ML20235B535
| ML20235B535 | |
| Person / Time | |
|---|---|
| Issue date: | 09/10/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20235B538 | List:
|
| References | |
| FOIA-87-652 NUDOCS 8709240135 | |
| Download: ML20235B535 (92) | |
Text
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TRANSCRIPT OF PROCEEDINGS l
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION In the Matter of:
PUBLIC MEETING WITH INDUSTRY REPRESENTATIVES )
TO DISCUSS LICENSE RENEWAL REQUIREMENTS FOR
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OPERATORS AND SENIOR OPERATORS
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Pages:
1 through 91 Place:
Bethesda, Maryland Date:
September 10, 1987 QT f' tl0 Heritage Reporting Corporation Official Reponers O
1220 L Street, N.W.
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washington, D.C. 20005 1
(202) 628-4888
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UNITED STATES NUCLEAR REGULATORY COMMISSION
)fL OFFICE OF NUCLEAR REACTOR REGULATION
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3 In the Matter of:
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)
I 4
PLblic Meeting with Industry Representatives
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To Discuss License Renewal Requirements for
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S Operators and Senior Operators
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6 Thursday 7
September 10, 1987 8
Holiday Inn 817.0 Wisconsin Avenue 9
Bethesda, Maryland 10 The meeting convened, pursuant to notice, 11 at 9:30 a.m.
12 PRESENT:
13 JACK ROE, NRC 14 RICH STAROSTECKI, NRC
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J1M TAYLOR, NRC 15 JOHN HANNON, NRC VIC STELLO, NRC 16 JOE COLVIN, NUMARC 17 MIKE TUCKMAN, DUKE POWER PAUL CHUDZIK, DUKE POWER 18 RANDY HOLT, BG&E
.KEVIN NIETMAN, BG&B 19 ERIC ANDERSON, FP&L LEE WILLIAMS, FP&L 20 TED AMUNDSON, NSP BILL JESSOP, UNION ELECTRIC 21 EDGAR LINDAMOOT, VERMONT YANKEE NRC 22 M.J. WILSON, NORTHEAST UTILITIES PETER RICHARDSON, NEW HAMPSHIRE YANKEE 23 GENE EARNEY, MONTICELLO PORTHAM STATES POWER ROBERT M.
GALLO, USNRC REGION I 24 RALPH BEEDLE, NEW VoRK POWED AUTHORITY J.W.
HAMPTON, DUVE POWER 25 LEE CATALFORNO, PUBLIC SERVICE ELECTRIC & GAS v
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1 PRESENT (Continued)
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2 DEYWOOD HUGHES, BOSTON EDISON
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MICHAEL EVRINGHAM, MAINE YANKEE ATOMIC POWER 3
JOHN D.
KOUTOUZIS, CONSOLIDATED EDISON OF NEW YORK PAUL D. VIGGIANO, DUKE POWER 4
E. MORRIS HOWARD, GEORGIA POWER JIMMY D.
SMITH, NRC/ SIB 5
JOHNIE G.
SMITH, FLORIDA POWER RAMON RAGUSE, COMMONWEALTH EDISON 6
RIJ7 JACKSON, GULF STATES UTILITIES TIM HENDERSON, YANKEE (ROWE) ATOMIC ELECTRIC 7
JOHN WYRICK, WASHINGTON PUBLIC POWER SUPPLY SYSTEM MIKE SHORT, SOUTHERN CALIFORNIA EDISON 8
R.
JOE JOHNSON, TVA ROBERT G. JONES, TVA 9
JIMMY D. VANDERGRIFT, ARKANSAS POWER & LIGHT M.H. CEAWFORD, SYSTEM ENERGY RESOURCES, INC.
10 JIM SMEDEK, NRC GARY HELGESON, ASSOCIATED TECH TRAINING SERVICES 11 MARK L.
MARCHI, WISCONSIN PUBLIC SERVICE CORP MIKE SEl,LMAN, NORTHERN STATES POWER 12 JOSEPH F. GASPER, OMAHA PUBLIC POWER DISTRICT DANIEL F.
PACKER, LOUISIANA POWER & LIGHT 13 LEE S. WILLIAMS, ALABAMA POWER KEN MCCOY, INPO
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14 TAU TIPTON, NUMARC
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KEN ROUSH, PENN POWER & LIGHT
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15 FRANK L.
MACIUSHA, ROCHESTER GAS & ELECTRIC JACK ALEXANDER, LONG ISLAND LIGHTING l
16 ROGER BALDWIN, VIRGINIA POWER TERRY M. WILLIAMS, VIRGINIA POWER 17 DAVE CRUDER, VIRGINIA POWER STEVE FRYE, DUKE POWER 18 C.W.
HEKE, NRC s
TERRY FINK, FLORIDA POWER & LIGHT 19 JIM MOLDEN, PACIFIC GAS & ELECTRIC COMPANY WILLIAM TROSKOSKI, OEDO, NRC 20 RUSSELL J.
TADYCH, CLEVELAND ELECTRIC ILLUMINATING RICHARD A.
SIMPKINS, TOLEDO EDISON 21 GARY TRIMBLE, ATTS, INC.
MIKE NIEMEYER, TU ELECTRIC 22 JERRY J.
HOLMAN, QES CORP J.J.
CAREY, DUQUESNE LIGHT 23 A.F.
GIBSON, NRC, REGION II E.W.
MERSCHOFF, NRC-NRR 24 L.A.
WIENS, NCC-NRR JERRY WACHTEL, NRC-NRR 25 J.J.
PERSENSKY, NRC-NRR l
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)P'N PRESENT:
(Continued) g
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2 TOM MURLEY, NRC-NRR 3
RON EATON, NRC-NRR WALTER GUINN, INPO 4
TONY HINSON, INDUSTRIAL TRAINING GROUP BEN A.
HIRST, INDUSTRIAL TRAINING GROUP 5
JERRY WALKER, HOUSTON LIGHTING & POWER l
GLEN WELDON,' HOUSTON LIGHTING & POWER I
6 KEN WOODWARD, SOUTH CAROLINA ELECTRIC & GAS SCOTT NEWBERRY, NRC-OEDO 7
R.E.
SCHEFFSTALL, KMC, INC.
WILLIAM W. THOMPSON, GPU NUCLEAR-TMI l
8 DOMINIC DIIANNI, NRC-NRR PD-III-3 l
JACK WELLER, PUBLIC SERVICE COMPANY COLORADO 9
RICK RIVERA, PUBLIC SERVICE COMPANY COLORADO J.P. THOMPSON, CAROLINA POWER & LIGHT 10 J.F.
BAKER, INTERFACTS, INC.
W.E.
SHORT, INTERFACTS, INC.
11 ART BIVENS, NUMARC FRANK SPANGENBERG, ILLINOIS POWER 12 EDWIN G.
FINTH, PHILADELPHIA ELECTRIC l
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1 PROCEEDINGS jh 2
MR. TAYLOR:
I am here representing Vic Stello, who 3
is the EDO, and am the Deputy EDO for Regional Operations, and 4
also acting as Deputy EDO period.
Vic would be here himself.
5 He is in Europe, and will be back tomorrow.
I appreciate you 6
coming to this meeting.
And I appreciate and thank NUMARC for 7
setting this up on a relatively short notice.
8 The meeting was called because of growing concerns by 9
Vic and those of us on the staff about problems with operator 10 requal exams and operation requalification in general.
I do 11 appreciate you coming.
I think that we would like to keep this 12 meeting very calm and collected.
And I appeal to you, although 13 this is am emotional subject to many of you, I appeal to you to N".
14 keep it steady as she goes, as I know you will,.and as 15 professional as you can.
16 Frankly, we called this meeting, because we wanted 17 the feedback from some representatives of the industry.
We 18 have been getting individual feedback from many people.
But wo 19
,really need that.
We need to examine your comments and 20 thoughts as arranged with the NUMARC folks to see where we go 21 from here.
22 We do not want to see an examining process cause loss 23 to the industry of good operators.
Because that to us is 24 another step in diminishing sa fet:y ra t her than doing what our 25 job really is which is enhancing safety.
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Vic, I talked to him a number of times before,he left 2
for Europe on this subject.
I think that we come to you with 3
the desire to get your thoughts in a calm and rational way.
4 Again thank you for coming.
And I particularly thank Joe and 5
NUMARC for taking the lead in making this meeting possible.
6 MR. COLVIN:
Good morning.
I am Joe Colvin, 7
Executive Vice President of NUMARC.
And I was tasked, because 8
no one else would take this job, of providing the opening 9
comments, and as Jim said, trying to maintain some degree of 10 order to this meeting.
11 This past May 16th the new rule on operator licensing 12 went into effect.
And with it, the change to a six year 13 license that required the NRC to administer a requalification b"
14 exam once during a six year period.
15 Today we are here to provida some feedback and some 16 industry experiences on the implementation of the new rule.
I 17 think that we have some concerns that the implementation of the 18 new rule and current practices for implementing that are having 19 an adverse impact on our people and on our training programs.
20 And consequently, as Jim said, they adversely affect the safe 21 and efficient operation of our plants.
22 We have a number of utility representatives present 73 today to speak to you and to provide comments, plant managers, 24 training managers, and licensed operat ors.
And they should 25 present some recent and specific examples as to how the NitC v
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1 administered requalification examination has impacted and
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2 afiacted their people and their training programs.
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3 We also have a number of other utility f
representatives in the audience.
And if I could just ask you 4
5 to stand, so that we could get a sense of how many utility a
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people we have here.
Please go ahead and just stand up.
Good, ;
7 thank you.
8 MR. TAYLOR:
That makes the odds about even.
9 (Laughter.)
10 MR. COLVIN:
I knew that you were going to say that, 11 Jim.
12 MR. TAYLOR:
I had to, Joe.
13 MR. COLVIN:
We want to make sure we do.
We do have
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14 a lot of good turnout from the utilities.
And I think that we
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15 can not only expect good feedback from the people who are set 16 up to present and come up to the podium, but from the others in 17 the audience.
We do intend this feedback to be positive and 18 constructive, and we hope that it will be useful to you in 19 making any needed improvements, i
I 20 The general comments that the presenters will make 21 will focus in the following general areas.
First of all, the 22 impact on people, morale, professionalism, operators giving up 23 the'r licenses, et cetera.
24 The second area is the impart on safety, the loss of 25 experienced operators, the shift on training, the focus away s-p Heritage Reporting Company
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from performance based training, and operating the plant, s-
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2 overemphasis on theory a.--d memorization, the impact of the
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random selection process, and the short two week notice of the 4
operators.
The impact on the training programs, the scheduled 5
- disruption of the training classes, the quality and reliability 6
of the examinations themselves, and their overemphasis on 7
theory, the fact that some are not performance based, et 8
cetera.
9 The impact on team training.
I think that that is an 10 area that we do want to focus a little bit of attention on.
11 The training programs that we have put in place at INPO and the 12 NRC and that the industry are trying to put in place are 13 focusing on the importance of team training and building the b"
14 shift operating crew as a team.
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15 And lastly, I think tnat we have seen some 16 inconsistency in implementation within regions as well as 17 across regions, and we would like to focus some comments on 18 those areas.
19 Additionally, Bill Jessop from Union Electric will 20 briefly discuss the requalification pilot program that was 21 conducted in cooperation with the NRC and the NUMARC working 22 group on operator requalification which was through 1986 and 23 then through early 1987.
24 Just before we go ahearl awl ask Mike Tuckorman
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the NRC have a mutual interest to assure that the operators are 2
well qualified and well trained to safely operate our plants, v
3 And we recognize the NRC's role in assuring that the operators l
4 in fact have that to meet their role in protecting public 5
health and safety.
We hope that the feedback that we give you 6
today will help you in making the needed improvements to this 7
program.
8 With that, let me introduce Mike Tuckman, plant 9
manager of Oconee.
Mike.
10 MR. TUCKMAN:
Thank you very much, Joe.
My name is 11 Mike Tuckman, and I am the station manager of the Dukes Oconee 12 Nuclear Station.
This is a three unit station BMW designed.
13 It has been in operation over fourteen years.
I have been b
14 through a SRO training program myself.
And my plant has gone
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15 through two NRC administered requalification exams, one in 1984 16 which was basically a whole shift with a large amount of 17 warning, and the second being this past June and July with the k
18 short random selection process.
In both cases, our exam 19 results have been judged satisfactory.
20 I feel that I bring you firsthand comment.s relative 1
1 21 to the effeet of the 10 CFR 55 rules and the way that we have
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22 chosen to implement them on plant operation.
23 One of the things that my upper management always 24 says is that you can say anythina as long as you have a smile 25 on your face.
Let the record show that I am smiling, v
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(Laughter.)
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2 MR. TUCKMAN:
From an operational standpoint, Oconee v
3 has 103 licensed operators on shift and directly supporting 4
shift operation.
Our requalification program requires that 20 5
percent of our operators be off shift in requalification 6
virtually at all times to meet our schedules and commitments.
7 The requal exam picked an additional 20 percent of our 8
operations, and hence it was not possible for us to curtail our 9
present requal program, but in essence had to take this 10 additional number of people off shift.
11 I would like to discuss the effects of that on us.
12 We took 19 people from shift operators for a period of four 13 weeks.
We chose to take personnel off for two weeks prior to 5
14 the exam.
If you ask why did I do that.
Basically our k,)
15 experience with NRC exams indicates that there is a different 16 body of knowledge necessary for.the NRC exams as what we teach 17 using the systematic approach to training in what we feel is 18 necessary at our plant.
19 If I had confidence that the exam would test steady 20 state operator knowledge of what you would expect an operator 21 to know on shift, I would not have taken them off two weeks 22 early.
They were also off shift for the two weeks of the exam.
