ML20245A494

Forwards Olb Manual Chapters,Effective to Date

ML20245A494
Person / Time
Issue date:	04/12/1989
From:	Perkins K Office of Nuclear Reactor Regulation
To:	Gallo R, Peebles T, Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8904250236
Download: ML20245A494 (87)

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' r, WASHINGTON, D. C. 20555 APR 12 1999 MEMORANDUM FOR: Those on Attached List FROM:

Kenneth E. Perkins, Chief Operator Licensing Branch Division of Licensee Performance and Quality Evaluation, NRR

SUBJECT:

0LB MANUAL CHAPTERS Enclosed find a copy of all the OLB Manual Chapters. They are the effective chapters to date. As additional chapters are produced or revisions occur, they will be forwarded to you. Suggested revisions or questions regarding these chapters should be directed to Mr. Ralph Cooley on FTS 492-1054.

\\d h Kenneth E. Perkins, Jr., Chief Operator Licensing Branch Division of Licensee Performance and Quality Evaluation, NRR

Enclosures:

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a MANUAL CHAPTE& LIST CHAPTER TITLE DATE OLB-MC-110 Revisions to Examiner Standards 03/10/89 and Manual Chapters OLB-MC-160 Interactions with Regions 03/09/89 OLB-MC-170 Examiner Qualification and Refresher 03/15/89 Training OLB-MC-220 Procedure for Processing Initial 03/17/89 License Application Pursuant to 10 CFR Part 55 - Requests for Administrative Review and Hearings OLB-MC-225 Procedures for Processing Renewal 01/09/89 License Applications Pursuant to 10 CFR Part 55 - Requests for Administrative Reviews and Hearings OLB-MC-300 Regional Operator Licensing Program 03/10/89 Assessment OLB-MC-310 Annual Office Review Visit Procedure 01/19/89 l OLB-MC-320 OLB Program Reivew of Operator 01/19/89 ) Licensing Functions at Licensee Facilities 1 l \\ l l 1

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gg APR 12 M g,,- ' List.of addressees for memo on OLB Manual Chapters ' dated Robert m. Gallo, Chief Operations Branch _~ l Division'of> Reactor Safety, RI -Thomas Peebles, Chief Operations Branch Division of Reactor Safety, RII Geoffrey C. Wright,' Chief Operations-Branch Division of Reactor Safety,'RIII Johns P. Jaudon, Deputy. Director Division of-Reactor Safety, RIV Dennis F. Kirsch, Chief Reactor Safety Branch Div.ision of Reactor Safety and Projects, RV Pete Eselgroth,' Chief Operations Branch Division of Reactor Projects, RI John F. Munro, Chief 10perator Licensing Section A Operations Branch Thomas Burdick, Chief Operator.' Licensing Section Operations Branch Division of Reactor Safety and Projects, RIII John Pellet, Chief Operator Licensing Section Reactor Safety Branch

Division of Reactor Safety and Projects, RIV John 0. Elin, Chief Operations Section

' Reactor Safety. Branch Division of Reactor Safety and Projects, RV

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_/ APR 12 1999 L HEMCRANDUM FOR: Those on Attached List FROM: 'Kenneth E. Perkins, Chief Operator Licensing Branch Division of Licensee Performance and Quality Evaluation, NRR

SUBJECT:

OLB NANUAL CHAPTERS Enclosed find a copy of all the OLB Manual Chapters. They are the effective q chapters to date. As additional chapters are produced or revisions occur, they will be forwarded to you. Suggested revisions or questions regarding these chapters should be directed to Mr. Ralph Cooley on FTS 492-1054. t \\L A Kenneth E. Perkins, Jr., Chief Operator Licensing Branch Division of Licensee Performance and Quality Evaluation, NRR

Enclosures:

As stated CONTACT: I Ronald B. Eaton, NRR 49-21056

? . D: MANUAL CHAPTER LIST CHAPTER TITLE DATE OLB-MC-110 Revisions to Examiner Standards 03/10/89 and Manual Chapters

OLB-MC-160 Interactions with Regions 03/09/89 OLB-MC-170 Examiner Qualification-and Refresher

_03/15/89~ Training OLB-MC-220' ' Procedure for Processing Initial -03/17/89 License Application Pursuant to l 10 CFR Part 55 - Requests for Administrative Review and Hearings OLB-MC-225 Procedures for Processing. Renewal 01/09/89 License Applications Pursuant to 10.CFR Part 55 - Requests for Administrative Reviews and Hearings OLB-MC-300 Regional Operator Licensing Program 03/10/89 Assessment OLB-MC-310 Annual Office Review Visit Procedure 01/19/89 OLB-MC-320 OLB Program Reivew of Operator 01/19/89 Licensing Functions at Licensee Facilities 9 1 I

[- - g OLB-MC-110' j 03/10/89 J 1 REVISIONS TO EXAMINER STANDARDS AND MANUAL CHAPTERS A. PURPOSE To outline the administrative procedures for revising the Examiner Standards and Manual Chapters, i d B. BACKGROUNO ] 1. As NRR's designee, OLB is responsible for defining the direction of the Operator Licensing Program by developing, distributing and-managing changes to the Examiner Stan,dards and the Manual Chapters. The delegation and assignment memoranda and the implementation procedures also require that changes to these procedures be managed by OLB. 2. OLB reviews correspondence from NR8 and the regions that may affect the operator' licensing program, and evaluates any identified items for inclusion as a revision to the appropriate standard. Potential generir items submitted by the regions are handled in the same manner. C. IMPLEMENTATION 1. Revisions to the Examiner Standards shall be made on a continuing basis,by the following revision procedure: a. A suggestion for revision, from any source, is forwarded to OLB, Regional Support and Oversite Section (R50), identifying the needed revision and the reason for the revision, b. RSO evaluates and compiles the suggested revision onto the Standard Revision Request, Attachment 1, forwards the revision with recommended action to the OLB Branch Chief. RSO will also determine whether a change to the Manual Chapters is necessary as a result of this proposed revision. c. The OLB Branch Chief will review the suggested revision and recommended action, then assign responsibility for completion of action and write-up of the suggested revision to RSO or EDS, d. Upon completion of the write-up, RSO sends the revision to the Electronic Text Processing Branch (ETPB) for typing and to update the ETPB data base on the Standards. The instructions to ETPB should request that the Operator Licensing Examiner Standards, NUREG-1021, be maintained in a single file under " Examiner Standards," and that the revision date be typed in l the upper left hand corner of all pages that change. The revision date should be chosen about two months into the future so that the distribution of the revision will take place near the selected date. 1

.,,y ',c J OLB-MC-110 03/10/89 .,e e. When all of the changes have been typed, proofed, and finalized through ETPB, an Examiner Standards Revision Form (See Attachment 2) shall be prepared identifying the consecutive . revision number, the date of the revision, the title of the [. .NUREG, and the filing instructions. The ES pages shall be L marked with a single vertical black line on the right page margin '(1/2 inch from the right page edge) opposite any line that changes. A 1/8-inch vertical line shall'be placed on the -ight margin opposite any area where one or more. lines have been deleted. f. A memo is prepared for the Director, Divicion of Licensee Performance and Quality Evaluation (DLPQ), and forwarded to the Regional Office counterpart along with a copy of the lined revisions, the revision notice and the summary of revisions. The summary of revisions should be a brief synopsis of each significant revision including a brief statement of the reason for the revision, g. Complete NRC Forms 379, 335, and 426 and forward the change to the Policy & Publications Management Branch / Division of Publications Services, Office of Administration for publication _and distribution. 2. Revisions to the Manual Chapters shall be made on a continuing basis by the following revision procedures, a. A Standard Revision Request Attachment 1, from any source, is forwarded to OLB, RSO, identifying the needed revision and the reason for the revision. b. RSO evaluates and compiles the suggested revision onto, and forwards the revision with recommended action to the OLB Branch Chief. c. The OLB Branch Chief will review the suggested revision and recommended action, and either approve / disapprove the recommended action or provide direction to revise the action. The suggested revision will then be returned to RSO for completion of action. d. Upon completion of write-up, RSO sends the revision to ETPB for typing and to update the ETPB data base on the Standards. The instructions to ETPB should request that the Manual Chapters, be maintained in a single file under " Manual Chapters," and that the revision date be typed in the upper right hand corner of all pages that change. The revision date should be chosen about two months into the future so that the distribution of the revision will take place near the selected date. 2

LI op .) ] OLB-MC-110 ( 03/10/89 l e. When all of the changes have been typed, proofed, and finalized through ETPB, an OLB Manual Chapters Revision Form (Attachment 3) shall be prepared identifying the consecutive. revision number, the date of the' revision, and the filing instructions. The OLB Manual Chapters pages shall be marked with a single vertical j black line on the right page margin (1/2 inch from the right j page edge) opposite any line that changes. A 1/8-inch vertical i line shall be placed on the right margin opposite any area where one or more' lines have been deleted. 9 f. A memo is prepared for the Chief, OLB and forwarded to the f regional office counterpart along with a copy of the lined revisions, the revision notice and the summary of revisions. The summary of revisions should be a brief-synopsis of each l significant revision including a brief statement of the reason for the reyision. 3. RSO will track all prospective changes to the Examiner Standards and OLB' Manual Chapters using the Standards Change Log, Attachment 4. 4. A separate log shall be maintained for the Examiner Standards and l for the OLB Manual Chapters. The RSO Section Chief or his designee (s) shall maintain these logs. I i i I l 1 i s. 3 l -l

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• OLB-MC-110 03/10/89 ATTACHMENT 1 STANDARD REVISION REQUEST l

1 STANDAR0/ MANUAL CHAPTER NO. i Source of suggested revision Recommendation RSO Branch Chief Comments l Assigned for action to: Due Date: j Branch Chief 1 Signature /Date Date Completed: Closed incomplete: Action taken: Approval Branch Chief, Signature /Date 4 I-l l

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L OLB-MC-110 l 03/10/89 i -l 1 j L l l ATTACHMENT 2 ) EXAMINER STANDARDS REVISION FORM l .NUREG NO. 1021 REVISION NO. l DATE TITLE: Operator Licensing Examiner Standards i FILING INSTRUCTIONS PAGES TO BE REMOVED NEW PAGES TO BE INSERTED ES NO. PAGE NO. DATE ES NO. PAGE NO. DATE EXAMPLE ES 110 PAGE 3 & 4 N/A ES.110 Page 3 & 4 1/1/87 After pages are filed, file this revision notice along with the Summary of Revisions in front of the last revision notice. Revisior.s' filed by Date l b 5 I

I ,s;, I W OLB-MC-110 03/10/89 s. F ATTACHMENT 3 OLB MANUAL CHAPTER REVISION FORM REVISION NO. DATE TITLE: OLB Manual Chapters l ~ FILING INSTRUCTIONS PAGES.TO.BE REMOVED NEW PAGES TO BE INSERTED. OLB-MC WO. PAGE NO. DATE OLB-MC NO PAGE NO. DATE-EXAMPLE OLB-MC-110- 'Page 3 & 4 N/A OLB-MC-110 Pages 3 & 4 1/1/87 l After pages are filed, file this revision notice along with the Summary of , Revisions in front of the last revision notice. Revisions filed by Date h' i 6

-_----m_--, ~h' aC c OLB-MC-110 03/10/89 I ATTACHMENT 4 l STANDARDS CHANGE LOG STANDARD DATE SOURCE ASSIGNED DATE SENT COMMENTS COMPLETED ACTION RECEIVED TO OUT FOR RETURNED NUMBER COMMENT 12345 ~ l f P \\ 7 l i

j i OLB-MC-160 l 03/09/89 j l l J INTERACTIONS WITH REGIONS

A.

