is ueually an 16 operator who was in the control room and his boss was in 17 there also, and we typically have to answer those questions 18 as to why didn' t they know something, or why did they do 19 something a certain way. And we typically fall back on the 20 licensing process, the requalification process, facility 21 training programs, and they may juet be visible when things 22 happen.
23 MR. WARD: Okay.
24 Well, we have talked about the general approach
() 25 and the reasons for it. Maybe a couple more specific ACE FEDERAL REPORTERS, INC.
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0150 04 15 68 1 questions.
f^3 MPBwrb V
2 Well, first of all, I guess there is a comment I 3 want to make about our June meeting. If you remember, at 4 our June meeting we had presentations from four or five 5 utility training managers, and they had what seemed at the 6 time to be rather persuasive stories about severe problems 7 with the NRC requalification exams. And they had some 8 anecdotes of, you know, terrible questions -- examples of 9 terrible questions, and that sort of thing.
10 I was, at the time, as it turned out, kind of 11 temporarily persuaded by their case. But then the Region 12 representatives came and gave us some anecdotes of their own
~h 13 and some statistics, and I found, you know, the statistics (d
14 that were presented and the anecdotes to be kind of 15 persuasive that there really has been a problem in a lot of 16 utilities, and a lot of utilities seem to kave pretty lousy 17 requalification programs.
18 Now, by this 20 percent of 50 percent thing, the 19 NRC seems to have gotten their attention. I guess one way 20 to look at it would be, you know: maybe this has been a 21 temporary expedient to try to improve the situation among 22 all the licensees, you know, get their recalcitrants doing a 23 better job. But maybe it has done its job and it is not 24 necessary as a permanent sort of thing, that the NRC could
() 25 fall back to, you know, the more usual, more traditional ACE-FEDERAL REPORTERS, INC.
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[ sMPBwrb 1 forms of auditing this particular -- for compliance with y) 2 this particular regulation.
3 That's one way to look at it.
4 MR. MICHELSON: Are there any cases wherein the 5 NRC audit was performed and things looked all right, but 6 they went ahead and gave requalification exams anyway to 7 that utility just to kind of verify, and they found by 8 requalification exam that things were not all right?
9 Unfortunately, I'm afraid we don' t have that 10 statistic that we need, and that is--
11 MR. WARD: Would you say it again?
12 MR. MICHELSON: I will say it differently.
() 13 How do you know that your auditing program is 14 identifying the weak requalification programs? How do we
. 15 know that? Have there been any cases where we identified 16 one as looking good by audit, and then giving the exam 17 anyway and finding out it wasn' t good?
18 I don' t think there are probably any of those 19 cases.
20 MR. WARD: Have you been scientific, have you 21 gone in and given the 20 percent of 50 percent of a plant 22 that you didn' t think needed it?
23 MR. MICHELSON: That looked good?
24 MR. BOGER: We, I think, have gone to all the
() 25 plants now over the last couple of years. So we had to hit ACE-FEDERAL REPORTERS, INC.
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l 0150 04 17 70 1 some of those programs that were previously identified as
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2 successful through our audit means. And I think we probably 3 have found some that, after we gave an exam, may have turned 4 out to be unsatisfactory.
5 MR. MICHELSON: Those are the ones I would like 6 to hear about a little bit, because that tells me if we 7 decided to recommend they use only auditing, then we would 8 have a feel for how many you might miss.
9 MR. WARD: That's a good point; is this more 10 extreme auditing tool necessary?
11 MR. MICHELSON: Yes. It may be necessary; I 12 don't know.
() 13 MR. WARD: Can you answer that, Bruce? Or are 14 there enough data?
15 MR. BOGER: I don' t think we have looked at it 16 that way. We recognize that there are problems with some of 17 the questions we ask, and I hope you would realize that. I 18 was one of the ones who stood up in front of everybody and 19 pointed out some of the bad questions on those exams.
20 We think that our exam is improving. But I think 21 that right now we think that we are getting information as a 22 result of these examinations that we didn' t get as a result 23 of our audits.
24 MR. MICHELSON: And that's important.
() 25 I am getting a little more convinced. You know, ACE. FEDERAL REPORTERS, INC.
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c150 04 01 71
~ MPBwrb 1 I have never been against the idea of requalification
)
2 programs, I was concerned, though, about some of the things 3 that they were trying to find. --you know, the type of 4 examination being given.
5 If the examination, the theory part is a little 6 more oriented toward the kind of theory that they ought to 7 never forget and ask questions, that they ought to always 8 know, that would be great. But when I looked at the 9 samples-- All samples I looked at of tests, they certainly 10 were asking a lot of questions. And I wondered how helpful 11 is it to the operator to even know about that at the time 12 that he would most likely have to respond in a hurry.
() 13 I think if you go back and tailor the exam on the 14 theory part a little better, the practical part-- I assume 15 there is no question about, and I haven' t heard any 16 complaints about, the practical part, the walk-throughs or 17 the simulator exams: I haven' t heard anybody complaining 18 that they were doing -- running them through some kind of an 19 exercise they ought not to run them through, but it has been 20 all focused on the theory part, I think.
21 Isn' t that right?
22 MR. BOGER: We probably run in a dif ferent cycle, 23 or circle of friends. And I certainly receive complaints 24 about all aspects of the examination.
() 25 MR. MICHELSON: Oh, I suppose.
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c150 04 02 72 MPBwrb 1 MR. BOGEP.: We have a lot of ef fort under way to 2 make them better.
3 If I could take just a little short while to go 4 ah'ead and explain a little bit about how we intend to use 5 these performance based training programs in car 6 examinations.
7 As Forrest understands, way back when, we always 3 had complaints about our examinations not being 9 job-related. And we used the buzz word " operationally 10 oriented."
11 The discussions you have had today are very 12 similar to what we have when we have a new examiner come on
(~) 13 board, and we try to tailor this examiner's knowledge and v
14 background into that of what we think an examiner should do, 15 what questions he should ask. And we get these, you know, 16 what level of theory do you ask?
17 Well, the way we try to address that was to make 18 our examinations content valid, that is, based on the job 19 knowledge and the job content. What we did is, we worked 20 with INPO to take their job task analysis and create what we 21 call a knowledge catalogue for PWRs right now that contained 22 those knowledges and abilities that an operator should have 23 to operate the plant.
24 We had a panel of subject matter, experts, people im
( ) 25 whe were licensed people that should have known the plant, ws ACE FEDERAL REPORTERS, INC.
I 202-347-3700 Nationwide Coverage 800 336-6 4 6
0150 04 03 - 73 MPBwrb 1 SRO types, evaluate these knowledges and abilities, throw 2 out the ones that were unimportant, add ones that they 3 thought were important, and then rate each one as to its 4 relative importance to plant safety.
5 In addition to that, we developed a catalogue --
6 I'm sorry; a handbook to use that catalogue, so that we 7 would sample from those knowledges and abilities across the 8 board. So we wouldn' t home in on any one.
9 In addition to that, we have had examiner 10 training on the use of the catalogue and the handbook with 11 the emphasis on how to take a given knowledge or ability, in 12 particular one that may reflect a facility learning ability, 13 and then turn that into a testing objective for the NRC.
(' )
14 That way we have a testing objective that relates back to 15 the operator's job through that f acility's learning 16 objective, through, again, another process of peer review of 17 questions that an examiner developes to try and make sure 18 that that question really does reflect not only the job 19 knowledge but makes sense, reads well, is gramatically 20 correct, in trying to foster among the examiners this 21 awareness that we are trying to make the exam as job related 22 as possible.
23 We always get to the point where we disagree on 24 what level of knowledge that is, what level of theory we 25 In particular, calculations are one of my
(}) have to address.
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I c150 04 04 74 1, MPBwrb 1 favorites. If it is a calculation that needs to be done on
(',) 2 the job, I think it is fair game; if it is one that has to 3 do with the design charact, eristics of a heat exchanger, then 4 I would disagree: I don' t think that should be on the exam.
5 But we are working that area to try and focus on 6 the job requirements. And I have made a long story even )
7 longer', but that is basically where we are headed on our 8 examination. And I think that you will see in the rule 9 change that that's what we plan to do, make more use of the 10 facilities training program and learning objectives to 11 arrive at an examination that we considered content valid 12 and reliable.
7s 13 MR. MICHELSON: Apparently the Crystal River exam
(_)
14 didn' t get that level of thought. Is that a correct 15 appraisal?
16 MR. BOGER: Right. Well, as far as the industry 17 goes, you know, with accreditation and approved programs, 18 the industry had a couple of years to come up to that 19 speed. Not all f acilities have accrediting programs at this 20 time. So we are chicken-and-egg, we are trying to use our 21 generic catalogue of knowledges and abilities until we get a 22 facility--
23 MR. MICHELSON: Was Crystal River an accredited 24 program?
(^N 25 MR. BOGER: I don' t believe so.
\_]
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c150 04 05 75 1~ MPBwrb 1 DR. REMICK: No.
(}
k 2 MR. MICHELSON: Have they applied for 3 accreditation and been examined yet?
4 DR. REMICK: I don' t know. But isn' t this the 5 one where the learning personnel were getting ready to go 6 through the accreditation, therefore the requal programs 7 were suf fering from that? Am I right or am I mixing that 8 up?
9 There was one recently where one of the reasons a 10 requal program had broken down is that they 9ere working on 11 accreditation and kind of ignoring requal. I'm not sure if 12 it is Crystal River or not.
13 MR. BOGER: I cannot address Crystal River, but I 14 am aware that that is--
15 MR. MICHELSON: Crystal River, it was several 16 months ago that they had this flap. Wasn' t it six months 17 ago when they found out the operators were failing so badly?
18 It was several months ago. But I didn' t know whether they 19 had ever been accreditated.
20 DR. REMICK: No, they have not.
21 MR. MICHELSON: Okay.
22 MR. WARD: Thank you, Bruce. I appreciate it.
23 I would like to take a few minutes to talk about 24 the frequency of exams.
{'; 25 As I understand it, the operator's license is ACE-FEDERAL REPORTERS, INC.
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0150 05 01 76 1 ,MPBmpb 1 sort of legally renewed every two years on the basis of his
'O 2 job performance and something else. That has almost gotten 3 to be somewhat unconnected with the requalification issue, 4 it seems to me.
5 Now the requalification exams that the company 6 gives and that the NRC gives in ten percent of the cases are 7 really annual. I mean they are every year rather than every 8 two years, right?
9 MR. BOGER: Yes.
10 MR. WARD: And the basis for that, the original 11 basis for that was the sort of thing that Forrest was 12 talking about, where you want to check how people are doing
<w 13 on a fairly frequent basis so you can tane the program. And U
14 whether that is for the group or for the individual, I guess 15 I am not completely clear.
16 But is that part of the problem with the whole 17 thing, that this is too frequent? I mean there might be a 18 need for, for example, for annual examinations of the 19 population of operators just for the purpose Forrest was l
20 talking about, the original idea to tune the retraining 21 program.
22 But as far as the examination of individuals to 23 recertify their license, perhaps that should be, you know, 24 on a much longer period, maybe five years or something. I
{} 25 mean it is now nominally two years except that it's sort of ACE-FEDERAL REPORTERS, INC.
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0150 05 02 77 MPBmpb 1 an unreal period. But maybe the requalification exams for 2 which the operators as individuals are held accountable.
3 either by the NRC or by the company, should be something 4 much less frequent than every year, maybe every five years.
5 What do you think that would do to the process?
6 DR. REMICK: Well, under the new Part 55 the 7 written exam would be every two years.
8 Am I correct?
9 MR. BOGER: That's correct.
10 DR. REMICK: The performance exam annually. So 11 they are proposing a change.
12 MR. WARD: Is that enough? I mean is it 13 necessary that it be a written exam every year?
('j]
u 14 DR. REMICK: I guess it depends on what again .is 15 the purpose.
16 MR. WARD: I am trying to separate the individual 17 from the program, maybe, if that is possible.
18 I think a part of the problem -- You know, we 19 hear that operators are spending -- There are six shif ts.
20 They are spending 20 percent or 15 percent of their 21 professional time in training. And to the extent that is 22 helping them run the plant better for that 80 percent that 23 they are running the plant, that's fine. But to the extent 24 it is just for passing exams, it is, you know, of
( ,) 25 questionable utility, it seems to me.
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0150 05 03 78 1 MPBmpb 1 DR. REMICK: I personally think the two-year is 2 reasonable. I think -- Beyond that, I haven' t thought about 3 it. If it is going to be a lengthier period of time, if it 4 is going to be used to tune your requal programs, I guess I 5 would be concerned if it were less frequent than every two 6 years.
7 MR. WARD: But maybe those two thing.. could be 8 separated more explicitly; requalifying the individual 9 versus tuning the retraining program.
10 MR. MICHELSON: Would there be any merit in 11 having the exam be anonymous? But if there is a certain 12 failure level on the exam then -- You have got to keep the 13 individual people doing their best; but if the whole program 14 drops below a certain point then each member knows he is 15 going to be reexamined personally.
16 MR. WARD: Maybe that is sort of the point.
17 Maybe there ought to be an annual examination --
18 MR. MICHELSON: But anonymous.
19 MR. WARD: -- with anonymous results to tell you 20 about the program. And then each individual would be held 21 accountable --
22 MR. MICHELSON: On a five-year basis.
23 DR. REMICK: Don' t forget this is not the only 24 exam they are taking. They are being retrained on a routine
{} 25 basis and taking exams at the end of modules or sessions.
l l
l ACE-FEDERAL REPORTERS, INC.
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0150 05 04 79 MPBmpb 1 And so you have that.
2 MR. WARD: Maybe that is enough.
31 MR. MICHELSON: Well, that is the classroom exam 4 the NRC doesn' t verify. This is the NRC exam that I have in 5 mind.
6 MR. WARD: Remember, 90 percent of these are 7 still given by the company, not by the NRC.
8 MR. MICHELSON: True. That's roughly right.
9 MR. WARD: Yes.
10 DR. REMICK: Well, I personally feel that what is 11 now called annual, whether it is going to be every two years 12 or whatever, the exam should be used to tune your program 13 and not be used as a club or given greater importance on
(^}
\v 14 making conclusions, strong conclusions about the 15 requalification program.
16 I do think you need something to direct your 17 program, and I think that's useful. But I think we are 18 putting too much weight on it now. And so people are 19 studying to pass that exam. And I think that is twisting it 23 around, though maybe that should be the philosophy. I don' t 21 think it should be the philosophy.
22 I think that exam is a useful one to know where 23 you have gross weaknesses, and therefore you want to address 24 those. And if an individual has really severe gross
() 25 deficiencies you might even want to pull him off and get ACE FEDERAL REPORTERS, INC.
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0150 05 05 80 MPBmpb 1 him accelerated training before you allow him to operate 2 it.
3 I think that is a good concept myself, but I 4 think it is being distorted by the NRC coming in and using 5 that to make judgments. I can't fault them that they can 6 make judgments from them, but I think the cost of 7 demoralization of people and so forth is perhaps not worth 8 the price. The cost is not worth the benefit.
9 MR. WYLIE: Certainly for the newer and larger 10 plants there have been so many changes to the plant itself 11 in the first several years that you almost have to train and 12 give exams on just the modifications that have been made in T 13 those few years. And get a plant out further in time and
('J 14 hopefully when it settles down you can take care of all 15 these changes. But that might be something else.
16 Most of the plants I have been associated with 17 have spent more money or changes in the first five years 18 since that plant was built than the original cost. There 19 are a lot of changes being made 20 But the license period was proposed to be six 21 years, wasn' t it?
22 DR. REMICK: Yes.
23 MR. WARD: It is proposed to be what?
24 MR. WYLIE: Six years.
() 25 DR. REMICK: Six years.
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0150 05 06 81 MPBmpb 1 MR. WARD: Well, what does that mean, though?
2 MR. MICHELSON: You have got to requalify every 3 two years by examination anyway.
4 MR. WARD: Yes. But what happens after the sixth 5 year that is different than after the second or fourth year?
6 DR. REMICK: You get a three-year license.
7 MR. WARD: But is that the same thing as you do 8 after the sixth year?
9 MR. MICHELSON: Any special exam for the sixth 10 year?
11 MR. WARD: Mr. Boger nods hid3 head yes.
12 MR. BOGER: All it does is extend the period for
(' 13 us to process the paperwork from two years to six years.
'v) 14 That is probably the biggest change, short of having an 15 indefinite license, moving it up to six years.
16 DR. REMICK: This is a sideline that you might be 17 interested in.
18 The Japanese, they only have one required license 19 on shif t and that is for a three-year period. And for 20 renewal the person gets, I think it is two days in lectures 21 mostly on law and regulations, and then must pass an 22 examination. That's their philosophy.
23 MR. MICHELSON: What kind of an exam do they have 24 to pass?
() 25 DR. REMICK: Initially?
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0150 05 07 82 MPBmpb 1 MR. MICHELSON:' No, at the end of three years, or 2 whatever?
3 DR. REMICK: That's what I'm saying.
4 MR. MICHELSON: Just on law?
5 DR. REMICK: At the end of three years he has to 6 go and, if I recall, it is two days of lectures on law and 7 regulations, thoce type of things, and then pass an 8 examination on those two days.
9 MR. MICHELSON: On those two days.
10 DR. REMICK: Yes.
11 MR. MICHELSON: But never what he learned 12 initially.
/"3
'J 13 DR. REMICK: Right.