23 During that period, we incurred over 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br /> of overtime on 24 the part of operators, trainiots staff, and folks who hml to go 25 on shift to relieve them.
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1 Many of the activities of my operation group woro not
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2 performed during this four week period.
That included
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procedure upgrades that were necessary for an upcoming 4
refueling outage, solucing the spent demineralizers, and some 5
maintenance work that we wanted to do to improve our plant.
6 And that was basically because we did not have adequate support 7
on shift in operations in the staff area to support that work.
8 Also our daily review of operational activities that 9
is done by our staff could not be done because they were on 10 shift.
In short, our staffing levels did not accommodate 40 11 percent of our licensed operators being gone from the plant.
I 12 We had to reschedule many of our shift personnel in 13 order to cover the necessary shifts.
This put staff pe'rsonnel b"
14 on shift in key roles and removed recent operating experience.
15 The number of substitutes on shift was much greater than wo 16 normally experience.
In essence, we destroyed the teams that 17 we worked so hard to build on shift.
I personally feel that 18 that decreased the safety of our plant.
19 At the time of the exams, I was very lucky.
I have a 20 three unit station and all three units were in operation.
Had 21 I been in an outage, it would have been almost intolerable, and 22 we certainly would have suffered schedule slips.
Trying to I
i 23 accommodate requal training and requal exams were two different l
24 things that caused us great dit.ficulty l
25 The conduct of this exam went directly against what v
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we are trying to do with your operator training program.
In a p
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2 recent letter to utility C'Ar, Zack Payton f rom INPO pointed 3
out the benefits of team trufo'ng.
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At Oconee, we have used two SROs and two ROs together 5
in the control room as a team.
That is the way that we have 6
trained.
One of the SROs is a knowledgeable SRO procedure 7
reader.
The other is the SRO in charge in the control room.
8 As I say, we train as a team.
This examination basically undid 9
that training.
10 Also Mr. Payton pointed out the need to drill on 11 expected, or likely, or things that are reasonable on the 12 simulator.
The exam scenario takes us far beyond the design 13 basis of the plant and impacted that training also.
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14 I might point out some problems that we had O(,/
15 specifically with the simulator exam.
We had numerous 16 discussions between folks in the region with John Hannon and 17 myself and others concerning the format approach to simulator 18 exams.
19 The NRC concerns basically focused around two areas.
20 One, they did not know how to exam a four man team, as they 21 have always examined three man teams.
And the second was that 22 the technical specifications did not require me to have two 23 SROs in the control room all of the time.
24 However, we did wind up with a pilot program in which 25 we were allowed to have two SROs.
The second one was allowed w
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to come into the control room approximately two to three
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2 minutes after the start of a casualty.
We did not have any 3
observation by NRR during that time period that we used the 4
second SRO in those requalification examinations.
5 Consequently, I have no assurance in the future that 6
we will be able to use our four man team and really do not know 7
how to train for the next cycle.
The argument that we do not l
8 have a tech spec that requires two SROs in the control room is l
9 true.
However, I have seven SR0s on shift, and I can guarantee 10 you that when I have a casualty that more than one of them will 11 be in the control room.
12 Personnel are randomly selected for the actual 13 simulator exams.
They have not worked together before.
And
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14 regardless of how standardized the training program is, when x
15 you get thrown together at the last minute, you do not perform 16 as effectively as you normally would.
17 The simulator scenarios were beyond the design basis 18 of our plant.
The lead examiner stated, "Our purpose is to 19 challenge the operators not to verify minimum qualifications."
20 Let me just give you two examples of scenarios which I
21 have occurred at our plant in the past from NRC exams.
The 22 first from 100 percent power a seismic event occurs making all 23 stat alarms inoperable.
Group six control rods fall on the 24 floor.
We have an atlas, an<l we also havu a s t oam gonora t or 25 tube leak, end a steam line rupture.
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1 Another exam scenario that did occur this time from K
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2 100 percent power we have a small break LOCA, a 300 gpm
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3 leakage.
Of course, attempts to trip the reactor all fall, and 4
the supply from the voided water storage tank, the manual valve 5
fails to close which prohibits poration and make-up.
The valvo 6
which failed is a manual valve, it is locked open by tech 7
specs, and it is surveilled shiftly by tech specs, and it is 8
alarmed in the control room.
Clearly, that was beyond the r
9 design. basis of our emergency operating procedures and the way 10 that we operate.
11 In my estimation, we are causing training to be 12 focused on the extremely unlikely events at the expense,of the i
13 more realistic events that we could expect to occur.
14 We are fortunate that all of my operators passed the f()
15 operating portion of that examination.
However, due to the 16 focus on NRC type scenarios such as this, I actually got a 17 finding from INPO that my training program did not address 18 enough, attention on the routine or the expected occurrences.
19 I feel that the NRC exams in the simulator area are detracting 20 from safety.
21 The written examination is one of the major 22 complaints from my operators at our plant.
The examinations 23 were not operationally oriented.
They were merely a subset of 24 the initial license exam that was givnn at the same timo.
Wo 25 do not feel that they effectively evaluate the performance of i
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an operator in a requalification situation.
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1 Let me give you some examples of questions and V
3' problems that we had on the written exam.
Theory questions 4
that do not have a direct operator orientation have really no 5
place in the requal exam.
For instance, one question was name 6
the contacts in the RPS channel in the order that they exist.
7 Studying by schematic in the order that the contacts exist is 8
really irrelevant.
9 Another question, the reactor is at 100 percent 10 power, the 4 delta T is at 60 degrees, and 100 percent mass 11 flow rate.
If natural circulation has a core delta T at 40 12 degrees and core heat is 2 percent, what percent mass flow rate 13 do you have.
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14 That is a fine question in an academic setting, but I
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G) 15 we do not have a meter thet tells us that.
A better question 16 might have been what kind c.f delta T would you expect in a 17 natural circulation condition operationally oriented.
18 The second part of the written exams that gave us 19 problems was the reliance on memorization of information which 20 is readily available in the control room.
That places 21 unnecessary stress on our operators.
1 22 A couple of examples from that.
One question was 23 place the following sections of emergency procedures in the 24 correct order of priority IN11, the EOPs <10 that for you.
If 25 you follow them, you are going to wind up in the right place.
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Another question.
What are the criteria that must 2
be met in order to utilize the reactor trip recovery procedure 3
for start-up.
Every operator when you pull the procedure, the 4
- first thing that_you read in it is what the requirements are 5
before you use that procedure.
6 And another one.
List five situations with the NRC 7
. operations center shall be contacted following the initial 8
notification of an-emergency.
I would ask how many folks from
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.NRC could answer that questionthere today.
10 Basically, the requal objectives for our tests were 11 not used in its development.
Consequently, we had a much 12 broader field of endeavor to study from.
The knowledge skills 13 and abilities book is too generic for use in the requal b
14 process.
The KSA book should not be used to develop requal 15 questions.
It is causing difficulties for our personnel.
16 Although your examiners are highly dedicated andr
- 17 professional personnel, the credibility of these persons at our 18 site is at an all time low.
Experience on the BMW designed 19 plant which we have was exceptionally low during this 20 examination.
Our operators feel victimized by the written and 21
. simulator examinations.
22 The examiners had a grand total of eight hours on a g
23 simulator at our plant before the examination.
It is almost an 24 insult to the operators of our plant tn be examined by persons 25 that have such inexperience in our plant and our procedures.
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And to be given a welk-through after you have been a licensed ss
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2 operator for fifteen years at a plant by somebody who just O
3 comes in is in fact ridiculous.
4 The requal exam issue has been the most negative 5
issue to hit our plant.
The operators feel totally victiinized.
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They must perform for themselves, for the utility, for INPO, 1
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and for NRC.
They are putting their personal careers on the 8
line virtually every year.
There is really no peace of mind 9
for those people.
The short notice is like playing requal l
10 roulette.
You never know when your number is coming up.
You 11 could not have designed a more stressful situation for our 12 eperators.
13 Numerous operators at Oconee have asked for transfer 14 requests and are seeking head hunter applications for other
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15 places.
My historic turn-over rate for the last several years 16 in operators and particularly licensed operators is under 2 17 percent.
That to me is what contributes to the strength of my 18 platit.
Anything which takes away from that is deleterious.
19 A case in point.
I have a third level manager at the 20 plant.
All of my shift supervisors report to this individual.
21 He was selected to take the requalification examination.
The 22 morning of the requal exam at 7:00 in the morning, he came into 23 my office and said I refuse to take that examination, I refuse, l
24 knowing full well that it mas "ont him ich and certainly m mld I
25 cost him his position.
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He did not take the examination.
We dropped his 2
license.
And he is being reassigned outside of operations at a 3
lesser position.
He had 24 years with our company.
4 Several others of my staff at that level have 5
seriously asked and are requesting that we drop their licenses.
6 I have had numerous discussions with our non-licensed 7
operators.
They do not see the advantage of going for a 0
license now.
We need new blood in that category.
9 The operator requal issue has used a considerable 10 amount of time on the part of my training staff, my operations 11 management staff, and my time.
I am in an outage right now.
I 12 do not want to be up here.
I would rather be back home.
13 If I can summarize my remarks, we do feel that the
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14 NRC has a responsibility to assure themselves and the public 15 that the nation's nuclear power plants are operated in a safe 16 manner.
I think that both the NRC and my management know who 17 to look to for the ultimate safe responsible operation of the 18 plant, and that is me.
And that obviously includes the 19 qualification of our operators.
20 The problems that I have outlined are causing 21 difficulty for the operators, for the utilities, and indeed for 22 the NRC.
If continued, I think that it will have a definite 23 impact on the safety of your plants.
We urge you to examine 24
, ways in which the goals f or sa tet y wh ich are common between the 25 utilities and the NRC can be met.
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We certainly understand that rule making is a 2
long-term process.
We feel that there are opportunities within 3
the interpretations of the rule to make the exams more 4
reasonable.
5 I have completed my talk and I will smile.
Thank you 6
very much for y'our attention.
7 (Applause.)
8 MR. COLVIN:
Thank you, Mike.
9 I didn't mention it earlier, nor did Jim, but I think 10 our intent would be to go through the people who have prepared 11 comments and then have an interactive session with other 12 comments, if that is satisfactory.
13 The next speaker is Paul Chudzik, who is a Shift
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14 Supervisor at Oconee.
Paul?
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15 MR. CHUDZIX:
I checked my weapons at the South 16 Carolina line.
17 Gentlemen, my name is Paul Chudzik.
I am currently a 18 Senior Reactor Operator Shift Supervisor at Duke Power 19 Company's Oconee Nuclear Station.
I supervise a shift of six 20 SRO assistant shift supervisors, seven RO control room 21 operators and 12 non-licensed nuclear equipment operators.
22 Some of you call them EOs, some call them AOs.
I have 5 years 23 experience on U.S. naval submarine reactors and 13 years 24 experience with Babcock and Wilcox reactors.
I have boon an 25 SRO for 9 years.
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1 I was selected to take the NRC Requalification I
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2 Examination June 26, 1987.
The written exam was administered C
3 July 13th and the operational exams went through July 24th.
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am happy to say now that I passed all aspects of our exam.
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However, I was not happy to have been chosen.
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From the time of the exam announcement to the day of 7
selection, there was very few topics of discussion amongst 8
licensed personnel except the exam.
A comment I heard from a 9
fellow shift supervisor was that on the day of selection his 10 shift, in the control room, the air was thick with 11 anticipation.
His words were, "You could cut it with a knife."
l 12 It is obvious that the operators were preoccupied 13 with the exam, not on the plant.
The low morale of tho 14
' operators was surpassed only by that of the selectees.
We were O
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15 taken off our normal shift rotations, squeezed into the 16 Training Department's already busy schedule, placed on 4 p.m.
17 to midnight the first week, with simulator training on weekends 18 and random hours the second week. This disrupted our work j
19 routines and our family life.
f 20 All of us began innediately to put in 12 to 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 21 days when it became obvious that the amount of information we j
l 22 were going to be able to required to reproduce was far too much j
l 23 to get in in an 8-hour day.
We split this study time between j
24 self-study and simulator training.
25 The selectees were not the only ones whose schedulus i
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were impacted.
For every person taken off shift, _others had to v
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work overtime on' scheduled days off or were taken'from day 3
shift staff positions to work shifts in order to keep control 4'
room staffing at required levels. 'All of us were struck to our-L 5
professional cores.
Some saw no way out except for a career 6
- change.
After spending years building ~a secure position, then having to face the possibility of starting another career only 7
8-added to the anxiety.
This made studying onl,y more difficult.
9 NARSEGNA requalification program, which is two weeks' 10 in classroom and simulator training out of a 10-week shift 11 rotation is designed to cover the entire plant in two years.
12 Two weeks is an impossibly short time to cram two years of 13 lecture notes and maintain any sort of retention.
In fact, I b-
.14 attribute,our high pass rate to the professionalism that our q
15-operators display in studying and striving for superior grade i
16 averages'during our normal requal program.
17 The simulator training for the exam consisted of two
~
18 SROs and two ROs going over previous NRC exam scenarios.
We 19 were not certain up until the exam, itself, if we would even be 20 tested the way we practiced.
At the last moment, we were i
21 allowed to have this staffing level, but we were told the 22 examiners would choose each team.
We had practiced for two 23 weeks and built our teams but were not allowed to be examined 24 with them.
Actually, even this is not how we operate or train 25 and this is not in keeping with the INPO philosophy of Leam s-
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effort.
p
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2 On shift, even on be.ck shift, we have many more
's 3
people than the NRC minimum.
We train on the simulator to 4
learn and fine-tune our teams, but for exams, we are forced to 5
train on unreal scenarios under unusual staffing conditions.