PURPOSE' 1. The purpose of this chapter to establish a system for processing the interactions between the regions and headquarters such that-the following criteria are met: a. New policies or policy changes which affect the procedures and l practices for examining and licensing of applicants for NRC i operator licenses, pursuant to Part.55 of Title 10 of the Code of Federal' Regulations, are consistently implemented by all regions. b. Policy interpretations, applicable to the operator licensing process, are only made by headquarters and' consistently implemented by all regions. 2. To identify the recurring information the regions should forward to OLB and the method for OLB to request non-routine information-from the regions. 3. To provide guidance for the coordination of information that the regions are required to send to OLB. B. BACKGROUND 1. It is the responsibility of OLB to provide policy and guidance to the regions for examining and licensing of applicants for NRC opera-tor licenses, commensurate with 10 CFR 55. Consequently, OLB will i ensure that the regions consistently implement the operator licensing process in accordance with established procedures and regulations. These procedures are outlined in Attachment 2, Procedures for Regional Implementation of Operator Licensing Functions. 2. Frequent interactions exist between the regions and headquarters dealing with the interpretation of policy, directives associated with I' applicant elibility, or other aspects of the operator licensing pro-cess. These communications deal with topics applicable to both power reactors and test facilities. 3. The system used to document these interactions and consistently apply associated actions must be formalized. This system will include an i efficient means of distribution and filing. As a result, the loss ? of, or duplication of, information will be prevented. Furthermore, this system will facilitiate the consistent application of policy by headquarters and the regions. 1

~,. OLB-MC-160 03/09/89 i 4. OLB is frequently requested to supply information on the Operator Licensing. function'and the training and education of nuclear power plant personnel. To support these requests, data compiled on a regional basis will be synthesized into data sets by OLB for reporting of national data. 5. OLB must receive timely and accurate information from the regions to document the performance of the Operator Licensing Process. This l data provides feedback to OLB that is necessary for the consistent management of its assigned program responsibilities and effectively interface with other government agencies and facility licensees. C. IMPLEMENTATION 1. Report on Interaction a. All interactions with regional offices or contractor examinor staff that require an interpretation _of policy, practices, regu-lations, NUREGs, or other applicable directive, shall be documented on Attachment 1, Report on Interaction. Headquarters personnel will not act on informal requests for interactions, such as tele-phone. requests for policy. interpretations. However, informal communications with headquarters are appropriate to verify that an intended interaction request is necessary, or to solicit assistance in developing a suggested resolution. After the sug-gested resolution is worked out and has the concurrence of the appropriate regional Branch Chief, a completed work copy of i should be forwarded to OLB. It may be electron-ically mailed (using " cross-talk" or equivalent) to OLB personnel facilitating this interaction. I b. Headquarters personnel will work with regional staff, as necessary, to facilitate final resolutions. In any case, headquarters is responsible for documenting the final resolution for all inter-actions.on the master file copy, and forwarding copies of this master to all regional operations sections. The OLB Branch Chief must concur with the final resolution, distribution, and follow-up action, as required. c. Final resolutions that require follow-up action, such as a revision to the Examiner Standards, will be initiated and tracked by appropriate headquarters personnel, delegated by the Section Chief, Regional Support and Oversight Section. I d. Any interaction that requires interpretation of a regulation will be sent to the Office of General Counsel (OGC) for concur-rence with the suggested resolution. The final resolution of these interactions will then be initiated by the responsible i headquarters personnel, commensurate with the OGC recommendation. c 2

c ..c OLB-MC-160 03/09/89 e. The OLB Branch secretary will maintain a master file of all completed interaction forms (Attachment 1). They wil be filed by subject matter directly related to 10 CFR 55, Exam.'er Standards chapter ES-XXX, or other directive not cover-by the Examiner Standards that may affect the examining proces..All regions will have access to this file, via communication with' the OLB Branch secretary. f. To ensure that headquarters policy is implemented consistently among all-regions, the OLB Branch secretary will provide all regional operator licensing sections with file copies of inter-action reports (Attachment 1), which have received final resolu-tion. Furthermore, the OLB Branch secretary will maintain a record of all interaction reports that have not received final resolution. Interactions that have been sent to OGC for concur-rence, will be so indicated. The section chief, Regional Support and Oversight Section, will periodically review this record to ensure that these interactions are finalized in a timely manner, and that any associated follow-up action is initiated. g. All regional OLB Section Chiefs will ensure that their respective licensir.g assistants maintain file copies of all applicable com-pleted interaction forms (Attachment 1). They will be filed by subject matter directly related to 10 CFR 55, Examiner Standards chapter (ES- ), r other directive not covered by the Examiner Standards that may affect the examining process. h. To ensure that OLB policy is consistently implemented, each regional file will be readily available to all licensing person-Qel attached to that region. It is each regions responsibility to keep their' respective file current with the master file aat headquarters. i. Contract personnel will process their interaction concerns via 'the regional chief examiner that they are working with, if appropriate, otherwise directly to headquarters. j. Individuals initiating interaction-requests will check their respective section's files to prevent duplication, before forward-ing the request to headquarters for final resolution. The app-repriate regional Branch Chief (or above) must concur with any interaction request before it is forwarded to OLB headquarters for processing. All requests will be sent to Section Chief, Regional Support and Oversight. 2. Coordination of Information a. The OLB Licensing Assistant should be sent all requested information from the Operator Licensing Tracking System (OLTS) whenever possible. 3

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'8 e f.- OLB-MC-160 03/09/89 \\ b. OLTS is provided to document most of the statistical data f required for tracking the operator licensing process.. Regional 1 licensing assistants should use NRC Forms 157, 396, and-398 as sources for OLTS information. Consequently, :ach Regional Office will ensure that their licensing assistants are verifying and 1 entering this data on OLTS as soon as possible. Regional licensing assistants should contact the Licensing Assistant at l headquarters for specific instructions on OLTS utilization. c. A copy of Attachment 2 of ES-201, Power Plant Examination 3 Results in Summary, will be provided to the Licensing Assistant

l at headquarters, upon completion of grading and determination l

of licensing actions. d. The regional contractor needs should be identified on the WYLBUR computer system. The assigned regional Chief Examiner is responsible for verifying that this data is maintained current and complete. e. Waiver requests are tracked by OLTS. However, waivers are not l granted or managed via this system. Therefore, a copy of all re'gional correspondence to individual applicants, or licensees in general, concerning granted or denied waivers pursuant to ES-111, NUREG 1021, shall be sent to headquarters, Regional' Support and Oversight Section. f. Appeals of license denials or application denials are processed in accordance with ES-112, NUREG 1021. g. Each regional office shall ensure that data to be entered into OCTS is verified and that data entry into 0LTS is en a timely, as received basis (normally one work week). D. DOCUMENTATION 1. Report on Interaction a. All interactions forms (Atta oment 1) will be completely and legibly filled out by the pe, son initiating the request. Areas not applicable should be so marked. b. Individuals initiating the interaction request, as well as headquarters personnel cha ged with processing the request, will verify that the following ninimum items are included on the Report on Interaction request form (Attachment 1): The issue of concern is adequately captured. 1 The specific action requested is offered. 4

.a .o. OLB-MC-160 03/09/89 I The suggested resolution is offered. The subject matter filing area is filled in. The appropriate regional management concurrence. c. Headquarters, Regional Support and Oversight personnel, will fill out the final resolution, distribution, and follow-up j action, as required, after concurrence by the OLB Branch Chief. 2. Coordination of Information a. The following list is a summary of the recurring records and documents that should be submitted to OLB: Examination Results Summary Sheet, ES-201-2 Schedule of contract examiner requirements (via WYLBUR) Examination reports Waiver action requests (telephone requests are acceptable) b. Appeals are sent directly to the Director, Division of Licensee Performance and Quality Evaluation (DLPQ), pursuant ES-112, NUREG 1021. W 3 e b 4 5

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9. B ACKGROUND 10 SPECIFICJPROPOSED ACTION REQUIRED i

11. RECOMMENDED RESOLUTION

12. FINAL RESOLUTION 13 FOLLOW UP ACTION REQUIR ED /Cheen woroonsre so,i

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OLB-MC-170 03/15/89 EXAMINER QUALIFICATION AND REFRESHER TRAINING J A. PURPOSE To provide the requirements and guidelines for initial qualification and certification of licensing examiners and establish continuing training through formal classroom, observation and on-the-job training. 8. OBJECTIVES To provide a standardized technique for determining and documenting that a license examiner trainee (LET) has met the minimum experience and training requirements to certify as a licensing examiner. To ensure that LETs meet the minimum knowledge and ability requirements to assess reactor operator and senior reactor operator competence pursuant to 10 CFR 55. To set forth a program of continuing training to maintain certified examiners current in the examination process. To establish an examiner evaluation process that documents performance and provides a form of feedback to reenforce or improve upon that performance. C. DEFINITIONS i Cross Certification: Once certified on one NSSS vendor, the process of becoming certified on one or more additional NSSS vendors. i Equivalency Examination: An examination administered through the Technical Training Center or its contractors in lieu of specific course attendance. Observation Training: An on-the-job training assignment at a facility licensee. Required Training: The combination of experience, formal and on-the-job j training necessary to acquire the minimum level of knowledge and skill to administer licensing examinations pursuant to 10 CFR 55. Supplemental Training: Courses and planned activities that are not required for every examiner certification but may be necessary for some individuals to perform examinations on specific vendor types. 1 l

4 c' OLB-MC-170 4 03/15/89 Refresher Training: The minimum required continuing training to maintain examiner certification. Training and Qualification Journal: The document that describes a combination of formal classroom and on-the-job training that meets the minimum requirements to certify as an examiner and that identifies some desirable supplemental trai ni n'g. D. POLICY To ensure that all' personnel assigned as examiners have sufficient knowledge of plant operations and examination techniques, LETs will certify by completing the minimum requirements set forth in the Training and Qualification Journal. This standardized process will help assure a consistent approach to training examiners across all regions. Each examiner must complete the required training or verify through successful completion of a written equivalency examination, th'at he/she has an acceptable level cf knowledge and skills in those areas identified in the Training and Qualification Journal. All Section Chiefs will certify as an examiner in accordance with the requirements set forth in the Training and Qualification Journal. Equivalent training and experience will be considered by the Chief, OLB, in reviewing the examiner certification training programs submitted for approval for all Sect. ion Chiefs. 1 Training requirements for all examiners will be governed by this Manual Chapter and the Training and Qualification Journal. These documents encompass l regulatory, admini'strative, technical and examination practices pertinent to evaluating the performance of applicants pursuant to 10 CFR 55. E. RESPONSIBILITIES AND AUTHORITIES Director, DLPQ, sets and approves policy governing examiner qualification and training. Director, Technical Training Center, Implement and administers formal classroom and simulator training. Branch Chief, OLB, concurs with all Section Chief training programs, applications for waivers of training requirements and extensions of the required 24 month limit on completing examiner certification. Regional Administrator implements program responsibilities delegated to the region with the resources budgeted for the region. Regional Branch Chief, manages the requirements of this chapter in the region. i ~ 5 f 2 I s 1

OLB-MC-170 03/15/89 Regional Section Chief, tailors the LET training to the specific needs of the individual, supervises their progress and recommends additional training or I certification as necessary. F. TRAINING AND CERTIFICATION Only those examiners that have successfully completed the requirements for examiner qualification and are certified, have the authority to make independent evaluation of license applicant performance pursuant to 10 CFR 55. Examiners must be thoroughly knowledgeable in the technical areas of nuclear power plant operation and in the techniques of developing and administering examinations to evaluate the competency of an applicant's performance. Preparation for certification as a licensing examiner involves the successful completion of the requirements of the Qualification and Training Journal which includes being evaluated by a certified examiner during the administration of a written examination and operating test at a nuclear power plant. Due to the constraints of scheduling examinations the various parts of a complete examina-tion need not be completed as the same facility to certify. However, all sub parts of the process must be successfully completed under the observation of a certified examiner. The certifying examiner is responsible for the evaluation of the operator license candidate involved in the certification process and, if necessary, will insert himself/herself into the process to ensure that an adequate bases for a licensing decision exists in accordance with the requirements of the Examiner Standards, NUREG 1021. Individuals who fall to successfully complete the training and certification process within the allotted time, could be removed from consideration as a licensing examiner. However, each case will,be considered on an individual basis by regional or headquarters management as appropriate. Certified examiners are exempt from the requirements of this chapter for their current certification. However, certified examiners desiring to cross certify must meet the provision of paragraph I of this chapter. G. TRAINING AND QUALIFICATION J0URNAL The training and Qualification Journal has been established to guide and document, in a consistent format, the certification of all LETs. The Chief, OLB, is responsible for maintaining and updating the Journal. The Journal consists of nine guides. Each guide is briefly described below along with any testing or waiver options. Approval of all training waivers and the basis for granting the waiver must by documented by the approving authority as part of the LETs training record. Courses which are required for initial certification are identified as mandatory below. Courses which are required for cross certification are identified in Section I. 3 7

e.. OLB-MC-170, L 03/15/89 1, INITIAL ORIENTATION-This guide serves to' introduce LETs to.the basic documents and procedures.that are used by'the NRC and its contract examiners in the conduct of normal busi-ness with facility licensees. All or a portion of this guide may be waived as appropriate to the background and use of the examiner in accordance with the guidance given in Sections E and G above. 2. EXAMINER STANDARDS'AND ASSOCIATED OLB DOCUMENTS This training is. intended to be an in depth indoctrination of LETs to.the. Standards, Handbooks, Catalogs, NUREGs and other. documents that govern the examination process. All or a portion of this guide may be waived for certified or previously certified examiners in accordance with the guidance given in Sections.E and G l

above, 1

3. TECHNOLOGY TRAINING PROGRAM This training is coordinated through and conducted by the-Technical Training Center (TTC) or its contractors. Each of the available courses is listed below with a brief narrative of the course content. NPP Fundamental: inis is a self-study, self-examination course designed to cover' basic reactor theory, electrical theory and control system instru-mentation. M)st LETs should posses the basic knowledge offered by this course; therefore, it is at the discretion of the cognizant supervisor. It is highly recommended that each LET review the learning objectives and self-administered exam of this course to determine if any benefit can be derived'from~ studying the lessons. TTC Full Course Series: This series consists of three weeks of systems training followed by two weeks of advanced training and one week of simulator training on plant operations and system interrelationships. Satisfactory completion of each phase of this training must be demon-strated achieving a minimum course grade of 70%. In lieu of course attendance, a minimum 70% score on an equivalency examination created and administered by TTC is acceptable. The decision to use an equivalency examination rests with the certifying official. This requirement may be waived in accordance with the guidance in Sections E and G above. LETs who have previously completed SRO training are not re' quired to take this training nor is a waiver needed. Integrated Facility Operations: This course consists of one week of ) simulator training on integrated plant operations. Attendance at this course is optional for certification but highly recommended early in an examiners career. Emergency Procedures Guidelines: This is a one week classroom / simulator course on the purpose, function and use of E0Ps. Attendance at this course is mandatory unless previously licensed as an operator or senior operator at a nuclear power plant of the same vendor type. 4