14 MR. MICHELSON: And he can do this forever?
15 DR. REMICK: Initially he took a simulator exam.
16 He spent several weeks on a simulator. And it is a team 17 type of thing. He is assigned a couple of operators.
18 By the way, the only license is for someone at 19 shift supervisor level.
20 He is assigned several operators and he trains 21 for several weeks and has to pass apparently a fairly 22 complete simulator exam. Then he goes and gets I think, 23 once again, something like -- Yes, I think it is two days of 24 lectures on law and regulations. He must pass it.
() 25 But for renewal it is just that portion of it ACE-FEDERAL REPORTERS, INC.
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0150 05 08 83 73 MPBmpb 1 that he has to pass.
V 2 MR. MICHELSON: Initially he has to have a theory 3 exam as well?
4 DR. REMICK: No. As I say, it is simulator.
5 MR. MICHELSON: But no theory?
6 DR. REMICK: And then laws and regulations, yes.
7 MR. WARD: Well, what other retraining is there?
8 I mean there are no other exams?
9 DR. REMICK: No. The company gives him a 10 simulator. They call it a family training. It is
'il l interesting, their family concept, the family team. They 12 don' t get as much, I think, simulator training as oar people
(} 13 do. But there is not the --
14 MR. WARD: Originally or in retraining?
15 DR. REMICK: In retraining.
16 Of course there are only two simulators in Japan, 17 two sites, a PWR simulator and a BWR simulator. So they 18 don' t get quite as much. They do get some, but not as much 19 as we do.
20 But they don' t have the full-fledged l 21 requalification program that we have going back to theory i
l 22 and things like that. Initially they don' t have it for 23 their exam.
l l
24 MR. MICHELSON: Who else is in the control room
() 25 besides the operator? Is that the only requirement?
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0150 05 09 84 l_ MPBmpb 1 DR. REMICK: That is the only on-shift license.
[h 2 Now they have three --
3 MR. MICHELSON: I'm thinking in terms of 4 technical knowledge available on-shift.
5 DR. REMICK: Incidentally, one thing I should 6 add--
7 MR. MICHELSON: There may be a dif ference there.
8 DR. PEMICK: I should add that that license does 9 not require a college degree, but they point out that it is 10 pretty tough if you don' t have a college degree.
11 The other people on shift, they have a -- they 12 are very much organized like we are. That is, a shift 13 supervisor that must have it.
(S G
14 We have assistants; they call it a sub-shift 15 operator. Then they have a lead operator; th6n typically 16 two, what we would call ROs, and two what we would call 17 auxiliary operators. Then they have patrolmen who are kind i
18 of trainees.
19 MR. MICHELSON: Do they have an STA or something 20 like that?
21 DR. R2 MICK: No.
22 MR. MICHELSON: So they have less technical 23 knowledge on the shift than we have.
24 DR. REMICK: Yes, although many plants have
(~T 25 another shif t during the daytime that handles a lot of the V
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0150 05 10 85 MPBmpb 1 -- To get the administrative duties off the people on shift, 2 they have another set of operators, a duplicate set during 3 the daytime handling procedural changes and checklists and 4 things like this to relieve them. So they have those 5 additional people on the day shift. But no engineering 6 expertise, no nothing like an STA that I can recall.
7 Now they do have, that is very interesting -- I 8 don' t want to divert our discussion here -- but they have 9 three other licenses that are required. They are not 10 required on shift, they just must have them to plan. One is 11 called -- It is a nuclear engineer, but there is another 12 word that comes with it. And then they have one -- a chief
(~~T 13 nuclear engineer, excuse me.
(_/
14 Then they have a chief electrical engineer and a 15 chief boiler and turbine engineer, something like that. But 16 these are usually technical department heads, all 17 engineers. They are not required to be on snif t, as I say, 18 and the two of them --
19 MR. WARD: They are not required?
20 DR. REMICK: They are not required to be on 21 shift.
22 The electrical and the turbine -- and the boiler 23 turbine type of person are carryovers from fossil plants.
24 That is a legal requirement of fossil plants too. So it 25 just means that somebody in your organization has to have a
( })
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0150 05 11 86 MPBmpb 1 license, and they added the chief nuclear engineer for 2 nuclear plants.
3 MR. MICHELSON: They are licensed, these people?
4 DR. REMICK: They are licensed.
5 MR. MICHELSON: They are examined once?
6 DR. REMICK: Yes, unless they don' t perform for a 7 while. Then they might have to take -- In other words, they 8 do that a couple of years and then they are removed and then 9 they come back, they might have to be reexamined again. And 10 -they typically -- The utilities will have one chief nuclear 11 engineer for every two units. But, as I say, their 12 technical department heads who carry that license don' t have r~x 13 to be on shift. But their responsibility is to make sure O
14 that that plant is operating within the laws and 15 regulations.
16 MR. MICHELSON: There is some other licensing 17 group? I thought you said there were three licenses, one 18 for operators and one for these engineers.
19 DR. REMICK: That's correct. There is one 20 license for on-shift. That is the equivalent of our shift 21 supervisor. And then these three, chief nuclear, chief 22 electrical and chief boiler and turbine.
23 MR. MICHELSON: And that's it?
24 DR. REMICK: That*s it.
1
() 25 MR. WYLIE: These people who claim to be college 1
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0150 05 12 87 1 graduates, are they the same level as our college graduates?
{}MPBmpb 2 DR. REMICK: I'm sorry?
3 MR. WYLIE: I mean they claim -- I know even in 4 their fossil plants they claim their operators are college 5 grad ua tes .
6 DR. REMICK: You have to be careful. They.will 7 call anybody who has a technical education an engineer, 8 whether he is a college graduate or a graduate of a 9 technical high school. That's an engineer. So in that 10 sense there is a dif ference.
11 But I think if you say that -- if you find out 12 the person has a college education, the chances are it is s
13 equivalent to our saying it is a college education here.
14 MR. WYLIE: Oh.
15 DR. REMICK: But when they say engineer --
16 MR. WYLIE: Okay, yes.
17 DR. REMICK: --
it could be a high school 18l graduate or a college graduate.
19 MR. WYLIE: That throws me off track because they 20 claim on their fossil plants their operators are technical 21 engineers.
22 DR. REMICK: That's correct, and he could be a s
'2 3 ~ high school graduate. .
24 MR. WARD: As I recall it, the French also have a 25 dif ferent s em with less emphasis on the examination and ACE-FEDERAL REPOR E ,INC.
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0150 05 13 88 T xMPBmpb 1 licensing of individuals.
U 2 As I recall, there is the group -- I mean the 3 shift crew is examined as a group on the simulators, and 4 that's the only examination there is, I think. I'm not sure 5 that's right, but it is markedly different.
6 Let me ask Bruce: Has there been any interest in 7 the NRC in qualifying groups as opposed to individuals?
8 MR. BOGER: Not in the licensing. And we have a 9 lot of activities that are related to team training, and
.0 that's typically crew-based and af ter-the-f act. And in my 11 mind there is no intention of licensing crews of people as 12 opposed to individuals.
() 13 MR. WARD: What do you mean by related to team 14 training?
15 MR. BOGER: One of the I guess outputs of the TMI 16 action plan was to consider team training as one of the 17 elements of a qualification or requalification. And I'm not 18 sure where that study ended up, but that was one of the 19 things that we had considered.
20 I think -- I look at my staf f and they are all 21 looking the other way.
22 (Laughter.)
23 MR. WARD: So it has been rejected as a proposal 24 or it hasn't been adopted?
() 25 MR. BOGER: Yes. So far as I know we are not l
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2 MR. WARD: All right. Well, that answers my 3 question.
4 Okay. Back to the subcommittee.
5 We have talked around about this a good bit.
6 There are a couple of points that we haven' t addressed.
7 And one of Commissioner Asselstine's questions 8 was -- concerned the impac t -- I think the way it was stated 9 in the transcript was the impact of this requalification 10 program on regionalization. I don' t think he really meant 11 that. Let's say he meant the impact of regionalization on 12 this.
(} 13 What have we got to say there?
14 As I recall, the burden of what we heard from the 15 Staff about the effect of regionalization on licensing exams 16 and requalification exams is that it was permitting them to 176 have a better quality of people do the NRC job. I forget 18 whether it has Staf f full-time employees or contractors.
19 The fact that examiners could live in the regions and work 20 from there seemed to be a benefit to the NRC in attracting 21 the sorts of people they wanted for the job. That's the 22 only thing I recall from what we have heard.
23 MR. BOGER: That's true.
24 MR. WARD: Do you see any other impacts of
( )j 25 regionalization on this requalification issue?
l ACE-FEDERAL REPORTERS, INC.
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0150 05 15 90 MPBmpb 1 MR. BOGER: In a positive or negative sense?
2 MR. WARD: Well, either way.
3 MR. BOGER: Well, obviously if you don' t have a 4 centralized group you have to deal with the effects of five 5 individual groups conducting examinations. So, you know, 6 from that sense we have really tried to issue guidance on 7 the qualification on how to give exaihs, which facilities to 8 consider for requalification exams. So from that 9 standpoint, you know, it was a negative influence as far as 10 additional concerns on our end.
11 From a positive standpoint we did indicate that 12 we have been able to track more examiners and it has been a 13 chance for resident inspectors to perhaps use their (G")
14 knowledge of a particular plant in the examination field.
15 And the locations of some of the regional offices 16 has proven to be quite an attractive improvement means.
17 MR. WYLIE: Would this perhaps to some extent 18 account for the dif ferences between regic's, the plants that 19 we have heard where in some cases we hear horror stories 20 about the examinations, and then in other cases that 21 everything is a bed of roses, everything is just great?
22 Would that account for that?
23 MR. BOGER: I think it is fair to say that the 24 regions do have dif ferent points of view. And each one
() 25 determines the amount of resources that they are going to ACE FEDERAL REPORTERS, INC.
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0150 06 01 91 MPBmpb 1 devote to a particular plant or set of examinations, and 2 that could in fact change the results of the positive 3 actions, the more thorough approach.
4 I should indicate another positive approach is 5 that in the regions you do have a lot more indication from 6 the resident inspectors, who then can feed back recent plant 7 occurrences, things to be aware of, more detailed plant 8 knowledge. There are issues like that that are a positive 9 effect.
10 MR. WARD: You mean the examiners would have more 11 personal contact with --
12 MR. BOGER: With the facility. They would know
(~) 13 the facility better. Plus they would know the resident U
14 inspector, so that the resident inspector could in some 15 cases look at their exams and make sure that the terminology 16 . was correct and that the procedure referenced was indeed the 17 la test procedure, and that there wasn' t an additional plant 18 change that had beer implemented without updated training l
- 1. 9 material that the examiner had. So there are a lot of 20 positive influences that way.
21 DR. REMICK: I think the major negative I have 22 heard is the inconsistency from Region Three to people who 23 bless that they are in a particular region or curse that 24 they are in a particular region from the requalification
/ ) 25 s tand point.
I \_)
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0150 06 02 92 MPBmpb 1 MR. WARD: Okay.
2 Let me go back again to something we've talked a 3 little bit about, another one of Commissioner Asselstine's 4 questions. And maybe we can get a little bit more of a 5 discussion.
6 The question, paraphrased, is: Is the 7 requalification program fostering the gradual increase in 8 the engineering expertise on-shift.
9 Now I don' t know whether that is -- whether you 10 think that is even a desirable goal, that there be an 11 increase in engineering expertice on all the shifts across 12 the country. So that might be a question.
13 But does the requalification program as it stands
(^)3 t
14 now or as it could be have anyth.ing to do with this 15 I particular issue?
16 DR. REMICK: I think probably -- I don' t quite 17 understand it, unless there is something I am missing. I am 18 not sure I know what the connection is.
19 MR. WYLIE: Well, I have some changes. If it 20 says does the requalification program cause a gradual 21 increase in technical competence on the shift, I would have 22 to say yes.
23 MR. WARD: Well, I would interpret that as the 24 same thing, engineering expertise and technical competence.
() 25 MR. WYLIE: I think it does.
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1 0150 06 03 9-3 MPBmpb 1 MR. WARD: How so?
2 MR. WYLIE: Well, in absence of it I don' t think 3 you would have the same quality of technical competence, I
4 personally. I mean that is my opinion. In the absence of 5 it, say you didn' t even have it, you know, I think you would 6 have poorer operations.
7 MR. WARDt But just -- Because the requal 8 training programs include engineering subjects, is that it?
9 MR. WYLIE: Well, y's, I think so, the technical 10 subjects. That makes them look better, more qualified 11 technically and competent operators.
12 MR. MICHELSON: I interpreted the question 13 somewhat dif ferently. I don' t seem t' o have Asselstine's
(~]
\~j 14 wording here.
15 DR. REMICK: Here it is.
16 MR. MICHELSON: You have got his wording?
17 DR. REMICK: Yes.
18 MR. MICHELSON: We had better bring that one l
19 along. It is a little different than what John had put in 20 his letter, I think -- Well, no, I guess it is the same.
21 I didn' t know what it meant by " engineering 22 knowledge" as opposed to an understanding of how your plant 23 operates and things of this sort, which is not engineering 24 knowledge necessarily. So it is a question of was he
(~') 25 thinking in terms of increasing the depth of comprehension?
v 1
l ACE-FEDERAL REPORTERS, INC.
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0150 06 04 94 MPBmpb 1 Is that what he mesnt by " engineering knowledge" as opposed 2 to some other term he might have used?
3 MR. WYLIE: I think it is a lawyer's way of 4 saying competence in terms of operation of the plant.
5 MR. MICHELSON: Clearly it will increase the 6 competence, continued operation. Whether it will increase 7 the engineering knowledge, I don' t know. It depends on how 8 you define it.
9 And I didn' t know if he was seeking something 10 deeper or what. In other words, there are those who think 11 they would like to have graduate engineers operating the 12 plant, and does requalification somehow help that. And I
/~N 13 think the answer is it does not. I don' t think it gives you V
14 the kind of background that maybe a graduate engineer might 15 have, nor is that necessary either. It's not necessary to 16 have graduate engineers running the plants. That's another 17 argument.
13 MR. WYLIE: Nor is it necessary to make that a 19 prerequisite.
20 DR. REMICK: Does the Staff have any insight on 21 that question?
22 MR. BOGER: I think in the context of a lot of 23 the material that has been before the Commission lately has 24 been engineering expertise on shift. Should the STA be n
() 25 there? Should the SRO have to agree? And I think he may ACE-FEDERAL REPORTERS, INC.
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0150 06 05 95 MPBmpb 1 have been looking at that context when we were developing 2 engineering type knowledge among the operators as a result 3 of requalification.
4 MR. MICHELSON: That's what I thought. And if 5 that is the case I would say the answer to that question 6 would be I don' t think the requalification program is making 7 a significant change in that kind of availability on shift.
8 MR. WARD: Could it or should it?
9 MR. MICHELSON: I don' t think it -- Well, that 10 gets back to the question should you have engineers running 11 the plant as operators. If the answer is yes, then the 12 requalification program had better do something to bring
/~T 13 operators up as close to that as you can get. But I don' t b
14 believe it has ever been decided that you need engineers to 15 operate the plant.
16 MR. WYLIE: Well, I am frankly disturbed about 17 the use of STAS anyhow. I think it varies from utility to 18 utility, but in the last several plants that we have looked 19 at in our ACRS work what we are finding is they are taking a 20 junior level engineer that just came to the company and they 21 are making him the STA and they are doing some training.
22 Basically he is a ned kid on the block, wet behind the 23 cars.
24 And here you have got experienced, well trained, f~) 25 highly technically competent operators. And I have asked v
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i I l
0150 06 06 96 l 1 several of them a question: Would you listen to this guy in 0_MPBmpb 2 an energency? And basically they say no. So I mean, that's 3 what you've got.
4 So I think the requal program is, if you want to 5 say, it may well -- to answer that, I think it does 6 gradually increase the technical competence on the shif t.
7 DR. REMICK: I think we could answer, if we are 8 in agreement, that we don' t see a relationship between 9 requalification and engineering knowledge necessary, however 10 -- and then make your point. I think that would be the way 11 to handle that.
12 MR. WARD: But I suspect his question really was 13 -- as Bruce said, he was really groping to see if there was 14 anything here related to the engineering expertise on shift 15 question.
16 MR. MICHELSON: Are we upgrading operators 17 somehow to make engineers out of them?
18 MR. WARD: Yes.
19 MR. GIMMY: I think the answer is no to that 20 because --
21 MR. MICHELSON: Yes, I hope so.
22 MR. GIMMY: --
the questions they complain about 23 are the same old questions that they had to pass on the 24 first license test. So, A, they are not learning any more;
(^T 25 B, if they were slowly but surely getting bites of an U
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0150 06 07 97 MPBmpb 1 engineering education, why, if we define that as four years 2 of college, at the requal rate it would take 100 years to 3 get there or something.
4 So it is not going to make degree-holding 5 engineers out of them.
6 DR. REMICK: There is an interesting sideline to 7 this:
8 One could argue that the NRC requalification 9 requirements, and the answer is no. But the INPO 10 accreditation process where -- The STA is one of those 11 positions that is accredited , the training of it, and that 12 requires retraining or continuing training. And presumably
(~] 13 that STA, if he's in an accredited program, is going to V
14 continue to learn engineering things.
15 But it's not the NRC requalification requirement 16 because that's just for operators and SROs. But the INPO 17 accreditation process should add some engineering expertise, 18 that requalification program. But that's not what he's 19 asking.
20 MR. GIMitY: The answer to his question is no.
21 MR. MICHELSON: But the INPO accreditation 22 process is only based on if you have an STA then here is the 23 kind of program to get him accredited.
24 DR. REMICK: Every plant has to have an STA, even 25
() if that STA is an SRO on shif t.