6 Due in part to the examiners' limited knowledge of 7
the plant and that they were writing the exam from lecture 8
packages sent to them by our Training Department, the written 9
exam contained some poorly written questions.
Some tested 10 one's ability to recall obscure facts and figures.
Some wero 8
11 word games where the correct answer was buried in the choices.
12 A few had two correct answers.
To be fair, there were good 13 questions and a few were somewhat operator-oriented.
14 The original exam schedule was to be a written exam i
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15 and a simulator exam.
That's what we were told.
Late in the 16 first week, we were told there could be oral plant walk-through 17 exams also.
This was not confirmed until the middle of the 18 second week.
This left little or no time to get proficient on 19 plant status items.
In fact, the walk-through exams were 20 little more than en oral version of the written exam, except 21 that the operator could display his analytical ability to uso 22 plant resources to solve problems.
23 Part of the morale problem stems from the 24 interpretation of 10 CFR 55 that a licenso hold < r could be 25 tested annually for the rest of his or her career.
Ii there N,
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were written assurances that one would only have to take the
(
2 exam once in a six-year license cycle, then more people would v
3 consider it a reasonable part of the job.
4 A few of the selectees are still highly stressed by 5
the exam process even though it is over for now except for 6
those who are being retested.
I, for one, took what was for me an inordinate amount of time to calm down.
8 There in building among operations personnel a 9
reluctance to pursue advancement paths. Reactor operators don't 10 want to become senior reactor operators.
Nuclear equipment 11 operators don't want to become reactor operators.
Many staff 12 senior reactor operators are considering moves that don't 13 require a license or are trying to get their job descriptions
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14 changed so a license is no longer required.
(0,)
15 The general feeling is one of intimidation and 1
16 harassment.
In an industry that is already regulated to the 17 extreme, people are approaching burn-out and are looking for 18 ways out.
19 In conclusion, a written examination administered to
)
20 personnel who already have licenses does little to
'st their 21 operational ability.
A reasonably conducted simulator exam and 22 a walk-through exam more properly displays an operator's 23 boardsmanship, communication skills, plant familiarity and 24 ability to use technical ice s uit rces at hand to show that. ho or 25 she can operate a nuclear power plant in a sale manner.
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23 1
(Applause.)
g, (G
2 MR. COLVIN:
Our next speaker is Randy Holt, who is a 3
Senior Reactor Operator from'Calvert Cliffs, Baltimore Gas and 4
Electric.
5 MR. HOLT:
Good morning.
My name is Randy Holt and 1 6
work at Calvert Cliffs.
I have 6 years of naval experience, 11 7
years at Calvert Cliffs and 7 years as a senior reactor 8
operator.
9 Our facility is due to have an NRC Administrative 10 Requalification Exam in October of this year.
It is the 11 feeling of many operators that these new exams will ultimately 12 lead to a severe retention problem within the ranks of our 13 facility.
In a relatively short period of time, our experience
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levels could dwindle significantly due to forced career changes 14
(
15 and operators just giving up their licenses.
16 I'm talking about excellent operators who are forced 17 to change due to excessive stress and added aggravation placed 18 upon them by these new exams.
19 Our future license candidates are seriously 20 reconsidering any moves into the control room based on what 21 they see happening to more experienced license holders.
- And, 22 in short, our experience levels at our facility could be 23 reduced to dangerously low levels.
24 Our profession coul<l f.i 1 l with operators great at l
25 taking tests but totally unable to operate that facility on a l
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daily basis, f%
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2 We feel that our ability to retain a license and to 3
retain the respect our profession should command by the NRC is 4
being seriously -- excuse me.
Is being undermined by the NRC 5
either knowingly or unknowingly through these exams.
6 There is already enough stress and aggravation in our 7
profession just due to shift work, training program changes and i
8 daily plant operations.
The added stress of these exams is 9
more than enough to force career changes regardless of economie 10 conditions or job opportunities.
11 All the gains we have made through the team concept 12 are being seriously challenged.
We operate as a crew, so, 13 please allow us to be tested as a crew and demonstrate our (k:L.
14 professionalism within that framework.
\\s 15 I would like to thank the members of this meeting for 16 allowing me this opportunity to voice some of the concerns we 17 operators have in regard to this new exam.
18 (Applause.)
19 MR. COLVIN:
The next speaker is Eric Andersen. Eric 20 is a senior reactor operator for Florida Power and Light, 21 Turkey Point.
22 MR. ANDERSEN:
Good morning.
I am Eric Andersen.
I 23 would like to make a correction.
I am currently a reactor 24 operator at the Florida Pown anr1 f. i gli t Company 's Tu rkey Peii nt 25 nuclear facility.
I received my RO license in October of 1983.
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25 /26 1-I am presently in the training process to upgrade to senior (9
2 license.
'V 3
I would like to relate some of the experiences that 4
myself and my peers regarding the effects of the NRC 5
Administered Requal on plant operation, career path, and, 6
primarily, the people involved.
7 During February of 1986, I was one of the licensed 8
personnel selected as the first group to undergo NRC 9
Administered Requal Testing at Turkey Point.
I was an 10 alternate for that test but prepared as if I would be a 11 participant.
The exam was to be administered in conjunction 12 with the testing of a new license class which included both Ros 13 and instant SROs for initial license.
14 The sheer volume of materials which would be fair
,)
15 game for questioning was overwhelming.
A thorough review 16 within the 10-day period between notification and testing was 17 impossible.
Most of chose to study primarily the material 18 which had been presented during a recent plant requal cycles.
19 No one really knew what to expect, what kind of questions would 20 appear on the written test or be asked during the oral exams..
21 What the level of detail of answers required would be as high 22 as during the initial Jicense exam.
23 I think the majority of licensed operator:s would 24 agree that he or she is never mor" bruik sma rt than when 25 preparing for an initial license examination.
This makes sense w
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when you realize that for the past 18 months or more the v
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individual's entire job has been to learn plant operations and 3
prepare for a license examination.
Even with this much 4
preparation, it is rare that anyone Aces an NRC license 5
examination and, in reality, many do not pass at all.
6 Testing current R0s and SROs to the same level of 7
detail as a new licensee seems unreasonable if the exam given a 8
requal group turned out to be the same one given to the initial 9
license group minus what many of us consider to be some of the 10 easier questions.
11 One of *he major ccncerns confrw ting all of us was:
12 What happens to my career if I fail?
13 The shift supervisors and management people involved
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14 felt that a failure, even with subsequent satisfactory retest, f3 t
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would permanently the respect and credibility levels among 16 their crews.
17 The examination a]so have the potential to force the 10 loss of present position and pay grade.
This imposed undue 19 stress on many individuals and their immediate family.
Many 20 individuals were in a position, financially, where the loss of 21 license and/or shift commander's pay would have made it I
J 22 difficult to meet their current financial commitments.
23 i
We lost our most experienced control board operator, 24 an SRO, following the exam.
Upon tw"i ui ng wo r<l o f Iho group's 25 poor pass rate and his own failure, this individual's mental
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state began to deteriorate to the point of breakdown and he was 2
relieved of all duties on the nuclear site.
The individual has 3
since un'dergone rehabilitation and is now a control center 4
operator at one of our fossil units.
This gentleman had been a 5
licensed RO/SRO for 13 years.
6 Some operators with high blood pressure problems i.
{l 7
found that condition extremely aggravated beforo, during and 8
for quite some time after the examination.
Many of us had 9
found that the examination process.had'put us in a near. crisis 10 state of mind and that even upon completion had took quite some 11 time to return to normal.
12 Our low overall pass rate on this initial requal 13 group spurred media interest.
Press releases questioned the
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14 competency of the operators and the safety of the plant.
This
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15 brought on numerous questions from family and friends as to the 16 accuracy of the stories.
Our professional expertise and 17 integrity were in question.
Operator morale was declining and 18 many began to look for a way out.
19 Following receipt of the first requal group's 20 examination results, all license holders who had not yet been j
21 tested were asked not to assume unit responsibilities or duties 22 and not to perform any control manipulations until remedial 23 training and further NRC testing was completed.
Our licenses 24 were suspect even if you had not yet had the opportunity tc i
25 prove otherwise.
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.This left the plant operating staff with 8, and I
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will put it in quotations, " good" licences with any prior
-)
s 3
operating experience:
4 who had passed the requal exam and 4 4
SRO upgrades from the initial license class.
5 I should point out at this time that Turkey Point is 6
a dual-unit facility.
k 7
The remainder of the operating staff with " good" 8
licenses was composed of the newly licensed ROs and instant 9
SROs from the initial license class.
Neither plant management 10 nor the NRC Regional Office felt comfortable in having this 11
.many brand new licensees running the units.
Therefore, it was 12 agreed upon to use the experienced operators whose license 13 expertise was now in question as advisors to the new operators.
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14 The advisor position was designed to keep the control room
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15 experience level up.
No one who had failed th' requal exams I
16 could be used.
Advisors were composed of individuals waiting 17 to be in the subsequent test groups.
18 These advisors' role was to stand behind the new 19 operators 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, 7 days a week and insure normal l
20 day-to-day operations ran smoothly and that his experience 21 would be available in the event of a unit transient.
i 22 During this period, control room morale reached an 23 all time low.
We had played a large role in the training of j
i 24 the new operators during the requ i rmi un-shifL t.i m e, sigoing 25 off learning modules, conducting practice oral exams, v
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et cetera.
Now, they were qualified operators and we were not.
k (m\\_-)
2 We did not understand why those of us who had not yet been 3
tested were treated as if we had already failed.
4 The NRC requal process also affected my career path 5
in a less obvious manner.
The requal process, initial and 6
subsequent testing of all operators took place in a time period 4
7 in which an SRO upgrade class had been previously scheduled.
i 8
Seven operators with sufficient experience to qualify for the 9
SRO upgrade found themselves preparing for a test to keep their 10 RO license rather than having the opportunity to upgrade their 11 license and pay rate.
Due to NRC requal and unit outages, the 12 SRO upgrade could not commence until June of this year.
13 I would like to close by thanking all of you for bt 14 myself and my peers for the opportunity to present some of the 7
t
\\s 15 impacts of the NRC Requal Exams on the people who must endure 16 them.
It is our hope that a more equitable examination process 17 with less involved stresses on those to be tested can be found.
18 Thank you, 19 (Applause.)
i 20 Seven operators with sufficient experience to qualify i
21 for the SRO upgrade found themselves preparing for a test to 22 keep their RO license rather than having the opportunity to 23 upgrade their license and pay rate.
Due to NRC requal and unit 24 outages, the SRO upgrade could not commence until Juno of this l
25 year.
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1 I would like to close by thanking all of you for I V) 2 myself and my peers for the opportunity to present some of the l
l l
3 impacts of the NRC Requal Exams on the people who must endure l
4 them.
It is our hope that a more equitable examination process-5 with less involved stresses on those to be tested can be found.
6 Thank you.
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7 (Applause.)
I 8
MR. COLVIN:
I think at this time, the comments by 9
the presenters have focused on operator impact, impact on 10 morale and, primarily, the impact on shift operations.
And 11 Rich Starostecki would like to kind of summarize for a minute 12 before we go in and talk about the training, the impact on 13 training, training programs and the training staff, itself.
14 MR. STAROSTECKI:
I simply want to reinforco maybe 15 what we have been hearing.
16 VOICE:
We can't hear you.
17 MR. STAROSTECKI:
I wanted to summarize what I have 18 been hearing.
Let me try and summarize what we've been hearing 19 from the last couple of speakers and recognize that we are 20 going'to have a transcript and we will rely on that to try and 21 pull more information out.
1 22 One, we have got to distinguish between the 23 reluctance to go through and be subject to a requal exam and 24 not having one.
I don't know if we c:an face that quantion.
I 25 think as the last speaker has said, we need to improve the s.
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process.
I donft believe it is.really feasible to say we are
/
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'2 never going to do away with the process of requalification.
s.
3 There are problems with the fact that the current 4
approach based on what the speakers have said does not test the 5
operational skills and abilities.
The written exams are too 6
theoretical and the operating tests are artificial in that they 7
have artificial shift staffing and the scenarios deal with 8
complex severe accidents.
9 Please don't interpret that I'm making a judgment of 10 these comments are good or bad.
I am trying to summarize what 11 I heard.
12 Then nature of the NRC requal exam process produces 13 anxiety and stress due to the notification time being short and 14 it has an adverse impact on staffing in the plant due to the s,/
15 fact that people are pulled off shift to prepare them for the 16 requal exam.
17 There is a perception and view on the part of the 18 operators that the NRC examiners are not qualified.
The only 19 other point that I've gotten out of this discussion so far is 20 that the operator feedback to the NRC is weak.
And that we 21 need to have a forum like this to get discussions from the 22 operators and this raises the question of do we have other 23 forums or other vehicles where we could be hearing this kind of 24 feedback or) a more routine Ims is.
And we nood to expleiro i t.
25 Jack, did you have any other observations?
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MR. ROE:
I think that capsulized it.
2 MR. STAROSTECKI:
I am not trying to capture all of 3
the comments I've heard.
I am trying to highlight what some of 4
the notes some of us are taking saying here is what we are 5
hearing.
If we have other major points that need to be raised, 6
let's review them towards the end of the meeting.
(
7 MR. COIViN:
Thanks, Rich.
8 Let me introduce Ted Amundson who is the supervisor 9
of training in Northern States Power, who is our next speaker.
10 MR. AMUNDSON:
As the introduction indicated, I am 11 Ted Amundson.
I am the Superintendent of Training at the 12 Prairie Island Station of Northern States Power Company.
13 Prairie Island has had two NRC Administered Requalification
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14 Exams, one in 1985 and again in June of 1987.
In both cases,
)
15 our experiences were negative.