OLB-MC-170 03/15/89 Radiation / Contamination Protection: This course provides the fundamentals of radiation protection and contamination control. This course if optional 4. OBSERVATION TRAINING This training is intended to provide the LET an opportunity to learn firsthand the duties and responsibilities of licensed operators through direct observation as well as simulated performance at a nuclear power plant. The training shall conform to Appendix A of the Training and Qualification Journal. All LETs must participate in this observation training unless pervious experience permits a ) waiver of this training by the Chief, OLB. Satisfactory completion of this ] training is based on completion of the tasks in Appendix A and a discussion of the observation training with the LET's Section Chief or supervisor. 5. WRITTEN EXAMINATION PRACTICES This training is mandatory for all LETs and is comprised of a course that is structured to provide practice in the construction of content-valid written test items in the various formats acceptable for NRC licensing examinations. Participants must satisfactorily complete all workshop exercises of the course. There are no waivers permitted for this course. 6. SIMULATOR EXAMINATION PRACTICES This course is mandatory for all LETs and is intended to provide structured practice in the development and administration of simulator tests including the grading of candidate performance. This course combines classroom and l simulator instruction.and is conducted at the Technical Training Center (TTC). Participants must 3 successfully complete all workshop exercises. There are no waivers permitted for this course. 7. WALKTHROUGH EXAMINATION PRACTICES This course is a one week workshop conducted at TTC. It is a intended to help standardize the development, administration and grading of the walkthrough portion of the operating test administered to license operator applicants. Participants must satisfactorily complete all workshop exercises. There are no waivers permitted for this course. 8. ON-THE-JOB TRAINING This training familiarizes the trainee in the administrative documents and procedures associated with operator licensing. Topics include the operator licensing tracking system (0LTS), the licensing process, the appeal process and the examination question bank (EQB). The timing of this training is at the discretion of the LETs supervisor and is not mandatory for certification as an examiner. 9 5

, n' OLB-MC-170 03/15/89 9. CERTIFICATION EXAMINATIONS. Certification examinations are administered after the Section Chief _or supervisor verifies that all other training required by this chapter and the Training and Qualification Journal has been completed. The LET will be evaluated as satisfactory by the Section Chief, supervisor or designated alternate, in the construction of an entire written examination and operating test (simulator and walkthrough portions) to certify as an examiner. For NRC examiners this portion of the qualification process includes review and evaluation of licensee applications. Successful completion of this section is mandatory for all examiners to certify. H. SEQUENCE OF CERTIFICATION TRAINING COMPLETION If possible, the LET should participate in the training courses in the same sequence as they are presented in the Training and Qualifications Journal. i However, in all cases the following sequence will be otderved unless speci.fically waived by the Chief, OLB. Technical training series courses at TTC will precede the examination techniques courses, Integrated Facility Operation course and Emergency Operating Procedures course. Certification written examinations and operating tests must.be' accomplished last. I. 01055 CERTIFICATION To cross certify to another reactor type, (BWR to PWR or PWR to BWR), the examiner must complete. the TTC tecnnology series for the new reactor type. The option to use an equivalency test in the lieu of course (s) attendance is available. Those examiners certified on one PWR vendor that desire to cross certify on another PWR vendor type, may obtain the systems manuals from TTC and study the material on their own. However, they must pass an examination administered by TTC on the reactor vendor type for which cross certification is desired. In addition, the Emergency procedures Guidelines course must be completed. Cross certifying examiners need not repeat the observation training or any of the Techniques Practices courses unless specifically requested by their supervisor. In all cases of cross certification or the reactivation of a previously certi-fied examiner, the new short courses developed by TTC may be used instead of the traditional series at the discretion of the examiner's supervisor or the applicable contract monitor-. Additional certification examinations are not required to cross certify, J. TIME LIMITATICl FOR INITIAL CERTIFICATION The training and certification process for one vendor type will be completed within 24 consecutive months from the date of initial hire or assignment to a position that requires the employee to certify as a licensing examiner. 6 1 l

OLB-MC-170 03/15/89 K. MAINTENANCE OF EXAMINER CERTIFICATION (POWER REACTORS) To maintain certification, an examiner must attend a refresher training course at least once every two years and administer operating tests to initial or renewal applicants at least once during each calendar year. Examiners that are certified on more then one vendor type need only attend one vendor refresher course to maintain all vendor certifications. However, the examiner's supervisor should inake every attempt to alternate vendor courses for subsequent ref resher training. Any examiner who does not maintain certification shall recertify before admin-istering operating tests. Decertification for operating tests shall, at a mini-mum, consist of being observed, by a certified examiner, administering a com-plete operating test. The decertification shall be documented on NRC Form 308 and maintained in the individual's training folder. Decertification is only required on one vendor type for examiaers with previous multiple vendor certi-fications. The burden for ensuring technical competency and examiner skills for examincrs administering licensing examinations rests with the app,ropriate licensing authority management. The requirements of this chapter represent the minimum acceptable procedure to recertify. There are no requirements for maintaining examiner certification on non power reactors. L. EXAMINER EVALUATIONS At intervals of no greater than one year, each examiner shall be evaluated by his/her Section Chief (preferably) or a designated alternate during the admin-istration of licensing examinations, pursuant to 10 CFR 55. On a biennial basis, all Section Chiefs will be evaluated by headquarters OLB certified exam-iner. All examiner evaluations will be documented on NRC Form 308. Evaluator shall be or have been certified to administer power reactor examinations. Con-tractor examiners will be evaluated annually by the appropriate contract program manager, OLB technical monitor or other designated NRC examiner. All contract examiner evaluations shall be coordinated with the appropriate OLB technical monitor. Completed evaluations on a'l contract examiners will be sent to the appropriate 018 tecrnical monitor. The evaluator should discuss the results of the evaluation, including recom-mendation for improvement, with the examiner as soon after the evaluation as practical. Comments / suggestions should be kept as objective as possible and were possible linked to the Examiner Standards or other appropriate NRC directives. OLB program reviews of operator licensing functicns at licensee facilities will be in accordance with the appropriate OLB manual chapter. e 7

OLB-MC-220 03/17/89 PROCEDURE FOR PROCESSING INITIAL LICENSE APPLICATION PURSUANT TO 10 CFR PART 55 - REQUESTS FOR ADMINISTRATIVE REVIEW AND HEARINGS A. Purpose This procedure specifies policy and practice for: (1) processing informal NRC staff reviews of initial license application denials, (2) issuance of proposed and final denials of license applications, and (3) reapplication after issuance of a final denial of an application. B.

Background

Operator license applicants who fail a written examination or operating test administered pursuant to 10 CFR Part 55 are notified of their failure in writing, including the nature of-deficiencies noted. The notification letter constitutes a proposed license denial and apprises the applicant of options as specified ic Section C-below. One of these options is to seek reconsideration of the proposed denial through informal review described in Section D below. Should the proposed denial be sustained as a result of this review, the applicant, pursuant to 10 CFR 2.103(b)(2), may request a hearing. A second option available to the applicant is to request a hearing immediately pursuant to 10 CFR 2.103(b)(2). Applicants who fail a written examination or operating test may reapply pursuant to the provisions of 10 CFR 55.35, but only after their application has been finally denied. A final denial may occur in one of three ways: (1) as a result of an applicant's failure to respond to a proposed denial within the twenty days allowed by either requesting NRC staf f review of the written examination / operating test results or requesting a hearing, (2) as a result of the applicant's failure to respond to the letter sustaining the NRC staff's proposed denial after review within the twenty days allowed to reauest a hearing, or, (3) as a result of a hearing requested by the applicant. No reapplication pursuant to 10 CFR 55.35 will be accepted in the absence of a final denial from the NRC. 2. Applications Similar procedures regarding informal NRC staff review and issuance of denials apply in those cases where an application for an operator license has been denied by the NRC staff because the applicant has failed to meet the eligibility requirements set out in 10 CFR 55.31. The specifics of this process are delineated in Section E below. 1 of 13

l J OLB-MC-220 ) 03/17/89 C. Procedure for Processing Informal NRC Reviews Based Upon Written Examination and/or Operating Test Failures Upon receipt of a written notification of a proposed denial (Attachment 1), an i I applicant has 20 days from the date of the proposed denial to exercise one of the following three options: 1. Do nothing. The proposed denial then constitutes a final denial and the applicant may reapply pursuant to 10 CFR 55.35, 2. Seek informal NRC review of the proposed denial by submitting a request for reconsideration to the Director, Division of Licensee Performance and Quality Eva?uation (DLPQ), U. 5. Nuclear Regulatory Commission, Washington D. C. 20555, to review the examination / test in light of the contentions raised by the applicant. However, if a request is submitted, reapplication will not be considered pursuant to 10 CFR 55.35 until a final denial has been issued. 3. Request a hearing as provided by 10 CFR 2.103(b)(2). A hearing request is required to be submitted to the Secretary of the Commission. V. 5. Nuclear Regulatory Commission, Washington D.C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of the General Counsel, at i the same address. However, if a request is submitted, reapplication will not be considered pursuant to 10 CFR 55.35 until a final denial has been issued. Requests for informal reviews must: (1) identify the item (s) for which additional review is being requested and, (2) be accompanied by documentation supporting the item (s) placed in contention by the applicant. The package containing the su porting documentation for the review and the review request must be mailed or delivered to the Director's office (DLPQ) within 20 days of the date of the proposed denial. The review should be completed within 45 days of receipt of the package. Requests will be reviewed in accordance with the guidance in Section 0 below. I.f appropriate, a letter will be issued sustaining the proposed denial (Attachment 2). it the review results in overturning the proposed denial, a license will be issued by the appropriate licensing authority. No license will be backdated as a result of this review process. If the review sustains the proposed denial, the applicant will have the option, which must be exercised within 20 days of the date of the second letter of notification of proposed denial, of requesting a hearing pursuant to 10 CFR 2.103(b)(2). In the case of the first notification of proposed denial to the applicant, the applicant may take no action and thereby elect to forego the opportunity for informal review or hearing. Or, if informal review is selected and the proposed denial is sustained, the applicant may forego the opportunity for a hearing in the second notification. If the applicant fails to request irformal review or a hearing as appropriate, the proposed denial becomes a l l 2 of 13

l OLB-MC-220 03/17/89 ) 1 l final denial as of the date of the notification and the applicant may reapply within the appropriate time specified in 10 CFR 55.35, with the time running from the date of the notification. No reapplication pursuant to 10 CFR 55.35 will be considered if a request for informal review or a hearing is ] outstanding. D. Procedures for Informal Review of Examination / Test Results by the Director, DLPQ 1. Written Examination Review Procedure a) Upon receipt of a request for informal review by an applicant, the appropriate region will be notified and a complete copy of the review package will be forward to that region. b) The region, within five working days of receipt, will assess the applicant's contentions. If the contentions justify overturning the failure, the region will issue the appropriate license. c) If the region sustains its original decision, it will so inform the Chief, OLB, prior to expiration of the five working days, of its decision. d) When an original decison is sustained by the region, the Chief, OLB, will form a three person board which includes at least two certified examiners who were not, directly or indirecily, involved in the written examination to review the applicant's documented contentions. One of the three members of the board will be a supervisor or senior licensing examiner and act as t,he chairman. e) The board shall review; (1) the written examination and grading as applied to the applicant, (2) the reference material supplied by the facility, and (3) the contentions and supporting documentation provided by the applicant. The review shall focus on those portions of the examination contested by the applicant. The board will document its findings on each of the applicant's contentions. f) The board review will ordinarily take place in the regional office of examination origin. The board chairman will generally brief the regional program management on their preliminary findings and recommendations. The regional management may provide any additional concerns at that time. The board will consider these concerns. The results of its findings along with a recommendation to sustain or overturn the written examination failure will be submitted to the Chief, OLB. If the region continues to have concerns, they may be raised to the Chief, OLB. The Chief, OLB, will make his recommendation to the Director, DLPQ. g) The Director, DLPQ, after considering the results of the review board, will make the decision on sustaining or overturning the applicant's written examination. 3 of 13