1 ACE-FEDERAL REPORTERS, INC.
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0150 06 08 98 MPBmpb 1 MR. MICHELSON: It is not going to remain 2 indefinitely that way, is it? I thought you could 3 substitute an SRO later.
4 DR. REMICK: No.
5 MR. WARD: He has to meet the qualifications of 6 the STA.
7 MR. MICHELSON: Yes.
8 Oh, he has to -- But he has to be degree-holding, 9 then.
10 DR. REMICK: Absolutely, yes.
11 MR. WARD: Well, that is what is a little 12 controversial now.
(~N 13 DR. REMICK: That is on the street, isn' t it?
k]
14 MR. MICHELSON: Is it on the street now, he must 15 be degree-holding?
16 MR. WARD: I mean a separate STA doesn' t have to 17 have a degree. He has to have some sort of equivalency.
18 But if he is combined with the SRO, that person has to have 19 a degree.
20 MR. MICHELSON: Oh, if the SRO happens to be the 21 STA then he must be a degree-holding person? Is that what 22 you're saying?
23 DR. REMICK: Degree-holding with a couple 24 exceptions.
em qj I 25l MR. BOGER: If you want to use the SRO as the ACE FEDERAL REPORTERS, INC.
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0150 06 09 99 1 MPBmpb 1 STA, he must hold a degree.
2 MR. MICHELSON: He must then hold a degree in 3 engineering or science?
4 DR. REMICK: Or physical science?
5 MR. BOGER: If he really has a dual role he has 6 to have the elements of both.
7 MR. MICHELSON: But if he is the STA alone he 8 doesn' t have to be degree-holding?
9 MR. WARD: Well, he has to have some 10 equivalency.
11 MR. MICHELSON: But it is pretty broad.
12 MR. WARD: Yes, it is.
13 MR. MICHELSON: Pretty loose.
14 MR. WYLIE: What is the rationale for that?
15 DR. REMICK: The five-man Commission.
16 ( Laug h ter. )
17 MR. WARD: The Staff proposed something 18 different.
19 The Staf f proposed that the requirements -- for 20 as long as the person met the existing requirements for STA 21 and SRO that a single person could hold the dual role.
22 MR. MICHELSON: Yes.
23 MR. WARD: But the Commission changed that and 24 tightened it up. It said, 'Okay, if there is going to be a
()
25 dual role we are going to tighten down the requirements and l
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I 0150 06 10 100 1 -s MPBmpb 1 say it really has to be a degree.'
O 2 DR. REMICK: Of course you could argue that 3 probably over the long term it is a possibility the 4 Commission might get rid of the separate STA because that 5 was always a possibility. So you may make an argument that 6 basically in time with future Commission actions that that 7 difference may not exist.
8 MR. MICHELSON: I would say there would be at 9 least an SRO on every shif t with a degree if you eliminate 10 the STA. They are backing into the idea that they want a 11 degreed person.
12 MR. WARD: Okay.
13 Well, we are going to take a little time later 14 this afternoon to, if not draf t a letter on this subject, at 15 least talk about the elements of what will be in a letter.
16 But at this time, while the Staff is -- You know, the Staff 17 might not be with us then.
18 While the Staff is still with us I would like to 19 talk a little bit about the presentation at the full 20 committee meeting next week or whenever it is -- the week 21 after next, I guess.
22 We have got -- Let's see.
'23 John, I have got the schedule here. We start out 24 Thursday morning with that, 8:45 to ten a.m. This is the 25 agenda as it stands now, Thursday, December 5. So it is
{])
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0150 06 11 101 MPBmpb 1 two and a quarter hours.
2 And to the Subcommittee now, how do you think we 1 3 should present this information to the full committee so 4 that we can end up writing a report of our advice on the 5 subject?
6 DR. REMICK: This may sound like an educator, I 7 guess, but it always worries me about -- On an issue like 8 this, the chances are that a good portion of the full 9 committee isn' t going to understand what even are the 10 requirements of a requalification program. So it makes it 11 awfully hard to focus because people have misconceptions.
12 It seems to me that we ought to have some kind of
(~'T 13 a -- It has to be brief, but maybe a 15 minute tetorial on
\_)
14 what we mean by requalification; what are the requirments, 15 basically.
16 MR. MICHELSON: And there has to be a little bit 17 of experience presented so that they know it in a problem.
18 We have to talk about the program, the dif ficulties, why are 19 we here.
20 MR. WARD: Yes.
21 MR. MICHELSON: We should have a little bit of 22 time so that they can focus on the seriousness of the 23 problem, if it is serious and so forth.
24 MR. WARD: Okay.
25 MR. MICHELSON: In other words, what has gone
(( )
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0150 06 12 102 MPBmpb 1 wrong with the ideas o'f the requalification program. And we 2 will tell them first what the program is.
3 MR. WARD: Okay. I guess in the introduction we 4 car. talk about that and remind then of Asselstine's 5 questions.
6 MR. MICHELSON: Yes.
7 And you need to remind them of the present 8 auditing process and the requalification exam by the NRC as 9 opposed to by the utility, and the fact that there have been 10 some discrepancies between what the utilities thought they 11 had done and what the NRC's exam verified that they had not 12 done.
(~s, 13 MR. WARD: Okay.
q) 14 So if we had a tutorial on just the requirements 15 for requalification in the regulation and in practice, and 16 then talk about how the NRC audits that, and then talk about 17 the 20 percent of 50 percent NRC administered 18 requalification exam, and then give sort of a balanced 19 presentation on recent experience.
20 Now how could we get that? Should we ask someone 21 representing the licensees to come in and give a part of 22 that?
23 MR. MICHELSON: It takes so much time, though.
24 They would want a half an hour. If you asked Crystal River ,
() 25 or Florida Power to como in they would want at least a half ACE-FEDERAL REPORTERS, INC.
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0150 06 13 103 MPBmpb 1 an hour.
2 MR. WARD: What about asking KMC to come in to 3 give a short -- I mean could someone from the Staf f give 4 the, you know, a summary of the regional experience?
5 MR. BOGER: Yes.
6 MR. WARD: And if we could get someone from KMC 7 to give the industry perspective on the experience. We 8 would have to get these all to add up to --
9 MR. MICHELSON: Tell them to include Crystal 10 River because that is the main one I studied a little bit.
11 And it looked like a pretty bad experience, as near as I 12 could tell.
{} 13 MR. WARD: Okay.
14 What else?
15 MR. MICHELSON: I was on the subcommittee.
16 That's why I spent so much time on it.
17 MR. WARD: Okay.
18 Well, what else then?
19 John, can you think of anything? We could work 20 out the times for this a little later, and you could get 21 with Bruce.
22 MR. SCHIFFGENS: Okay.
23 MR. WARD: I guess that kind of closes all 24 the....
() 25 Okay. If you will plan on that, John will get ACE-FEDERAL REPORTERS, INC.
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l 0150 06 14 104 MPBmpb 1 with you on the details. We have an hour and forty-five 2 minutes, but you have got to allow a lot of time in there.
3 Those sound like several ten- or fifteen-minute 4 presentations at the most. The committee members will have 5 a lot to say.
6 MR. BOGER: If John can identify those areas he 7 would like us to address, certainly we will respond.
8 MR. WARD: Okay.
9 MR. WYLIE: Might I ask something? It is not 10 pertinent, I don' t think, to writing the letter. But back 11 in February, you know, we discussed with the Commissioners 12 the check-operator concept of administering the requal r~S 13 exams. And then later the Commission met with Newmark and V
14 at that meeting discussed that with them. And the chairman 15 said that he would request the Staff to work with Newmark 16 toward the trial program.
17 And I don' t know whether Mr. Boger can address 18 what has happened on that request or not, what has taken 19 place.
20 MR. BOGER: Newmark has formed I guess a working 21 group to address the check-operator concept. They have had ,
22 a couple of discussions with the Staff and they have not 23 really come back to. the Commission to present any sort of a 24 program.
() 25 MR. WYLIE: So the ball is in Newmark's court?
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0150 06 15 105 MPBmpb 1 MR. BOGER: As I see it, yes, sir.
2 MR. WARD: I see. 1 3 MR. MICHELSON: Does the check-operator have 4 anything to do with the theory part or just with the 5 practice part of the exam?
6 In other words , the walk-through could be a 7 check-operator or the simulator exam could be a 8 check-operator. But would the theory part be a ;
9 check-operator?
10 DR. REMICK: As I envision it, it would be the 11 entire exam.
12 MR. MICHELSON: Would that mean that the
(^3 13 check-operator decides what kinds of questions to ask and so
%)
14 forth out of perhaps a library of questions?
15 DR. REMICK: As I would envision it, yes.
16 MR. MICHELSON: I had never thought of the theory 17 part being anything other than an exam put together by NRC, 18 for instance, for this particular plant, and the 19 check-operator j ust administers the exam.
20 DR. REMICK: As I would envision it -- And if the 21 Staf f wants to respond to it -- personally I thought that 22 this would take you back to what was the case before the 1 23 Commission imposed this NRC audit, that you would be back --
l 24 the.t the utility would be responsible, but if you had a l
(} 25 check-operator you would have somebody designated as l
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0150 06 16 106 MPBmpb 1 somebody who the Commission had confidence in could 2 administer a good requalificatioc examination. So you 3 wouldn' t be letting it necessarily entirely to the utility, 4 but maybe having the training manager being the one doing 5 it; that there would be somebody who is named as the 6 check-operator, that he has experience and that we have 7 confidence in, that he is going to administer the 8 requalification examination. I always envisioned that would 9 be the entire exam.
10 MR. MICHELSON: Would he have to take the 11 questions out of a standard library of questions or would he 12 make up his own?
~% 13 DR. REMICK: Personally, I hadn't thought that d
14 through. I would hope it would be performance-based. And 15 certainly a library is helpful to anybody writing an exam on 16 ,
ideas.
17 If that library was good performance-based 18 questions, I would say why not. In fact, it would be very 19 helpful. You could get some kind of consistency across the 20 entire cour.try by doing that.
21 So my answer would be I would think so, yen, if 22 it was a good library of questions.
23 MR. MICHELSON: Somehow I had always thought of 24 the check-operator as the one who goes up with the pilot to f')
t- .
25 see if he knows how to fly the plane.
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0150.06 17 107
),MPBmpb 1 DR. REMICK: He is that. But, as I say, that was 2 j ust my own personal view when we had talked about it. I 3 could see that this is somebody administering the 4 requalification exam, the written, the walk-around, the 5 simulator.
6 MR. WYLIE: Let me ask a question. -
7 The FAA concept, the check operator, isn' t he 8 certified by FAA as the check-operator in that airline?
9 DR. REMICK: The check-pilot, yes, sir.
10 MR. WYLIE: The check-pilot. So in concept --
11 MR. WARD: There might be a number of them on a 12 given airline.
13 MR. WYLIE: But the concept we were looking at 14 here, then, it would be the NRC certifying the utilities' 15 check-operator?
16 DR. REMICK: Yes.
17 MR. WARD: Well, does the NRC now -- I mean there 18 is someone in the utility who signs off on the performance 19 of the operator every two years now, right?
20 MR. BOGER: Right.
21 MR. WARD: Certifies to the -- And who is that?
22 Does the NRC certify that person or does it have any
- 23 requirements for who that is?
24 MR. BOGER: It is typically a senior vice l
(} 25 president or someone.
l l
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c150 06 01 108 MPBmpb 1 MR. WARD: Yes.
2 MR. BOGER: We don' t have any licensing 3 requirements on such a person, but we hope that he is high 4 enough in the chain that he is responsible for the 5 operations of the plant and the operators.
6 DR. REMICK: Actually, Dave, there are two 7 people:
8 The one that Bruce was talking about, the person 9 who certifies that this person has performed as an operator; 10 he has successfully passed the requalification program and 11 this type of thing is the senior VP. But there is another 12 person who administers the annual exam. And I think this 13 varies across the industry. But quite typically there is
(^)s L
14 somebody who is deigned to be able to prepare the questions 15 this year, and he is exempt from them. But quite often, 16 then, he cannot do that next year or he can' t do it many 17 more than two years. Somebody else has to do it so he can 18 be tested.
19 Am I correct? That's the way it generally 20 works.
211 MR. BOGER: Yes.
22 DR. REMICK: So there are two people. One is the 23 person who certifies and the other is the person who writes 24 the annual requalification examination. And many utilities f')
v 25 I know have a system where they make sure that that guy f
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0150 06 02 109 MPBmpb 1 isn' t exempt for years and years.
2 MR. WARD: He might take the exam every other 3 year. Bat is he typically the plant manager, the operations 4 superintendent or the head of the training department, or is 5 he a shift operator?
6 DR. REMICK: It is one of the former, but I think 7 it varies from plant to plant, in my understanding. But 8 that is not the gospel. It is just an impression I have.
9 It could be the training manager, if perhaps he was 10 licensed.
11 12
.f^g 13' Q ,!
14 15 16, 17 18 19 20 21 22 23 24 25
(*)
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0150 07 01 110 MPBagb 1 MR. MICHELSON: It has to be a licensed person, 2 doesn' t it?
3 DR. REMICK: I don' t think it has to, but 4 typically it is.
5 MR. BOGER: Typically that person used to be an 6 SRO but what happens a lot of times now is the people who 7 are responsible for developing the examination, the writing 8 of the questions and reviewing those questions, do not have 9 to take the exams. That's one of the sore points you 10 mentioned if somebody can do it year af ter year and just 11 review the exam rather than taking the exam.
12 MR. WARD: But a lot of the thrust of some of the r3 13 emotion behind the check-opccator sort of thing is that this (J
14 should he a peer of the people taking the exam. I would say 15 that means it should be a working SRO and, under the 16 existing system, the person who now does that may be an SRO, 17 may hold an SRO license, but he doesn' t really work as an 18l SRO, he works as the office manager or as the training 19 supervisor or something lika that. And so I think a lot of 20 people who are behind the check-operator kind of thing are 21 behind it to get it over to where it is a real peer 22 evaluation and not just by someone who holds an SRO.
23 MR. MICHELSON: Now I gather it doesn' t even have 24 to be a licensed person.
25 MR. WARD: No.
(U~S ACE-FEDERAL REPORTERS, INC.
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0150 07 02 111 1 MPBagb 1 MR. MICHELSON: -- who does the examining.
()'^
2 MR. WARD: But just requiring that it be someone 3 who holds an SRO won' t get the peer evaluation part in 4 there.
5 Okay. Well I guess we have yakked about this 6 enough. Let's take a break for lunch. We will come back 7 at, as the agenda says, at 2:30 for the remainder of the 8 agend a .
9 Thank you very much.
10 (Whereupon, at 1:30 p.m., the meeting of the 11 Subcommittee was recessed, to be reconvened at 2:30 p.m.,
12 this same day.)
-O 14 15 16 17 18 19 20 i 21 22 23 24 25 ACE-FEDERAL REPORTERS, INC.
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0150 07 03 112 1 AGBagb 1 AFTERNOON SESSION l' ' 'i 2 (2:30 p.m.)
3 MR. WARD: We will reconvene and the first topic 4 on the agenda this af ternoon is a review of the final rule 5 on 10 CFR Part 55 and Ms. Shankman -- or first you have an 6 introd uc tion?
7 MR. BOGER: Yes, I do.
8 MR. WARD: Okay. Go ahead, please.
9 MR. BOGER: First of all, I would just like to 10 chank the Committee for getting together with us. We 11 appreciate the opportunity to present this rule change, it's 12 an item that has been of considerable interest in the NRC r- 13 and the industry and we recognize the tight timeframe you
(_3/
14 have between now and next week's f all Committee meeting. So 15 what I'd like to do is basically tell you a little bit about 16 the history or refresh your memories on why we have 17 proceeded with the rule change.
18 Basically a lot of it is outgrowth of the TMI-2 19 accident where we came up with a lot of potential chsnges to 20 the operator licensing program and we felt that we needed to 21 put them all in one place.
22 In addition, in December of 1982, the Waste 23 Disposal Act came out requiring us to take some action in 24 this area.
{} 25 ( S lid e . )
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/"s AGBagb 1 As you will remember, this was all combined in a b 2 training and examination type package and then in February 3 of '84, SECY 84-76 was our proposed rulemaking on training 4 and qualifications.
5 In September of that year, af ter considerable 6 discussions with industry and Newmark and INPO, the 7 Commission decided that we would defer the training rule but 8 we would continue on with the operator licensing portions of 9 it.
10 so we went ahead and we published the proposed 11 changes to Part 55, which is the operator licenses, and we 12 also published the associated Reg. Guides to implement this
(} 13 regulation in the November / December 1984 timeframe.
14 The public comment period lasted about 90 days, 15 it ended in around March of 1985, and we went through a lot 16 of discussion on the resolution of the public comments. As 17 you see, we had over 1600 comments from individuals or
- 18. corporations and we, in fact, encouraged this comment period 19 and this amount of comments. We sent the copy of the 20 proposed rule change and Reg. Guides to every licensed j 21 operator and also to training organization and facilities, 22 so we tried to send them to the people that were directly 23 af fected by the rule and we had considerable comments.
1 24 We received regional input on the resolution of
()
25 comments to make sure that we were hitting those issues that l
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0150 07 05 114 1 AGBagb 1 the folks that are actually conducting the exams now were
[b
.2 having problems with and we also tried to factor in the 3 Commission's policy statement on training and qualification; 4 in particular, we tried to make use of industry initiatives 5 in this area to make sure that our regulations were focusing 6 on the direction that the Commission has guided us and also 7 the direction that we believe the industry is taking anyway.
