ML20235M504
| ML20235M504 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 09/22/1987 |
| From: | Colvin J NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| To: | Starostecki R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20235M506 | List: |
| References | |
| NUDOCS 8710060214 | |
| Download: ML20235M504 (7) | |
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i NUCLEAR MANAGEMENT AND RESOURCES COUNCIL i
1726 M Street, NW.,
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'j) j Washington. DC. 20036 t
j (202) 872,1280
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September 22, 1987 l-a i
I Mr. Richard W. Starostecki j
c Associate Director for Inspection
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anfs Uechnical Assessment,
v office of Nuclear Reactor Regulati'on i
U.S. Nuclear Regulat'ory Commission Washington, DC 20555 4
Dear Mr. Starostecki:
h Thank you for providing the opportunity at the public
.l meeting September 10th for industry representatives involved g
j directly in operations and training.to comment on their L
individual experiences and concerns.with the operator'requalifi-cation program and implementation of 10CFX55.
It seemed evident at the meeting that'the'NRC recognizes and shares some of our concerns regarding the impact on the operators, on the training programs, on plant opepations, and the combined effects on plant 3
safety.
4 We are pleased that the NRC staff is taking scra immediate.
steps to improve the situation and we,look forward to'further interface with yor ;a:nd your staff on how to 11ilprove the operator requalifiestion process.
We are forming - 0 NUMARC Working Group i
i to continue to work >with NRC on this and related issues, t
e Enclosed for your,information is an edited compilation of
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written comments received by NUMARC from utilities that did not <
have the opportunity to speak at the September loth meeting.
We have attempted to group the comments into appropriate categories but we recognize that there is some overlap.
These comments
'9 reflect opinions of individual utilitied.
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Mr. Starostecki September 22,'1987~
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. Enclosed also for your information are' written comments from the Prairie Island Nuclear Plant operators who asked that they be provided in their entirety.
If.there.are any questions on this information please call Tom Tipton, Director of the' Operations, Management and Support Division, or me. ' We look-forward.to working with.you and your staff on this very important-issue.
' Sincerely, n Q.).s.<> L oe F.
Colvin xecutive Vice President 4
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& Chief Operating Officer JFC:bjr Enclosure Jaknes Taylor cc:
Jack Roe c.
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Compilation of Utility Comments on Operator Requalification and Implementation of 10CFR 55 Eight utility representatives provided verbal comments on Operator Requalification at the NRC Public meeting September 10, 1987.
A number of other utility representatives did not speak or were not present but provided written comments to NUMARC for use in supporting any utility /NRC initiatives to address the operator requalification issue. The following is an edited compilation of written comments received by NUMARC, but which were not presented at the pu'c :.ic meeting.
Attempts were made to group the comments into the following categories; impact on operations, impact on
- training, impact on operators, impact on
- safety, and recommendations; however, a comment listed under one category may apply to others as well.
Imoact on Onerations and Trainina The random selection of examinees with only ten working days notice results in significant disruption in the training and operation schedules.
The normal operating crews' rotation in the plant is disrupted when operators are removed from shift for placement in an examination preparatory course.
If the operators are not removed from the shift, they may be distracted from their normal shift l
duties.
As a result of the requalification exam process many utili'ies have had to significantly alter their requalificatien program from concentrating on material necessary to safely operate the plant to material necessary to pass an NRC requalification examination.
To enable operators to pass the NRC administered exams some utilities are conducting extra requalification programs in addition to their normal requalification training.
This may require substantial additional overtime for operations shift coverage and in most cases disrupts the normal requalification I
program by diversion of training resources for the additional I
training.
In some cases all normal requalification training stops to prepare the selected individuals for the requalification examination.
In at least one case, the NRC notification of the requalification examination two weeks in advance was " totally unexpected and resulted in plant restart schedule modification, cancelled vacations, and modifications to training schedules."
Examination Content Two weeks is not enough time to prepare operators for the type of written examination and operating test that the NRC is administering.
The NRC is examining at the same level as in the initial licensing examination.
Operators taking the initial
examination have just completed an extensive, intensive training l
program designed to prepare them to pass this rigorous l
examination.
Requalification candidates have been doing what they received their license for---operating the plant.
The NRC examiners in many cases make no distinction between the two examinations.
The requalification exam quality, scope, and depth frequently are not consistent with the standards utilities have incorporated in their requalification training programs.
For example, the depth of detail of readily available information expected to be retained by licensed operators detracts from the task-related training being provided.
Unless NRC examiners clearly demonstrate that their requalification exams reflect the performance-based objectives to which utilities are training, then the erratic unpredictability of their exams will dilute the requalification training as the utilities try to " cover all bases."
This will ultimately result in teaching to pass the exam, rather than reinforcing and enhancing
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l licensed operator skills.
The concern then becomes one of operational safety because of this shift in training emphasis.
This concern is increased by the inevitable stress and uncertainty placed on the individual operator by the present NRC examination methodology.
Another concern is that some of the examiners lack the knowledge and skills to either write or administer the written and simulator examinations.