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OLB-MC-220 03/17/89 2. .0perating Test Review Procedure g a) Upon receipt of a request for informal review by an applicant, the appropriate region will be notified and a complete copy of the review package will be forward to that region. b) The' region, withir, five working days, will assess the applicant's contentions. If the contentions justify overturning the failure, the region will issue the appropriate license. c). If the region sustains its original decision, it will so inform the Chief, OLB, prior to the expiration of the five working days of its

decision, d)

When an original' decision is sustained by the region, the Chief, OLB, will form a three person board which includes at least two certified examiners who were not, directly or indirectly, involved in.the operating test to review the applicant's documented contentions. One member of the board will be a supervisor and will act as the chairman. e) The review will consist of evaluating the examiner's comments, the examination report and the simulator scenarios as administered..The applicant'.s contentions will then be reviewed against the information and documentation provided for the review (e.g., plant system descriptions, operating procedures, logs, chart recorders, recorder traces, process . computer printouts,-video recordings, etc.) to determine if the applicant's contentions have merit. The review should ensure that specific examples of unsatisfactory performance were used to document each "U" rating and that all comments are technically and procedurally correct. The review board will document its findings on each of the applicant's contentions. Based on the documented findings of-the review, a recommendation to sustain or overturn the test failure will be made, f) The board review will ordinarily take place in the regional office of examination origin. The board chairman will generally brief the regional program management on its preliminary findings and recommendations. The regional program management may provide additional concerns at that time. The board will consider these concerns. The results of its findings along with a recommendation to sustain or overturn the operating test will be submitted to the Chief, OLB. The Chief, OLB, will then make his recommendation to the Director, DLPQ. g) The Director, OLPQ, after considering the results of the review board, will make the decision to sustain or overturn the operating test failure. E. -Procedures for Processing Application Denials due to Incompleteness and/or Failure to Meet Eligibility Requirements Upon review of NRC Form 398 and NRC Form 396 submitted by the applicant to demonstrate eligibility requirements for taking a license examination, if the Regional staff concludes that an applicant does not meet the requirements set 4 of 13

OLB-MC-220 03/17/89 out in 10 CFR 55.31, the applicant and the facility licensee will be contacted and the deficiencies noted. The applicant will be given the opportunity to supply additional information to complete the application. If, after supplying additional information, the application does not meet the eligibility require-ments, the applicant will be notified in writing that: (1) the application is being denied and (2) the deficiencies upon which the denial is based (Attachment 3). Within 20 days the applicant may exercise one of the following options: (1) Request a review of the application denial by submitting a request to the Director, Division of Licensee Performance and Quality Evaluation, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, stating therein the reasons for the request. (2) Request a hearing pursuant to 10 CFR 2.103(b)(2). A hearing request is to be submitted to the Secretary of the Commission, U. 5. Nuclear Regulatory Commission, Washington, D. C. 20555 with a copy to the Assistant General Counsel for Hearings, Office of General Counsel, at the same address. If the applicant exercises option E(1) and the application denial is sustained (Attachment 4), the applicant may requesc a hearing pursuant to 10 CFR 2.103(b)(2). F. Notes 1. Lette'rs informing an applicant of an examination failure or an application denial must be signed by the Branch Chief or above. OLPQ generated correspondence will include a distribution copy to the regional Licensing Assistant for tracking purposes. 2. The utility's authorized representative who signed the applicant's application shall be sent a copy of all correspondence generated as a result of this procedure. 3. The Chief, OLB, is responsible for keeping Regional management informed of applicant review requests. 4 All correspondence referenced in this procedure is to be sent to the applicant via certified mail, return receipt requested. l ~ 5 of 13

3,,, em io OLB-MC-220 '03/17/89 1 ' ATTACHMENT 1 R0/SRO PROPOSED LICENSE DENIAL FROM REGION R Cate Docket No. 55-(Number) Applicant Name Street Address City, State' Zip'

Dear (Name):

This is to inform you that,. based on a grading-of the (written-examination / operating. test) taken on (examination date(s)) in connection with your application-for a-(senior) reactor operator: license for.the (facility'n,me), which indicates.that you did not pass that -(examinatics/ test) it is proposed that your application be denied. Enclosed is.,.t' copy of the (written examination / operating test) results indicating those areas in which you exhibited deficiencies. A copy of the master.. answer key is-also provided. If you accept.the proposed denial and' decline'to request either an informal NRC staff l review or a hearing within 20 days as discussed in options 1 and 2 below, .this proposed denial will-become a final denial. You may then reapply for a license pursuant.to 10 CFR 55.35. If you accept this proposed denial, the following information is provided: a. Because-you passed a (written examination / operating test) on . (date), you may request a waiver of that portion. This waiver will be granted by the NRC and will be valid up to one year from.your (examination / test) date. b. Because you did not pass the (written examination / operating test). administered to you on (date), you will be required to retake an (a) (written examination / operating test). c. You may reapply for a license two months from the date of this letter. A reexamination will be scheduled, upon request by you or your facility management, shortly af ter receipt of your reapplication. a. Because this.is your second (or subsequent) examination failure, you will be required to retake the written examination and the operating test. A waiver for previously passed examinations or tests or portions thereof will not be considered. b. You may reapply for a license (six, 24) months from the date of this letter. A reexamination will be scheduled, upon request by you or your facility management,. shortly af ter receipt of your reapplication. 6 of 13 i Q

i y i ] OLB-MC-220 03/17/89 1 a. Because you did not pass either the written examination or operating test administered to you on (date) you will be required to retake the written examination and the operating test. b. You may reapply for a license (two, six, 24) months from the l date of this letter. A reexamination will be scheduled, upon request by you or your facility management, shortly after receipt of your reapplication. If you do not accept the proposed denial, there are two options available to you: 1. Within 20 days of the date of this letter, you may seek reconsideration of the proposed denial by requesting an informal NRC staff review of the grading of your examination. Your written request is to be sent to the Director, Division of Licensee Performance and Quality Evaluation, Office of Nuclear Reactor Regulation, U. 5. Nuclear Regulatory Commission, Washington, D..C. 20555. This request must include identification of your responses tc the portions of your examination which you believe were graded incorrectly or too severely. In addition, provide the basis, including supporting documentation, such as procedures, instructions, computer printouts, chart traces, etc., in as much detail as possible, to support your contention that certain of your responses were graded incorrectly or too severely. You will be informed of the results of the staff's reconsideration and, should the proposed denial be sustained, at that time you would trave the right to hearing pursuant to 10 CFR 2.103(b)(2). 2. If you do not seek reconsideration, you may, within 20 days of the date # this letter, request a hearing pursuant to 10 CFR 2.1C3tb)(2). A hearing request is required to be submitted, in writing, to the Secretary of the Commission, U. S. Nuclear Regulatory Commission, Washington, O. C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of the General Counsel, same address. You may not reapply for a license, pursuant to 10 CFR 55.35, until your license has been finally denied. Failure on your part to exercise either option 1 or 2 within the 20 days specified constitutes a waiver of your opportunity for informal review and your right to demand a hearing and renders this letter a notice of fina1 denial of your application, effective as of the date of this letter, for the purpose of reapplication under 10 CFR 55.35. If you have any questions, please contact (name) at (number). Sincerely, 7 of 13

I OLB-MC-220 03/17/89 (Regional Branch Chief or above)

Enclosures:

As stated cc: (Facility's authorized representative who signed the applicant's i 1 NRC Form 398) CERTIFIED MAIL - l l RETURN RECEIPT REQUESTED I i Use these paragraphs for initial RO or SR0 licensing applicants who I pass either the written examination or operating test but fail the other l Use these paragraphs for second and subsequent retake applicants Use these paragraphs for applicants who fail both the written examination and operating test i 8 of 13

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OLB-MC-220 j 03/17/89 j ATTACHMENT 2 R0/SR0 PROPOSED LICENSE DENIAL FROM DLPQ Date Docket No. 55-(Number) (Applicant Name) (Street Address) (City, State Zip)

Dear (Name):

In response to your letter dated (date), we have reconsidered the proposed denial issued to you on (date) and have reviewed the grading of j the (written examination / operating test) administered to you on (examination date(s)) along with the information you supplied contesting the grading. We find that you did not pass the. (examination / test). The results of our review are enclosed. Consequently, the proposed denial of your license application is sustained. If you accept the proposed denial and decline to request a hearing within 20 days as discussed below, the proposed denial will become a final denial. You may then reapply for a license pursuant to l 10 CFR 55.35. If you accept this proposed denial, the following ) information is provided: 1 a. Because you passed a (written examination / operating test) on (date), you may request a waiver of that portion. This waiver will be, granted by the NRC and will be valid up to one year j from your (examination / test) date b. Because you did not pass the (written examination / operating test) administered to you on (ciate), you will be required to retake an (written examination / operating test). c. You may reapply for a license two months from the date of this letter. A reexamination will be scheduled, upon request by you or your facility management, short 'y af ter receipt of your reapplication. a. Because this is your second or subsecuent examination failure, you will be required to retake the written examination and the operating test. A waiver for previously passed examinations or tests or portions thereof will not be considered. b. You may reapply for a license (six, 24) months from the date of this letter. A reexamination will be scheduled, upon i request by you or your facility management, shortly after receipt / of your reapplication. a. Because you did not pass either the written examination or operating test administered to you on (date) you will be 9 of 13

l OLB-MC-220 f 03/17/89 required to retake the written examination and the operating test. b. You may reapply for a license (two, six, 24) months from the date of this letter. A reexamination will be scheduled, upon request b'y you or your facility management, shortly after receipt of your reapplication. If you do not accept the proposed denial, you may, within 20 days of the date of this letter, request a hearing pursuant to 10 CFR 2.103(b)(2). A hearing request is required to-be submitted, in writing, to the Secretary of the Commission, U. 5. Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of the General Counsel, same address. i Failure on your part to request a hearing within the 20 days specified i constitutes a waiver of your right to demand a hearing and renders this letter a notice of final denial of your application, effective as of the date of this letter, for the purpose of reapplication under 10 CFR 55.35. If you have any questions, please contact (name) at (number). Sincerely, (Director, Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation)

Enclosures:

As stated cc: (Facility's authorized representative who signed the applicant's NRC Form 398) CERTIFIED MAIL - RETURN RECEIPT REQUESTED Use these paragraphs for initial R0 or SR0 licensing applicants who pass either the written examination or operating test but fail the other Use these paragraphs for second and subsequent retake applicants Use these paragraphs for applicants who fail both the written examination and operating test 10 of 13

pQ y .OLB-MC-220 03/17/89 p ATTACHMENT 3. R0/SR0 INITIAL APPLICATION DENIAL FROM REGION Date Docket No. 55-(Number) .(Applicant Name) h (Street Address) .(City, State Zip) I