Both cases, our failure rate 16 was judged to be unacceptable, however, because of the good 17 operating record and acceptable remedial programs, the NRC has 18 allowed us to continue with our requalification programs 19 without extensive further testing.
20 It is our opinion that the implementation of l 21 10 CFR 55 is having detrimental effects on the safe operation 22 of our nuclear facilities.
These effects include unnecessary 23 modifications to training programs based on examiner feedback, 24 cancellation of scheduled training to support unplanned 25 examinations, a declining morale and increased stress level of v
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our operations personnel.
The morale and stress levels are g
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2 resulting in a higher turnover rate of our licensed and non-3 licensed operators.
4 We believe that most of these effects are the result 5
of examination practices that are not based on valid job 6
performance measures.
And in my following comments, I would 7
llike to give additional details on these effects and some of 8
our problems with the examination process.
9 At the end of each examination, the examiners are 10 issuing feedback licensees on observations made during the 11 exam.
Some of these comments are based on observations during 12 the simulator exam and the oral exam.
And sometimes reflect a 13 lack of perspective on the part of the examiner.
Jrt 14 No plant will operate exactly like the simulator or s
k, 15 the test conditions indicated.
Yet, we are making changes to s
16 training and operating practices based on these comments.
For 17 an example, we modified methods of verifying bi-staples being 18 tripped on the simulator after feedback from a recent exam.
19 But because the simulator and the plant used different methods 20 to trip bi-staples, the procedures used on the simulator will 21 not work in the plant and vice versa.
It appears to us that 22 the testing process is driving the operation of the plant in a 23 negative way in this particular case.
24 Training schedules, i nc lud.i m s the s i mula t< > r are 25 established as long as one year in advance of the present. Tho C
s Heritage Reporting Company (202) 628-4888 l
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practice of notifying licensees that they will receive an NRC
,m i
2 exam with only two weeks' notice is disruptive to these 3
schedules.
The simulator must be made available to administer 4
exams.
Training staff must be used to run the simulator in 5
support of the exams and training staff may be selected to 6
receive the exams.
7 The result is that the simulator and training staffs 8
are not available to conduct training and scheduled training 9
must be cancelled.
At Prairie Island, we cancelled four weeks 10 of requalification training in June because of an NRC 11 requalification exam.
It is our view that any practice that 12 leads to the cancellation of requalification training is 13 counterproductive to the operating of our plants in the safest 14 manner possible.
s
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15 The uncertainty of the HRC exam process is creating 16 additional stress for the operator and is resulting in a 17 declining morale of operation staff.
Operators take a great 18 deal of pride in doing their jobs in a professional manner and 19 of being able to handle any event that they might encounter.
20 But because the exams they are receiving are not totally based 21 on job performance measures, they are failing these exams at a 22 higher than acceptable rate.
An exam failure is devastating to 23 an operator's morale.
24 Consequently, experienced nporators are leaving t ho 25 nuclear industry whenever the opportunity to do so arises.
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the last year, four of our most senior licensed operators at v['}
2 Prairie Island transferred to a fossil unit.
Virtually, all of V
3 the licensed operators applied for the positions, but only four 4
vacancies existed.
Also, eight non-licensed operators 5
transferred to jobs in either fossil units or to the l
6 maintenance department.
7 A survey of the operators indicated that the 8
uncertainty over licensing and examination practices was a 9
major contributing factor in their decision to transfer to a 10 fossil unit or to the maintenance department.
As a result, we 11 are operating our plants with less experienced operators.
12 It has been our philosophy of operations to provido 13 the best possible technical support to our operators.
We
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14 accomplish this goal by licensing system engineers and other (j
15 technical support staff.
The new 10 CFR 55 standards make it 16 virtually impossible to maintain all of these staff licenses.
17 Consequently, we plan ~to eliminate approximately 30
~
18 staff licenses, thus risk reducing the technical and 19 operational expertise of those individuals providing technical i
20 support to the operators.
21 The examinations administered by the NRC are not 22 always based on job performance measures generated by a formal 23 job and task analysis.
Examinations that not in agreement with 24 established job performance measuren result in training 25 programs that first train the incumbent to do the job and then G#'
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to pass the exam.
These validation problems occur in both the
/(x) 2 written and operating exams.
l s
3 Several problems occur frequently in the written 4
exam.
One is that written exams are closed book and require 5
memorization of vast quantities of information, readily 6
available to the operator in references and procedures while 7
performiog his duties.
8 Job performance measures based on job and task 9
analysis indicate that the operator may use the information in 10 these references to accomplish tasks and memorization is not i
11 required.
For an example, an NRC requalification exam 12 administered in June at Prairie Island required incumbents to 13 recall from memory the initial actions in the loss of 14 instrument error procedure.
(O
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15 The Prairie Island Administrative Directive governing 16 the use of procedures does not require these steps to be 17 memorized, but does require the procedure to be in hand when 18 performed.
19 In addition, the NRC examiner referenced the KSA, 20 knowledge, skills and abilities catalogue as a justification 21 for this question.
However, the reference listed in the KSA 22 catalogue is for knowledge of the basis or reasons for actions 23 contained in the procedure for loss of instrument error, not' 24 recall of the actual steps, themselvm.
25 Misuse of the KSA catalogue is occurring frequently.
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Recently, the NRC examiners have requested all learning
)
2 objectives be included in the reference material used to write 3
exams.
Terminal and enabling objectives for each of our 4
lessons are sent to the NRC.
5 Systematic approach to training dictates that 6
questions written to enabling objectives may not be appropriate 7
for comprehensive exams, but examiners routinely write 8
questions to the enabling objectives and seldom write questions 9
to terminal objectives.
10 For an example, on the recent NRC requalification 11 exam, the incumbents were required to recall from memory four 12 conditions under which reactor coolant pump trip criteria does 13 not apply.
This question was directly related to an enabling is 14 objective in a lesson in our Emergency Operating Procedures.
k, 15 But a question written to the terminal objective would'not have s
16 been written in this form.
17 A better way to test the knowledge is to give a 18 condition or set of conditions and then to ask if the reactor 19 coolant pump criteria applies or does not apply.
20 Another concern with the written exam is the tendency 21 to ask questions that do not rate high in importance to the l 22 safe operation of the plant.
This tendency seems to be related 23 exam integrity concerns.
The concern is that once a question 24 is used, it should not be us~I again.
However, exam i nteg r i t-y 25 issues should not preclude testing the same concept or 7'")-
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1 knowledge over and over again.
A different type of question or n
2 approaching the concept in a different way should satisfy exam 3
integrity concerns.
4 There should be a core of very important knowledges 5
that should be sampled on every test.
Unfortunately, this does 6
not appear to be happening.
The KSA catalogue was an attempt l
7 to focus written exams on the most important issues, but by 1
8 allowing questions to be written on items that are rated 2.5 or 9
higher, virtually, all information is testable and the desired 10 focus is not achieved.
11 A particular problem with the SRO written exam is the-12 over-emphasis on procedures.
50 percent of the SRO written 13 exam is on procedures and is closed book.
The SRO must commit
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14 huge quantities of information to memory that the job and task b)
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15 analysis indicate is not necessary.
16 For an example, a common question is to list all 17 items or areas that are discussed during a shift turnover.
But 18 when performing the turnover a checklist is always used that 19 specifies the areas to be discussed.
Memorization of these 20 steps is not necessary.
21 The theory sections of written exams often test for 22 concepts that are not observable to the operator and are not 23 supported by job and task analysis.
For an example, a common 24 NRC theory question asked to differentiate between delayed 25 neutron fraction and effective delayed neutron traction.
v Heritage Reporting Company xi (202) 628-4888 J
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Although these concepts are important in building the knowledge
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necessary to safely operate a reactor, they are nct directly 3
observable to the operator and should not be tested on a 4
comprehensive exam.
l l
5 The systems section of exams also tests knowledges 6
that are not supported by job and task analysis. The need to 7
write questions that have a well-defined answer has led to l
8 writing many system questions that simply require recalling 9
facts about the system, set points, or interlocks.
The types 10 of questions that require analysis or problem solving are not 11 being asked.
12 For an example, on the recent NRC requalification 13 exam, the incumbents were asked to recall interlocks that must 14 exist prior to starting a reactor coolant pump.
The
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15 consequence of not knowing this information is minimal, 16 considering the reactor coolant pump starting procedure 17 discusses these two interlocks immediately before the step that 18 is used to start the pump and the operator is required to have 19 this procedure in hand in starting the pump.
l 20 The use of enabling objectives by the NRC to write 21 their exams leads to a common problem in all sections of the 22 written exam.
Many lesson plans were written with the thrust i
1 23 that they should have -- they should prepare trainees to pass 24 an NRC exam as well as train t. h e incumbant to < in a joli.
425 Consequently, many enabling objectives were written
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because.the knowledge had been tested on previous NRC exams but 2
not because-of information derived from job and task analysis.
3 Several problems exist with the simulator exam, also.
4 One of the key difficulties we have with the simulator exam is 5
the number of malfunctions the operator must deal with.and the 6=
degree of proficiency the operator must demonstrate in handling l
7 multiple major malfunctions.
8 The pass / fail criteria seems to hav'e gone.well beyond 9
an analysis of whether or not the operators are maintaining the 1
10 plant in a safe condition and within the limit'specified by the 11 technical specifications.
12 For an example, on a recent NRC requalification exam, 13 the SRO lailed the simulator portion of the exam,because he b-14 failed to recognize that he had met the safety injection b
15 termination criteria and he allowed the pressurizer to go 16 solid.
Almost immediately, the operator recognized the problem 17 and entered the rediagnosis procedure, but the simulator model 18 failed.before the procedure could be exerci' sed.
19 The stated cause of the failure was that the 20 pressurizer power operated relief valves were challenged.
21 However, the relief valves opened because of the problems with 22 the simulator model not because of the missed SI termination 23 criteria.
Our SI pumps don't havo enough head to lift our 24 power operated relief valves.
25 Either the simulator exams should be more rea l i s t. i c w.
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or performance standards sh)uld be relaxed.
When the
/' h 2
malfunction summary page in the simulator shows 15 malfunctions b
3 active at one time, it is not reasonable to apply the same 4
performar.ce standards as when only one malfunction is active.
5 Another problem with the simulator exam is the 6
emphaals on demonstrating supervisory skills.
Over the last 7
two years, the nuclear industry has been emphasizing team 8
building and diagnostic skills in its training programs.
9 However, the NRC is criticizing operators for relying on team 10 skills and falling SROs for not issuing orders for every action 11 taken and not responding immediately to every alarm that occurs 12 on the simulator.
13 These actions are not conducive to team work and lead L-14 to a training dilemma.
Do we train operators to use team f'
15 skills or do we send them to acting school to learn how to
\\_
16 demonstrate command and control?
17 Problems exist with the conduct of the oral exams, i
18 61so.
Questions continue to be asked that cannot be supported 19 by job and task analysis.
For an example, on the recent NRC 20 requalification exam, SROs were required to demonstrate and 21 discuss the detailed use of the bills assessment computer.
22 This function would be performed by a radiation protection 23 specialist during an actual emergency and is not a requirement 24 of the SRO's job.
25 SRO's are also asked to discussed how to verity v
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calculations made on liquid and gas release forms.
Again, this
(/
function is performed by the radiation protection group and is 2
N_
3 not a task for the SRO.
4 Sometimes trivial questions are asked in the oral 5
exam.
A couple of recent examples at Prairie Island were:
Why 6
is the spent fuel pit blue?
And:
Why does the far end of the I
7 spent fuel pit appear shallower than the near end?
8 We appreciate this opportunity to express our 9
concerns with the implementation of 10 CFR 55 and we look 10 forward to uorking with both industry and the NRC in 11 implementing changes to the operator licensing process that 12 will improve the safe operation of our nuclear plants.
Thank 13 you.
14 (Applause.)
( j 15 MR. COLVIN:
The next speaker is Lee Williams who has 16 of the training of Florida Power Light Company.
Farley Nuclear 17 Point.
18 VOICE:
Oh man.
Ahh.
19 MR. COLVIN:
Excuse me.
20 MR. WILLIAMS:
I would comment on that.
But you all 21 let it go.
Particularly since Alabama plays Penn State this 22 week.
I will luagh after the game, and maybe I can cruise on 23 it.
24 First of all, J would like
- t. o say 'Thank you' f or t he 25 opportunity to address the group.
My name is Lee Williams.
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I am the Training Manager, Farley Nuclear Plant, Alabama Power
_f E
2 Company.
3 I have been associated with nuclear power, either in 4
the commercial industry or United States Navy for over 21 5
years.
Involved in operations and maintenance and training.'
6 Right now I feel like I'm the man in the middle.
I'm 7
one foot on each side of a cause, and my inch is growing wider 8
every day.
1 9
On one hand, I'm responsible to deliver to the 10 Operations Department, well qualified personnel, to operate the 11 plant.
And on the other hand, I have to prepare those people, 12 to pass an NRC exam, to get in the plant to operate.
And those 13 two things are not necessarily the same.
In most cases, they
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14 are not.
15 It's really unfortunate, because how well our 16 candidates do on the examinations, reflects on me, and my i
17 profession, and my professionalism.
Basically, that boils down 18 in being in the self-operating.
However, we do own exams, as i
19 reflected in our self-operating, regardless of how well the l
20 people can operate the plant.
And the fact that they failed an i
21 exam may not be a fair judge of how well our operators are 22 trained and qualified.
Particularly.in the case, some of the i
23 people making those determinations for licensed personnel, may 24 not possess'the credentials to make that iudgement.
25 However, let me say that I have had some pos i t i ve i
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experiences, recently.
Thank goodness life is not all 2
negative.
We have our most recent NRC re-qual exam, June the 3
22nd of this year.
A lot of fear and concern in going into it.
