ML20212D139

Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors

ML20212D139
Person / Time
Site:	Palo Verde
Issue date:	10/17/1997
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR42426, FRN-64FR19868, RTR-NUREG-1021, RULE-PR-55 102-04031-JML-A, 102-4031-JML-A, 62FR42426-00008, 62FR42426-8, AF62-2-033, AF62-2-33, NUDOCS 9710310009
Download: ML20212D139 (7)

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_ . _ _ . gy James M. Levine TEL (602)393-5330 Mail Station 7602 P O Box 52034 Palo Verde Nuclear Sentot Vice Presg g y g)$g6077 Phoenix, AZ 85072 2034 Generatng Station Nuclear

.- 7J2 04031 - JMUAKK/KR OFF ',0cibber 17,1997 ADJUD_ MF Rulemakings and Adjudications Staff U. S. Nuclear Regulatory Commission ,

Washington, D.C. 20555 -

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Dear Secretary,

(62 FR 9'2>1;If)

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1,2, and 3 Docket Nos. STN 50-528/529/530 Comments for Proposed Rule for NUREG-1021, Interim Revision 8," Operator Licensing Examination Standards for Power Reactors" These comments are submitted by Arizona Public Service Company (APS) on behalf of PVNGS Units 1, 2, and 3 in response to the subject draft NUREG-1021, Interim Revision 8. We appreciate the opportunity to have participated in the voluntary pilot examination program and to comment on the NRC's proposed rule.

APS particularly wishes to emphasize comment #10 in the enclosure, regarding significant reactivity manipulations. The use of simulators for these manipulations should be allowed. The present requirement could place an economic impact on utilities where full power operation could be limited in order for trainees to manipulate the controls. In addition, maneuvering the plant for training purposes can result in unnecessary plant transients and could impact plant safety. The industry has invested heavily in fidelity simulation facilities. These facilities accurately reflect the plant conditions and provide the controlled training environment necessary for effective

training. A large variety of complex control manipulations can te conducted on these simulators that are not allowable on the actual plant.

I If you have any questions regarding these comments, please contact F. W. Riedel, l

Operations and Engineering Training Department Leader at l (602) 393-6580.

Sincerely, go3go9971017

!g 55 62FR42426 PDR l l

I JMUAKK/KR/mah

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, Ru am: king cnd Adjudications St:ff l Comments for Proposed Rule for NUREG-1021, Interim Revisior. 8," Operator Licensing Examination Standards for Power Reactors" Page 2 cc: K. E. Perkins (all with enclosures)

J. L. Pellet S. L. McCrory J. H. Moorman i

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! ENCLOSURE NUREG-1021 OPERATOR LICENSING EXAMINATION STANDARDS FOR POWER REACTORS l INTERIM REVISION 8 l

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NUREG-1021, Operator Licensing Examination Standards for Power Reactor, Interim Revision 8 The following comments are in regards to the proposed rule change to 10 CFR 55 40 and the resultant changes to NUREG-1021.

The proposed rule change is as follows:

(a) Power reactor facility licensees shall prepare the required site-specific written examinations and operating tests.

(b) Power reactor facility licensees shall submit the written examinations and operating tests to the Commission for review and approval.

(c) Power reactor facility licensees shall proctor the site-sr)ecific written examinations.

(d) In lieu of requiring a power reactor facility licensee to prepare the examination and tests, and to proctor the site-specific written examinations, the Commission may elect to perform thore tasks.

(e) The Commission will prepare and administer the written examinations and operating tests at non power reactor facilities PVNGS' comments regarding NUREG 1021 Interim Revision 8 are as follows:

1. ES-201 B second paragraph: Changed from "shall participate" to "that choose to participate."

COMMENT: Rulemaking will require the utilities to participate. This paragraph will need to change to reflect rulemaking.

2. ES-201 C.1.e second paragraph: Allows for " Supervisors who approved the course materials but did not perform instructional activities for the license applicants may review and approve the examination materials."

COMMENT: Clarification is needed as to what constitutes " instructional activities." is the supervisor allowed to ht.ve contact with the class in accordance with ES-201, D.

Personnel Restrictions?

3. ES-201 C 2.h second paragraph: States "If any of the facility-developed examination materials (written, walk-through, or simulator) require substantive changes and cannot be made to conform with the examination standards at least five working days before the scheduled examination date, regional management shall consult OLB and make a decision whether to proceed with the facility-developed examinations or develop the examinations in-house." It goes on to further state that "If examination problems are identified at the last minute, the examinations should be postponed: substantive examination changes will not be made during.the examination week."

COMMEN r: Substantive changes should not be made during the examination week.

Some guidance as to what constitutes " substantive" would be helpful.