Dear (Name):

l This is:to inform you that your application for a-(senior) reactor operator license submitt'ed~ in connection with the (facility name) is hereby denied. (Region to discuss deficiencies and which part of 10 CFR 55.31, ES-202, ES-203, NRC. approved facility training program, or Regulatory Guide 1.8 was involved.) When you have met the requirements of 10 CFR 55.31, you may submit another application. If you do not accept this denial, there are two options available to you.- You may, within 20 days of the date of this letter, take one of the following actions: 1. Request reconsideration of this denial of your application. Your written request is to be sent to the Director, Division of Licensee Performance and Quality Evaluation, Office of Nuclear' Reactor Regulation, Washington, D. C. 20555. Include with your request' specific reasons for your belief.that your application was improperly denied. Should it be determined that the denial of your application remains appropriate, you would then have 'he right to a hearing pursuant to 10 CFR i 2.103(b)(2). 2. If you do not request reconsideration, you may request a hearing pursuant to 10 CFR 2.103(b)(2). A hearing request is required to be submitted, in writing, to the Secretary of the Commission, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of the General Counsel, same address. If you have any questions, please contact (name) at (number). Sincerely, (Regional Branch Chief or above) cc: (Facility's authorized representative who signed the applicant's NRC' Form 398) 11 of 13 --. _ _ - _ _ = _ _ - _

OLB-MC-220 03/17/89 CERTIFIED MAIL - RETURN RECEIPT REQUESTED 4 4 e i b 12 of 13

OLB-MC-220-03/17/89 ATTACHMENT 4 R0/SRO INITIAL APPLICATION DENIAL FROM OLPQ Oate Docket No. 55-(Number) (Applicant Name) (Street Address) (City, State Zip)

Dear (Name):

This is in response to your request for reconsideration of the denial of your application for a (senicr) reactor cperator license issued to you on (date) submitted in connection with the (facility name). Our review of your application still indicates that you did not meet the eligibility requirements. (DLPQ to discuss deficiencies and which part of 10 CFR 55.31-ES-202, ES-203, NRC approved facility training program, or Regulatory Guide 1.8 was involved.) When you have met the requirements of 10 CFR 55.31, you may submit another application to the appropriate Regional office. If you do not accept this denial, you may, within 20 days of the date of this letter, request a hearing pursuant to 10 CFR 2.103(b)(2). A hearing request is required to be submitted, in writing, to the Secretary of the Commission, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, with a copy to the Assistant General Counsel for Hearings, Of,fice of the General Counsel, same address. If you have any questions, please contact (name) at (number). l Sincerely, (Director, Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation or above) cc: (Facility's authorized representative who signed the applicant's NRC Form 398) CERTIFIED MAIL - RETURN RECEIPT REQUESTED 13 of 13

s OLB-MC-225 01/09/89 PROCEDURES FOR PROCESSING RENEWAL LICENSE APPLICATIONS PURSUANT TO 10 CFR Part 55 - REQUESTS FOR ADMINISTRATIVE REVIEWS AND HEARINGS l l A. PURPOSE This chapter is established to specify the procedures for the NRC staff in processing requests for administrative reviews and hearings by 10 CFR Part 55 licensees in connection with failures of NRC-administered requalification examinations and denials of applications for license renewal. I l l B. BACKGROUND Due to tne differences between initial license and renewal license applications, i this separate chapter is established to specify the procedures to be used to process licensee requests for administrative reviews and hearings related to license renewal. The 1987 revision to 10 CFR Part 55 included a requirement that applicants for renewal of six year licenses pass a comprehensive written examination and operating test administered by the NRC during the term of the current six year license. By this change to the regulations, failure of NRC-administered examinations may be the basis for revocation of a current license and/or denial of an application for license renewal. NRC-administered requali-fication examinations are administered in accordance with the Examiner Standards, NUREG 1021. C. PROCEDURE FOR ADMINISTRATION OF NRC EXAMINATIONS An NRC-administered requalification examination will be administered to each six year licensee during the term of the six year license. If the licensee passes, he/she should be -so informed ( Attachment 1). If a licensee fails the first NRC requalification examination administered pursuant to 10 CFR 55.57, the facility will take corrective action consistent with its NRC-apprcved requalification program, i.e., the facility will remove the individual from licensed duties, remediate the individual, and retest the individual in the areas of weakness. If the individual tests satisfactorily, the facility licensee may return the individual to licensed duties. The Regional Office that has the licensing authority for the licensee who failed the first NRC-administered requalification examination will inform the licensee of the failure (Attachment 2) and administer a second requalification examination to the individual. The second NRC-administered examination will usually be administered within six months of the initial failure notification, and will address the area (s) where the licensee exhibited deficiencies. If the licensee fails a second NRC-administered examination, the NRC will issue an orrier suspending the individual's license effective immediately. The NRC will also issue an order to show cause why the individual's license should not be revoked on the ground that repeated failure of an NRC-administered examination raises a substantial public health and safety ouestion regarding continued safe operation of the facility for which the operator is licensed. In the case that the individual has a renewal application pending before the NRC, failure of the second examination would be the basis for denial of that renewal application. 1 of 8

OLB-MC-225 01/09/89 A licensee who has successfully passed an NRC-administered requalification examination for the purposes of license renewal may subsequently be part of another operating crew and therefore subject to the simulator portien of another NRC-administered examination to qualify other members of the operating crew for license renewal. If the licensee who successfully passed an earlier simulator portion of a NRC-administered examination fails a subsequent examina-tion, the facility licensee will take corrective action consistent with its NRC-approved requalification program as described in paragraph one above. The licensee will be informed of the failure (Attachment 3) and administered another NRC-administered simulator examination in about six months. If the licensee fails the re-examination, effective immediately the NRC will suspend the operator's license and issue an order to show cause why the license should not be revoked. D. PROCEDURE FOR DENIAL OF AN APPLICATION FOR LICENSE RENEWAL If, upon review of NRC Forms 398 and 396, submitted by a licensee to demon-strate eligibility for license renewal, the staff concludes that the licensee does not meet the requirements for renewal pursuant to 10 CFR 55.57, the licensee shall be notified and the deficiencies noted. The licensee will be given the opportunity to supply supplemental information. If, after additional information is supplied, the NRC staff still concludes that the application is inadequate for license renewal, the licensee will be issued a proposed denial of his/her license renewal application, which notes the deficiencies (Attach-ment 4). Within 20 days of the date of the letter of notification of proposed denial, the licensee may exercise one of the following options. 1) Request, in writing, a review of the application. Such a request should te sent to the Director, Division of Licensee Performance and Quality Evaluation, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555, and should include the reasons for the revicw request and supporting documentation as applicable. 2) Request, in writing, a hearing pursuant to 10 CFR 2.103(b)(2). A hearing request is required to be submitted to the Secretary of the Comission, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of General Counsel, at the same address. If the licensee exercises option (1) and the application denial is sustained (Attachment 5), the applicant may request a hearing pursuant to 10 CFR 2.103(b)(2). E. PROCEDURE FOR DENIALS THAT ARE OVERTURNED If, as the result of a hearing process, the licensee's failure of a requalifi-cation examination is overturned: (1) the licensee's license will be reinstated, (2) the licensee will be eligible for license renewal pursuant to 10 CFR 55.57 if all other requirements are satisfied and (3) the facility licensee may return the licensee to licensed duties when he/she has been brought current with respect to the facility requalification program and the provisions of 10 CFR 55.53(e). If, as a result of a hearing process, the denial of a licencee's renewal application is overturned, the licensee will be eligible for license renewal pursuant to 10 CFR 55.57 if all other requirements which were not at issue in the hearing are satisfied. 2 of 8

.s. OLB-MC-225 01/09/89 F. NOTES 1. Letters informing a licensee of a proposod denial must be signed by a l Branch Chief or higher. DLPQ-generated correspondence will include a l distribution copy to the appropriate regional Licensing Assistant for i tracking purposes. 2. The facility licensee's representative, authorized to sign the renewal application, should receive a copy of correspondence to the licensee generated as a result of this process. 3. The Director, DLPQ, will keep regional management informed of the status of his actions as a result of-this process and will acknowledge corres-l pondence from the licensee. 4. All correspondence.sent to the licensee is to be sent via certified mail, return receipt requested. 5. It is inappropriate to ask the facility licensee to reassess the need for ~ an operator's license while the informal review process or a hearing is ongoing. 1 i 6 3 of 8 L_____________________________._ l

_ _ _ _ _ _ _ = _ _ _ _ _ _ - _. _ _ _ _ _ _ _ - - OLB-MC-225 01/09/89 t R0/SR0 REQUALIFICATION EXAMINATION PASS LETTER PROM THE REGION DocketNo.55-(Number) (ApplicantName) (StreetAddress) (City, State Zip)

Dear (Name):

Thit. letter is to inform you that you passed the NRC-administered requalifica-tion written. examination and operating test taken on (date). Enclosed is a j copy of the results of your examination. Your facility training department has i a copy of the master answer key. If you have a question, please contact (Name) at (number). Sincerely, (RegionalBranchChief) cc: (FacilityauthorizedrepresentativewhosignsNRCForm398) CERTIFIED MAIL-RETURN RECE!PT REQUESTED ~ l I l U 4 of 8

.+

OLB-MC-225 01/09/89 RO/SR0 REQUALIFICATION EXAMINATION / TEST FAILURE LETTER FROM THE REGION Date Docket'No.55-(Number) Applicant Name Street Address -(City,StateZip)

Dear (Name):

This is to inform you that, based on the grading of the NRC-administered requalification (written examination and/or operating test) taken on (date), you did not achieve an acceptable score. Enclosed is a copy of the results indicating the area (s) in which you exhibited deficiencies. Your facility training department has a copy of the master answer key. This failure places you in the same status as if you had failed a facility-administered requalifi' cation examination. Therefore, you are subject to the j requirements set forth in the NRC-approved requalification program for the facility for which you are licensed and must meet those requirements prior to resuming licensed duties. A second NRC-administered requalification examination will be administered to you in the area (s) in which you exhibited deficiencieson(Date). Failure to pass a second NRC-administered requalification examination will result in your license being suspended effective imediately and you will be required to show cause why your license should not be revoked. In that event, q you would have the right to a hearing ;egarding those matters. If you have any questions, please contact (name) at (number). Sincerely, (RegionalBranchChieforabove) ] cc: (Facility authorized representative who signs NRC Form 398) CERTIFIED MAIL-RETURN RECEIPT REQUESTED 6 5 of 8 I m_______

OLB-MC-225 01/09/89 R0/SRO SUBSEQUENT REQUALIFICATION SIMULATOR / TEST FAILURE LETTER FROM THE REGION Date Docket No. 55-(Number) (Applicant Name) (StreetAddress) (City,StateZip)

Dear (Name):

This is to inform you that, based on the grading of the NRC-administered simulator portion of the requalification operating test taken on (date), you did not achieve an acceptable score. Enclosed is a copy of the results indi-cating the area (s) in which you exhibited deficiencies. Another NRC-administered requalification simulator test will be administered to you on (Date). I Failure to pass this NRC-administered requalification simulator test will result in your license being suspended effective imediately and you will be required to show cause why your license should not be revoked. In that event, you would have the right to a hearing regarding those matters. 1 If.you have any questions, please contact (name) at (number). i Sincerely, (RegionalBranchChieforabove) cc: (Facility authorized representative who signs NRC Form 398) CERTIFIED MAIL-RETURN RECEIPT REQUESTED I 6 of 8 I l I

.?.

u. e P

OLB-MC-225 01/09/89 ' Attachment 4 R0/SR0 RENEWAL APPLICATION DENIAL FROM REGION-Date DocketNo.55-(Number) Applicant Name. Street Address. (City, State Zip)

Dear (Name):

This is to inform you that your renewal application for a (senich) reactor E operator license. submitted in connection with the (facility name) does-not demonstrate your eligibility for license renewal for the following reason (s):- If you :do.not accept this proposed denial, you may-within 20 days of the date .of this letter, exercise one of the following options. (1) Request reconsideration of the application denial by submitting such a request to the Director, Division of Licensee Performance-and Quality Evaluation, U. S. Nuclear Regulatory Commission, Washington,.. D.C. 20555, stating therein the reasons for the request and support-ing documentation as applicable. If the proposed denial is u h ld, .you may then request a hearing pursuant.to 10 CFR 2.103(b)(2)p e (2). Request a hearing pursuant to 10.CFR 2.103(b)(2). A hearing request is req 0 ired to be submitted, in writing, to the Secretary of the Comission, U.S. Nuclear Regulatory'Comission, Washington, D.C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of'the General Counsel, at the same address. If you have any questions, please contact (name) at (number). Sincerely, (RegionalBranchChieforabove) cc: (Facility authorized representative who signs NRC Form 398) CERTIFIED MAIL-RETURN RECEIPT REQUESTED b 7 of 8 i