4 What do we face?
That was the basic feeling of our licensed I
5 personnel.
What's ahead, or what's this exam is going to be 6
like?
7 I want to say that we provided the two truckloads of 8
material, that's usually requested.
That also increases our 9
concern.
Obviously, when you're drawing from that much 10 material, besides just what was covered in the retraining 11 program.
12 But I will say a positive thing here.
That the 13 written exam was based totally on the objectives of our re-qual
{
14 program.
I think it's very positive.
Our operators walking 15 out of the exam said, if I didn't pass it, I shouldn't have my 16 license.
17 14 of the 18 candidates that took the written exam, 18 rode in the 90's.
Everyone passed the written exams.
19 The oral exams were acceptable.
A few cf the trivial 20 questions, we had the same question why is spent fuel pool 21 blue.
Few others like that.
But overall they were good, and 22 acceptable.
23 Simulator, we had two failures of the 10 candidates.
24 And that leads to my area o f'
<oncorn, ovor the simulator oxams.
25 v
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During:a recent simulator exam, I got so aggravated, and so v
2 upset at the way the scenerio was going, I left the control-
.\\
l 3
booth'rather than say or do something that I shouldn't.
Walked 4
to my office and collected my thoughts, and let pressure calm c
5 down.
And then went back to talk to the people involved.
6 o
Their comment about the particular scenerlo was, well 7
it was not well thought out.
Now to me, when we're asking for 8
professionalism, in the operation of.our plants, that is 9
totally unacceptable.
Redeeming the qualifications of a. person 10 on a person.that is not well thought out.
11 The scenerlos create multiple malfunctions, which I-12 don't have any problem with that.
But there has to be.a line 13 of reasonableness drawn, as to what we mean by multiple 14 malfunctions.
Many times, the multiple malfunctions take us beyond the design of the plant.
Beyond the design capability 15 16 of the simulator.
And beyond the design bases of the 17 procedure.
And the stated purpose of this is to, and I'm 18 quoting again,
..to see them think on their feet..".
I hate 19.
to have to be examined in that environment myself.
20 Also, in the area of simulator exams, one of our 21' candidates that failed, and this is not what failed him.
But j
22 it keyed me to something in looking at his exam report.
23 Received an unsatisfactory "U",
during an up power transit 24 condition.
Feed water pumps are in manual.
All feed rog 25 valves are in manual.
And one of them failed, as is.
And M
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47 I
there increasing power.
And this~ condition went on for J/
2 approximately five min'utes, best I can tell from the notes.
3 No alarms of any kind came in on the control board, 4
before the man saw that the valve had failed.
Took action and 5
now he's got two feet reg valves in manual control, increasing 6
He was deemed unsatisfactory because it went 7
for five minutes.
8 Now those of you who'have a license, can appreciate l
9 that if'you consider the fact that the other things that are in.
l manual, $nd the amount have changed and is.taken in a five 10 11 minute period.
12 So all that is to get to this point is that we need 13 less subjectivity in our simulator exams.
And we need to make i
14 sure we are not going beyond the capabilities of our equipment, 15 our procedures, and the design of our plant.
16 Some of the negative experiences we've had of our 17 recent qualification exam.
We had one shift supervisor said, 18 I'm not just up to this hassle, I want to surrender my-i 19 license.
i 20 When he first told me that, I tried to, as part of my I
21 responsibility as counseling.
Get him up, said let's go on.
I 22 After several days of similator training, I saw that his heart 23 wasn't in it, and that I was fighting a loosing battle.
24 lie wound up. surrendering his license over the concern 25 of facing the continuous, or continual annual re-qual exams, l
H s,
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2
48 I
administered by the commission.
[W 2
One of the other people that was in training at the k
3 time, when he saw the shift supervisor surrender his license, 4
an operator that had worked for him previously, and I'm quoting 5
- again, "He's the best shift supervisor I ever worked for."
The 6
man has 20 years utility experience.
And over ten years at the 7
Farley Station in license capacity.
8 Some of our non-licensed operators are beating out of 9
their jobs.
Going into the craft areas.
One reason is that we 10 require that they must progress upwards in this area, in order 11 to provide new blood, as someone said earlier, in the control 12 room.
And now this is no longer a desired career path.
And so 13 the plant experienced that these people have gained in the non-14 licensed position over the years, is being lost to the pipeline
(,/
15 or career path for those people in the control room.
16 We had over 3,000 additional man hours required in 17 our efforts to prepare for the recently administered exam.
18 You might ask, well if your people ready to take an exam or if 19 they were qualified, you wouldn't need that time.
That's true 20 if there was no uncertainty as to what you were facing.
One of 21 our operators made the comment, it says, it's a crap shoot i
l 22 everytime you take an exam.
l l
23 With the adverse impact that the utility is facing, J
24 we have no choice but to <lo overything we can to prepare.
25 During this period of time, over 60% of my operations j
l l
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49 g
training department was assigned to prepare these people to 1
n 2
take the exam.
That's not without cost in other areas.
3 Training was cancelled, post-poned.
Schedules were upset.
4 Twelve hour shifts were worked by those in the plant, to make 5
up the differences of the shift' coverage.
One entire crew was 6-almost removed from the shift.
Obvious.ly, this has a f
7 detrimental effect on the team training.
8 The short notice involved has tremendous effect on my schedules,.and which I schedule my simulator time.
Months and 9
10 years in advance.the people,make vacation and schedule plans, 11 and the cost that goes in with it.
We had two individuals on 12 the list to take the exam.'
They were ultimate did not have to 13 take it.
But who had reservations to leave the continental 14 U.S.
for almost a year.
Have they have not been able to change-15 those. reservations, that would've a personal lose to.them in 16 several thousands of dollars.
17 I have recently completed, filling out generic letter 18 8614, it's in the process of being sent in by a licensing 19 group.
Which tells the commission when we will be conducting 20 re-training.
When our exams will be given.
And when we expect 21 to have initial exams.
The purpose of this request is so they 22 can have effective scheduling, and utilization of their 23 resources.
I asked the same consideration.
I face the same 24 problems that they do.
25 Our re-qualification program, as all of you know is v
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based on a systematic approach.
And I hear that, it appears
[%
2
'w that the current trend of re-qual is that it will also cover, 3
or it will be the same as initial program.
If what I'm hearing 4
is true, I'm very concerned about this.
Since the purpose, the 5
focus, and the scope of our re-qualification program is totally 6
different than that of initial trainig.
7 You've heard us verbalize, today, some of our 8
concerns and problems with NRC re-qual examn or administration 9
of it.
I think we all agree, I've heard my operators 10 verbalize, I don't mind taking the test as long as it relates 11 to my job.
12 I think both the commission'and the utilities have a 13 responsibility to lend the public have assureness that we're 14 operating our plants in a safe and efficient manner.
I really i(
/
15 like to think about these problems more in the line that they 16 are opportunities.
And I'd like to offer, I know I can speak 17 for most of the utilities, I think, myself and my staff and our 18 resources to work with you, to solve these opportunities.
So 19 that we can assure safe operation of our facilities.
20 Thank you.
21 MR. COLVIN:
Lee you did well, even though you're not 22 from Pennsylvania.
23 The last speaker that we had on here was Bill Jessop, 24 who heads up the trainino from Uni.on niectric I hope I giit 25 that right, Bill.
And Bill is going to talk for a minuto about e
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some of the results of the original pilot program.
And some of R)
I 2
the issues we have faced before, that I think we're still k- /
l 3
facing today.
4 MR. JESSOP:
My name is Bill Jessop, and I am the 5
supervisor of operations training at Union Electric's Callaway 6
plant.
I have an active SRO license.
And I've been working 7
with our company representative, Newmark's working group 11, 8
for the last couple of years.
Dealing with operator re-9 qualification issues.
JO We've been discussing a lot of problems this morning 11 that have dealt with the re-qualification process.
I'd like to 12 take a quick look back, at some of the work that Newmark and 13 NRC has done over the last several years.
In trying to address N_
14 some of these problems.
15 Most of the concerns we've discussed this morning, 16 have dealt with problems that have existed for some number of 17 years.
The major difference is with the implementation of the 18 new 10CR 555, deal with the notification requirements.
The 19 amount of advace notice an individual gets.
And the fact that 20 an individual has to pass an NRC administered examination, as a 21 condition of license renewal.
22 The other concerns that have existed for several 23 years still exist, and are in fact accentuated with the new 24 part 55.
And those problems are tho validity, the relevancy of 25 written examination questions.
And the quanfications of v
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52 1
evaluators for operating exams.
2 Several years ago, in 1985, the NRC and Newmark v
3 working group got together to address some of these concerns.
4 Late in 1985, and early in 1986, the result of all these work 5
came out as the Operator Re-qualification Pilot Program.
6 My plant Callaway was the first plant to have this l
7 program implemented.
The experience that we had with the 8
operator re-qualification pilot program was similar to what 9
other plants have.
Basically, what we did was we wrote up the 10 written examination based on our job and task analysis.
11 Submitted it to Region III for approval.
They reviewed it and 12 approved it.
We wrote the simulator scenerlos for the 13 operating examination, again submitting these to the region for 14 review and approval.
And we administered the examination.
15 The region had an examiner down when we administered 16 these exams.
And he monitered and evaluated the entire 17 process.
Conducting a go evaluation on the simulator.
And 18 also took the written examinations back to the region for dual 19 grading.
f l
20 That is basically how the program worked.
There were 21 some differences among the implementation to the various 1
22 regions.
23 In February 1987, early this year, we got together at 24 the conclusion of the first r>ha s e of this program, Lu work out 25 some of those problems.
6 Heritage Reporting Company
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In February, the first phase of the program was l
[
'3 2
concluded.
Approximately six or seven of the utilities had l
O 3
gone through the initial phase of the pilot program.
Both the 4
NRC and Newmark evaluated that experience, and both were 5
positive.
And the second phase of the program was instituted.
6 That's second phase just recently concluded.
And as 7
a point that continued on through the implementation of new 8
part 55.
9 The concept of the pilot program addressed the major 10 concerns that we're addressing today.
The clear advantages of 11 the pilot program, one, the written examination is written from 12 a jot and task analysis, specific base.
Specific for the 13 utility.
Specific for the unit.
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14 Throughout the operating exam, is conducted by
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)
15 qualified individuals, licensed or certified on the plant that 16 the examination is being taken place on.
17 In addition, the scenerlos for the operating exam are 10 written by subject matter experts from the utility.
And from 19 our perspectis e, it advantages, the NRC has the opportunity to 20 monitor and evaluate the entire process, concentrating on the 21 monitoring and evaluation function.
22 The pilot program concept continues to be one of the 23 better answers to the concerns we're hearing today.
We need to 24 take a hard look at what we'vu dono t ri t.h" pi}ot program.
Anti 25 attempt to use the entire program, or salvage elements of the g-w Heritage Reporting Company
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(202) 628-4888 L_---
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program for use in solving some of the problems that we've seen Df I
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2 with the implementation of the new part 55.
3 Regardless of the amount of time an individual gets I
4 to study for an examination, if the individual feels that the l
5 examination is not relevant to his jcb, or he feels that the 6
evaluator is not credible, we're going to continue to have F
jJ 7j problems.
8 I sincerely hope that the work that both the NRC and 9
Newmark did in this operator re-qualification piJot program can 10 be useful in solving some of the problems that we've seen 11 today.
12 Thank you.
13 MR. COLVIN:
Let me go ahead and introduce our last 14 speaker.
Kevin Nietman, who is the Supervisor of Nuclear
(
15 Training at Baltimore Gas and Electric, and they are in the 16 process of preparing for NRC administered recall examinations -
17
- I believe it is in October.
18 MR. NIETMAN:
Good morning.
My name is Kevin 19 Nietman.
As Joe said, I am the Supervisor of General Nuclear 20 Training at Calvert Cliffs Nuclear Power Plant for Baltimore 21 Gas and Electric.
22 And also as Joe said, we have not yet had an NRC 23 requalification exam, so my remarks will be brief and will be 24 based only on the changes that we have ma<h-t.o the t. raining 25 program at Calvert Cliffs as a result of learning that we wilj l
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have an NRC requali(ication exam this October.
I 2
In order to prepare the operators at Calvert Cliffs i
3 for the recall exam, the training that had Ecen prepared for 4
the final one-third'of the year, 1987, was scrapped.
The 5
reason we only scrapped the fin,a1 third was because that.was 6
-all that was left when we learned that we would have a recall.
7 exam.
8 New training sessions were prepared to better support 9
candidates who will be chosen by the NRC to take the exam.
10 Generally speaking, the depth of the new training was reduced 11 from what had been prepared prior to the Part 55 rule change, 12 and the scope was broadened to include typical NRC initial 13 license examination topics.
\\'
14 O
Emphasis was added to memorization'of set points, JS instrumentation, and reactor theory that is not directly 16 related to reactor operation.
Some of the topics that were 17 dropped due to the rule change were diagnostic and teamwork 18 training, a review of auxiliary building ventilation, case 19 studies of INPO's significant operating event reports, 20 electrical theory review, and a review of several abnormal 21 operating procedures, such as loss of component cooling, water
\\
22 loss of service water, and some others.
23 The aim of the Calvert Cliffs continuing training 24 operator program is, of coursu, to i mt irr ive iho r epera t inn o f 25 Calvert Cliffs' nuclear power plant.
To do this, topics v
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1 included in the training program were covered in more depth
'N
/
2 than is required by regulation.
I
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3 Teamwork, interpersonal skills, and diagnostic skills j
l 4
are stressed.
By proscribing the content of the continuing 5
training program via non-performance based requalification 6
examinations, the value of continuing operator training will be 7I significantly diminished.