8 (Slide . )
9 Okay. There are three main objectives to the 10 rulemaking: basically one is to improve the safety of 11 nuclear power plant operations by making sure that the 12 operators are better qualified or better able to do their 13 jobs.
s)s 14 Second was to improve the basis for licensing 15 exams and conducting operating tests. This was to make sare 16 that we were looking at the operator's job and make sure 17 that the exams reflect that job and also to make our 18 operating tests reflect the job through the use of 19 simulators and simulation devices.
20 Finally, it was to respond to the Public Law, 21 Section 306 of the Waste Disposal bill which required us to 22 establish regulations in the area of examinations, 23 particularly in simulator examinations.
24 MR. WARD: Let's see, did the Section 306 of the
{} 25 law require you to establish regulations in the area of ACE FEDERAL REPORTERS, INC.
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N 0150 07 06 115 AGBagb 1 training?
2 MR. BOGER: Training and qualifications, also to i
3 establish regulations in the examinations of operators.
4 MR. WARD: Yes, but I mean the training part of 5 the rule was deferred to wait and see what Newmark and INPO 6 would come up with. How did you get away with it under the 7 law?
8 MS. SHANKMAN: Section 306 said regulations or 9 other appropriate guidelines. And I think Jay can speak to 10 how that's been interpreted.
11 Jay, do you want to. . . .
12 MR. BOGER: Jay Persensky was responsible for the 13 whole rule but primarily the training rule at the start and
{J')
14 he might be able to better address that.
15 MR. WARD: Well I mean specifically the point is 16 somehow you've been able to interpret things so that the 306 17 didn' t -- permitted this action of deferring to Newmark and 18 INPO on the training.
19 MR. PERSENSKY: Jay Persensky, NRC Staff.
20 The way the Nuclear Waste Policy Act was written, 21 it said regulations or guidance. And using the guidance 22 guidance and the many negotiations and discussions with the 23 industry, we elected to put out the training and 24 qualifications policy statement which we feel constitutes t)
Lj 25 guidance but we also have the two-year evaluation period in ACE-FEDERAL REPORTERS, INC.
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0150 07 07 116 AGBagb 1 order to follow-up on that if necessary.
2 DR. REMICK: I have a slightly dif ferent 3 question:
4 Now taking the policy statement in which the 5 Commission said that it would not issue other rulemaking for 6 a period of at least two years, how do you catisfy yourself 7 that this is not inconsistent with that policy statement?
8 MS. SHANKMAN: They exempted on-going work in 9 operator licensing and specifically culled that out. That 10 was not part of the policy statement and didn' t preclude us 11 from issuing these regulations.
12 MR. PERSENSKY: The policy statement specifically
( 13 excluded licensed operators and senior operators with regard 14 to the licensing process itself.
15 DR. REMICK: I see. So this fits within that 16 category of on-going activities at that time?
17 MR. PERSENSKY: Correct.
I 18 MS. SHANKMAN: I'm Susan Shankman, I'm with the 19 Operator Licensing Branch. And John asked us to go through 20 this package by the numbers and so that's what we' re going 21 to do. You can stop me at any time.
22 MR. WARD: That sounds a little ominous, put it 23 that way.
24 MS. SHANKMAN: What, by the numbers?
25 MR. WARD: 2es.
i
)
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0150 07 08 117 AGBagb 1 MS. SHANKMAN: Yes, well.... Is your package as 2 big as mine, did John. . . .?
3 MR. WARD: Yes.
4 MS. SHANKMAN: Okay.
5 MR. WARD: We just want it explained to us. You 6 don' t have to go through it by the numbers.
7 MS. SHANKMAN: Well.... We'll try to follow it 8 in terms of the way it's organized in the rule. And 9 obviously some parts relate to other parts, not sequentially 10 the way they're organized in the rule. So that may -- bear 11 with us anyway.
12 (Slide.)
13 The beginning, of course, is the general purpose, 14 scope, as it has been in the past, it applies to individuals 15 who manipulate controls and those who direct licensed 16 activities.
17 The definitions in this particular rule follow 18 others that the Commission has issued, except there are a 19 few that are particularly new since we issued it for pub:ic 20 con.me n t . And rather than discuss them absent the context, 21 I'll just tell you that as we get to them we'll discuss 22 actively performing the duties of a licensed operator, 23 simulation facilities and the systems approach to training.
24 Those are now in the definitions section.
f^') 25 DR. REMICK: Could I ask you to try to point out u-ACE-FEDERAL REPORTERS, INC.
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0150 07 09 118 1 AGBagb 1 one other thing?
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2 The copy that John sent us several weeks ago, I'm 3 tola, has been revised. We would be particularly interested 4 in your pointing out any changes in today's version versus 5 what we received a couple weeks ago.
6 MC. SHANKMAN: For this particular section, we 7 have added the definition of a systems approach to 8 training since we mentioned it under requalification and 9 under content of exams. We've put in the five basic 10 elements that appear in the policy statement as the NRC's 11 definition of what we mean when we refer to a systemmatic 12 approach to training or a systems approach to training.
13 And then as we get to the pages, I'll tell you
~'
14 where there's something different.
15 DR. REMICK: All right.
16 ( S lid e . )
17 MS. SHANKMAN: The exemptions in this are pretty 18 much what they've always been under operator licensing, that 19 is, students in nuclear engineering courses are exempted 20 from having to be licensed.
21 We've also clarified what we meant by " trainees."
22 We've always exempted trainees from needing a license to 23 manipulate the controls, but we've now made it trainees in 24 NRC-approved operator training programs. And that came out
{} 25 of some experiences where....
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1 0150 07 10 119 I 1 ,AGBagb 1 DR. REMICK: A question of kind of academic
(' '\
'# curiosity: have you ever had any difficulty with 2
3 universities that don' t have nuclear engineering courses; 4 they might have a research reactor but they don' t have a 5 nuclear engineering department hence, literally, nuclear 6 engineering courses but they give a nuclear engineering 7 title? I'm thinking of Rensselaer, for example, I don' t 8 think they have a nuclear engineering degree. Have you ever 9 run into this problem?
10 MR. BOGER: We've never had anyone bring it up 11 before.
12 DR. REMICK: I remember once some years ago at 13 our university we ran into a problem where people were in a G,r y 14 radiochemistry course and wanted to use a reactor and we 15 took a literal meaning, no, they couldn' t do it in 16 radiochemistry it was intended to be nuclear engineering. I 17 think that's a little strict.
18 But I was wondering -- I was reading this the 19 other day, I was thinking have you ever run into a problem 20 there, so sharply defining it as nuclear engineering 21 courses 22 MR. BOGER: We never have.
23 DR. REMICK: Okay.
24 (Slide.)
/} 25 MS. SHANKMAN: The medical requirements are ACE-FEDERAL REPORTERS, INC.
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0150 07 11 120 1 AGBagb 1 basically the same as when we put out the proposed rule.
O 2 We've done some clarifying, when we have to be notified 3 about disabilities. This originally came from a petition by 4 KMC that said won' t you please simplify the process by which 5 medical evaluations are made and documented. We keep the 6 biennial medical exams. I'll talk tomorrow about Reg. Guide 7 1.134 where we specifically endorse the ANSI standard, the 8 3.4 1983.
.9 But instead of having the complete documentation 10 sent on every applicant for operator, we're now asking for a 11 certification by the facility on a revised 396 form and the 12 form is basically a certification. I have copies of
<- 13 anybody's interested . It asks the facility to certify to us
(_)S 14 that the candidate, applicant, operator has been examined by 15 a licensed medical practitioner and meets the standards in 16 the AMSI standard and where they don't, we ask them to send 17 in medic,al documentation.
18 And this is a way in which NRC can get out of the 19 medical business and only in the unusual case will we ask 20 for documentation and then we will send it to one of our 21 medical experts for review.
22 In terms of notifying us about incapacitation 23 because of disability or illness, we've always asked for 24 that. We've asked for it within 15 days; we' re now asking
(~') 25 for it within 30 days because the agency is going to 30 days
</
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0150 07 12 121 1 on everything as a consistent standard.
{~}AGBagb 2 And we're also saying that if that incapacitation 3 is less than 30 days they dcn' t even have to let us know; 4 that takes care of temporary conditions. But if it is going 5 to be longer, then we require that we be notified and also 6 that they send us documentation when the operator returna to 7 license duties and justify it based on medical evidence.
. 8 I think it is straightforward and hopefully less paperwork 9 and less problems.
10 (Slide.)
11 MR. WARD: I guess the only -- what are you 12 saying, that it becomes important is when -- or dif ficult
() 13 is with a psychiatric illness.
14 MS. SHANKMAN: In the Reg. Guide, we --
15 MR. WARD: Is where you talked about that?
16 MS. SHANKMAN: Yes.
17 MR. WARD: I'll wait until tomorrow then.
18 MS. SHANKMAN: Okay. Thanks.
19 Okay, in terms of applying to us to be licensed, 20 as you may remember -- I don' t know, when we came down last 21 time we were all -- this was tucked in with the training 22 rule so it may not have been highlighted, but we've been l 23 using Form 398 for a long time and now we have the rule to 24 say what we've been doing.
) 25 There are a lot of changes like that in this rule i' ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800-33M646 _ ._
0150 07 13 122 AGBagb 1 where we have cleaned up the rule to make sure that it 2 conforms with what we're doing.
3 The difference here -- and this is new on your 4 package -- on page 26, under 55.31( A) (4 ) we have added words 5 that basically say if an applicant has completed an 6 NRC-approved training program that uses a simulation 7 tacility acceptable to the NRC that we will then administer 8 an appropriate licensing exam and operating test.
9 So you can also decode that -- because in the 10 rule we don' t mention INPO -- but what we' re saying in the 11 statement of considerations is that an NRC-approved training 12 program will be an INPO-accredited program, will f all under t') 13 that category, if they use a simulation facility. It also C/
14 allows us the option if the INPO program is not working to 15 not approve it, so it gives us the most flexibility.
16 So if they're in an approved training program 17 with a simulation facility, they do not have to document all 18 the training as they have in the past.
19 (Slide.)
20 DR. REMICK: Do I infer from that then if they 21 have decided not to go the INPO-accreditation route that you 22 would require documentation of specific training received?
23 MS. SHANKMAN: No, if it's an NRC-approved 24 training program, not necessarily.
25 DR. REMICK: But if it was not NRC-approved --
(])
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?~TAGBagb 1 MS. SHANKMAN: If they are not in an NRC-approved O
2 training program that uses a simulation facility, no, they ,
3 would have to document their experience and their training 4 courses the same way as they do now based on the Reg. Guide.
5 DR. REMICK: I'm not if this is the appropriate 6 place to ask this question but I had better do it or I'll 7 forget: On the medical exam there you have the statement 8 that this is not to change the current requirements for 9 procedures for non-power reactors.
10 MS. SHANKMAN: Right.
11 DR. REMICK: Does that mean that non-power 12 reactors will continue to get the medical doctor to submit
() 13 these forms directly to the NRC, or will the non-power 14 reactor licensee certify?
15 MS. SHANKMAN: We're caught in a bind. I ,
16 understand they' re redoing -- the ANSI-15 committee is 17 redoing the medical requirements and so until that occurs, 18 we're going to maintain the status quo, which is yes to have 19 them....
20 DR. REMICK: Right.
21 MS. SHANKMAN: But we hope that that's going to 22 change and then we would have to update our Reg. Guide that 23 endorses -- you know, the 15-point instead of the power 24 reactor Reg. Guides.
() 25 The written examinations and operating tests, the ACE-FEDERAL REPORTERS, INC. l 202-347 3700 Nationwide Coverage 800 336 4 646
0150 07 15 124 AGBagb 1 content of them has been a concern, as you all expressed 2 earlier. And in a perfect world, the utilities would have 3 done a systemmatic analysis of job requirements, they would 4 have a training program that reflected that, the learning 5 objectives would be measurable, we'd know the conditions and 6 s tanda rd s through which somebody would be judged as 7 mastering those things and we could take the learning 8 objectives from any given facility and turn them into 9 excellent testing objectives and our tests would reflect job 10 requirements perfectly.
11 But I noticed it's not a perfect world, so in the 12 interim we have, as was described before, this catalog, more
(~N 13 of a generic job test analysis that speaks to what is U
14 important knowledges and abilities for an operator. We're 15 using that and as information becomes available from the 16 f acility, we will use those learning objectives, as they 17 become accredited, as there is a job task analysis in place 18 that reflects job performance. And we're also working 19 really hard to train our examiners on how to do that 20 transformation from the facilities learning objectives into 21 testing objectives and into questions.
22 The biggest problem, as I'm sure you're aware, 23 when you have a test is to keep the test from getting in the 24 way of testing -- of showing what quality you' re testing.
25 And if we' re looking at confidence of operators, you don' t
()
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0150 07 16 125 AGBagb 1 want to have a test that tests test-taking instead of 2 confidence as an operator.
3 And the job task analysis, learning objectives 4 and then testing objectives and good questions makes the 5 test less obtrusive and makes the exchange between the 6 examiner and the applicant one of can they do the job 7 instead of can they take the test.
8 The rule now has been written in such a way -- I 9 hate to describe it as an accordian, but as the job task 10 analyses get better in any given plant, we will be able to 11 use the learning objectives more and more, and that is 12 stated in the introduction to the content of the exams. But
(~} 13 as a licensing agency, we had to list minimum categories in J
14 which we would test, so that's also included.
15 So that we have drawn a box that allows us to use 16 the learning objectives but we have also stated what 17 categories we expect somebody to have competencies in.
18l That's under 55.41 for the operator end 55.43 for the senior 19 operator. Those categories are not -- well I'm not a 20 reactor operator so I'm going to say that to me they don' t 21 seem significantly dif ferent than they have been in the 22 past.
23 The one area where we did revise the categories 24 based on public comment was under the operating tests, ktere
() 25 there were two categories that seemed to be confusing to ACE FEDERAL REPORTERS, INC.
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0150 08 01 126 AGBagb 1 those people who were reading them, and based on public 2 comment we rewrote them to make it clearer that in an 3 operating test, in the walk-through and the simulator or 4 simulation-facility part of the test, we expect operators to 5 demonstrate the knowledge and ability to assume the 6 responsibilities of their assigned position and that ggjelso 7 expect them to be able to function within the control room 8 team.
9 Now obviously we license individuals but there 10 are certain team behaviors that we expect them to be able to 11 demonstrate.
12 DR. REMICK: Let me ask a question:
{} 13 The NRC is using,the terminology " knowledge and ability" and INPO has been using " knowledge and skills."
14 15 And is there any reason for why you selected " ability?"
16 I'm not necessarily -- it's caused me to do a lot 17 of thinking and now I say " knowledge, skills and abilities" 18 because I can see there are dif ferences --
19 MS. SHANKMAN: Well KSA's are the standard 20 terminology used when you talk about job task analysis leads 21 you to a delineation of the knowledge, skills and abilities 22 needed to do those tasks and that's the way it's talked 23 about in the literature.
24 But " skills," depending on which author you' re
() 25 reading, of ten means psycho-motor and " abilities" usually ACE. FEDERAL REPORTERS, INC.
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[mAGBagb s 1 means an application of psycho-motor plus some underlying
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2 learned behavior. So I think we chose " abilities" to make 3 it very clear that it's not enough to be able to turn the 4 knob if you don' t know why you' re doing it and you don' t
-5 have something else going on with it.
~
6 INPO, why they chose " skills," I don' t know. I 7 think the way they use it they're using it the same way we 8 use " ability."
9 But ability is different from knowledge because 10 knowledge implies cognition. And ability would mean -- I 11 like to make the distinction I talk a wonderful game of 12 tennis but you could beat me just by standing on the court.
13 So I have the knowledge to play good tennis but not the
(])
14 ability. And I might have the skill, I might be able to hit 15 the ball and move around but somehow getting my act together 16 on the tennis court is like a whale, you know, on land.
17 DR. REMICK: And that ability, you might not be I
18 able to keep score.
19 MS. SHANKMAN: Whatever -- no, that might be 20 knowledge, I don' t know.
21 DR. REMICK: But I think isn' t ability that you 22 interpret that that you might have to plot this or calculate 23 that or estimate this --
24 MS. SHANKMAN: Yes, it's much more applied, much i
() 25 more applied than knowledge and much less connected to your ACE FEDERAL REPORTERS, INC.
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l 1
0150 08 03 128 )
i AGBagb 1 muscular skills and physical reality than skills.
2 Jay, do you want to add anything? No.
3 But KSA's you'll see in the Army and any of the 4 services and the government agencies that talk about 5 delineating things, they just put KSA's. And I just think 6 that our book was so thick we said Gee what could we take 7 out and we took out skills: you know, reading and answering a the phones, things that were clearly related.
9 DR. REMICK: That cut the pages down by a third, 10 right?
11 MS. SHANKMAN: And then we tried writing on the 12 backs and.... No one ever said the operator's job was ew 13 uncomplicated.
O 14 Okay. I'm trying to just think whether we added 15 anything. We added something to page 38 which is the 16 integrity of exams and tests. We now have a page 38A and 17 the reason is simply that when press reproduced it we 18 deleted something and they continued the deletion beyond the 19 point where we meant to have it deleted. So the 38A is just 20 putting back in what should have been there last time --
21 DR. REMICK: My copy doesn' t have a 38A.
22 MR. WARD: Mine doesn' t either.
23 MS. SHANKMAN: Well so much for integrite af 24 exams and waiver of examination requirements.
f3 v
- 25 DR. REMICK
What section is that?
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0150 08 04 129 1 MS. SHANKMAN: It's under examinations and gAGBagb 2 tests.