OLB-MC-225 4 01/09/89 R0/SRO RENEWAL APPLICATION DENIAL FROM DLPQ Date DocketNo.55-(number) (ApplicantName) (StreetAddress)) (City, State Zip

Dear (Name):

'This to inform you that review of your. request for reconsideration of the proposed denial of your renewal application for a (senior) reactor operator license submitted in connection with the (facility name) has been completed.. Your renewal application is-hereby denied. 1 (DLPQ to discuss deficiencies and applicable part(s) of the Examiner Standards, and 10 CFR Part 55 that. apply.) When you have met these requirements, you may submit another application to the appropriate Regional office. If you do not accept this denial, you may, within 20 days of the date of this letter, request a hearing pursuant to 10 CFR 2.103(b)(2). A hearing request is required to be. submitted, in writing, to the Secretary of the Comission, U.S. Nuclear Regulatory Comission, Washington, D.C. 20555, with a copy to the Assistant General Counsel for Hearings, Office of t,he General Counsel, at the same address. If you have any questions, please contact (name) at (number). Sincerely, (Director,DivisionofLicensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation orabove) cc: (Facility authorized representative who signs NRC Form 398) CERTIFIED MAIL-RETURN RECEIPT REQUESTED l 8 of 8 l I

4*.

e. OLB-MC-300 03/10/89 ) REGIONAL OPERATOR LICENSING PROGRAM ASSESSMENT A. PURPOSE The regional operator licensing program assessment will use the methodology set forth in the 300 series OLB manual chapters to evaluate the operator licensing functions in the regions to assure consistent, uniform operator licensing program administration. The program office is responsible for verifying that licensing examinations are administered uniformly throughout the country. B. BACKGROUND The operator licensing function was delegated to Regions II and III in 1 November, 1982, Region I in July, 1983 and Regions IV and V in September, l 1983. NRR's role of providing continuing guidance and coordination criteria was identified in delegation and assignment memoranda to the regional administrators. C. IMPLEMENTATION 1. The Operator Licensing Manual Chapters are designed to provide a methodology for evaluating the operator licensing function within and among the regions. They do not constitute a basis for requirements on the regions but are used to evaluate complia6ce of the regitns with requirements stated in the Examiner Standards or other authoritative references. 2. The program assessment procedures are organized in the following OLB chapters: OLB-MC-300 Regional Operator Licensing Program Assessment OLB-MC-310 Annual Office Review Visit Procedure OLB-MC-320 OLB Program Review of Operator Licensing Functions at Licensee Facilities 3. In addition to evaluating regional compliance with requirements, OLB will feedback suggestions and recommendations for alternate methods and procedures for performing the operator licensing function when appropriate. 4. Prior to making a regional review, the team leader should review the l previous assessments to identify weak areas as possible candidates for coverage during the next assessment. i 1 l l

. 3 OLB-MC-300 03/10/89

~ 5. The Assessment Team' Leader should use Attachment 1 to assist in preparing for the regional visit. i D. DOCUMENTATION I i 1. Each Manual Chapter identifies to the regional offices the j methodology and the criteria used by OLB review team to perform.its i program responsibilities. 2. OLB shall be sensitive to the potential increased workload caused by j excessive and repetitious record keeping. Program reviews will audit the documentation maintained by the regionc and recommend consolida-tion or elimination of duplicate or unnecessary records. In particu-lar, documentation should not be maintained solely for the purpose of supporting the OLB audit function. l 4 9 1 1 'I b 1 2

e-OLB-MC-300 03/10/89 ATTACHMENT 1 PREPARATION FOR A REGIONAL VISIT This checklist should be completed prior to performing an assessment per OLB-MC-300. Inspection: OLB-MC-Region: Date: Assessment Team Leader: Assessment Team: Assignments made to Assessment Team Members, YES I Regional Office properly notified of assessment. YES Attachments and applicable sections of the assessment that may be completed before traveling to the regional office are identified and. assigned to the team. YES Previous assessments reviewed. Weak areas noted as possible candidates for review this assessment. YES Assessment Team Leader 1 l Date 3

og, OLB-MC-310 01/19/89 ANNUAL OFFICE REVIEW VISIT PROCEDURE A. Purpose To establish a procedure and criteria to review the administration of the operator licensing functions in the Regions and to review OLB support of the Regional offices in carrying out the operator licensing functions delegated to the Regions. B.

Background

1. NRR is responsible for regulatory policy and the licensing of operators pursuant to 10 CFR Part 55. To monitor the execution of-this responsibility, OLB shall oversee the operator licensing functions delegated to the Regions. The oversight function will include an Annual Office Review Visit (AORV) conducted in accordance with the procedures of this manual' chapter. sc 4" 2. The objectives of the Annual Office Review Visit include: a. Evaluation of compliance with the Examiner Standards and.other policy guidance to improve the quality of Operator Licensing I examinations. b. Evaluation of Regional consistency in applications of agency ' regulatory requirements, policies and practices. l i c. To provide feedback to management concerning the adequacy of the operator licensing functions delegated to the Regional offices. Evaluation of examiner feedback and implementation of the feedback. 1 'l 3. A detailed review of all functional areas or all aspects of a function is not required each year. Items of particular interest ) for review shall be those identified problem areas from previous reviews. 4. The Operator Licensing Manual Chapters document the criteria and methodology to evaluate the administration of the operator licensing functions in the Regions to ensure consistent operator licensing program admini tration in accordance with the Operator Licensing ? Examiner Standards (NUREG-1021) and other policy directives. C. Implementation Procedure 1. The Assessment Team Leader shall contact the appropriate Regional Section Chief to arrange an optimal time for the visit. The date should be selected to coincide with a time when most examiners are in the office and available for discussions. In addition, the visit ~ 1 l 1 L___-_____-_-___--_________

c. o g .j, OLB-MC-310 01/19/85 should be scheduled such that the Division of Licensee Performance and Quality Evaluation (DLPQ) Director or designee will be available l to conduct the exit briefing. Af ter the visit-has been arranged ver-bally, and approximately sixty days prior to the scheduled date of the visit, a letter in the format of Attachment 1 should be sent to the Regional office being visited. 2. The~AORV shall evaluate the administration of delegated operator licensing functions within and among the Region and the support and-guidance provided to the Regional offices by OLB.using Attachments 2 through 15, 3. Additional visits 'may be scheduled if necessary to meet the objectives of t g eview program. However, a region should receive no more than two vThts in any two year time frame unless unforeseen

(

or special circu,mstances arise. 4. The AORV will be performed by an assessment team consisting of the necessary expertise to adequately evaluate the areas assigned by the program office. The review of various Examiner Standard (ES) qual-ity assurance checkoff sheets will include the reviewer's evaluation, on a sample basis, of those items on the examination / test for which the QA was performed. 5. An exit meeting shall be scheduled at the end of the AORV to discuss the findings of the review team and any concerns of the Regional office. The Director or his designee should join the review team to conduct the exit meeting and discuss any policy matters with Regional office management. 6. Attac-hments a. Examination Administrative Requirements, Attachment 3, shall be completed in conjunction with the examination packages selected for review. If an item is not applicable, e.g., security agreements, N/A should be put by the item number, b. Operating. Test, Attachment 3, should use the same examination packages as in the review of the written examinations to review Regional performance in administration of operating tests. c. Written Examination, Attachment 4, should be used to review two or more examination packages. Generally, examination packages with at least five written examination candidates and approxi-mately the same number of operating examination candidates should be selected for review. Since each Region is responsible for quality assurance of all examinations, no distinction shall be made between examinations written by NRC or contract examiners. Portions or this review may be performed prior to the arrival at the Region office. The examination package shall be reviewed for compliance with the latest Revision of the Examiner Standards. 2

g* e OLB-MC-310 01/19/89 d. Requalification Program Evaluation, Attachment 5, should be ) J used to review the last two requalification program reviews unless there is a particular reason not to e.g. the plant was reviewed during the previous AORV. e. Review of Correspondence and Transmittals, Attachment 6, shall be used to review the Region's method of disseminating guidance from the program office. There should be a means to ensure that all examiners receive clarification or interpretations of established policy or the Examiner Standards. f. Review of the Operator License Tracking System (OLTS) Entries,, shall be used to assess the accuracy and timeliness of Regional OLTS data, g. Review of Licensing Assistant Activities, Attachment 8, shall be used to review records kept and maintained by the Licensing Assistant for completeness and accuracy. h. Review of Medical Evaluations, Attachment 9, shall be used to review the methods the Region uses to track medical evaluations for completeness and accuracy, i. Review of the Examiner Training Program, Attachment 10, shall be used to review the Region's implementation of the requirements of ES-103 for initial training and certification of licensing examiners and continuing training and certification. This shall include a review of the records of audits of oral examinations. j. Review of Manpower Resources and Utilization, Attachment 11, shall be used to evaluate manning levels and review efficiency of examiner utilization. Discuss examiner retention and recruiting problems with the Section Chief and/or examiners, if applicable. k. R.: view of Region Operating Procedures, Attachment 12, shall be used to perform a review of the overall operating procedures of the Region, includir.g scheduhng of examiners, issuance of guidance by the Regional office not in accordance with the Examiner Standards, contractor monitoring, the use of scenario banks, and the processing of waivers. 1. Review of License Denial Appeal Process, Attachment 13, shall be used to perform a review of the processing of license denial appeals. Review of Examination Question Bank Usage, Attachment 14, shall m. be used to perform a review of Examination Question Bank (EQB) usage. n. General Implementation 1) Some portion of the reviews may be performed prior to the arrival of the review team on site. This is recommended 3

o' OLB-MC-310 01/19/89 as the time spent on site can be spent more efficiently. 2) Many of the reviews may be performed concurrently on the sane examination packages. This is recommended where applicable. 3) Where comments are needed to further document review team findings, use Attachment 15 to add information to another attachment. There is a place on Attachment 1$ to denote the attachment and section number to which the additional information app 10 5. D. Documentation Required 1. A report s' hall be prepared by the team leader upon completion of the AORV. This report shall summarize the findings of the assessment team regarding the adequacy and :onsistency of program implementation by the Region. The report shall be from the OLB Branch Chief to the DLFQ Director with copies to the cognizant Regional Division Director and other appropriate Regional office personnel. Prior to final distribution of the report, a preliminary copy may be sent to the Region for review and comment. The Region's comments will be considered for inclusion ir the final report. 2. Upon complet. ion of the assessment activities for all five Regions, a Summary Report shall be prepared which briefly provides an overview of the implementation af the Operator Licensing function. 3. The Summary Report shall address the completeness, adequacy and uniformity of the implementation both within and among the Regions, and'will briefly address significant findings of a generic nature. Individual Regional annual reports may be attached to provids backup information and details if deemed necessary. The Summary Report shall be prepared by OLB for the signature of the Director, NRR, for submittal to the Executive Director for Operations (EDO) with copies to the Regional Administrators and other appropriate management personnel, m 4 4 ) 1

OLB-MC-310 01/19/89 ATTACHMENT 1 EXAMPLE OF LETTER TO REGION SCHEDULING ANNUAL OFFICE REVIEW MEMORANDUM FOR: , Director ~ Applicable Division of Applicable Region FROM: , Director l Division of Human Factors Technology, NRR

SUBJECT:

PROGRAM REVIEW OF OPERATOR LICENSING The Operator Licensing 0.anch is preseatly planning to perform an annual office review visit the week of of OLB has discussed this visit with of you staff and confirmed the date. (Regienal contact) has also agreed to arrange for working space for the review team. will lead a team consisting of himself, an examicer from Region and OLB Licensing assistant. (DLPQ representative) will arrive on to discuss DLPQ programs, review the visit findings, and will conduct the exit briefing on Enclosed for your information is the agenda for this review. DISTRIBUTION: CONCURRENCE: Central Files Team Leader DLPQ RF Section Chief OLB RF Branch Chief OLB Branch Chief DLPQ Deputy Div. Dir. RSO Section Leader EDS Section Leader DLPQ Deputy Div Dir. 'AQRV Team Leader OLB Licensing Asst. We appreciate the cooperation you and your staff have exhibited regarding this review and our last review. I believe that the program review is an important function that depends on the type of cooperation we have received from your Region to be successful. If you have any questions pertaining to thi

review, please call (RSO Section Chief) on FTS I

Director, Division of Licensee Performance l and Quality Evaluation, NRR

Enclosure:

Aganda cc: , (applicable branch chief, applicable Region) , (applicable section leader, applicable Region) , (applicable section leader, Region of ' visiting' examiner) l , (applicable person in ED0's office) 5 i ^ - - - -