8 Our training program will probably have to be 9
permanently changed in future years as a result of the NRC 10 requalification examinations, if they are as similar to the 11 ones that we've heard about this morning.
12 And the goal that we have for the existence of the 13 operator training program to improve the operations of the 14 operators at Calvert Cliffs will be much more difficult to r
l(
15 achieve.
Thank you.
16 MR. COLVIN:
I think at this point that concludes our 17 prepared remarks.
We would like to open it up and have some 18 interaction, and have some other people, who would like to make 19 comments, provide those comments to the group.
20 MR. STAROSTECKI:
What I would like to do is, maybe -
21
- there are a lot more notes I took on the training topics.
22 Let me make a few remarks and maybe it will stimulate some 23 discussion.
24 The pilot program concept has been around for years, 25 and it is a good sut..essful program.
Maybe we ought. t.o do more v
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1 with it.
Understand, that's a test of the program, because one
>y t.he i
25 operators, and we are creating an artifi.cial climate through w
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the written test and the operating test, that the operators are
/%
l -
2 adversely reacting to.
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3 The simulator scenarios that are being developed seem 4
to be very artificial, and are they really reasonable tests of 5
the operator's knowledge and skills?
A point well taken is 6
that the emphasis that we NRC examiners are placing on 7
supervisory skills of SROs is very subjective and maybe even 8
detracts from the team training these individuals are getting.
9 Coordination of schedules -- obviously we can talk 10 about it, but we've got to implement something that makes more 11 sense if we are to seriously re-examine the requalification 12 process, which means how do we deal with individual operators 13 to make sure that they are getting the kind of requalification
\\"
14 training they need.
-s i
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15 And we have to acknowledge that is why we have 16 requalification training.
People do get rusty.
You can look 17 back over history and you find individual operators, for one 1
18 reason or another, cancelled classes, don't take home reading 19 assignments.
They get rusty.
We owe it to them to get them j
I 20 the training they need to get back into the control room.
21 So there is a need for good requalification training, 22 and it is disturbing to hear that requalification programs are 23 being reoriented to satisfy NRC requalification exam testing.
24 So with that summary of what t heard from the l a s t.
25 set of speakers, maybe we can have some other points or r
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1 questions raised from the audience -- not that one is right and
-V(
2 the other is wrong, but more so, take a look at what options 3
are available to us, in what direction we both ought to be i
4 taking with. regard to serving the needs of the operator.
i 5
It is not acceptable to have two training programs.
i 6
One to improve the operator skills to safely run the plant,'and-I l
7j the other,'to teach him how to take an exam.
That's wrong.
I l
8 But we do need to factor in some way that we can sample and-9 understand that the needs of the operators are being met.
10 So with that as a capsule summary -- and again, 11 please don't take my comments as having passed a judgment of 12 good or bad, I am trying to summarize what I am hearing, and I 13 am also trying to say what some of the examiners from the NRC b"
1 14 might say if they were here, because -- go ahead.
15 VOICE:
Several issues are involved with the safety 16 problems when you have. people who have to pass the test, 17 operators, are covered by other people.
Several people spoke 1
18 about that.
t i
19 MR. STAROSTECKI:
They did, yes.
That comment was J
20 noted that people are taken off shift, and therefore somebody 21 else is standing twelve hour shifts, so the individual can be 22 prepared for a test.
Is that your comment, sir?
23 THE VOICE:
Yes, plus the safety of the plant as 24 covered by the staff people who are not operators.
25 MR. STAROSTECK1:
Let me make a comment.
There ar" v
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some good things about Part 55.
One of-the good. things about 2
Part 55 that I don't think people appreciate is that t.lus NRC 3
has said it is good to have staff people with an operating 4-license, however, we recognize that it doesn't make sense to 5
- have staff people in the control room every day.
6 Therefore, you can have an awful lot of staff 7
licenses, and they can be out of the plant.
The only 8
prerequisite we've put on them is make sure they've
.9 participated in the recall program, and, before they go back 10 into the. control room, in the event of a strike or some other 11 situationi beef up their training.
12 That is, in essence, what Part 55 says, and it's done-13 away with that age old question of, what are you doing in terms 14 of actively performing the duties of?
We used to have people 15 at the vice-president's level at.these plants having a license.
16 It's difficult for some of us to understand if the vice-17 president is going to go in the control room to run a ship.
18 But if he does have a license, he ought to be 19 involved in training.
Before he goes back in that control 20 room, he ought to have some parallel watch standing to 21 understand what is going on.
So there was also a comment made 22 about detracting incentive for staff to hold licenses.
23 I think that is an interpretation question, and that, 24 again, reinforces my need for, whora nra tho forums to have a 25 dialogue to raise these kinds of concerns.
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Any other criticisms, comments, feedback?
s-
{}
2 VOICE:
I would like to say something.
v 3
MR. STAROSTECKI:
If you could identify yourself 4
when you come up, make a comment, or ask a question, that would 5
help.
6 MR. McCOY:
I am Ken McCoy.
I am the Director of the 7
Plant Operations Division at INPO in Atlanta, and one of my 8
responsibilities is to evaluate operating crews at nuclear 9
stations for INPO.
10 I'd like to make three points.that have been raised 11 in some detail by people here already, but that are raised by 12 my evaluators at INPO who are looking at operating crew 13 performance.
14 The first is that training programs for improving
(
15 operator proficiency and crew performance presently are 16 adversely impacted by the examination process.
I think that 17 comment has been made several times, and we are very interested 18 in improving that current situation.
19 The second is that operating crew performance, which 20 involves the entire team working effectively to handle 21 situations and transients that evolved in the plan, is being 22 adversely affected by the simulator examination process 23 currently being used.
We would like to see that process 24 improved.
25 Third is that operatur professiorialisiti is l>e i nig s
f-~
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adversely affected by the perception of the operators to the s.,
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testing and evaluation process.
We feel that improving 3
operator professionalism is a major thrust that the industry l
4 has been working on, and we would like to see that area focused 5
on in the process.
6 To sum all of that up in a simple form, it appears to 7
my evaluators that the heart of the matter is that the
+
8 examination process be viewed as fair, by both the operators 9
and by the public, who are looking to the Commission for 10 assurance of public safety.
11 We feel that this is not an impossible task to l
12 achieve, that there is a model that exists where a similar i
13 situation currently does lead to professionalism and a sense of
\\-
14 assurance of the public, and that is the examination of airline O
t i
15 pilots.
suJ 16 We would suggest that the analogy be looked at there, i
17 It is our understanding that the pilots accept the examination 18 process in a positive frame that enhances their professional 19 status, and also that the public accepts that process as an 20 assurance of their public safety.
21 Thank you.
22 MR. STAROSTECKI:
Thank you, Ken.
Let me just say 23 that I am reacting very positively to that kind of comment, 24 because that is a proposed suggest iv m that we can di, si>mething 25 with.
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Now, let'me raise a question that I have as a result
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necessarily now, but we need to hear back -- and that is, 4
with the differing number of plants, if we take an FAA type of 5
approach and use a check operator concept, one of the problems 6
operators have high-lighted to us is that each plant is 7
different, and therefore, how do you educate somebody on a new 8
plant or a different plant, such that they are more familiar 9
with that.
10 I think the problem can be managed, but we need some 11 constructive feedback about how to deal with that kind of 12 issue.
It is not a simple answer, and maybe it is a good 13 answer, but we need to do more work on it.
ji 14 Unfortunately, standardization in the aircraft k,)
15 industry helps them do that better, and we don't have
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16 standardization in the power plant industry.
17 Yes, sir.
10 VOICE:
I would like to comment on that.
I'm Joe 19 Johnson of TVA.
I claim that I asked the airline pilot that I 20 flew up here on, and Delta is responsible for the validation of 21 Delta's own pilots, and the FAA monitors the process.
22 I just want to make sure that we understand what "it" 23 is that we're talking about, doing "it" like f.he FAA.
Very 24 clearly and succinctly stated it is that thr> utility shtmirl im 25 responsible for the competency of the operator, that the NitC, v
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'eing in the role of the FAA, would monitor that process, and 1
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if you didn't feel that we were teaching the~right thing, you Q,/
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would tell the trainers, teach more pressurized thermal shock.
4 If we didn't pass to your satisfaction that you l
5 observed there, then we could crank it up.
I just want to make 6
sure we understand what "it" is when we are talking about the i
7l FAA, and it's clear Delta is responsible for the safety record 8
of the Delta pilots, therefore, this business about uniformity 9
is not germane to this issue.
10 I just want to assure that nobody doesn't agree that 11 the FAA only is a monitor.
The FAA van ride with the pilots, 12 and they can watch the way Delta gives the exams.
I checked 13 specifically on this flight into Washington.
k' 14 Someone else made the comment, that's not true.
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15 VOICE:
Excuse me, a few short air facts.
Without 16 belaboring the FAA; anyone that wants to compare FAA and our 17 training, there'was a very nice study commissioned by the 18 Nuclear Regulatory Commission about six years, and released as 19 New Regs/CR 1750, that compared nuclear training with the 20 airline training.
21 So if you want to see where the comparisons are, it 22 is kind of interesting that this is being brought back today 23 from six years ago.
They did a fine study that, essentially, 24 hasn't been used.
25 MR. STAROSTECKI:
Yes, sir.
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MR. LINDAMOND:
I'm Ed Lindamond from Vermont Yankee, v
[O Correct me if I am wrong, but it sounds like you like the pilot T
2 3
program.
You said it was a good review of the training 4
programs, and if I am reading correctly, it states that the 5
examination process we have going on in recall now is exactly 6
that, a review of the training programs.
7 It's got a caveat it says if we don't do well, you 8
can address our operating license.
But in fact, it states 9
pretty explicitly that that's exactly what it's supposed to be, 10 a review of the training programs, and you seem to have qualms 11 that it, in fact, was not -- the pilot program wasn't enough of 12 a review of the individual licensed operators.
Is that true?
13 MR. STAROSTECKI:
The new Part 55 throw the wrinkle
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16 MR. LINDAMOND:
That's true, but it doesn't really 17 state what type of exam that is.
' Surely the pilot program 18 examiner worked with that, if he was really okay on those You'renotreadi;ththatone?
19 exams.
20 If you revi/w that exam or proof it, is that not
)
21 really good enough --
1 22 MR. STAROSTECKI:
The current practices say there is l
23 a conflict there, all right?
And I think we are now seeking to i
24 resolve some of those conflictn.
Y< iti aie n e s t-go i sig
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a 25 unanimous answer.
You'll get various points of view.
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1 I am saying, in my own personal judgment, the pilot v(m 2
concept-la sound, it's good, and lets us have an awful lot of 3
insights and information.
Maybe we can expand on it and apply 4
it, but we've got to change current practices and the current 5
examiner standards, which also have to be changed to keep up 6
with Part 55.
7 So there are so many balls in the air that we need to 8
look at each individual operator to write a comprehensive 9
written exam and the operating test mandated by Part 55, that 10 should we change the examiner's standards for the way we do 11 that, the way we implement the new Part 55, or should we spin 12 off from using the old pilot concept.
13 Maybe the two will merge.
I don't know.
(1 14 MR. COLVIN:
Excuse rae, Rich.
f3
()
15 MR. STAROSTECKI:
Yes?
16 MR. COLVIN:
Just let me interject one comment.
It 17 seems that you might explain -- at least for my benefit, 18 perhaps for others -- how you are interpreting the words "NRC 19 administered exam."
I think if we are looking at the pilot 20 program and other things where the utility develops the exam --
21 and we've heard comments that the examination -- what we are 22 looking for is a professional examination that's developed 23 through approved type testing procedures and methodology as 24 based upon requalification, the utility in rievoloping those 25 type of exams, and the pilot program developed that.
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1 Yet I get the feeling that that can't be used as an
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that.
4 MR. STAROSTECKI:
The guidance was received from the 5
Commission as that we, NRC, must prepare the exam ourselves, 6
and administer it.
We are not in a position at this time --
l 7
we've got to look at more of the pros and cons, but we are not t
8 in a position at this time to adopt a utility prepared exam, 9
and the whole essence of the pilot project was just that.
10 The utility prepares it, we may accept, reject, 11 modify portions of it, but we adopt it as our own, recognizing 12 that it was prepared by the licensee.
Yes?
f 13 MR. CAREY:
Rich, I am Jack Carey of Duquesne Light.
14 I feel like I really qualify to make a comment --
O(,)
15 MR. STAROSTECKI:
Could you speak up, Jack, a little j
16 bit.
It's not recording.
17 MR. CAREY:
But anyway, I think that there were some 18 very good points made here.
Number one was subjecting these 19 people to an unreal world.
You're training them to, number 20 one, use their procedures.
I really don't understand why we're 21 taking this truckload of information and putting a pretty I
i 22 severe burden on the examiner to try to come up with a new 23 question.
He says, by golly, it may have been used in the last 24 two years and may be compromised and t.he poor devils may have 25 memorized that.
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But why can't they have, really, an open book exam.
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They work with reference material
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By golly, you'know, it's been a long time since I 4
took a professional engineer's exam and that was an open book 5
exam, and I've certainly never heard anyone question the 6
validity of an open book exam.
I 1
You're asking these people to memorize and be 7
8 expected to trot it out, and in a very short period of time.
9 The other thing that I would like to suggest is, in a sincere 10 way, I think,.the focus is on the quality of the exam, the way 11 the questions are written, what they are attempting to do.
12 We are training our people to work as a team, we 13 certainly expect them to function as an integrated team.
We f.
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14 are attempting -- at least as I see the NRC -- to take each
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15 individual member of that team and throw them out there on 16 their own.
17 I think that what they are doing in the testing is 18 contrary to what we do in our training, and since the only man 19 in this particular situation is the man taking the test.
I 20 guess that I would feel comfortable if on the other side of the 21 fence there was a.little bit of pressure.