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4. ES-201 C 3.f third sentence: Adds requirement that the Chief Examiner exercise their judgement to ensure that the exams are prepared to the appropriate level of difficulty.

COMMENT: This requirement is entirely subjective and results in the " moving target" acceptance criteria. This is currently being interpreted differently in the different NRC regions. Clear guidance needs to be established so that the facility writers can

, hit the mark the first time and not require substantive changes to the exam.

l 5. ES-201 D 2.a: Significantly changed the personnel restrictions. The guidance now states that " Facility employees who had any direct involvement in training the license applicants shall not prepare the outlines for the written examinations or the operating tests." Also,"no one who provided 15 percent or more of the scheduled classroom instruction or 20 percent or more of the total scheduled classrocm and simulator instruction may participate in developing the written examination

! questions.

COMMENT: Originally, simulator training was exempted from this requirement.

Simulator contact time should not be factored into the criteria for who can write written test questions. The contact time limit should be for the classroom instruction not including the GFE;.

6. ES-201 D 2.c: Now clearly requires signing the security agreement before gaining

, knowledge of the exam.

COMMENT: Once the security agreement is signed, it does not allow for any training related activities with the applicants until the exam is completed. The

security agreement needs to be revised to allow training related activities (i.e.

supervisor review and approval of training materials).

7. ES-201 Attachment 2 first paragraph: Adds flexibility to provide limited reference material. The fifth paragraph calls for sending everything unless otherwise directed.

These two conflict.

COMMENT: The facility should not be required to send any reference material to the regional office. Reference material should only be provided if requested to support j exam validity.

8. ES-201 Attachmant 21.a last paragraph: Adds that the material sent to the NRC be i "comolete, comprehensive and of sufficient detail to support the c'evelopment of accurate and valid examinations without being redundant."

l COMMENT: As in the previous comment, reference material should not be provided l for facility written exams. This paragraph should be deleted.

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9. ES 201 Attachment 215.b: Increases the material required on malfunctions available on the simulator. It specifically requires a:

• list of all malfunctions with identification numbers and cause and effect information, including a concise

description of the expected range of results that will occur upon initiation and an indication of which annunciators will be actuated as a result of the malfunction."

COMMENT: This is available to the NRC during the exam validation week at the site. Exam validation eliminates the need to send this documentation.

10.ES 202 C.2.b fourth paragraph: Requires significant control manipulations ... at least five are required on the facility for which the license is sought.

COMMENT: The use of simulators for these manipulations should be allowed. The present requirement could place an economic impact on utilities where full power operation could be limited in order for trainees to manipulate the controls. In addition, maneuvering the plant for training purposes can result in unnecessary plant transients and could impact plant safety. The industry has invested heavily in fidelity simulation facilities. These facilities accurately reflect the plant conditions and provide the controlled training environment necessary for effective training. A large variety of complex control manipulations can be conducted on these i simulators that are not allowable on the actual plant.

11.ES-3018 first paragraph: The lead in statement requires the applicant to demonstrate an understanding of and the ability to perform the actions necessary to

accomplish a representative sampling from the 13 items identified in 10 CFR

{ 55.45(a).

COMMENT: The problem here is that this is the only place that this requirement

exists. The skyscraper model of ES-401 should be modified to ensure that this requirement is met when selecting test items for inclusion on the exam. Currently, if the exam is developed in accordance with ES 401, this requirement probably won't be m..

12.ES-301 B.2: The applicant's knowledge and abilities relative to each system are evaluated by administering JPMs and specific follow-up questions.

COMMENT: Recommend that the prescripted questions for the JPMs be eliminated.

They have little discriminatory value and this testing medium is already accomplished via the written exam and Category A " Administrative Topics."

13.ES-301 E.2.a: The chief examiner shallindependently review each operating test for content, wording, operational validity, and level of difficulty.

COMMENT: This requirement is entirely subjective and results in the " moving target" acceptance criteria. This is currently being interpreted differently in the different NRC regions. Clear guidance needs to be established so that the facility writers can hit the mark the first time and not require substantive changes to the exam.

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14.ES 301, Form ES-301-4: The target quantitative attributes at the bottom of the QA

checklist list requirements for scenarios and scenario sets. ,

COMMENT

This is not described anywhere in the text. The only way you would know this is if you used the QA checklist. Normally this is done after the scenarios

. are developed, i

i 15.ES 303 D.2.c first bullet under the fifth paragraph: Allows for failure of an applicant who made errors with serious safety consequences for the plant or the public, even

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if the failure can not be justified on the basis of the competency grades.

2 COMMENT: There should be no case in which an applicant makes an error of

!. sign;ficant safety consequences that can not be justified by competency grades.  !

- This item should be deleted from the standard or the grading tool chould be modified.

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