L,. OLB-MC-310' 01/19/89 ATTACHMENT 1 (Continued) AGENDA (day and date) time (beginning) Brief Region staff on schedule to for the visit. (team leader) time (ending) time (beginning) Start review of examination packages, to per MC-310-1, MC-310-2, MC-310-3, time (ending) .(team leader, Regional examiner) Start Operator Licensing Program Audit per MC-310 8, (OLB Licensing Assistant) (day and date) time (beginning) Complete review of examination packages, per MC-310-1, MC-310-2, to MC-310-3, (team leader, Regional examiner). time (ending) Continue review of Operator Licensing i Program Audit per MC-310 8, (OLB Licensing Asst.) time (beginning) Requalification program audit per to MC-310-4, and review of Exam Schedul-time (ending) ing, Waivers and Contractor Monitoring, per MC-310-11 and EQB use and problems, per MC-310-13. (team leader) Licensee Denial and Appeal process per MC-310-12, and Examiner Training Program per MC-310-9, and Manpower Resource and Utilization per MC-310-7. (Region examinei-) Review of Office and Docket Management Activities ptr MC-320-5. (OLB Licensing Asst.) (day and date) time (beginning) Complete Suinmary Review, prepare to Summary notes. time (ending) , (All three team members) time (beginning) Brief (DLPQ representative) on to

findings, (all time (ending) three team members) i 6

l h

<? OLB-MC-310 01/19/89 ATTACHMENT 1 (Continued) (day and date) Exit Meeting with Region Management. I e 4 bl 7

3. OLB-MC-310 01/19/89 ATT CHMENT 2 Examination Administrative Requirements Date of Review: Facility: 1. Preexamination Check Sheet action items completed within the prescribed times. (ES-201, Attachment 1) Yes No Comments: 2. ' Examination Assignment Sheet correctly' filled out. (ES-201, Attachment 3) Yes No Comments: l I 3. Pre and Post Examination Security Agreements executed when required. (ES-201, Attachment 2, Enclosure 4) Yes No 4. Applications (NRC Form 398) Reviewed and Signed by examiner. (ES-201) Yes No 5. Regional schedule forecasts and information on WYLBUR meet the intent of ES-201, Paragraph D. Yes N o___ 8 L_1__ _ _ _ _ _ - _ _ _

OLB-MC-310 01/19/89-ATTACHMENT 3 OPERATING TEST Date of Review: Facility. 1. General Pre and Post Examination Security Agreements executed when required. a. (ES-302, Attachment 2)- Yes No b. Scenario revisions are documented on all copies used for evaluation. (ES-302, Paragraph C.3) Yes No c. Examiners administered 5 or fewer operating tests per examiner per week. (ES-201, Paragraph D) Yes No___ d. All portions of the operating test were given on the same day. (ES-201, Paragraph C) Yes___ No 2. Simulator Examination a. Transient / Event checklist documents proper coverage for license level. (ES-301, Attachment 9) Yes No b. Competencies checklist documents proper coverage. (ES-301, ' 0) Yes No c. Control Room Systems coverage is appropriate relative to the different requirements for simulator and nonsimulator examinations. (ES-301, Paragraph G.2.a) Yes No d. Was a startup certification audit performed. (ES-301, Paragraph G.4) Yes " No 3. Facility Walkthrough a. A minimum of two systems from Attachment 12 or 13, with 3 of 4 subject areas evaluated. (ES-301, Paragraph G.2.b) Yes No___ 1 9

~ OLB-MC-310 01/19/89 ATTACHMENT 4 Written Examination I 8 Date of Review: Facility: ~ 1. Category weighting in accordance with ES-401.B Yes No 2. . Examination item format complies with ES-401.B.1 - 6. Yes No j 3. . Written Examination Quality Assurance Checkoff Sheet complete. (ES-401, ) Yes No 4. Examination Administration Quality Assurance Checkoff Sheet complete. (ES-402, Attachment 1-) Yes No 5. Any changes to examination gradings are fully documented by reviewer with original grading lined out but legible (no white out or other obscuring methods used). Yes No___ 9 l 4 10 l

OLB-MC-310 01/19/89 ATTACHMENT 5 Requalification Program Evaluation Date of Review: Facility: 1. Administrative Controls and Procedures a. Facility notification sent at least 90 days in advance of examination date. (ES-601, Paragraph C.2.a.(1)) Yes No_ b. Reference material received at least 60 days in advance of examination and reviewed. (ES-601, Paragraph C.2.a.(2)) Yes No Facility notified of selected participants at least 30 days in c. advance of examination date. (ES-601, Paragraph C.2.a.(3)) Yes No d. Selection of Operators criteria used to select operators. (ES-601, Paragraph C.2.b.) Yes No e. Facil.ity involvement meets the requirements of ES-601, Paragraph C.2.c. Yes _ No f. Examination Security Agreements executed. (ES-601, Attachments 2 and 3) Yes No 2. Evaluation a. Minimum sample size of 12 examined. If No, enter date of next requalification examination , and go to paragraph c. ( Yes _ No _ b. Requalification program was evaluated as satisfactory. (If No, list areas of facility weakness:) Yes _ No t l 11

1' < E..1 OLB-MC-310 01/19/89 I AT7ACHMENT 5 (Continued) l. c. Individual performance l Number of Operators Pass Fail d; Total number of requalification examinations given in the preceding Fiscal Year i. e. Evaluation checklist completed. (ES-601, Attachment 4) l-ves No Comments: f. Evaluation of Facility Evaluators completed. (ES-601, Attachment 5) Yes No ( g. Simuiator Scenario Review Checklist completed. (ES-601, Attachment 6) Yes No h. Video Tape Agreement executed if applicable. (ES-601, Attachment 9) i Yes No 1. System Walk Through Test Plan completed. (ES-601, Attachment 10) Yes No j. NRC Checklist for Open Reference Test Items completed. (ES-601, 1) Yes No k. Job Performance Measure Quality Checklist completed. (ES-601, 2) Yes No 1. Job Performance Measure Worksheets completed. (ES-601, Attachment 13) Yes_ No 12

OLB-MC-310 01/19/89 ATTACHMENT 6 R 9w of Correspondence and Transmittals Date of Review: Period Reviewed: Reviewer: A. Region / Headquarters Interactions 1. Number of documented requests (memos, telephone conversations, etc.) for OLB assistance during the period reviewed 2. Average time to receive response from OLB 3. Method used to disseminate information to examiners 4. Disciass and summarize Regional views on level of OLB support and current area of significant disagreement between the Region and OLB. l l 13 - ) i 1

OLB-MC-310 01/19/89 ATTACHMEkT7 Review of Operator Licensing Tracking System Entries i Date of Review: Period Reviewed: Reviewer: A. Status of OLTS Entries / Licensing Assistant Interaction with OLTS 1. OLTS entries up to date within one week of review date. Yes No ___ 2. Number of errors found during a comparison of a random sampling of dockets with their OLTS entries. Application Data Exam Data License Data Educational Data Training Data Experience Data Meets Requirements Data Appeal Data Waiver Data Other Comments: M-Afpf - e-- h 14

OLB-MC-310 01/19/89 ATTACHMENT 7 (Continued) 3. OLTS problems Licensing Assistant is experiencing Comments: i l i j l 4. OLTS developments conveyed to Licensing Assistant Comments: 9 15

e.' OLB-MC-310 01/19/89 1 ATTACHMEN'l 8 Review of Licensing As,sistant Activities I Date of Review: Period Reviewed: Reviewer: A. Review of Licensing Assistant Activities 1. Applications are logged in as received. YES NO 2. Applications are processed within 30 days of receipt. YES NO 3. Docket files maintained up to date. YES N0 4. Facility files being maintained. YES NO B. Docket Management and Office procedures 1. Docket security is designed and maintained to ensure the privacy of applicants. YES NO 2. The docket locator system provides for the capability to track the physical location of dockets at all time. YES N0 3. Completeness of docket l contents verified by a. A random sampling of dockets checked for applications, most recent exam, medical (Forms 396, 396A), copy of license or denial letter, and the first page of Form 157. YES NO b. A trace of a minimum of one application through the complete proce:s from date of receipt to issuance of license or denial. YES N0 4. Docket is complete and up to date. YES NO 5. License Logs are complete and up to date. YES NO 16

OLB-MC-310 01/19/89 ATTACHMENT 9 Review of Medical Examinations Date of Review: Period Reviewed: Reviewer: 1. ~ Who performs medical evaluations in the Region, when required? 2. Region has implemented an effective medical examination tracking system to monitor the status and location of medical reviews. YES NO 3. Average turnaround time for medical evaluations. 4. Randomly check several dockets to ensure: a. NRC form 396 and, if appropriate, NRC doctor's review are filed in each docket. YES NO b. Only current medical examinations have been accepted. (medical exam valid for 2 years) ] YES N0 1 1 5. Check'several dockets for which the medical evaluations require license restrictions. Are the restrictions stated on the license? 17

f -[* OLB-MC-310 01/19/89 i ATTACHMENT 10 j l Review of the Examiner Training Program 4 Date of Review: Period Reviewed: Reviewer: 1. Training program implemented and active for new examiners (ES-103, Section F). YES NO 2. Perform a sample review of l new examiner training journals for compliance with the intent of ES-103. Comments: ( 3. Each examiner audited on an annual basis in accordance with ES-103; as documented by a completed 'NRC form 308. YES N0 4. Each examiner has attended the refresher training course at 2 year intervals (ES-103). YES NO 5. Other training completed by examiners is documented. YES NO 6. Technical training courses utilized during previous 12 months: Name of course

1. Sent Name of course
2. Sent 4

18

l-,~ OLB-MC-310 01/19/89 ATTACHMENT 10 (continued) Number of courses per trainee in initial training. l Number of courses per trainee for refresher training. l 19 I

OLB-MC-310 01/19/89 ATTACHMENT 11 Review of Manpower Resources and Utilization 1 lt Date of Review: Period Reviewed: Reviewer: A. Manpower Resources 1. a. Examiner losses over past twelve months b. Examiner gains over past twelve months c. Reasons for attrition d. Problems being experienced in recruiting. 2. Number of times an examiner was loaned to another region (s) for examination purposes durina the review period? a. To this Region b. By this Region to another Region 3. Examiner background summary 1 i l a. Number who have held a RO or SRO license at a commercial facility b. Number with a degree in engineering or science c. Number with no previous operations experience (either research reactor, commercial, military or unlicensed government) B. Manpower Utilization 1. Number of meetings between Regional personnel and utility training staffs other than routine meetings associated with specific examina-tion assignments. 2. Number of training conferences and workshops held by utility organizations (e.g., MID Atlantic Training Group) in the Region, and number attended by examiners (indicate number of examiners attending) (e.g., MID Atlantic Training Group) Number of conferences q Number of examiners attending 3. Number of man hours spent in support of the annual program review by Region personnel. 20 i f l l

j' s>' a* l OLB-HC-310 01/19/89 L ATTACHMENT 11 (Continued) 4. List other official duties assigned to examiners. 5. Obtain RITS breakdown of examiner time usage. Obtained f T 6 e 21 l 1 i

>w* OLB-MC-310 01/19/89 ATTACHMENT 12 Review of Region Operating Procedures Date of' Review: Period Reviewed: Reviewer: A. Scheduling. 1. Section Chief has exam schedule for at least the next six months-on WYLBUR (ES-201). YES NO 2. Section Chief has requested OLB to assign any contract examiner assistance required in the next six months (ES-201). YES NO B. Standards 1. Has the Region issued any examiner guidance which is at variance with OLB guidance? (If yes, explain in comments) YES' NO e ( 2. Examiner Standard in.use is up to. date through Revision. YES NO ~ C. Contractor Monitoring 1. Were. Contractor Examiner Evaluation Forms (ES-501, Attachment 4) filled out for each examination fn which there was contract examiner participation? Number of examinations with contract -examiner participation Number-of ES-501, Attachment 4 forms filled out 2. Problems experienced within the review period with contract examiners. Were the problems documented on Contract Examiner Evaluation Forms (ES-501, Attachment 4)? 3. Review the file of ES-501, Attachment 4, Contract Examiner Evaluation Forms at OLB and in the Regional files. Are there any outstanding action items for either the Region or OLB7 D. Scenario Banks / References 1. Does'the Region have a bank of oral and/or simulator sc9narios? YES NO 22 .__-__x_-

9. 'OLB-MC-310 01/19/89 ATTACHMENT 12 (Continued) 2. What procedure is in place for. updating 'the scenarios? 3. Describe the Scenario Bank and its availability to examiners. E. Waivers 1. Number of applications that requested waivers during the review period. 2. Number of waivers granted. 3. Number of waiver requests required OLB consultation. 4. Spot check waivers to ensure they conform to NRC policy (ES-204). (Document any findings in comments) Checked 5. Is the Region obtaining concurrence for any non-standard waivers of examination requirements (ES-204). YES NO 6. Does the Region notify candidates in writing of the action-taken on the waiver request? YES NO 7. Does the Region track waivers (ES-201)? YES NO Is th' waiver decision 8. e documented on NRC form 398 (ES-204, C.3, For NRC use block) YES NO Comments: 'l I 23

ia .1

• OLB-MC-310.

