Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power ReactorsML20212D139 |
Person / Time |
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Site: |
Palo Verde ![Arizona Public Service icon.png](/w/images/9/93/Arizona_Public_Service_icon.png) |
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Issue date: |
10/17/1997 |
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From: |
James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
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To: |
NRC OFFICE OF THE SECRETARY (SECY) |
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References |
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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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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML17313A9791999-05-20020 May 1999 Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20081B5721995-03-0808 March 1995 Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data 1999-09-28
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML17313A9791999-05-20020 May 1999 Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data ML20055F4531990-06-29029 June 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Modified for fitness-for-duty.Rule Unnecessary & May Adversely Affect Morale of Licensed Operators ML19327B1631989-09-0707 September 1989 Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Should Not Attempt to Dictate Standardized Form of Decommissioning Trust Agreement ML20235V7101989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Rule Will Not Improve Maint,Reliability or Safety of Arizona Nuclear Power Project Plants 1999-09-28
[Table view] |
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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 -
1 PRCn - " E 8 .__ -
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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1 Enclosur l TT3 IllllIlll!IllMllllllllll
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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.
I
.-- -. - - - = . . __--_- - -_- - - - . - .- -- -
- 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.
1 2
- 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
]
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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