ML21051A001
| ML21051A001 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/12/2021 |
| From: | Gardner A - No Known Affiliation |
| To: | Office of Administration |
| References | |
| 85FR77280 00005, NRC-2020-0227, NUREG-1021 R12 | |
| Download: ML21051A001 (12) | |
Text
2/20/2021 blob:https://www.fdms.gov/1c8e1a9c-19d5-4feb-84b5-98c123c03f4f SUNI Review Complete Template=ADM-013 As of: 2/20/21 12:12 PM E-RIDS=ADM-03 Received: February 12, 2021 PUBLIC SUBMISSION ADD: Maurin Scheetz, Christian Status: Pending_Post Tracking No. kl2-k17w-a14u Cowdrey, Mary Neely Comments Due: February 16, 2021 Comment (5)
Publication Submission Type: Web Date:12/1/2020 CITATION 85 FR Docket: NRC-2020-0227 77280 NUREG-1021, Operator Licensing Examination Standards for Power Reactors" Comment On: NRC-2020-0227-0001 Operator Licensing Examination Standards for Power Reactors Document: NRC-2020-0227-DRAFT-0006 Comment on FR Doc # 2020-26460 Submitter Information Name: Andy Gardner Address:
Bridgman, MI, 49127 Email: ajgardner@aep.com Phone: 269-465-5901 x3088 General Comment Attached are the comments on behalf of D.C. Cook's Operations Training team.
Attachments Comments on NUREG-1021 Rev. 12 blob:https://www.fdms.gov/1c8e1a9c-19d5-4feb-84b5-98c123c03f4f 1/1
No. Section Comment/Basis Recommendation Section 1, GENERAL Missing statement "and the licensee shall first notify the NRCs regional Confirm if NRC contact is required during ES-1.2 step 3, page 1 of office to ensure that a point of contact remains available to respond to written exam and ensure it is added back in 1 6 questions." Is contact no longer required or not allowed at all? the section if so intended.
(line 41-46)
Indicates that applicants tablets, cell phones or other communication devices Add similar wording to the operating test are not allowed into the examination room for the written exam. There is no section if they are not allowed or add a ES-1.2 step 4, page 2 of corresponding statement about them not being allowed during the operating statement that they cannot be used if that 2
6 (line 10-12) test. is the intent. Another option would be to place the statement in the overall section covering all aspects of the exam.
States; answers will be documented vice questions from students Include questions and answers will be ES-1.2 step 7, page 2 of 3 Is the documentation of the question still required or only the answers documented if that is the intent.
6 (line 30) provided?
The following statement was removed: Many of the questions will require Add statement back in from Rev 11 if the you to use plant reference material, while others should be answered without intent is still for applicants to request ES-1.2, step 10, page 4 the use of references. If you need to consult a reference to answer a question, permission to use a reference.
4 of 6 ask the examiner if it is acceptable to do so.
(lines 34-35)
Should that guidance be added back for clarity?
Section 2, INITIAL PREEXAMINATION ACTIVITIES Is there any time limit on previous employment? Example if an examiner Add a time limit to this restriction.
ES-2.1 page 10 of 20 worked at a utility 10 years ago when the candidates were in initial non-5 (line 9-15) licensed operator training are they allowed to be part of the license exam?
References ACAD 10-001, Revision 1. Revised eligibility requirements are Revise to reference ACAD 10-001, Revision contained in ACAD 10-001, Revision 2, which will be released soon. 2 or make a general statement to reference ES-2.2, page 3 of 22 Additionally, the ACAD may be revised more frequently than NUREG 1021 to the latest revision of the ACAD 10-001 since 6
(starting on line 10) update programmatic requirements for initial license program content. A the NRC participates in the revision process revision stating to reference the latest revision of ACAD 10-001 or latest per INPO guidance.
revision of the NANT academy guideline for operator eligibility and selection.
Form 2.3-2 (revised op A bullet has been added under Walkthrough Criteria, that states; specific Provide clarification if the added bullet 7 test QA form), ES-2.3, designation if it meets alternate path criteria. results in new/additional requirements for page 10 of 19 alternate path JPMs.