22 It would appear to me that there should be a separate 23 board that reviews examination questions, and, by golly, if a 24 fellow hasn't developed a good, reasonablo, fair, comprohansivo 25 exam, maybe he should be removed from administering exams f or a Heritage Reporting Company
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while.
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2 (Laughter and clapping.)
3 MR. STAROSTECKI:
Jack, let me expand that's not the 4
adverse consequence is the end of it, but you raised a good 5
point.
And that is if we are to develop more operationally 6
oriented exams we need to get operationally oriented people 7
either preparing them or reviewing them and maybe that's not 8
bad idea to set up some sort of review process before their 9
admission.
For example, let me give you one bit of data just 10 so people have a reference point.
11 Some regions use the resident inspector to review the 12 exam and make sure the questions are relevant to that plant 13 because I know that we at NRC have administered exams to
)f 14 certain plants where they didn't have the systems that they s
k, 15 were being asked questions on.
That doesn't make sense and it s
16 does call into question the competency of the people who 17 prepared the exam.
18 Now we, like you, have a variety of problems.
We 19 need to maybe set up some internal checks and balances to 20 create better exams.
We're looking into a national test and 21 we have spin-off from that.
And maybe focus more on just one 22 section that has all these operational specs, get some 23 operators, get some ex-resident inspectors and you guys at the 24 national board.
I think we need to considor that.
That'n good 25 feedback. There's a question in the back.
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MR. HEARSTt I'll come up.
My name is Ben Hearst.
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2 I'm with the Industrial Scramblers in Atlanta, Georgia and l
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3 we've been working'in the nuclear industry for about six or 4
seven years.
And during the past couple of; years we've been 5
studying this whole exam issue in cooperation with several 6
utilities.
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7 And as a part of that study we took a look at a 8
number of utility exams.
And before I make comments on those, 9
how many of you in here have taken exams? The SRO's don't have 10 to raise their hands, I know they have.
Now everybody let's 11 get your hands up if you've taken exams before.
- Anybody, 12 everybody, most everybody.
How many of you really like to go 13 in there and take those exams, hold your hands up.
(Laughter) 14 NowthinkaboutyourexamalsofromthisperspectiveI (s_ j 15 How many of you have taken exams that you feel real good about 16 when you got through taking the exam, that you knew you passed 17 that exam?
All right, if you look back on those you might also I
18 remember taking some exams that you felt very insecure about.
)
19 How many of you had those?
You didn't know what you did on 20 them.
Do you remember the qualities of those exams?
Basically 21 has to do with how the questions are developed.
How 22 professionally they were prepared and how valid they are in 23 terms of what you thought you should be tested on.
24 Now those are verv i.mpor t a n t concepts when ytiu ty + t i
25 into this area of testing.
Especially it you intend to make f
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sure that that test has something to do with performance on the w
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I think what we're seeing NRC do here is to imply that
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exam and operating a power plant safely and efficiently.
5 Which, of course, there should be.
Very difficult to achieve.
6 Now that leads me to the comments about testing and 7
the observations we've made.
We studied in detail about 14 8
utility-administered exams and nine NRC-administered exams.
9 And we took a look at these in terms of the content validit,y on both sides and we also measured these exams using accepted 10 11 psychometrics practices.
12 We analyzed the difficulty with discrimination and 13 the reliability of these exams.
And of course the utilities j;
14 might be pleased to know that they do a little bit better job i
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15 than NRC in developing quality exams.
They were a little bit 16 more valid and considerably more reliable.
17 Now what are these measurements and how can you use 18 them to improve testing?
Well my point is this, just as you i
19 raised your hands a few minutes ago, when you take a good exam
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21 about that exam.
Professionally developed exams are extremely 22 important, especially if you intend to project that performance 23 on a written exam to performance on the job.
24 You need to get some criterion measures from tho job 25 so that you can tell, in terms of supervisory evaluations, ul p
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how that SRO is doing and compare those to how they function on v/ %g.
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the written test.
Then you've got some predicted validity to 3
performance.
4 In our finding, one of the problems we have is the 5
quality or construction of the exam, how it's put together.
6 And this is especially true of the NRC exam.
We found 7
misspelled words, grammatical errors, punctuation errors, mixed 8
test forms, numerous, sometimes 50 to 60 test construction 9
problems when you're dealing with one examination.
And I guess 10 that we conclude, and we did conclude from that, that there's a 11 need to train the examiners, the NRC examiners themselves, how 12 to construct a better test.
13 If you have these types of problems in a test then-7, 14 the test is not measuring what it's intended to measure.
And
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15 that's validity, the test findings.
If it measures what it's 16 intended to measure and you get the results back, it's a valid 17 test.
But if you throw in all these grammatical errors, mixed 18 forms, misspelling, punctuation, then that test becomes an 19 obst'cle course and what you're measuring is somebody's ability 20 to figure out what the examiner's trying to.
And you see in a 21 case like that you don't have a valid test any more.
You have 22 something else.
It's an endurance test really, is what it is.
23 So in our experience, my suggestion would be let's 24 spend some time training examiners to wri te better test n so 25 that when people take them they know they've had a good ono and v-Heritage Reporting Company
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they can relate that to their job experience, their job 2
performance.
Thank you.
3 MR. TAYLOR:
Mr. Starostecki, can I ask another 4
question?
5 MR. STAROSTECKI:
Jim, let me just make an
((}
6 observation.
There's problems in the way tests are written, 7
there's problems with the way we administer simulated tests, 8
there's problems with the way we do walk-throughs.
We need to 9
address that.
Make no bones about that.
10 Understand the big change that happened this year 11 that we are not losing sight and that is the fact that the
)
12 operator, when he takes that re-qual test, this year for the 13 first time his license is in jeopardy.
And that, I think, has 14 had as you have indicated today a very big impact on the 15 attitude and morale of the operators because, as you all have 16 told us, is people are leaving because they don't want to be 17 subjected to their career being on the line every time they 18 talk to an NRC examiner.
19 After all is said and done, that one change is behind 20 an awful lot of the comments that we heard here this morning.
21 That is, the license is subject to a third-party review and I 22 don't know who that individual is that's going to be 23 controlling my future career.
That's a big part of the problem 24 behind the comments you'vo mmle.
mul we ran (tea.1 wi t h Iho 25 written exams and we need to do that job better, maybe v
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restructure the written exams.
But, four different areas, 7N
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MR. MACIUSKA:
My name is Frank Maciuska.
I'm a 4
senior reactor operator at GINNA station.
I also have a 5
Master's degree in instructional technology.
I'm in charge of 6
the re-qual program.
The biggest problem we've had at GINNA, 7
we've had two re-qual exams, one under the old format, just 8
under ES 601 and then, part of the pilot program.
The biggest 9
problem we've had is in exam length.
I know.
I took the first 10 one, I was a failure.
I failed to complete two sections of tho 11 exam but I still got a 78 overall.
I feel if I had had another 12
. hour I probably would have passed.
13 Our last exam,,our Vice President went down to our p-14 region and asked the region one thing we want you to do is'make (s,
15 sure that exam has the right length, four hours.
Well, exam 16 day came, gave the exam, at the end of an hour and a half the i
17 examiner that was with us walked'through and said, "An hour and 18 a half is up, you should now be on Section 2."
Now if that 19 doesn't put stress on the operator taking the exam, I don't 20 know what would.
Needless to say, at the end of four hours, 21 the exam was pulled and we still had three people writing the 22 exam.
One person did not finish.
23 I think what we need to addreas, one of the problems 24 wo need to address, along with what my prodocessor nald here, 25 is we need to construct good exams.
We have to have them time
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validated.
The exam questions, do we use an exam question more u'
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than once.
The only way to prove an exam question is valid and D
3 to get any statistical basis on whether an exam question is 4
reliable and valid is to use it more than once.
That's the 5
basic of statistics.
You'need a broad population, a sample 6
population.
And you do that by using it over and over again.
7 J
Another thing that we've experienced is m3xed signals 8
in the regulations that are being promulgated by the NRC.
New 9
reg 1021, standard 202, which covers exams, in Section 9 it 10 gives recommended times for different types of questions.
It 11 does not give a recommended time for short essay questions.
It 12 does say short answer but it does not say essay questions, 13 which are specifically allowed in Section 11, just two 14 paragraphs down.
So the examiner standards have to be looked k,)
15 at.
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16 Another thing that we found is there appeared to be a 17 contradiction between new reg 1021 and KNA catalogue 1122 in 18 regards to what ability is required for procedures containing 19 immediate action steps.
The signals aren't clear.
20 1021, ES 202, Section E says that memorization of 21 symptoms and automatic and operator actions for all procedures i
22 that require immediate action is necessary for the examination.
23 New reg 1122, however, says that the examinoo should 24 have the ability to recognize i.nd ica t i ons for system opernt i ng 25 parameters which are entry level conditions protecting tho s-g-~g Heritage Reporting Company
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specifications.
I have a re-qual audit coming up in January
- t 2
and I'm worried.
I'm worried because I don't know what they're 3
going to examine my operators or myself on.
I don't know it 1 4
need to memorize those or if just being able to recognize those 5
symptoms is appropriate.
To me, recognizing is by far a better 6
cognitive level to work towards.
1 7
Our last re-qual exam, oh this is great -- you may 8
wonder why are we having one.so soon.
In January of this year 9
we had a re-qual exam administered by our region, we weren't 10 accredited so they come up and they said well we'll just give 11 you one, even though you're not accredited.
But we'll give you 12 part of the pilot program.
So we administer a written exam and 13 everyone passed.
They're coming back again.
14
/~'h We will get our first simulator exam and, needless to
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15 say, there's a lot of stress among the operators.
It is a crap 16-shoot.
But as a trainer I'm in the classroom just about every 17 day around the simulator.
I find that the attitude of the 18 students has changed.
Why are you teaching me something that's 19 performance based when the NRC is going to ask me anything they 20 want.
So it's very hard to get down to business and train good i
21 operators when the examination process undermines what we're 22 trying to do in the re-qual program.
And that's the conclusion i
23 of my remarks.
Thank you.
24 MR. STAROSTECKI-Thank ym.
Question -- yos, Honry, 25 sorry.
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1 MR. HENRY:
Yes, Mr. Starostecki, thank you very g
2 much. Just a couple questians.
First of all, the basis -- 1 3
know your topic before was -- program.
take notice.
It's 1
4 unreasonable in that it really forces the training operators a 5
different way of giving exams, give exams six months, six 6
months, six months later.
I'm just not sure.
i 7
The other side, the other point is the three man 8
teams.
We're an accredited plant and pushing hard to do 9
diagnostic team work, communications skills.
We have a team.
10 We create a shift as a team, with five people on a team shift.
11 They come to the simulator as a team.
You want a certain 12 simulator, simulator examiner -- really -- people who havo 13 never worked together.
The operators should be able to able to 14 work together.
Q' 15 We're not really dealing with team. work but --
16 evaluate team work.
I guess my point -- random selection -.
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17 MR. STAROSTECKI:
Mr. Roe asked those three points.
10 Random 10 day is essentially a policy decision that was given I
19 to the staff that we should do this on a very random bacis on 20 about 10 days and we ought to be giving it randomly which means I
21 you go out to sample individuals, not shifts, and those kinds i
22 of policy decisions we need to re-visit and re-examine.
23 So, yes, that's part of the feedback we're getting, j
24 is that 10 days is havinq a severe imiact and pulling peoplo 25 off shifts and out of shift teams complicates it.
And, if in I
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'l fact, we have examiners who are putting together shifts of g
2 their choosing, we are having problems.
Those are policy i
3 questions, we need to re-visit them.
4 The three-man team, I think we're re-visiting that t
5-now.
We are making some assumptions and I think we've gone to 6
a conservative assumption to say, "You have a minimum shift 7'
staffing.
Assume one of them is out of the control room, see 8
how you handle the event."
Quite frankly as a minimum, after 9
some reasonable amount of time the individual ought'to be able 10 to come back.
And I think that negotiating process with some 11 regions is going on but we're re-visiting that too.
Don't have 12 the answers but certainly hear the concerns.
Yes, sir?
13 MR. RAGOOSE: My name's Ray Ragoose. I'm with LE 14 Commonwealth Edison Company for 34 years.
Been an SRO at~
(
i 15 LaSalle and an SRO at Quad Cities, presently with the 16 production training center for the company.
And I have a 17 couple comments to make concerning re-qual results.
We've 18 undergone re-quai exams at the Quad Cities station, the Dresden 19 station, the LaSalle station, Zion station, and had a pilot 20 operating test demonstration with Byron.
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22 Quad Cities and out of those results came probably some 23 improvements in our training program.
Although a largo company
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24 with several large utility plants, an< h o f tham have Ihoir own 25 specific training programs and they don't all appear to be the
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same or look like the same company.
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So we've had some benefits come out of the V
3 examinations although we've had lot of similar problems that we 4
expressed this morning concerning the effects of the 5
exam'inations.
We've also had some good results at a couple or 6
plants.
Two of them had 90 percent pass rate the first time 7
round.
8 But what I'd like to address a little bit more 9
pointedly is the examination questions.
I know our utility has 10 spent hundreds of hours developing an exam bank, submitting 11 thousands of questions, or preparing thousands of questions for 12 submittal to be used on exams.
I'm sure you utilities have 13 done the same.
I would think what these questions based on
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14 task-based training and performance evaluation that if a guy, I%
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15 even if he memorized the answers to all those thousand 16 questions, you'd have the evaluation of a pretty darned good 17 operator.
That's all I have to say.
18 MR. STAROSTECKI:
We have time for only a few more 19 questions so two more please.
20 MR. BOLTON:
I am Jim Bolton from Diablo Canyon.