01/19/89 ATTACHMENT 13 Review of License Denial Appeal Proc'ess Date of Review: Period Reviewed: Reviewer; 1. Number of appeals during the period reviewed Part R0 SRO Given by Given by NRC Contractor Written Ope: ating Total 2. Region appeal rate a. Total parts of R0 and SR0 exams failed during review period (i.e., if a candidate failed the written and the oral, he failed two parts). b. Total failed parts of exams appealed during review period, c. Appeal rate, computed by divided by b. (Appeals per failed part) 3. Number of appeals where the candidate failed more than one part of the exam (s). 4. Number of appeals granted (denials overturned) Total Administered Administered by NRC by Contractors 5. The appeal process is in compliance with MC-220 or MC-225 as applicable. YES NO 24

..? OLB-MC-310 01/19/89' 1 1 ATTACHMENT 14 - Exaniination Question Bank Usage Date of Review: Period Reviewed: Reviewer: A. EQB usage 1. How many computer terminals and personal computers are available for use by examiners for interaction with the EQB? Computer Terminals Personal Computers 2. Examiners actively use the EQB for development of written examinations. YES NO ! [' w 6 i 25

OLB-MC-310 01/19/89 ATTACHMENT 15 Additional Comments Attachment Section 4 4 4 l t I 26

{ ] OLB-MC-320 01/19/89 OLB PROGRAM REVIEW OF OPERATOR LICENSING FUNCTIONS AT LICENSEE FACILITIES A. Purpose To provide guidance for the Program Review visit to a licensee facility to review the administration of Operator Licensing examinations. Addition-ally, these facility review visits provide an opportunity for program office examiners to participate in operating test administration as a team member. This program office participation strengthens the program office ability to evaluate the Regions application of the Examiner Standards. B.

Background

1. OLB is responsible for assuring that the delegated Operator Licensing functions are administered in accordance with the Examiner Standards. 2. The reviewer shall observe operating tests and, when practical, the administration of the written examinations to evaluate compliance with the Examiner Standards, and to assess the uniformity of examination administration procedures within and among the Regions. 3. One goal ~of the examination reviews will be to provide feedback to individual examiners and the Regions relative to the intent and objectives of the Examiner Standards. 4. OLB reviews shall be for the purpose of evaluating compliance with the Examiner Standards and for evaluating consistency in the examin-ing process among the Regions. They shall not be for the purpose of personnel performance evaluations which are the responsibility of the Regions and of contractor management. C. Implementation Procedures 1. Review of the administration of the written examinations shall consist of the following three parts: a. Preparation for Written Examinations The preparation for the administration of the written examination shall be reviewed., Part A, shall be used to assist in the performance of this review, b. Observation of Written Examinations The administration of the written examination shall be observed with the reviewers present during portions of the six-hour exam-ining period. Attachment 1, Part B, shall be used to assist in the performance of this review. 1

s . :" ~ OLB-MC-320 01/19/89 c. Facility Review of the Written Examination The facility receipt of the written examination for review shall be reviewed. Attachment 1, Part C, shall be used to assist in the performance of this review. 2. Review of operating tests shall consist of the following four parts: a. Review of Preparation for On-Site Administration The preparation for the administration of operational examinations shall be reviewed. Operational examinations given by a single examiner to a sing'.e applicant should be reviewed whenever poss-ible. Attachment 2, Part A, shall be used for this phase of the review. b. Review of Oral / Walk-Through Examination Individual examiners shall be observed as they administer oral / walk-through examinations for the purpose of evaluating compliance with the Examiner Standards., Part f., shall be used for this phase of the review. Form 308 in ES-501 may be used as a checksheet during the observation of the opera-ting test to determine if the Ministration of the examination meets the requirements of the examiner standards. Form 308 shall not be used for a performance evaluation unless the person using it is the supervisor of the person being evaluated, c. Review o'f Integrated Plant Operations Examination Individual examiners shall be observed as they administer integrated plant operations examinations for the purpose of evaluating compliance with the 2xaminer Standards. The scenarios planned for use during the examination shall also be reviewed if a simulation facility is used., Part C, shall be used for this phase of the review. d. Review of Operational Examination Documentation Documentation of the Operating Examination shall be reviewed for the purpose of evaluating compliance with the Examiners Standards. The examiner.shall mail Form 157 with all applicable attachments (Copies of marked up scenarios, ES-301 simulator attachmi ~ts, etc.) to the reviewer. These forms are compared to notes made by the reviewer at the time of the Operational Examination to assure that the Form 157 notes are consistent with the examina-tion given and that the documentation package suppor+ o Pass / Fail decision. Attachment 2, Part D, shall be used to, this phase of the review. l 3. Followup discussion between the OLB reviewer and the examiner being reviewed may take place after the reviewer has had an opportunity to complete all necessary forms and will be documented on Attachment 3. 1 2

o ,e OLB-MC-320 01/19/89 However, completion of the attachments should not preclude any discussions immediately after the operating test. The objective of these discussions shall be to provide feedback to the examiner or to improve reviewer perception of the practices applied in the adminis-tration of the operating test. 'The reviewer shall also note those aspects of the simulator examination that he thought were particularly 4 I well conceived and carried out, and shall make the examiner aware of those aspects. The discussion shall not be used to discuss the rer-formance of the applicant, and the reviewer shall not discuss the Pass / Fail decision to be made by the examiner. D. Documentation Required 1. Notes of and discussion between the reviewer and the examiner shall be documented'on Attachmer:t 3. 2. A copy of Form 157 and attachments to Form 157 shall be appended to Attachments 1 through 3. i 3. All original form 308s shall be retained by OLB. Copies of all forms shall be forwarded to the Regional Section Chief who shall be respon-sible for providing copies to the specific Region examiners who were reviewed. In the case of contract examiners, OLB shall be responsible for forwarding copies of these forms ~to the contract examiners. 4. All documentation shall be handled in accordance with OLB-MC-140, Confidentiality of Personnel Information, where appropriate. 4 4 3 l lL _2__

OLB-MC-320 01/19/89 ATTACHMENT 1 Review of Written Examination Administration Date of Review: Reviewer: A. Preparation for On site Administration 1. Exam in proper format. (ES-401.B and ES-401.C) YES NO 2. Room arrangement satisfactory (ES-201, Attachment 2, Enclosure 2) YES N0 3. Proctors properly instructed as to their duties. (ES-402.C) YES NO 4. Instructions per ES-201, Attachment 2, read to applicants. YES NO 5. The applicants were informed of the passing criteria. (ES-402.0) YES NO 6. Time limits for partial exams clearly stated to applicants. (ES-402.0) YES NO B. Examination Administration 1. Time rbmaining for the exam periodically made known to the applicants. (ES-402.D) YES NO 2. Candidates' exams properly collected at the completion of allotted time. (ES-402.0) YES N0 3. -Master copies of exams annotated with changes promulgated to the applicants. (ES-402.C) YES NO 4. Exam properly proctored. (ES-402.C) YES NO C. Facility Review of Examinations 1. Examination review by the facility in accordance with the intent of ES-201, Attachment 2, Enclosure 4. YES NO Comments: 4 ___________.m

OLB-MC-320 ] I-01/19/89 ATTACHMENT 1 (Continued) l l i I l I l 1 l 1 I 5 l 1

E '. g.< .g OLB-MC-320 01/19/89 ATTACHMENT 2 Review of Operating Test Administration Date of Review Examiner Reviewed Reviewer This form shall be used to review the administration of an operating test for which an individual examiner will be reviewed. A. Preparation for On-Site Administration. 1. The entire' operating test for one l applicant was given by one examiner. (ES-201.C) YES NO 2. Optimum simulator crew size was used whenever possible (ES--201.C) YES N0 3. No examiner.was scheduled to give operating tests to more than five applicants. (ES-201.0) YES N0 4. Unauthorized personnel were not l allowed to witness the exam. l (ES-302.B) YES NO 5. Instant SR0 applicants were evaluated on thdir ability to manipulate controls, as well as directing the activities of the RO's. (ES-301.E and ES-301.G) YES NO 6. Plant direction and control was evaluated for all SRO applicants. I (ES--301.G) YES NO l 7. If applicant's application was for j more than one unit, differences between j I the units and shared systems were NO l covered. (ES-301.F) YES B. Instructions per ES-302, Attachment I were read to the applicants. l (ES-302.C) YES NO 9. Was the applicant informed of results of examination. (ES-302, Attachment 1) YES, NO 10. Proper documentation was obtained if an q applicant withdrew from the examination I process. (ES-302.C) YES NO l 1 I 6 i

... ~ OLB-MC-320 01/19/89 ATTACHMENT 2 (Continued) B. Oral / Walk-Through Portion 1. Questions were asked at the level of the license applied for. (ES-301.G) YES NO 2. The applicant was evaluated on the proper number and type of systems / items in each exam area. (ES-301.G.2.b, ES-301.G 3.b, ES-301, Attachments 12 and 13) YES N0 3. At least three categories were evaluated for each system. (ES-301.G.2) YES N0 4. If an applicant was rated unsatisfactory for a system or item, another system or item was examined. (ES-301.G.2) YES NO 5. At least one emergency procedure was evaluated during the walk-through. (ES-301.G.2.b) YES NO 6. At least one entry into a radiologically controlled area was made. (ES-301.G.2.b) YES NO 7. For SRO applicants: a. Administrative requirements for an Out-of-Service piece of equipment was evaluated. (ES-301.G.1) YES N0 b. Ability as the Emergency Plan Coordinator was evaluated. (ES-301.G.1) YES N0 c. A planned radioactive release was evaluated. (ES-301.G.1) YES N0 d. Fuel handling was evaluated at the appropriate location. (ES-301.G.1) YES NO C. Integrated Plant Operations Examination l 1. Examiners (as a group) have previously l prepared and reviewed the scenarios. (ES-302.C.3 and ES-301.G.2) YES NO l 7 l L.

3* + OLB-MC-320 i i 01/19/89 ATTACHMENT 2 (Continued) 2. Examiners reviewed the scenarios with the simulation facility operator to ensure smooth operation of the simulator. (ES-302.C.3) YES N0 3. Malfunction initiation signals were set up with the simulation facility opera-tors prior to the start of the examinations. (ES-302.C.3) YES NO -4. Candidates were allowed time to check control board status after each simulator initialization. (ES-302, ) YES NO 5. The scenarios tested a?1 of the required number of Normal Evolutions, Instrument Failures, Component Failures,_ and Major Plant Evolutions. (ES-301.G.3 and Attachment 9) YES NO 6. The scenarios tested all of the required competencies. (ES-301.G.3 and 6 Attachment 10) YES NO, 7. Questions during the simulator examination did not distract the applic' ant from the simulation facility. (ES-302.C.3) YES NO D. Operational Test Documentation l 1. All notes were legible and complete on Form 157. YES NO 2. All U's were documented on Form 157. (ES-303.C) YES N0 3. All documentation on Form 157 for part C, Integrated Plant Operations, was properly supported by notes on i ES-301, Attachment 4 and cross-referenced to the appropriate competency. (ES-303.C) YES N0 4. Pass / Tail recommendations were consistent with Form 157 and its attached documentation. (ES-303.C) YES NO 8 u

l a. l 1 OLB-MC-320 01/19/89 l-l ATTACHMENT 2 (Continued) l S. For a plant without an acceptable simulation facility: a. ES-301 Attachment 4, Operator Actions, was filled out for each discussion and transient. (ES-302.G.3) YES NO 9 D l d i l 9 i l

f . r. OLB-MC-320 01/19/89 ATTACHMENT 3 Reviewer / Examiner Feedback Discussions Date of Review: Examiner Reviewed: Reviewer: F W I B i 1 10 -_}}