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No. Section Comment/Basis Recommendation JPM cover sheets typically designate Alternate path. This information is also typically in the body of the JPM.
Section 3, INITIAL OPERATING TESTS ES-3.1, page 4 of 5 Steps 13.b and 13.c cover the same topic; using JPMs to test knowledge of the Consider combining the two steps into one 8 differences between plants on multiunit sites. step.
(lines 35 and 38)
ES-3.2, B.3.a. lists examples for Conduct of Ops Topics, including access Access controls for vital/controlled plant controls for vital/controlled plant areas. However, Rev 3 of NUREG-1123 areas should no longer be used as an ES-3.2, page 2 of 18 deleted KA 2.1.13, Knowledge of facility requirements for controlling example. Recommend replacement with a 9
(line 29) vital/controlled access. Thats the only KA statement that was applicable to new example.
that example.
ES-3.2, page 3 of 18 Bullet formatting is different than 3.a and 3. b. Consider closing bulleted lines (i.e. no space 10 in between each bulleted line).
(lines 26-32)
ES-3.2, B.3.c. lists examples for Radiation Control Topics, including radiation Radiation work permits should no longer ES-3.2, page 3 of 18 work permits. However, Rev 3 of NUREG-1123 deleted KA 2.3.7, the only K/A be used as an example. Recommend 11 (line 31) that was associated with radiation work permits. replacement with a new example.
ES-3.2, page 9 of 18 Definition/standard of alternate path JPM should be clearly stated in this Add clarification.
12 section since the term is introduced.
(line 20)
ES-3.2, page 12 of 18 senior reactor operator is spelled out, unlike RO, even though it is a Consider using SRO vice senior reactor 13 standard abbreviation (on list of abbreviations). operator for consistency.
Form 3.2-1, step 3 Text states the guidelines also apply to requalification examinations. It is Clarify how simulator testing guidelines unclear what specifically applies to requalification programs and what is specifically apply to requalification ES-3.3, page 1 of 17 inspectable per IP 71111.11, if anything. programs, if at all, and if IP 71111.11 will 14 (lines 5, 6 and 22, 23) change to incorporate those specific Clarify if the guidelines only apply when the NRC writes a requalification exam requirements.
per ES-6.
Step 2 states the IC should be representative of a typical plant status with Revise to state: the IC should be various components, instruments, and annunciators out of service. Although representative of a typical plant status, ES-3.3, page 1 of 17 15 this is not a change from Rev 11, it seems to denote an unnecessary which may include various components, (lines 42 and 43) requirement by not allowing clean ICs instruments, and annunciators out of service.
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No. Section Comment/Basis Recommendation The last sentence of the paragraph states: As such, the operating test should Add unless in the sentence to clarify the not include such events they are necessary to set the stage for subsequent statement.
ES-3.3, page 2 of 17 16 events or to test the SRO applicants knowledge of TS actions. It appears the (line 18) word unless should be included before they.
ES-3.3, page 5 of 17 The word with does not seem to belong in this sentence. Remove with or revise to clarify intent.
17 (line 10)
This states a component/instrument failure that occurs before the major Please provide a positive example of using could be credited for actions before AND after the major provided the actions this allowance.
to deal with the failure are different when comparing the response before and after. The provided example of excess letdown demonstrates when this could ES-3.3, page 8 of 17 18 NOT be used since putting excess letdown actions are the same both before (starting at line 8) and after the major. Is it acceptable to count the same malfunction twice, once before and once after the major, provided the actions to address the failure are different?
ES-3.3, page 10 of 17 Formatting is different for the Combustion Engineering PWR as compared to Close bulleted lines (i.e., no space in item 3, the others (double spacing between bulleted lines). between each bulleted line).