3 MR. PERSENSKY: 55.47, I believe -- 49, I'm 4 sorry.
5 MS. SHANKMAN: It's behind page 38 and it looks 6 like this.
7 (Displaying document. )
8 Not only was it lef t out of your copy last time, 9 it was left out this time.
10 MR. WARD: It doesn' t look like that's --
11 well....
12 MS. SHANKMAN: Let me tell you what it had on it.
13 MR. WARD: I mean in my copy page 38 ends with an
( })
~
14 Item A and 39 begins with an Item B so I suspect --
15 MS. SHANKMAN: Right, because 38A belongs in the 16 middle of the page. It is 55.47 and 55.49. Just so that 17 you'll know that we really did mean it, it is in the table 18 of contents in front of the rule and it really was only a 19 clerical error to leave integrity of exams out.
20 DR. REMICK: It would be good if John could get a 21 copy of tha t --
22 MR. WARD: He's got it.
23 MS. SHANKMAN: But it hasn' t changed from the 24 proposed rule and it spoke to waiver on 38A, you'll find
(,)
/ s 25 waiver of examinations and test requirements, and tha t' s ACE FEDERAL REPORTERS, INC.
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0150 08 05 130 AGBagb 1 based on past experience: if you passed our test in another 2 context than you may have it waived if it's just recently 3 you held a license from one plant to another and that hasn' t 4 changed much. But the integrity of examinations and tests 5 was something that we added to this rulemaking that hasn' t 6 been in operator licensing. And it says simply:
7 " Applicants or licensees shall not 8 engage in any activity that compromises the 9 integrity of any application, test or examination 10 required.by this part."
11 I think that it's always been implicit, but for 12 various events of which I'm sure you're aware we felt that 13 it was a good idea to make it explicit, so that's been r.dded
(]
Gi 14 to the rule.
15 Okay. Under operating tests, we have not only 16 asked that the quality of the tests change, that it be a 17 demonstration of ability, more so than it has been in the 18 past, but we've also said that the place in which we're 19 going to give the exam is going to be more than just a plant 20 walk-through, and we've put extensive requirements having to 21 do with simulation facilities.
22 Jerry Wachtel, who has worked on this and has 23 delineated those requirements, is going to talk to you about 24 that.
C'i 25 (Slide.)
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0150 08 06 131 l
AGBagb 1 MR. WACHTEL: There have been many changes made )
2 to Part 55.45 on simulation f acilities since the draf t 3 version of this directly as a result of public comments that 4 we received and I will explain to you what those are as I go 5 through this.
6 First, as Susan mentioned, the operating test 7 will be performed in a plant walk-through and within the 8 simulation facility; that is not to change from what has 9 gone before. That is essentially a continuation of our 10 present policy.
11 The major dif ference, however, is in the 12 simulator portion of that operating test. At the present
(~S 13 time we don' t require simulator or a simulation facility and L/
14 we have no specifications for those simulators that may be 15 used for the conduct of operating tests.
16 Now at a plant without a simulator we may merely 17 expand the scope of the walk-through portion of the 18 operating test and at a plant with a simulator or one plant 19 that has access to a simulator, we essentially are forced to 20 take the utility's word for the f act that their simulator is 21 of suf ficient fidelity and representation of the plant as to 22 make it suitable for the 2onduct of exams. This often is ,
1 23 the case, despite our examiners' and others telling us that ,
24 there are problems with simulators and with the fidelity of
(~)
V 25 those simulators as they mirror the plant.
1 i
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0150 08 07 132 AGBagb 1 So although the policy itself is a continuation, 2 the two mejor changes to it are that a simulator will be 3 required -- and we're using the term " simulation facility" 4 which I will describe -- and that the simulator itself will 5 have to meet certain requirements before it will be 6 acceptable for its use in the conduct of operating tests.
7 We have written the rule to encourage the use of 8 the industry-accepted ANSI 345 simulators. But we have also 9 written the rule explicitly to permit the use of other types 10 of simulators which, for whatever reason, may not meet the 11 industry standard, which is ANSI 3.5.
12 For example, some other devices that might be fS 13 proposed for use and might be acceptable for use under Part
\J 14 55 are simulators that were designed in earlier years of the 15 ANSI 3.5 standard and while they might have met an earlier 16 version they may no longer meet the current version of the 17 standard.
18 Another case might be a simulator that might meet 19 the ANSI 3.5 standard for a reference plant but such a 20 simulator might also be proposed for use in conducting exams 21 at other plants or at multiple units of one plant and that 22 might not be referenced to the particular simulator being 23 proposed.
24 other devices include part-task trainers,
(^T 25 engineering simulators, basic principles trainers or even l
l O
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0150 08 08 133
? sAGBagb l' the use of the plant itself for certain start-ups and
(._) ,
2 shu tdowns . Any one or more of these devices could '
3 conceivably be proposed for use in the conduct of the 4 simulator portion of the operating test and if it meets 5 certain requirements that we'll talk about that could be 6 permitted by us.
7 As I said, we are going to encourage the use of 8 ANS 3.5 simulators by accepting such simulators for use 9 based upon the utilities' certification to os that they have 10 a simulator that is a plant reference device and that meets 11 ANS 3.5 -- and the current version of that standard just 12 came out a month ago, so it's a 1985 standard.
/~T 13 For other simulators, for those other than those V
14 which are suggested to os as being certified to meet ANS 15 3.5, the obligation will be on the utility to submit an 16 application to the NRC which the NRC will then have to 17 review and approve before that simulation facility could be 18 used.
19 The major difference here between the rule in its 20 current form and that which was proposed and went out for 21 public comment is that we are now going to accept the 22 utility's certification that it has an ANS 3.5 simulator and 23 we will accept that certification and proceed to conduct 24 exams on that simulator, whereas in our draf t version of the
() 25 rule we required even ANS 3.5 simulators to be proposed in l
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0150 08 09 134 AGBagb 1 an application that we would have to review and approve.
2 The rule permits one year for a utility either to 3 submit to us a certification for an ANS 3.5 facility or to 4 submit a plan under which it will develop a simulation 5 facility as an alternative device.
6 That, too, is a change from the draf t rule, we 7 had originally required a 120 day period before we required 8 these plans to be submitted; as a result of public comment 9 that's been extended to a year.
10 The rule also now permits a four year grace 11 period, if you will, during which bme we have a phased in 12 implementation program -- and I'll talk more about that
(
U) 13 tomorrow when we discuss Reg. Guide 1.149 -- but we will 14 grant a four year period before which every utility will 15 have to have in place an accepted or an approved simulation 16 facility. That, too, is a change from the draf t version of 17 the rule in which we required a three year period. Based 18 upon public comment, that's been extended to four years.
19 As I said, the rule has been written to make it 20 easier for the utilities to have and use an ANS 3.5 machine 21 referenced to the unit for which they want to conduct 22 exams.
23 The process that those utilities will follow is 24 basically this: they will certify to the NRC that they have
([ ') 25 a simulation facility that is a plant-reference simulator l
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0150 08 10 135 7 sAGBagb 1 meeting the Commission requirements and that will mean -- as U 2 you'll see when gou look at the Reg. Guide -- an ANS 3.5 3 1985 simulator and then we, the NRC, will permit operating 4 tests to be conducted en that simulatiori f acility by 5 accepting the utility's certification.
6 The initial certification that they submit to us 7 will have to be based on the successful completion of 4
8 performance tests that the utility conducts on that 9 simulator and the description of the performance tests that 10 are acceptable is also contained in the Reg. Guide and shows 11 up in the present version of ANS 3.5 and the initial 12 certification also must include a schedule demonstrating a
.) 13 four year cycle in which they will conduct a continuing f,,j 14 series of perfonnance tests so as to document a continued 15 fidelity of the simulation facility and that it continues to 16 mirror whatever changes made be made to the plant over that 17 four year cycle.
18 DR. REMICK: A que.? tion on that point: why do 19 you specify at least 25 percent per year versus if they 20 decided that they would do 50 percent and 50 percent over 21 that four-year period? Are you specifically trying to have 22 them distribute that over a four year period? I thought it 23 was curious that you told them at least how much to do each 24 year rather than to do it over a four year period.
() 25 MR. WACHTEL: Part of that -- I guess there are ACE-FEDERAL REPORTERS, INC.
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0150 08 11 136 1 ,AGBagb 1 two parts to that answer: part is a throwback to the 1981
'- version of ANS 3.5 which was current until one month ago 2
3 today in which a four year cycle of performance tests was to 4 be conducted.
5 Part of it is because we, the NRC, are in the 6 procees now of developing an evaluation strategy whereby we 7 will have the capability to going out to simulators and 8 evaluating their fidelity against criteria that we are 9 developing now and that will be made available to the 10 industry and we are trying essentially to equalize the 11 workload and the burden on the people who are going to be 12 doing that work to make sure that they can get out and 13 conduct the kinds of reviews and audits that will be needed (J~}
14 to conduct in order to insure continued acceptability.
15 DR. REMICK: I'm not sure how I see that that 16 relates to the utility doing at least 25 percent per year; I
,17 can see how you might want. to distribute NRC load but why 18 are you specifying that they distribute that validation 19 or....
20 MR. WACHTEL: We're essentially going to be 21 audint the work that they do. It's not our intention to 22 conduct that work ourselves but only go back and audit and 23 it is conceivable that we will want to go back and reconduct 24 some of the tests if we' re n6t satisfied with the results.
(} 25 But essentially we will be satisfied for them to conduct ACE-FEDERAL REPORTERS, INC. 1 202-347-3700 Nationwide Coverage 800-336-6646 ;
l
0150 08 12 137 1 AGBtJb' I the tests and have the results of the tests available for b 2 our inspection and review.
3 DR. REMICK: Have you gotten any comments on 4 that, the at least 25 percent per year?
5 MR. KACHTEL: We got very few comments on that.
6 There were some questions that asked why it was necessary, 7 why we couldn' t just leave the process up to the utilities 8 but they were, I would say, no more than two or three 9 comments on that. For the most part, that breakdown was 10 pretty much acceptable.
11 DR. REMICK: Okay.
12 MR. WACHTEL: Let me tell you about the procedure s 13 to be followed for the non-ANS 3.5 simulation facilities:
U 14 First of all, instead of submitting to us a certification, 15 they will instead submit an application. The application 16 will include a complete description of the facility, what 17 components it may contain and how those components will be 18, used in the conduct of operating tests; they will include in 19 that initial application a documentation of the performance 20 tests that they have conducted to insure the acceptability 21 of that simulation facility and the results of those tests 22 and they, too, will present to us a four year program for 23 the conduct of performance tests on an on-going basis.
24 The application process for the non-ANS 3.5
(} 25 facilities is not any dif ferent than it was when it went out ACE-FEDERAL REPORTERS, INC.
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I 0150 08 13 138 i l
1 ,AGBagb 1 for public comment in draf t form except when we get to 2 periodic re-application. In the draf t version of the rale, 3 we required a re-application process with a complete 4 refiling of all of the performance tests every four years.
5 We have done away with that, we are essentially saying in 6 this version that the initial application will be 7 satisfactory; the only thing we will require is an annual 8 report stating that the simulation facility continues to 9 meet the standards established for it and that the four year 10 cycle of performance tests will essentially be refreshed 11 every four years as part of that fourth annual application.
12 So we have essentially simplified the process and greatly 13 diminished the paperwork.
14 Another simplification we' ve made is that which I 15 mentioned a moment ago that we are not requiring, as we did 16 in the draft rule, that each utility send in the results of 17 the performance tests to the NRC before our review. We are 18 requiring only that they maintain the data for a four year 19 period for us to be able to come out and inspect and audit.
20 So we dramatically cut down on the paperwork burden of that.
21 ( Slid e . )
22 There are some provisions of the rule that will 23 apply to all simulation facilities, whether they are 24 certified ANS 3.5 simulators or other devices. The first,
{} 25 as I just mentioned, is that the data that is collected ACE-FEDERAL REPORTERS, INC.
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~ _ .
0150 08 14 139 AGBagb 1 during performance tests shall be maintained on-site for a 2 four year period which, of course, will cover the full cycle 3 of the performar.ce tests and enable us to inspect or audit 4 as the case may be.
5 We have also -- and this is not a change from the 6 draf t version -- the NRC retains the right to inspect or 7 audit the simulation facility or any tests that have been 8 conducted on that facility at any time and, as a result of 9 that inspection and/or audit, we may withdraw our acceptance 10 or our approval, acceptance, of course, in the case of a 3.5 11 facility, approval in the case of other devices.
12 Af ter the four year phase-in period, we may cease (3 13 to conduct operating tests if we withdraw our acceptance or G
14 our approval.
15 And if -- the fourth point, if we do withdraw our 16 acceptance or approval and therefore cease to conduct 17 operating tests, then the utility may begin at any time to 18 submit to us a certification or an application for their 19 simulation facility as appropriate so that we can begin 20 again to conduct tests once the facility is back in shape.
21 That essentially sums up the rulemaking on 22 simulation facilities. We'll go into much more detail 23 tomorrow on the Regulatory Guide and the performance testing 24 and the details of that.
{} 25 DR. REMICK: When do you want any nits on the l
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l 0150 09 01 140 l_ AGBagb 1 ones that we are referring to, do you want them now or do
['~';
2 you want them at the end?
3 For example, on 55.45(a) -- I realize that you' re 4 talking about (b) --
it's minor, but when I read it I had to 5 read it several times and in the second sent6nce of 45(a) 6 you say "...the content will be identified in part from 7 learning cbj ectives derived from a systematic analysis. . . ,"
8 you don' t say systematic analysis of what. You're talking 9 about job analysis, a systematic job analysis. I think one 10 word in there will make people know what systematic analysis 11 you' re ref erring to.
12j MS. SHANKMAN: That's a typo. That paragraph g- 13 should be exactly the same as the one that's before the
%./ .
14 written exam. So thank you. Before the written exams is 15 there a paragraph that speaks to contents....?
16 Then it's a mistake.
17 g DR. REMICK: Yes, it j ust says " systematic 18 analysis." I think it would be helpful if " job" was put in -
19 there.
20 MS. SHANKMAN: It's a mistake. I'll fix it.
21 MR. WACHTEL: I'll turn the musical microphone 22 back to Susan.
23 MS. SHANKMAN: It's those kind of things, that's 24 why we're sending it around to a million people. I must r~s. 25 have read that sentence six times and it made perfect sense V,
l ACE-FEDERAL REPORTERS, INC.
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0150 09 02 141 1 .
to me, bN AGBagb 2 All right. On page 39 of your package, I hope, 3 there are conditions of the license.
4 (Slide.)
5 There has been a requirement as a condition of 4
6 the license to actively perform the duties or functions of a 7 license operator. And it was a very confusing requirement, 8 because under requalification we had that you had to be 9 actively and extensively engaged as an operator. And these 10 words were confused. And in the public comments, it was 11 very clear that our guidance in this area was, at best, 12 fuzzy in terms of how much participation one had to have in
() 13 plant operations to be considered active or actively and 14 extensively engaged and therefore able to maintain your 15 status as a licensed operator.
16 And in August representatives from all the 17 regions came in and hashed out the response that we were 18 making to the public comments and this issue came up full 19 force from each of the regions in one way or another.
20 And , as a result of that mee ting and then some 21 debate within the division and the branch, we came up with a 22 definition of actively performing which is down on page 18 23 and it says "... actively performing the functions of an 24 operator or senior operator means that an
() 25 individual takes responsibility for and carries ACE-FEDERAL REPORTERS, INC.
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0150 09 03 142 AGBagb 1 out a position on the shift crew that requires 2 the individual to be licensed as defined in 3 the facility's technical specifications."
4 Okay. So you have to be in a licensed position 5 and that's defined in the tech specs for that particular 6 plant. Then we' re saying under 55. 53 (E) that you have to be 7 doing that, actively performing the functions, for a minimum 8 of three shifts per calendar quarter. And in the 9 definitions sections we' ve also added the word "shif t," so 10 that it's a minimum of an eight-hour shif t. So that a 11 two-hour shift will not be sufficient.
12 And we said calendar quarter. That means a 13 minimum then of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in three months. And if you are (v~'s, 14 actively performing the functions of an operator 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 15 three months, you can maintain your status as an active 16 licensed operator or senior reactor operator.
17 DR. REMICK: That's all very clear to me except 18 when then you talk about over a four month period and I keep 19 saying --
20 MS. SHANKMAN: That's bee? deleted.
21 DR. REMICK: Well I hoped it wu, but I iust see 22 on page 12 it's there. I scanned to see --
23 MS. SHANKMAN: Page 12?
24 DR. REMICK: Page 12, it's the second paragraph,
() 25 the last two sentences. It says:
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1 0150 09 04 143 AGBagb 1 "However, to return to active 2 performance after a period of not participating 3 on shift..." -- oh, for four months, I'm sorry. That 4 is a different item.
5 That's an absence of four months.
6 MS. SHANKMAN: No, that's a mistake. That's a 7 mistake. You' re doing very well.
8 DR. REMICK: I thought I was but now I'm not 9 sure.
10 MS. SHANKMAN: It's deleted in the rule, it just 11 wasn' t deleted in the summary of the rule.
12 DR. REMICK: Are you sure? Because isn' t there
(~N 13 another one though that you are completely absent and is G
14 this what we' re talking about here?
15 MS. SHANKMAN: Yes. Let's look on page 39 of the -
16 rule and I will change the summary to conform to the rule, 17 because that is a change that's been made since the last 18 time this came down to you.
19 If you look on page 39 it says (E):
20 "If the licensee has not been actively 21 performing the functions of an operator or senior 22 operator, the licensee shall not resume activities 23 authorized by a license issued under this part 24 except as permitted by ( F) ."