In most cases, it is not their fault; they simply do not have the experience to know what to look for.
The NRC needs to redefine those operating skills which are necessary to safely operate a nuclear plant and then put its examiners through I
a program to show them how to evaluate these skills during simulator performance.
Regarding the content of the operating tests, there is concern that many NRC examiners are tending to set up unrealistic and very low probability simulator scenarios.
A test on the simulator is probably the best way to evaluate on operating team's ability to safely operate a plant and cope with plant casualties and failures if done appropriately.
Most of the utilities train their normally assigned shift crews together as a team on the simulator.
But there are complaints that the NRC examiners are breaking up these teams for the examination and that the advantages the control room crews receive from team training and work is lost with the random selection of operators.
Imnact on Ooerators
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The impact on people is a significant issue.
The operators have expressed a feeling of being placed in double jeopardy; having to pass both the utility's requalification examination and a virtually l
unannounced NRC examination. The short two weeks notice and random i
selection of personnel to take a requalification examination with questions and content that frequently have little relationship to the skills and knowledge needed to safely operate the plant have j
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caused operator morale to suffer tremendously.
. Vacation plans are disrupted.
Operators must learn to work with a different team on the simulator in a short period of time under pre-i examination stress.
Operators believe that they.must " cram" for the NRC examination that is. heavy on memorization of material that is not necessary'to be retained.
Operators feel that they are unfairly exposed annually to an NRC administered exam even though other professionals responsible for the health and safety of the public are not routinely tested.
There are numerous examples of long time experienced and valuable licensed senior operators dropping their licenses rather than continue.
One such Shift ~ Supervisor, an individual. who has operated a plant since initial critically in 1973, recently a
commented that he used to love his job and look forward to coming
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I to work.
However, the tremendous stress: due to.the barrage'of NRC requalification examinations is making life so miserable that he is now looking forward to retirement.
Some excellent and experienced operators have been forced to give up'their license simply because they har been unable to memorize an adequate' amount of material necessary.~ pass an NRC requalification examination.
Imoact on Safety Many operators are running from the unknown - an NRC examination.
Unfortunately, a wealth of plant experience is being jeopardized.
Obviously, loss of experienced operators can adversely affect the safety of a plant.
Placing a major emphasis on academic-oriented training and unrealistic cimulator scenarios does not improve the safety of a plant.
1 Summary The industry believes that NRC involvement in the requalification process is necessary, to assure themselves and the Congress that training is adequate; however, the present NRC approach'is seen as detrimental to the industry and NRC's mutual objectives of.
plant safety and reliability.
There is a discernible lack of consensus between the utilities and-the NRC as to how this is to be achieved.
The NRC should reassess its position on the operator requalification examination process.
People, including' operators,
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function best when they know what is expected of them.
Action
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should be taken to establish' meaningful,-task-based examinations to enable operators to improve and maintain their. proficiency.
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Individual Utility Recommendations o
The utilities should be allowed to schedule licensees for requalification examinations.
The utilities should be allowed to schedule licensees for examination once during the. renewal period after the facility l
requalification cycle is completed.
This will allow licensees to be examined with minimal disruption to shift operating and I
training schedules.
Utility scheduling will permit the NRC to i
meet its regulatory responsibilities and allay morale problems among the operators and training departments which random selection has caused.
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The NRC examination should be developed exclusively from validated objectives from the utility accredited program, or i
reached by mutual agreement between the NRC and the utility.
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l If available, questions from a validated question bank should be used, q
In this manner the utility training departments will be able k
to adequately address the NRC's training
- concerns, and examinations will reflect only those knowledges and skills an l
operator must possess to safely operate the facility upon which 1
l the license is held.
If the NRC determines that qualification j
standards are to be raised, or if a current concern needs to i
be incorporated into operator training, the specifics can be promptly communicated to the utility.
A common operator suggestion is to change the requalification o
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examination process to a utility /NRC exam.
The NRC would be
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involved in a parallel effort to the utility's effort, which 1
would include joint examination development, dual
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administration, and parallel grading.
This would result in i
uniform exams, and would relieve operators of double jeopardy.
l The qualifications of the examiner should be equal to or greater o
than the examinee.
i The NRC should employ examiners who have extensive operating experience at electric-generating nuclear plants.
These personnel should be assigned to administer examinations only to those plants of a ' design similar to that upon which they were previously licensed.
Operators will then be confident that they are receiving a fair and adequate examination which results in an accurate assessment of their professional competence.
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o Rather than the NRC developing requalification examinations independently, they could have review, approval and grading authority of selected utility developed examinations.
They currently do this with the contracted examiners.
This approach would insure the relevancy of the examination to the specific site and we.Ild support performance-based questions.
It would still provide the NRC with assurances that the training programs are effective and that the operators are maintaining a
satisfactory level of knowledge.
This will also allow the NRC to devote more time for the development of realistic simulator operating tests.
o Copies of technical specifications should be provided to operators throughout the examination process.
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