21 MR. STAROSTECKI:
Can you speak up?
22 MR. BOLTON:
Sure.
I'm Jim Bolton from Diablo 23 Canyon.
I got a phone call th.is week.
It didn't really 24 surprise me, it was from the NRC telling me that we're going tc 25 talk about our exams and we'd have initial operators.
Whal s-Heritage Reporting Company (202) 628-4888 L - -_
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surprised me was that we are now going to have re-qual people X
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2 taking our initial exams, our full initial exams.
3 If somebody would ask me what the policy was prior to 4
this happening I would have referred them to ES 601, which 5
clearly delineates that a re-qual exam should be more 6
operationally oriented as opposed to theoretically oriented.
l 7
It should be 60 percent of the content of the initial exam.
It 8
should be four hours in length and it should be based on the 9
re-qual program that was conducted.
10 I am very disheartened by the fact that the NRC, if 11 I'm right, the NRC is going to a policy that makes people take 12 an initial exam, that hasn't, if I can understand it, the NRC 13 recognizes that there is a difference between a re-qual exam jf 14 and an initial exam.
And I don't see that they're making.a
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15 distinction any more.
16 The second point I'd like to make is you made a 17 comment that the pilot program can evaluate a re-qual program 18 but it cannot evaluate an individual.
I'd like you to tell me 19 how you feel about what your program does when an individual 20 fails your exam.
21 MR. STAROSTECKI:
Let me just make a few quick i
22 observations.
What we're dealing with is just that kind of 23 problem.
Why are we giving essentially the same exam for 24 initial licensing as wel]
as for ra-qual.
And one of t.he 25 reasons we're here is to say we're not beholden to be giving Heritage Reporting Company
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written exams the way they've been done in the past.
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We do have problems.
I'm not going hear them and say 3'
we dont have problems and dismiss them all.
If we, in fact, 4
have practices today where we have people preparing written 5
exams for re-qual that are being more operationally oriented I 6
can flip it the other way around.
Maybe some people prepare 7
re-qual exams that are being used for initial licensing.
Be
.1 8
that as it may, the issue is real.
9 We are asking an awful lot of complex questions on 10 the written exam and the real issue is are we really getting 11 insights from it that are valuable in deciding whether the 12 individual's maintained a state of training.
And it is that 13 state of training that we question about.
14' In response to your second comment, I was reacting to-
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15 some experiences I've had where I had seen individual operators 16 fall a utility-administered re-qual exam, written test, with a 17 grade of 50 percent, two weeks later passes the utility re-qual 18 test with a grade of 95 and he's back on shift, i
19 When you go in and you talk to the operator he, quite 20 frankly, is very weak from an operational standpoint because of 21 a variety of circumstances.
And what I'm saying is that's 22 something that's not fair to that operator.
If he is burdened 23 with overtime, if he is burdened with routine work, and he
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24 needs to spend time in t r a.i n i n g, and I hat 's what som" mi nur 25 findings are coming up with, that people are registered for re Heritage Reporting Company (202) 628-4888
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qualification training but they're not taking it.
O 2
So your comment about juggling schedules for training 3
is disturbing because some people aren't attending your 4
training sessions.
And if'they're not attending the training 5
sessions and subsequently have trouble passing your exams let's 6
not just focus on the exam results, let's focus on why the 7
situation's occurring.
8 MR. BOLTON: You can fine the utility if that's not 9
the case.
I'd like to'see if the utilities agree with that 10 statement.
You can fine us if we don't put in as much time as 11 possible, is that not true?
I mean that's very isolated.
12 MR. STAROSTECKI:
It may be isolated but it happens 13 and I would hope -- I don't want to get into a discussion of 14 the enforcement policy but if the NRC's got to come in and tell
'O 15 you your re-qual program isn't working then there's something 16 drastically wrong.
17 And the example I'm highlighting happened about four 18 or five years ago before an uproar did pull involvement, before 19 a lot of NRC involvement.
But I'm talking about a large 20 utility that operated more than three power plants.
And I 2L don't think fining is the answer to some of those problems.
22 There was a question here?
One more question, it's 23 11:30 and we need to close it down.
24 MR. SilIFT:
John Swift, Florida Power CorporcLion.
25 Mine's not really a question as inuch as it is a coriiiiteli t.
We j
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And rescheduling, the operators working long hours to cover
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3 overtime, I think something we've skimmed over, and it's been 4
mentioned a couple of times.
You've even left it out in a 5
couple of your summations is all this has a tremendous effect
- 6 on plant safety.
We cannot leave that out when we talk about 7
- this, t
8 That's the first thing we have to address is plant 9
safety and how this stuff has affected. plant safety.
And it 10:
definitely is when you've got high turnover rates, poor morale, 11 and operators working long hours to cover for an NRC exam.
12 MR. STAROSTECKI:
That's exactly why we're here.
And 13-let me just make one other aside.
When we published Part 55 we,,'
14 had regional workshops and question and answer' sessions.
We f
13 promised at that time we would issue a new reg with all the 16 answers'to the questions.
That's still being reviewed because 17 we don't like some of the interpretations or impressions people 18 were getting from those workshops.
19 From a' safety standpoint we are not here to impose 20 the bare bones minimum.
We're not going to tell you to revise 21 your tech specs if you wart to augment staffing of licensed 22 operators.
We are looking for ways to improve safety and when 23 we see an impact oc safety we like to take measures like this 24 to get feedback m3re prunptIv.
I aaree with you.
This is a l
25 safety issue and that's why we're talking about.
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And that's not why we're not going to put it on the r
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2 back burner.
We're going to deal with it.
That's why we're s
3 going to fix whatever we have to do in terms of putting out our 4
interpretations to the existing Part 55 guides.
You know, from 5
this standpoint -- it's 11:30.
Let me just allow some 6
pertinent comments to be made by Jack Roe who is the Division 7
Director currently responsible for operator licensing and then 8
I'd like to have Joe Colvin make some closing remarks and Jim 9
Taylor.
10 Personally, I appreciate your being here today.
I'm 11 a little bit discouraged that we have to have forums like this 12 to get this kind of feedback and I think we need to look for 13 other vehicles to get these kinds of issues elevated between 14 the NRC and the utilities.
So from that standpoint, Jack, 15 would you make some comments.
16 MR. ROE:
I'd like to tell you what the NRC staff is 17 doing within the flexibility we believe the Commission has 18 given us within current regulations.
And also give you some 19 perspective of our discussions with our licensed examiners and 20 what they told us would be helpful from your perspective to do 21 our job.
22 The first thing is, we atilize our examiner standards 23 to try to reflect to our own staff and to the industry some of 24 our practices.
We currently are looking at what are in tho 25 examining stai.dards and we are taking several different
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approaches to try to react to some of the criticisms both h()
2 positive and negative about our program.
3 So I'd like to highlight some of the things that we 4
have got under consideration.
I want to let you know that we 5
are going to go through a deliberate process to evaluate these 6
things and we're not going to make these changes haphazard.
7 Therefore, from your perspective you might see that Duke got it 8
different than Commonwealth.
There is a reason behind our 9
approach is we are going to do things, we're going to evaluate 10 them with our professional staff and then come to a conclusion 11 about what is the proper way to go or various proper ways to go 12 if there's more than one option.
13 The first thing to let you know is indeed we are
):k 14 starting out to review the concept of examining the operating s
\\m, 15 team.
Greater than just minimum tech spec requirements.
This 16 is a change from what we have done before.
Our previous 17 approach as the regulators in this particular area have been a 10 conservative one, to take a look at.what we saw as the minimum.
19 We know that utilities would say almost all the time we have 20 that many people on the shift.
21 You know that the NRC does not regulate you almost 22 all the time.
We look at what are the minimum regulatory 23 requirements and and assure safe operators based on those.
24 However, we believe that we can meet
- t. hat ob.iec tive, to assure 25 safe operators, with other approaches to examining.
So wo are v
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looking at the team approach to examining the operators.
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2 The second thing that we are interested in now is a 3
pilot program with respect to giving open-book tests or you 4
might use the term " partially open-book tests".
That doesn"t 5
mean the book is half-way open, it means part of the exam will 6
be an open-book test.
Obviously there are things that wo 7j assume, the operator must know, not so much as memorized, but 8
he needs to know it to do his job on a day-to-day basis.
So 9
you will see that kind of program coming out that may touch 10 your utility.
11 The next thing we are looking at is the exam length.
i 12 Of interest to us is our perception was utilities preferred a 13 re-qual setting a shorter setting, 60 percent.
We found out,we
)f 14 were wrong.
We got some severe criticism that the exam was too
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15 short.
People wanted longer exams.
There may be two sides to 16 that story.
Some people want shorter, some longer.
So we are 17 going to look at both aspects.
18 The next thing we are looking at, and we're looking 19 at this hard because there are a lot of tasks in this 20 particular area, is videotaping and audiotaping different parts 21 of the exam.
It's got some pros and cons which we'll look at 22 it.
23 Overall, I want to let you know that the stafi is i
24 interested in taking various approa<:hes to examination of' 25 operators.
We are open to suggestions, we will take deliberato s-O Heritage Reporting Company (202) 628-4888
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steps to evaluate these suggestions and then make changes in s-
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2 the examining standards.
So if you've got viabla suggestions k
3 for us, we are very open.
I would suggest that you contact 4
your regional representatives or headquarters, depending on 5
what your desires are.
6 The next thing, let me tell you how maybe you can help us 7; i do the job better.
It was very opportune that Lee Williams 1 :
8 said the right statement today.
He said, "We gave the NRC good 9
training materials, they gave us a good exam."
It's 10 interesting to me when I talk to our examiners I say, "What's 11 the most frustrating part of doing the job."
They say, " Wh a't l
12 we get from the utilities."
I say, "What do you mean."
They 13 say, "You would be surprised at some of the things they send a
14 us."
If you're not looking very carefully at what you're 15 getting to the NRC, which they put a great deal of focus on to 16 give you your exams, then you need to enhance that particular 17 job.
Thank you.
18 MR. COLVIN:
Since it's after 11:30, then I'll try to 19 make this brief.
I'd just like to summarize and conclude our 20 presentation from NUMARC's standpoint, the industry standpoint j
i 21 and say I think we've heu good feedback from all the l
22 participants, from the industry and the utility participants in 23 the audience.
And good feedback that -- I think you've heard 24 that the impact on the operator trai.ning, on the oporatorn 25 themselves and on plant safety is significant from this change.
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7 think we've also heard that a root cause of a lot
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of the problems is the examination or the examination process 2
3 itself.
So we'd encourage you to move forward and try to 4
develop, or work with us to develop, a credible examination, 5
boll) written and operating and simulator, the operating test 6
both oral and the simulator, that is fair and credible in the 7
eyes of the operators and in the eyes of the utilities and the 8
public that we have to convince.
We request that you work 9
through the industry, you've had a lot of offers today.
I 10 think everybody in here is ready to work with you and provide 11 you with constructive criticism and constructive comments that 12 will help improve the program and resolve some of the 13 difficu.1. ties that we have with this Part 55 rule change.
];
14 I think we ought to focus our comments and focus our' k
15 corrective actions in two parallel paths, one focusing on the 16 short-term improvements, things we can do in the very near term 17 to alleviate the stress and the problems on the operator.
And 18 secondly to focus on the long-term improvements we may have to 19 go through that may require re-interpretation of the rule, 20 re-interpretation of the Commission guidance or perhaps even a 21 re-structuring of the rule itself.
22 We will through NUMARC, if necessary, establish a 23 working group to work with the NRC directly on this issue, 11 24 that's the appropriate method, a nil theit worl;lny group wou ld 25 build upon the work that was originally done by the operator 1
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re-qualification working group that Bill Jessup alluded to, 2
some of the work that they had done for about a year and a 3
half.
I think overall we believe that we've made tremendous 4
progress in training, tremendous progress over the last several 5
years in improving operator knowledgn.
And that's been through 6
cooperative industry and NRC efforts.
And we hope that the 7
. continuing dialogue that we have and continuing interaction i
8 will bring about improvements to both the operator training 9
program and the operator re-qualification program.
10 I want to thank all the participants for coming.
11 know a lot of you came from long distances including clear from 12 the West Coast and we appreciate your involvement and your 13 comments.
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14 MR. TAYLOR: Underlining what Joe Colvin said about 15 improving this process, I think we will try to make changes 16 that we can accomplish and still be under the current rule.
17 And then we may well look beyond the potential for rule change.
10 So I think we have to treat it in those two segments and I 19 think we will welcome a NUMARC working group to continue this 20 and I'd like to say that the very r'eason this meeting was set 21 up on relatively short notice was because of the concern of the 12 effect on nuclear plant safety that we felt.
So this meeting 23 is the first step.
I appreciate, and I think you should i
24 appreciate it, is that it's b= n a gomt exchanga.
I curtai.n1y 25 thank each of you for coming and I thank your utilities and Heritage Reporting Company (202) 628-4888 I
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NUMARC for doing this.
We'll probably have other meetings.
2 Thanks~very much.
3
[Whereupon, at 11:42 a.m.,
the public hearing was 4
adjourned.]
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1 CERTIFICATE 2
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3 This is to certify that the attached proceedings before the N.__/
4 United States Nuclear Regulatory Commission in the matter of:
5 Name: DUBLIC MEETING WITH INDUSTRY REPRESENTATIVES TO DISCUSS LICENSE RENEWAL REQUIREMENTS FOR OPERATORS 6
AND SENIOR OPERATORS 7
Docket Number:
8 Place: Bethesda, Maryland 9
Date:
September 10, 1987 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the Unitad States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a
):L 15 true and accurate record of the foregoing proceedings.
16
/S/
l Wit dhi GV/
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17 (Signature typed):
Peggy Daly 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25
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