( ,) 25 Now we have defined " actively performing" so ACE-FEDERAL REPORTERS, INC.
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l 144 0150 09 05 AGBagb 1 that's three shif ts in a calendar quarter. And if you 2 haven' t done that, then you have to go to (F), where it says 3 if (E) is not met then you have to do the three things.
4 And we tried to be as specific as possible: you 5 have to complete refresher training that has buen approved, 6 and tha t would mean -- it's particular to the facility and 7 most facilities, I understand, have some kind of plan 8 already in place but that may need to be updated.
9 Then it has to be certified to u-r that your 10 qualifications and status are current and valid, and that 11 would be the medical qualifications or whatever else, that 12 something hasn' t significantly changed.
r"N 13 And the third thing is a 40-hour parallel shift, V
14 and that's to bring you back up te -- it's currency in the 15 Air Force, I think, and -- it's the issue of currency.
16 And it also real,'y -- by doing this we've 17 established an inactive license, because you could be fully 18 participating in requalification and not be on shif t and 19 maintain your license but you wouldn' t maintain your ability 20 to go on-shif t without going through these three things.
21 DR. REMICK: Okay. So you're going to take out 22 the reference to the four months then?
23 MS. SHANKMAN: Yes. Tha t wa s -- a nd i t wa s in 24 here up until -- in fact when it came down to you before and 25 then there was a lot of discussion -- in fact we were
({ }
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0150 09 06 145 AGBagb 1 drawing time lines and it was unclear, how would you know.
2 DR. REMICK: Right.
3 MS. SHANKMAN: Okay.
4 MR. WARD: Well let's see, do you expect that 5 people will maintain inactive licenses and they could do 6 that indefinitely?
7 MS. SHANKMAN: Renewing it every six years, yes.
8 or if you fully -- the intent was if you fully participated 9 in a requalification program you could maintain your 10 license. And there is a need at plants to maintain backup 11 licensed personnel. But they're -- they don' t participate 12 on-shift, no.
(^ 13 We always have the option to make exceptions, so C) /
14 that if somebody is a plant manager and is participating in 15 the daily plant routine and not necessarily on-shif t, as 16 we've defined it, it may be that an exception is made for 17 that particular person. But as a matter of rule, that's not 18 what we intend to do.
19 Bruce, did you want to add anything?
20 No, okay.
21 DR. REMICK: So you could maintain your license 22 but not operate unless you met this?
23 MS. SHANKMAN: Right.
24 DR. REMICK: So at times of strike or something
()
v 25 people would have the license but they'd have to have this ACE-FEDERAL REPORTERS, INC.
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0150 09 07 146 AGBagb 1 training to be able to take over.
2 MS. SHANKMAN: Right. And we've taken out --
3 we've deleted under requalifications, when we get to that, 4 we've deleted those words " actively and extensively."
5 Nobody seems -- let's say everybody had an explanation of 6 what it was but none of them were the same, so with so many 7 -- you'd have two people and three definitions We decided 8 it was too confusing. And the public comments reflected 9 that confusion.
10 Okay. As a condition of the license we've added, 11 and this was added in the proposed rule, that we be notified 12 of any change in status and we've included under that 13 permanent re-assignment. You know, when you apply to have a V(";
14 license the f acility certifies the need for that license.
15 Well if that need goes away and' you're changed to a 16 different position we want to be notified. If you are 17 convicted of a crime we want to be notified. If you're 18 disabled, we want to be notified. So that's maintained in 19 there.
I 20 We also say that if you want to maintain your 21 license you must fully participate in requalification, 22 successfully complete requal programs and continue the 23 bien,*.al medical. So those are the conditions of the 24 license.
l 25 And we've changed the expiration of that license
(~)/
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I I 0150 09 08 147 ,
AGBagb 1 to be six years.
2 DR. REMICK: You make me recall a case a couple 3 of years ago where somebody -- an operator was convicted of 4 a crime and license terminated and this was appealed. Was 5 that ever resolved, that one can remove a license because of 6 conviction of crime? Was that ever resolved in the courts 7 or by lawyers?
8 MR. BOGER: If I remember that case, what 9 happened was the f acility didn' t want to use him anymore so 10 they didn' t submit his re-application or his renewal of his 11 license so we did not have to act on that.
12 DR. REMICK: But do you run into a problem here
(] 13 that that might come up in the future, that there's somebody v
14 convicted, you get notified but he possibly could continue 15 to operate, is that right?
16 MS. SHANKMAN: No, I think the intent is that --
17 the reason that he continued to be licensed was because we 18 weren' t notified , I don' t think the issue of whether we 19 could revoke his license -- that's covered in a different 20 section and my understanding from the attorneys that l
21 assisted me in this particular section was that if we had 22 been notified we maybe could have taken action. But the way
! 23 it was lef t is that he was sitting convicted of a crime and l
24 holding a license. And it wasn' t clear that that was a
S 25 condition of the license, that we be notified.
(U l
l ACE FEDERAL REPORTERS, INC.
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l 0150 09 09 148 AGBagb 1 DR. REMICK: In the case I'm thinking of I think 2 he was removed as an operator by the Licensee, I thought --
3 I think the NRC was notified but then I think the ind ivid ual 4 appealed whether he could -- his license could be revoked 5 for that. But maybe I'm wrong on the exact circumstances.
6 But you're saying that the Commission feels it 7 can revoke the license if a person is convicted of a crime.
8 MS. SHANKMAN: Right. The problem was that we 9 were not aware, fully aware of the circumstances.
10 DR. REMICK: I see.
11 MS. SHANKMAN: Ar.d if you want, I can follow up 12 and check with that attorney and let you know.
('s, 13 DR. REMICK: I'm more interested in knowing sy /
14 that if the Commission wants to revoke a license that it can 15 for something like conviction of a crime.
16 MS. SHANKMAN: All right. I'll check.
17 MR. BOGER: Yes, we can. That's what the purpose 18 of this is. It depends on the nature of the crime, of 19 course. That's why i t's there.
20 (Slide.)
21 MS. SHANKMAN: The six years -- we had proposed 22 five years and, I guess, we can' t count so good, so if you
! 23 have a biennial medical, a lot of commentors said, then you 24 go two, four, five and that means you have to have an extra
/~N 25 medical exam, so we made it six to conform to the biennial l O l
l ACE-FEDERAL REPORTERS, INC.
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0150 09 10 149 l_ AGBagb 1 medical.
k 2 okay. The renewal of a license is not changed 3 significantly in that you still have to submit your 4 paperwork, your Form 398, you still have to document that 5 you continue to operate, that you're current in 6d requalification and you successfully have completed the 7 requalification program approved for your facility and that 8 your medical status is up to date and that your performance 9 --
this has been added again by the attorneys -- that your 10 performance is satisf actory to the Commission.
11 And the intent of that is that that will reflect 12 any finding that we have, notifications, letters of
- 13 reprimand, and that's how we would evaluate satisf actory 14 -- satisfactory to the Commission.
15 (Slide.)
16 Well, our favorite subject.
17 Requalification, there were 1600 comments, 1599 18 were on requalification. That's the way it felt. There was 19 a lot of comments. As Bruce told you, we sent it out to all 20 licensed operatora. They had comments, the facility had 21 comments. Most of the comments we got from f acilities 22 included requalification.
23 And some of the commentors were particularly 24 concerned that it was too rigid: it had to be annual, we
(} 25 were locked into lectures, that there wasn' t any ACE FEDERAL REPORTERS, INC.
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l 0150 09 11 150 l
)
AGBagb 1 flexibility, that you had to take a comprehensive exam every 2 year.
3 So based on those comments and review and 4 discussion, the requirements now say that you need an 5 NRC-approved program -- that's the same -- and that the 6 cycle of that program can be no less than 12 months but can 7 be as great as 24 months. We' re now saying that the written 8 exam is given biennially but that it be comprehensive, but 9 that there continue to be an annual assessment but it be 10 i basically the operating tests: the walk-through and the 11 simulator.
12 And that that would be something -- in fact, some e' 13 commentors said that an annual operating test they thought b)'
14 was appropriate because any operator who's operating shoald 15 be able to pass an annual operating test.
16 And I think the operating test, if you look at 17 the requirements now, we're basically saying that the 18 operating tests for requalification will be similar to the 19 initial operating test but it will not have Category 1, 20 which has the theoretical emphasis. We' re also suggesting 21 that the comprehensive biennial written exam will be very 2*z similar to the initial exam drawn ,from the same job task l
23 analysis and learning objectives.
24 DR. REMICK: Could I give you a nit related to (v ') 25 tha t?
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0150 09 12 151 aGBagb 1 MS. SHANKMAN: What page are you on?
2 DR. REMICK: Well it's 41 and it's under renewal 3 of license but it refers to the biennial exam, item number 4 four near the top of page 41 where you talk about annual 5 requalification program. And I think you want to change it 6 to, like you did on the next page, biennial 7 requalification --
8 MS. SHANKMAN: It should say "requalification 9 program."
10 DR. REMICK: Right.
11 MS. SHANKMAN: -- because whatever is approved at 12 that facility could be annual -- I mean could be a 12 month
~S 13 program, it could be.... Good. Thank you.
(G 14 In the requalification program, as you looked 15 earlier at Appendix A, that's a very set delineation of a 16 program but it has more to do with traditionally-deriving a 17l program, so many hours of this and so many hours of that.
18 The systemmatic analysis of job requirements is 19 an option now under this rule, so that instead of the 20 program content delineated under old Appendix A, now 21 55.59(C), you can substitute a systemmatic analysis of job 22 requirements. And because we wanted to be clear on what we 23 meant by a systemmatic analysis, we've added that definition 24 on page 20 and, as I said, i' e the five elements from the
(} 25 policy statement.
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I
0150 09 13 152 l_s AGBagb 1 So that if you have a program that has those five k
2 elements: the job task analysis, learning objectives 3 derived from those, program evaluation, the trainee 4 evaluation and the move back into that from job performance, 5 that would constitute the alements of an acceptable program 6 and we would, based on those elements, approve a 7 requalification program that had those parts and it wouldn' t 8 have to then follow so many lectures on this and that.
9 The program might not feel that different to the 10 trainee but it would be based on job requirements rather 11 than those delineated in the rule.
12 MR. GIMMY: If the program is going to reflect 13 the job content, is that going to clash with the
(Nu.)
14 comprehensive biennial written exam where " comprehensive" 15 means the same thing as the original license exam?
16 MS. SHANKMAN: No, because if they are -- I don' t 17 think so. If the original license exam is based on the job 18 task analysis and learning objectives at a facility then the 19 requalification program, if it's also based on a job task 20 analysis -- this is all an imperfect world -- and learning 21 objectives then that exam should also be similar to their 22 initial exam. Because it's the same job. And the job 23 requirements and underlying knowledge and abilities should 24 basically be the same.
25 The program might not emphasize all parts of the
(])
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0150 09 14 153 AGBagb 1 job because some of them are fregaent, you use them on the 2 job and they' re reinforced all the time. But the infrequent 3 and, in our case, high-consequence things that are part of 4 the job would I think still be the same and they would 5 probably be the things on the operating tests and in the 6 written exam.
7 Do you see a conflict?
8 MR. GIMMY: That's what all the discussion has 9 been about all morning here was the fact that on the initial 10 licensing, whether it be for this or medical or anything 11 else, you tend to cover a lot of ground that you may never 12 cover again j ust for that background that it gives you.
13 And on the requal, because of the limited time
(^}
v 14 factor, you may want to stress only those aspects of the job 15 that would he actually performs.
16 MS. SHANKMAN: Well I think the requal program 17 should stress those things that are not frequent on the job 18 where, you know, you practice and those things that may be 19 required of you as an operator. But the comprehensive exam 20 is, I guess, to check that yoa' re still proficient in all 21 aspects of the job including the frequency. Because my 22 opinion is you're assuming that frequent tasks are 23 reinforced and done correctly and the comprehensive exam is 24 maybe a chance to check on that.
() 25 The annaal operating test, I would think, is ACE FEDERAL REPORTERS, INC.
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0150 09 15 154
- 1. AGBagb 1 going to emphasize infrequent, high-consequence -- you know, c ;
2 much the same as FAA does on missed approaches and engine 3 fires and things like that.
4 MR. WARD: You're still not getting what he's 5 saying here and that's because you' re from Mars and I think 6 I'm from Mars, coo. I didn' t quite understand the logic 7 that these gentlemen were giving us all morning.
8 What you've said here is just, you know, contrary 9 to what everybody was caying -- most people were saying it around the table this morning: there seemed to be a 11 concensus which is that the content of an original licensing 12 exam, by some logic, should include more material, more r~m 13 theoretical material or broader scope than the content of a
(-)
14 relicensing exam.
15 MS. 3HANKMAN: I thought we were talking about 16 the content of our program, our training program, for 17 initial would have more. I don' t know.
18 MR. WARD: Well same thing. Well maybe not.
19 MR. BOGER: Let me try to jemp in because I think 20 that the whole theory question is something that we have 21 been also trying to evolve at the same time as we're 22 developing the requalification:
23 We have always come under the gun for too 24 theoretical on the original exam as well as requalification fN s) 25 and in both areas we've been trying to change our ACE-FEDERAL REPORTERS, INC.
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1 0150 10 01 155 !
l AGBagb 1 examination to be less theoretical and more jr.b-related.
1 2 So what Susan was saying was as you get more and I l
3 more job-related we would sample from the same piece of l
4 material, we may change the sampling rate based upon whether l 5 somebody had seen that in normal operations or whether that 6 was an infrequent operation.
7 But the training program is still going to have 8 to have the theory and the basics so that somebody will have 9 the basis to be able to understand some of the other parts 10 of the training program. But our intent in both the 11 original or initial licensing and requalification exams is 12 to hit items that are job-related and that may make them r~N 13 less and less theoretical as we go along.
LJ 14 MR. WARD: So if you've got surveying on the 15 original licensing exam, you'll probably have on the --
16 MS. SHANKMAN: If the job task analysis shows 17 that surveying is something that you need as an operator and 18 the underlying knowledges and abilities are nee.'ed --
19 whether it's frequent or infrequent but it's of high 20 importance, that would be something that we would sample on 21 both exams.
22 DR. REMICK: More important to me is what's the 23 intent of that biennial exam now? I don' t think we have 24 those statements anymore that it's to identify the area 25 where people need training, am I correct? That's now been (v~)
l l
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MS. SHANKMAN:
~
2 No --
3 DR. REMICK: Did it stay in there somewhere?
4 MS. SHANKMAN: I don' t know if those words are in 5 there but I think in the discussions that we had with the 6 region and I also think it may be in the resolution of 7 public comments report, we did speak to it, identifying 8 individual weaknesses and being areas in which accelerated 9 retraining would be needed af ter weaknesses are identified.
10 And that is part of the justification in having -- in 11 maintaining a comprehensive exam every two years and not just having an annual operator test.
12J
(] 13 MR. BOGER: What happened is in the systematic or
%/
14 systems approach to training, that includes in it the loop 15 of taking a look at the results and revising the program 16 based upon what you find your candidates are doing. For the 17 people who didn' t happen to have that then the Part 55 18 that is in existence today still requirec that same 19 evaluatien.
20 DR. REMICK: Right, but is that statement in 21 there?
22 MR. BOGER: Yes.
23 DR. REMICK: That was a pretty good statement, 24 what the annual exam was intended to do. Is that still in
(} 25 50.59(C)?
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0150 10 03 157 7~sAGBagb 1 MR. BOGER: Yes, our intent was just to recopy O
2 Appendix A into the --
3 MS. SHANKMAN: That would be on page 46.
4 MR. BOGER: I think it's page 47.
5 DR. REMICK: It's 47-4.1, yes, it's still there.
6 Because I think that's bnportant and when we get 7 down to what's in that exam in theory, I don' t get so 8 concerned if that examination, the biennial examination on 9 theory is one tha t identifies weaknesses. But if it's 10 something that people get crucified on, the NRC comes in and 11 gives an exam and then from that determines the guy can' t 12 operate or he's no good or the requalification program is no
() 13 good, but then I have a problem. And that's the direction 14 we seem to have gone in the last couple of years under the 15 circumstances. But I don' t get too concerned if it's to 16 identify potential weaknesses. I do get concerned if it's 17 something else.
18 MR. BOGER: Let me step back. Remember we talked 19 -- or at least I was talking about the handbook where we 20 were using this catalog and the catalog had in it identified 21 the higher importance or at least the rated importance of 22 items. Hopefully if oitr examinations are doing the right 23 thing then we'd be sampling the more important items more 24 frequently. And the way things have worked out, most of the
() 25 theory items are on the lower end of the stick. You still ACE-FEDERAL REPORTERS, INC.
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0150 10 04 158 1 AGBagb 1 have to aample from those items but I think you'll sample O 2 them less frequently. But we will at least have some idea 3 as to how important they were to the job.
4 MR. MICHELSON: Why do you say you have to sample 5 them?
6 MR. BOGER: We are evaluating the overall ,
7 program, which would teach --
8 MR. MICHELSON: But you don' t have to do 9 anything. You sample them because you think it was 10 important to sample them and why do you think it's important 11 to take these lesser-graded items?
12 MR. BOGER: Well they have all been deemed of a
,r 3 13 certain level of impor tance .
G 14 MR. MICHELSON: Yeah, but these are admittedly 15 the lowest -- or you just said they were the lowest and yet 16 you feel that you have to include some of those.
17 MR. BOGER: The training program is supposed to 18 be teaching them across all items. We're just --
19 MR. MICHELSON: Well where did it say that it's l 20 supposed to be teaching across all items?
21 MR. BOGER: Well that's what an overall program 22 should --
23 MR. MICHELSON: Well yeah but I thought that's 24 what the whole morning discussion was about, maybe your
^T 25 overall has gone too far. You're encompassing too many (G
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i 0150 10 05 159 1 AGBagb 1 things that are not really important. That's what we' re
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\J 2 wrestling with, of course, is is that the case?
3 MR. BOGER: Is the question whether we're 4 sampling too frequently or at all?
5 MR. MICHELSON: At all. These lowest-ordered 6 items, the things that are thought least important to the 7 program you're still sampling. I think that's kind of where 8 the complaint's coming f rom.
9 MR. GIMMY: It's the interpretation of the phrase 10 " comprehensive written exam," " biennial written exam" which 11 you said is essentially the same as the one they took to get 12 the license in the first place.
f.3 13 MR. MICHELSON: Yeah.
~~
14 MR. GIMMY- Maybe if that said something like a 15 biennial written exam on the higher-rated -- the 16 higher-scoring job-related items or something like that.
17 MS. SHANKMAN: The initial exam should be on the 18, more important items. In our catalog we've rated items, all of which have been included as statements of 'knowledges and
^
19 201 abilities that licensed SRO's are empaneled and the INPO job 21 task analysis felt were important to have to be a licensed 22 operator. And then from that group we rated them one to 1
23 five and those that have an average rating below two were i e
24 not included in our initial exam.
,e~g 25 So we have already taken the lower order, if you L1 ACE-FEDERAL REPORTERS, INC.
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AGBagb 1 want to call them, items out of the initial exam and they 2 wouldn' t be -- well I don' t know, Bruce --
3 MR. BOGER: They wouldn' t be in the l
4 requalification exam.
5 MS. SHANKMAN: -- requalification exam either and 6 then we're saying that 70 percent of the exam should be 3.0 7 or above, because the panel, you know, yoa know graders, 8 you're not going to get 5.0 so we've closed the range even 9 smaller, allowing for plant-specific variability. We're 10 saying with that catalog that we're only testing those 11 things that are important and have been rated important and 12 have been rated important.
(} 13 Are you familiar with the catalog?
14 MR. MICHELSON: No.
15 DR. REMICK: Are the questions that you would 16 envision in the theory area, are these to be from the 17 learning objectives that the facility has determined from 18 the job task analysis?
19 MS. SHANKMAN: Yes.
20 DR. REMICK: That seems reasonable to me.
21 And you have identified them as fundamentals of 22 reactor theory including fission process, neutron 23 mollification, source ef fects, control rod ef fects, 24 criticality indications, reactivity coef ficients and poison f) 25 effects. You have iden tified the general effects.
v ACE-FEDERAL REPORTERS, INC.
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AGBagb 1 MS. SHANKMAN: Right.
I 2 DR. REMICK: But the specific questions would be 3 rela ted to learning objectives from the job analysis.
4 MS. SHANKMAN: Yes. And in the interim we're 5 using the job task -- the catalog that we have, because --
6 in the absence of better information.
7 DR. REMICK: And as plants come along and are 8 getting accredited and have learning objectives, you will 9 use those, is that correct?
10 MS. SHANKMAN: Yes. If they're learning 11 objectives that are measureable and safe conditions and 12 s tandard s --
N 13 DR. REMICK: They should be to be accredited.
(\J 14 MS. SHANKMAN: Right. In other words, they have 15 to be learning objectives.
16 MR. MICHELSON: Maybe I missed a part of your 17 earlier statement. When you said that you were sampling 18 from among the lower-rated questions, what did you mean by 19 that, how low a rating?
20 MR. BOGER: It's in the two to three.
21 MR. MICHE LSON: Well yeah, but then what I heard 22 j ust a moment ago here that you didn' t go below three at 23 all.
24 MS. SHANKMAN: No.
() 25 MR. BOGER: I don' t think so.
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0150 10 08 162 AGBagb 1 MS. SHANKMAN: No, 70 percent of the exam should 2 be three or above.
3 MR. MICHELSON: And then the other 30 percent can ,
4 be up to three.
5 MS. SHANKMAN: -- can be between two and three.
6 MR. MICHELSON: -- between two and three, nothing 7 below two.
8 MS. SHANKMAN: Right.
9 MR. MICHELSON: So these are pretty far down.
10 MS. SHANKMAN: Yes.
11 MR. BOGER: I wish I had the listing of what a 12 two means as opposed to a one or a zero.
MR. MICHELSON:
')
~/
13 Yes, an example.
14 MS. SHANKMAN: -- essential, the rating for five 15 equates to essential and one is of minor importance -- I'm 16 not sare that was the exact word we used. The assumption 17 was that everything in the catalog had to be somewhat 18 important at one plant or another or the panel wouldn' t have 19 included it. But then when they rated it, unless there was 20 a concensus that it was two or above -- oar guidance in the 21 handbook to examiners is to not sample from those items, 22 that they have just so much testing time.
23 Unless -- and I guess I want to say this because 24 it's not as cut and dried, you can' t say oh well this is a
()
v 25 1.8 and you could never ask it, because if they know ACE-FEDERAL REPORTERS, INC.
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0150 10 09 163 AGBagb 1 something about that particular plant, given that 2 snowflakes, you know, no two are the same but they're 3 basically the same, you may know something but they require 4 a sign-of f by their sec tion leader and they have to justify 5 that they're not capriciously asking that, that there is 6 some justification at that particular plant to ask that 7 particular question.
8 So as I said before, I think we're working really 9 hard to have examiners document the content of their exam 10 and then document that it is important. I think in the same 11 sense that you're saying.
12 Okay. On page 47, we' ve changed the annual exam
(^}
v 13 to the biennial written exam which we've been talking about 14 and then on page -- well, I'll get to page 53 in a minute.
15 ( Slide . )
16 We didn' t really change much in terms of 17 modification and revocation of licenses or the enforcement.
18 This is basically the same as it has been in operator 19 licensing. But j ust to call to your attention that 20 willfully violating any of these provisions is when we feel 21 that we have justification for revoking licenses.
22 Now on page 53 of your package, I hope you have 23 an addition of 50.54, i t' s -- I 'm sorry , it starts on page 24 52 and in 50.54 of the regulations we spoke to Appendix A in
!qj 25 the requal and we have revised that to now match 50.59(C),
1 ACE-FEDERAL REPORTERS, INC. ;
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0150 10 10 164 AGBagb 1 but in particular we're asking for the submittal of 2 requalification programs by each facility for NRC approval 3 and we've tried to rotate the work a little by making the 4 anniversary date their effective date of their license.
5 Do we get points, John, for finishing early?
6 MR. SCHIFFGENS: Yes.
7 DR. REMICK: I have something that it surprised 8 me you don' t have in here. I have a contention, and I think 9 I'm right: nowhere in Part 50 do you require licensees to 10 have training programs. You require them to have 11 requalification training programs but nowhere -- and I 12 thought this would be an appropriate time to fill that 13 void. Now maybe that could be interpreted as being an
(')l 14 inconsistent policy statement, but I've always thought it 15 surprising that there's no requirement that a licensee have 16 training programs. They all do, of course.
17 You do require them in Part 50 that in the PSAR 18 or FSAR or both they have to describe programs, but there's 19 no requirement like you have in Part 50 that thou shalt have 20 -- well you just referred to it here, 50.54, tha t they've 21 got to have a requalification program within three months of 22 getting their OL. There's no such requirement for training 23 programs. It's a major inconsistency in the regulations 24 that I don' t know if anybody's even thought of.
(~) 25 MR. GIMMY: Weren' t there some utilities way back v
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0150 10 11 165 Tm AGBagb 1 when in the very early days that had their operators trained O 2 by somebody else, like General Physics, totally, all the way 3 through license and then showed up at some plant to run it?
4 DR. REMICK: I wouldn' t be surprised.
5 MR. GIMMY: I thought there were in the early 6 days. Some far-flung utilities, one-reactor types, that 7 would have everybody trained by General Physics clear up 8 through getting the license, they'd show up at their plant 9 and run it but eventually they' re going to have to be 10 requalified and, of course, I guess theoretically they could 11 get that done by a contractor. I think that's where that 12 came from.
(')
V 13 DR. REMICK: No, but the question is should it be 14 pe rmi tted . According to the regulations now you could still 15 do that because there's no requirement to have training 16 programs. ,
17 MR. BOGER: What the regulation does is require 18 people to provide evidence that somebody has successfully 19 completed the facilities requirement to become an operator.
20 And then it talks about they have to provide evidence of the 21 courses and the number of hours of instruction and things 22 like that. I guess it implies it but you're right, it does 23 not specifically say thy shalt have a training program.
24 DR. REMICK: But if we do say that for requal
() 25 then it seems like it would be logically consistent that it ACE-FEDERAL REPORTERS, INC.
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0150 10 12 166 g AGBagb 1 should say that you should have training programs?
[J w
2 MR. GIMMY: Again a one-reactor company might not 3 want to have a training group in requal, they might want to ,
4 contract it out.
5 DR. REMICK: Well it doesn' t necessarily say you 6 have to have them yourself.
7 MR. MICHELSON: It just says your program says 3 I'm going to hire somebody else to do it.
9 MR. GIMMY: Yeah, that's your program.
10 MR. MICHELSON: Tha t's your program.
11 DR. REMICK: Well but that program would still 12 have to be described.
13 MR. MICHELSON: -- described and approved, but
(} }
14 I'm sure the NRC would approve such a program if that 15 trainer, w'1oever it is out t:ere, that contract trainer does 16 a good job.
17 MR. GIMMY: Some of the.se little airlines, you 18 know, don' t train their own -- have no pilot training 19 thing. They get them trained someplace else and get them 20 tested someplaca else.
21 MR. BOGER: But we require the training program 22 as part of the license -- Part 50 license application, not 23 Part 55.
24 MR. GIMMY: Well again the program might be,
() 25 though, to hire contractor A to do it.
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I 0150 10 13 167 7 3AGBagb 1 MR. BOGER: There are people Lhat were not b
2 facility employees that operate the plant, that's true.
3 They still have to maintain some sort of eligibility 4 requirements and the facility has to certify them to us and 5 they have to pass the test. That's true.
6 DR. REMICK: I honestly --
7 MR. WARD: But that's not really what he's 8 talking aboat.
9 MR. GIMMY: That's parallel to what some of the 10 little airlines do. You know, I can' t think of --
11 MR. WARD: No, the airline situation would be 12 where the pilot is not an employee of the airline. He was 13 talking about where their non-employees are qualified and
(])
14 licensed to operate --
l 15 MR. GIMMY: I don' t think they have any of that.
16 MR. WARD: But you're talking about the case 17 where an employee of the licensee for the plant is 18 trained --
19 MR. GIMMY: -- sent to General Physics --
20 MR. WARD: --
in somebody else's training program 21 and gets licensed at his own plant.
22 Aren' t there some --
23 MR. GIMMY: Like Westinghouse did that for their 24 contractors.
() 25 MR. BOGER: Most of the old plants -- licensed ACE FEDERAL REPORTERS, INC.
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-0150 10 14 168 ;
TN AGBagb 1 -- plants before they got licenses had to contract out that q-) '
2 training because they just didn' t have the capability 3 in-hoase and typically Westinghouse or the vendors would 4 supply a generic-type training program that would equate 5 them with the NSSS system. Then they would come back home 6 and receive specific plant training on their facility 7 procedures and individual systems. That's still happens.
8 MR. GIMMY: And what I'm saying here, as written 9 it would permit them to even do that for requal. The 10 programs could be, theoretically, could be to send them back 11 to Westinghouse to get requalified. That's okay, as long as 12 they've passed --
() 13 MR. PERSENSKY: As long it's approved.
14 MR. BOGER: As long as NRC approves it.
15 MR. GIMMY: -- as long as NRC approves the 16 program.
17 MR. PERSENSKY: Forrest, you're correct in that 18 Part 50 does -- the only requirement is that a program be 19 describe in their Preliminary Safety Evaluation Report.
20 When we wece proposing the training and gaalification 21 examination rule, that's one of the things we were trying to 22 correct, was to require training programs beyond the 23 operator licensing, you know, the licensed operator 24 program. And because of the change from the rulemaking to 1
() 25 the policy statement, the policy statement is about the only
)
l l
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(~)AGBagb 1 thing that would provide gdidance for the progran to apply
\> l 1
2 that meets the --
3 DR. REMICK: Bat now yoe're changing 55 which has 4 to do with training programs and the corresponding sections 5 of 50. It seems to me that if it's the intent of the 6 Commission that people have training programs -- and I 7 believe it is intent, I think that's a hole that nobody has 8 realized until recently. Everybody I asked in general say, 9 oh, you've got to be kidding, it's in there. It's not, at 10 least that I can find and I'm going --
11 MR. PERSENSKY: It is not.
12 DR. REMICK: And I question if it isn' t an oversight and if it isn' t oversight if this is not the time
(]) 13 14 to correct it unless it would be inconsistent in some way 15 with the agreed-upon policy statement of the rulemaking in 16 this area and it is not conside' red on-going at the time of 17 the policy state nent.
18 MR. PERSENSKY: Odr interpretation to date has 19 been that it would be inconsistent with the policy 7
l l
20 s ta temen t.
21 DR. REMICK: And yet that's unfo-tunate, it's
- 22 taken so many years to get 55 revised that it's a shamo to i
! 23 not go out and correct what I consider to be a deficiency.
l 24 It has no practical significance, everybody has training 25 programs --
f(
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('gAGBagb 1 MR. PERSENSKY: And in order to receive a
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2 facility license, at least for the last several or many 3 years you had tc have a training program described in your l 4 FSAR, because it is part of the SRP, the Standard Review 5 Plan, that we do review training programs.
6 DR. REMICK: Well you can handle the same thing 7 -- you can handle requal that way, too, don' t require 8 requalification but ask them to describe their 9 requalification programs. But I think it is properly done 10 in the case of requal programs and I think there's a void 11 there and it's a question in my mind, it's a policy question 12 of whether the Commission wants that void filled de not.
(]) 13 There is a legal question related to it. It 14 seems to me it came up in TMI in the proceeding, if I 15 recall, a question related to that and whether they are 16 required to have a program. At some hearing I think that 17 point was raised.
18 MR. PERSENSKY: It may well have been.
19 DR. REMICK: It might have been TMI.
20 MR. WYLIE: I had a question.
21 Under 55. 53, I guess it is -- yeah, okay, 22 condition of the license, 55.53, Subitem (G)(4), under your 23 other Conditions , is that other conditions defined?
24 MS. SHANKMAN: Where are you?
() 25 MR. WYLIE: 55.53(G), Subitem (4). It says ACE. FEDERAL REPORTERS, INC.
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/~ 1 you've got to record other conditions which af fect or could U]AGBagb 2 affect the performance of an operator or senior --
3 MS. SHANKMAN: No, they' re not defined.
4 MR. WYLIE: It's not defined.
5 MS. SHANKMAft: And in the resolution of public 6 comments we went around on that, a few people mentioned 7 that. The attorneys felt that it was better to leave it the 8 way it is because it is supposed to be something which the 9 operator or senior operator feels would affect their 10 performance of duty. And it's left to the licensee's 11 d iscre tion , the individual operator.
12 MR. WYLIE: Okay. It's something they're not (v~'; 13 penalized if they don' t do?
14 MS. SHANKMAN: No. But the conviction of --
15 MR. WYLIE: It says they shall notify.
16 MS. SHANKMANt Yeah. But the conviction of a 17 crime is specifically included to give a flavor of the 18 gravity of items that would be expected.
19 MR. MICHELSON: It doesn' t say such as, though.
20 It says includ ing .
21 MS. SHANKMAN: Right.
22 MR. WYL7.E: That's a condition of the license 23 though, I mean, presumably if you didn' t report something 24 then if somebody thought that you should have reported you
() 25 could revoke tne license.
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0150 11 04 172 AGBagb 1 DR. REMICK: I would think so.
2 MR. BOGER: He would probably be subject to a 3 little more review. If we found someone --
4 MR. WYLIE: It seems to me you ought to define 5 it. That's open-ended there.
6 MS. SHANKMAN: Yes, it is.
7 MR. WYLIE: You know, the wife ran off with the 8 barber or something.
9 MR. MICHELSON: That might affect performance.
10 MR. WYLIE: I'm sure it would.
11 MS. SHANKMAN: Let me see if I can find the page 12 in which we responded to that very comment.
13 (Pause.)
[s~')
14 on page 34 of the resolution of public comments, 15 Enclosure D, number 11 is --
16 DR. REMICK: What are you referring to?
17 MS. SHANKMAN: Enclosure B of your full package, 18 on page 34 -- it's like a j igsaw puzzle. Enclosure B, page 19 34, item 11.
20 MR. WYLIE: Page 34?
21 MS. SHANKMAN: Yes. And I think that that is the 22 same thing that I just said , that it is intended to be a 23 catch-all category and that the idea was certainly something 24 that in the opinion of the licensee that it could or
() 25 actually does af fect their performance.
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0150 11 05 173 73 AGBagb 1 That would include changes in their physical
(_)
2 cond ition . . . .
3 So it's Enclosure B, page 34, item 11.
4 DR. REMICK: I have 10 on 34, I don' t find 11.
5 MS. SHANKMAN: You're at page 34, Enclosure B?
6 DR. REMICK: Yes, and it goes down to 10( A) .
7 MS. SHANKMAN: Look in the new package.
8 The package that you got originally had not been 9 to an editor so the content of this item would changed.
10 MR. SCHIFFGENS: Item 11 is the one that you 11 want, regardless of the page.
12 MS. SHANKMAN: Well you'd want the one that says?
(} 13 DR. REMICK: What comment number?
14 MR. BOGER: Subpart F, 13-12, 16-4 --
15 MS. SHANKMAN: -- et cetera, et cetera 16 ... suggests Section 55.53(F)(4) be deleted as ambiguous or 17 further defined if meaningf ul. . . ," e t cetera, et cetera.
18 I'm sorry. In our attempt to have everything 19 sent to you it was sent --
?.0 MR. MICHELSON: I didn' t even bring it with me.
21 MR. WARD: I think our Reporter is having a 22 little trouble keeping up. Would one person talk at a time?
23 (Document displayed.)
24 MR. WARD: Are you happy with that?
() 25 Bruce, I guess it does that for your presentation ACE-FEDERAL REPORTERS, INC.
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0150 11 06 174 AGBagb 1 then?
2 MR. MICHELSON: Well could we ask a question on 3 this follow-up? Does this mean that if an operator has 4 smoked marijuana, for instance, you have to report it even 5 if he wasn't convicted of it or whatever?
6 MS. SHANKMAN: I would think if it's not going to 7 af fect his job performance --
8 MR. MICHELSON: Well how do you make that 9 de te rmina tion? Because it says "or could af fect," and that 10 could affect him. It depends on which doctor you talk to.
11 MR. BOGER: I'm going to defer that to the people 12 who worry about the fitness for duty.
13 MR. MICHELSON: I that how you're going to cover
( ')
14 -- whatever that finally says you'll do here. That's a good 15 way to interpret it.
16 MR. WYLIE: It seems like to me there ought to be 17 a definition then.
18 MR. MICHELSON: Yeah, that ought to be in this 19 document, well you can' t reference it yet though. But 20 tha t's rignt, tha t's where you'd pick it up.
21 DR. REMICK: The Staf f is coming back af ter our 22 break?
23 MR. BOGER: Yes.
24 MR. WARD: I was just going to let them go if i( ) 25 you' re finished .
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0150 11 07 175 7~xAGBagb 1 DR. REMICK: I'd like to have --
2 MR. MICHELSON: We' re through with our --
3 MR. WARD: You've got a few more questions.
4 Let's take a 10-minute break.
5 (Recess.)
6 MR. WARD: We will reconvene, perhaps for just a 7 short time. I think there might have been a few more 8 questions the Subcommittee would like to ask of the Staff 9 and then af ter that I would like to go into Executive 10 Session, which means we won' t need a record af ter that, the 11 Staff can go home if they want to but with the Subcommittee 12 I would like to begin to discuss the contents of our letter
(} 13 on the first requalification.
14 so let's take the time now to go into any more 15 questions that you had. I know Forrest had some, I'm not 16 sure if anybody else did or not.
17 Did you satisf actorily get an answer to the 18 question about the -- Charlie?
19 MR. WYLIE: I think it's sort of ambiguous, sort 20 of open-ended. I don' t know how you implement it.
21 MR. WARD: They agreed. Do you think it should 22 be tightened up?
23 MR. WYLIE: Well it looks to me that some way to 24 define what that condition is, what is the criteria by which
() 25 you measure what you report.
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0150 11 08 176 AGBagb 1 MS. SHANKMAN: You wouldn' t soggest that there 2 would be a list.
3 MR. WYLIE: A list?
4 MS. SHANKMAN: Yeah, not a list of conditions --
5 MR. WYLIE: I wouldn' t think a itst but some type 6 of criteria by what basis you report. I don' t know what 7 that is....
8 MS. SHANKMAN: Yeah. I think the fitness for 9 duty issue is an excellent one but we can' t put it in, per 10 se, and we can' t -- we ' ve addressed it tangentially maybe in 11 the beginning in the statement of considerations when we 12 mention that we expect a Commission policy statement on
(~'T 13 fitness for duty and alcohol and drug-related problems and Lj 14 programs would come under that and not under the medical 15 provisions.
16 MR. WYLIE: I know you had said like conviction 17 of a crime but say a guy is indicted for a crime; 18 unfortunately he's not convicted yet but it is certainly 19 traumatic as far as he's concerned. The way that's worded ,
20 you know, it says if anything could affect his performance 21 and I'm sure if I were indicted for a crime it would sort of 22 affect my performance, I would worry about it.
23 MS. SHANKMAN: I can go back to the attorneys and 24 work on that because it is definitely, that particular
(' }; 25 section -- this comes out of the enforcement attorneys' ACE-FEDERAL REPORTERS, INC.
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0150 11 09 177 AGBagb 1 experience.
2 MR. WYLIE: Okay.
3 MR. WARD: Forrest, did you have a question?
4 DR. REMICK: I'm sorry I'm late, I was on the 5 phone. Are you talking about whether you could use such a 6 word as if he is found anfit for duty, a very general term?
7 I'm not talking about fitness for duty but if he was for any 8 reason found him unfit for duty perhaps under Section D 9 where you.'re talking about any other condition, is that what 10 you were talking about?
11 MR. WARD: Yes.
12 DR. REMICK: The question I had -- oh, by the 13 way, going back to the question: I personally feel that the 14 Commission should fill that void about not requiring 15 programs and I'll try to convince the Subcommittee and the 16 Full Committee that we ought to at least point out to the 17 Commission that I think it's a void and they ought to 18 consider whether thay want to or not. I just want to alert 19 you of that.
20 But the other point that I did have: where does 21 one know that if you're going to be either an instant SRO or 22 an upgrade SRO whether you're going to have to take written 23 and oral RO, written and oral SRO and so forth, where is 24 that defined? Should it be in the regulations or is that
( ) 25 covered in the NUREG document and so forth? Where does one ACE FEDERAL REPORTERS, INC.
l 202-347 3700 Nationwide Coverage 80 4 336-6646
0150 11 10 178 AGBagb 1 out there know that if he's going to either be an instant or 2 an upgrade what he has to take?
3 MR. BOGER: Okay. It says that they have to take 4 both exams, written and operating. The details as to the 5 examination form, format of an oral exam and issues of that 6 nature show up in our internal examiner standards.
7 DR. REMICK: And I've read those but I forget 8 now, if I'm going to be an applicant for an instant SRO do I 9 know that I take only one oral exam versus two oral exams?
10 MR. BOGER: I think the examiner standards, the 11 NUREG 1021, would identify one examination cnd tell what 12 components it had. It differentiates between a reactor
(~} 13 operator oral exam versus an upgrade senice exam and an v
14 instant senior exam, depending on what you have to cover.
15 DR. REMICK: It does.
16 MR. BOGER: Yes, it does.
17 DR. REMICK: Okay.
18 And it also then apparently clarities -- in years 19 past the upgrade SRO did not have to take an oral exam which 20 I understand now the Commission does require. Is that 21 clarified in 1020 or 1021, whichever it is, I forget.
22 MR. BOGER: Yes.
23 DR. REMICK: It is. Okay.
24 That was my concern that people know, because it q
(v s 25 has changed apparently. It's been some years ago --
ACE-FEDERAL REPORTERS, INC.
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0150 11 11 179 AGBagb 1 MR. BOGER: It's been several years but what 2 happened was we had some requirements that were in the 3 f amous Dint letter of 1980 that changed the categories and 4 added heat transfer and required examinations and things 5 like that and we've tried to put them into the rule now so 6 we have one area that addressed eligibility, for instance, 7 and things like rk-t. There's been an effort to incorporate 8 them.
9 DR. REMICK: I'm thinking of it somewhat in the 10 legal standpoint so that there would be no question that if 11 you had somebody who was an instant SRO and they found out 12 that he took the written RO, he has to take the written SRO,
/^T 13 is that correct, also? And one oral, he doesn' t have to
\ .) ,
14 take two orals?
15 MR. BOGER: Right, he has to take an operating l
16 test and the operating test covers basically the same 17 subject matter in the regulation.
18 DR. REMICK: So nobody could claim the f act that 19 if he had one tha t he wasn' t -- the Commission didn' t do the 20 proper thing, didn' t carry out his duties?
21 MP. BOGER: That's correct. The written exam 22 would say -- cover the SRO plus the RO material and the 23 operating test just has the same requirements whether you' re 24 an RO or an instant senior or operating senior.
( ,) 25 MR. MICHELSON: Does the length of the test ACE-FEDERAL REPORTERS, INC.
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0150 11 12 180 AGBagb 1 differ?
2 MR. BOGER: It has to just to include more 3 material.
4 MR. MICHELSON: It sounds like there's more 5 scope, which would make the test longer.
6 MR. BOGER: For the instant SRO we' re giving 7 somebody a license essentially as an RO and an SRO at the 8 same time, so we have to add some length to the exam.
9 MR. EATON: But he only takes one written exam.
10 There was an inferece here tha t he took both the 11 RO written and the SRO written if he's an instant SRO and 12 that's no longer true, because we do not allow a fallback
(~x 13 position. He's either going for an SRO license' or he's
'd 14 going for an RO license. If it's an SRO license, it's an 15 SRO written and an SRO oral. And the distinction on the 16 oral is really the form as to whether it's an instant or an 17 upgrade.
18 DR. REMICK: He only takes one written exam?
l 19 MR. EATON: That's correct.
20 DR. REMICK: They used to take two.
21 MR. EATON: Yes, sir.
22 MR. BOGER: The senior written exam now says 23 cover . areas that are covered as an RO, in fact, there's an 24 overlap of one or two categories that it covers for them.
25 DR. REMICK: And the important thing is tha t's
( ')
ACE-FEDERAL REPORTERS, INC.
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0150 11 13 181 AGBagb 1 clear in the guide.
2 MR. BOGER: Yes, sir.
3 MR. WARD: I think I may have misunderstood but 4 did you say that the oral exam is the same for the SRO and 5 the RO? Or i t's the same for an instant SRO and an upgrade 6 SRO?
7 MR. BOGER: No, the regulation covers the major 8 subject areas under operating tests. How we address each of 9 those items are expressed in the examiner standards in the 10 NUREG 1021 and that's where we get the dif ferentiation 11 between what type of examination various candidates get, and 12 it is dif ferent depending on the license.
f)' 13 MR. WARD: Any other questions for the Staff?
O 14 (No response.)
15 MR. WARD: Okay.
16 Well then thank you very much, Bruce, and 17 everyone else. We' re goi.ng to stay for a while and :alk 18 about the letter on the requal. But we' re of f the record 19 now and thank you very much.
20 (Whereupon, at 4:37 p.m., the meeting of the 21 Subcommittee was adjourned.)
22 23 24
() 25 ACE FEDERAL REPORTERS, INC.
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CERTIFICATE OF OFFICIAL REPORTER O
This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON HUMAN FACTORS DOCKET NO.:
PLACE: WASHINGTON, D. C.
DATE: MONDAY, NOVEMBER 25, 1985 were 'neld as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
(siqt hk (TYPED)
MADELON P. BLOOM Official Reporter ACE-FEDERAL REPORTERS INC.
Reporter's Affiliation ,
O
. NRR STAFF PRESENTATION TO THE O ACRS l
SUBJECT:
FINAL REVISIONS TO 10CFR55 DATE: November 25, 1985 l
PRESENTERS: Bruce Boger, Chief Susan Shankman Jerry Wachtel PRESENTER'S TITLE / BRANCH /DIV:
Operator Licensing Branch Human Factors Safety -
PRESENTER'S NRC TEL. NO.:
492-4868 !
l l SUBCOMMITTEE: Human Factors l
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BACKGROUND SECY 84-76 (FEBRUARY 1984)
" PROPOSED RULEMAKING FOR OPERATOR LICENSING AND FOR TRAINING AND QUALIFICATIONS OF CIVILIAN NUCLEAR POWER PLANT PERSONNEL" COMMISSION ACTION (SEPTEMBER 1984)
DEFER TRAINING RULE; PROCEED WITH OPERATOR LICENSING r~s REVISIONS TO 10 CFR 55, "0PERATOR LICENSES" PUBLISHED 5- IN FEDERAL REGISTER (NOVEMBER 1984)
ASSOCIATED REGULATORY GUIDES PUBLISHED FOR COMMENT (NOV - DEC - 1984)
COMMENT PERIOD TO MARCH 1985 FINAL RULE AND REGULATORY GUIDES BASED ON:
OVER 1600 COMMENTS REGIONAL INPUT COMMISSION POLICY STATEMENT ON TRAINING AND QUALIFICATION (MARCH 1985)
/25/85 O
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O OBJECTIVES:
- 1. IWROVE SAFETY OF NUCLEAR POWER PLANT ORRATIONS
- 2. I WROVE BASIS FOR LICENSING EXAMS AND CONDUCTING O ORRATING TESTS
- 3. RSPOND TO P.L.97-425 - NUCLEAR WASTE POLICY ACT OF 1982, SECTION 306 .
4 0 11/25/8s i
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PURPOSE
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- DEFINITIONS i ACTIVELY PERFORMING ,,,
4- SIMJLATION FACILITY ,,, .
SYSTEMS APPROACH ,,,
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- SUBPART B - EXE W TIONS i
STUDENTS IN NUCLEAR ENG. COURSES i
- TRAINEES IN NRC APPROVED OPERATOR TRAINING O PROGRAMS 4
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SUBPART C - EDICAL EQUIREENTS BIEfNIAL EDICAL EXAM i
- CERTIFICATION BY FACILITY ON NRC FORM 3%
INCAPACITATION BECAUSE OF DISABILITY OR ILLESS
^
O - MJST NOTIFY NRC jf INCAPACITATION LONGER THAN 30 DAYS 1
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1 SUBPART D - APPLICATIONS
- FORM 398 I
- IF APPLICANT HAS COW LETED NRC APPROVED TRAINING PROGRAM THAT USES A SIRlLATION FACILITY ACCEPTABLE TO NRC 4
O THEN - WILL ADMINISTER APPROPRIATE LICENSING EXAM AND OPERATING TEST f
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- CONTENT - BASED ON FACILITY LEAPJilNG OBJECTIVES DERIVED
- FROM SYSTEMATIC ANALYSIS OF JOB INTERIM - NRC EFFORTS UNDERWAY TO IPPROVE CONTENT VALIDITY, REVISED CATEGORIES OF O RRATING TEST (12) DEPONSTRATE THE KNOWLEDGE AND ABILITY TO ASSLPE THE RSPONSIBILITIES OF THE ASSIGNED POSITION ASSOCIATED WITH $
SAFE O RRATION OF THE FACILITY O (13) DEP0NSTRATE THE APPLICANT'S ABILITY TO FUNCTION WITHIN THE CONTROL ROOM TEAM S0 THAT PROCEDURAL AND LICENSE LIMITATIONS ARE MAINTAINED.
~
INTEGRITY OF EXAMS AND TESTS 11/25/85 O
O PART 55.45 (B): OPERATING TESTS - ADMINISTRATION PLANT WALK-THROUGH AND SINLATION FACILITY WITHIN ONE YEAR, EITHER:
- CERTIFY A SINLATION FACILITY CONSISTING SOLELY OF A PLANT-REFERENCED SIN LATOR, OR SUBMIT A PLAN FOR DEVEL0ffENT OF A SINLATION FACILITY, FOR NRC APPROVAL AFTER 4 YEARS, A SINLATION FACILITY (ACCEFIED OR APPROVED)
NST BE USED Q FOR CERTIFIED SINLATION FACILITIES (NRC APPROVAL NOT REQUIRED)
INITIAL CERTIFICATION
, ANNUAL RECURRENT CERTIFICATION i
FOR OTHER SIMULATION FACILITIES INITIAL APPLICATION ,
C0lt11SSION APPROVAL ANNUAL REPORT 11/25/85 0
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- FOR ALL SIKlLATION FACILITIES
- COLLECTED DATA TO BE MAINTAINED FOR 4 YEARS j
- NRC MAY AljDIT AND WITHDRAW ACCEPTANCE / APPROVAL AT ANY TIE
\
~Q IF ACCEPTANCE / APPROVAL IS WilliDRAWN, NRC WILL CEASE TO CONDUCT OPERATING TESTS l-i
- FACILITY LICENSEE MAY AGAIN SlJBMIT APPLICATION OR CERTIFICATION .
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" ACTIVELY PERFORMING THE FUNCTIONS ..." FOR A MINIltN OF THREE SHIFTS PER CALENDAR QUARTER IF NOT -
- 1. REFRESHER TRAINING i
- 2. STATUS (E.G EDICAL AND REQUAL.) CURRENT AND l VALID 1
- 3. PARALLEL SHIFT - 40 HOURS
- NOTIFICATION OF CHANGE IN STATUS
- REQUALIFICATION PROGRAM
- BIEMIAL EDICAL EXPIRATION ,
i SIX YEARS 11/25/85
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RDEWAL
- ON FORM 398
- DOCLPENTATION OF:
4 EXPERIENCE CURRENT REQUAL, SUCCESSFULLY COPPLETED I
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- EDICAL CERTIFICATION ON FORM 3%
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- PERFORMANCE SATISFACTORY TO CO MISSION 1,
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- NRC APPROVED PROGRAM
- 12 - 24 MONTH CYCLE
- C0ffREHENSIVE BIEMIAL WRITTEN EXAMINATION
- A M UAL OPERATING TEST
- PROGRAM C0 K NT:
O APPENDIX A - NOW 55.59(C)
OR SYSTEMATIC ANALYSIS-0F EQUIREPENTS OF JOB
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SUBPART G - P0DIFICATION AND lO0 CATION OF LICENSES "WILLRA. VIOLATION" O SUBPART H - EWORC9ENT
" WILLFULLY VIOLATES" l
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