19 (lines 42, 43) and page 11 of 17 (line 1)
Recent changes to the BWR Owners Group guidelines have changed the setup Consider adding statement that the on some contingency procedures. Specifically, Alternate Level Control is no identified contingency procedures need not ES-3.3, step 5, page 10 longer a separate contingency procedure and has been added to the RPV be standalone EOPs and may be included in 20 of 17 Control EOP. It is still an EOP contingency path/procedure and should be the base EOPs.
treated as such.
All of these sections describe a missed CT or CPD as UNSAT or resulting in an Recommend maintaining a missed CT or automatic failure of the simulator operating test. CPD as a 3-point deduction to avoid ES-3.3, step k, Page 11 unnecessary elimination of competent of 17 (line 45)
Previously, a missed CT or CPD resulted in a 3-point deduction versus an operators from the licensed operator ES 3.6, page 4 of 27 21 automatic failure. Additionally, a single error in any of the other portions of pipeline.
(line 43) the NRC examination will not result in an automatic failure.
Table 3.6-1, page 6 of 27 Raising the grading threshold (i.e. making it harder for an applicant to pass) should be limited to closing gaps with licensing applicants that were 3
No. Section Comment/Basis Recommendation determined to not display the minimum requirements necessary to be licensed as competent licensed operators.
There is no evidence that the current grading criteria is inadequate to license competent applicants and the change was made as one of the actions to improve grading clarity and consistency. Many of the other changes including the new SPD category resulting in a 2-point deduction for errors of higher significance in addition to increasing clarity around PD grading will help improve grading clarity and consistency without the need for increasing the significance to automatic failure for a missed CT or CPD.
NRC evaluation of 417 previously examined licensed operator candidates graded with the proposed NUREG-1021, revision 12 grading criteria resulted in a 2.4% increase in failure rate (11 additional failures, 1 additional pass).
Additionally, the elimination of a broad category of items contained in Rev 11 that can constitute a critical task will make scenarios longer, more complex and increase difficulty, which was not evaluated in the NRC evaluation and is expected to further increase the failure rate.
The projected increase in failures will result in the loss of competent operators from the licensed operator pipeline impacting line organization staffing and unnecessary expense to the industry without a corresponding improvement in public safety.
Critical Task Methodology is described and discussed in this section. Step C.1 Proposed Replacement Language for Page is Identifying Scenario-Specific Critical Tasks and directs scenario developers 13 of ES-3.3:
to apply guidance to IDENTIFY and DESIGNATE CTs. [emphasis added] The developer should apply the following The list of items provided mainly describe Applicant actionswhat Applicants guidance to identify and designate CTs in must do or not do when responding to plant conditions to satisfactorily conjunction with facility CT lists or in the address the CT. When developing CTs, the author can only know what actions absence of such a list:
ES-3.3, page 12 of 17 22 the applicants SHOULD take, based on the procedural guidance and projected Do conditions exist which represent (line 38) plant response. The author CANNOT know, at this point in the process, what significant safety challenges? Examples actions the applicants WILL take when they perform the scenario. The list of include the following:
bullets on page 13 appear to be a description of how to determine if a post-
- Conditions that warrant initiation of scenario CT has been created. Rev. 11 CT methodology describes how to emergency depressurizations (BWR) determine whether a proposed malfunction is a safety-significant CT.
- Conditions requiring orange or red path CSF response (W and AP1000) 4
No. Section Comment/Basis Recommendation Recommend replacing these bullets with similar content to Rev. 11 describing
- Conditions that warrant how to determine safety-significance and moving these bullets to the post- performance of FRG transition (CE) scenario CT discussion. The proposed guidance cannot be followed as written
- Conditions that warrant declaration since the authors and examiners cannot know what actions an applicant may of SAE or GE take in the future. Conditions which are beyond the control of the crew or which are irreparably introduced by the scenario should not be designated as CTs.
This paragraph uses the term examination developers. Other text uses Use examination authors throughout.
ES-3.4, page 1 of 9 23 examination authors and examination writers. For consistency and (line 9) clarity, using a common term is suggested.
ES-3.4, page 1 of 9 Bullet 3 regarding Scenarios extracted should be deleted since this Delete bullet 3.
24 requirement is encompassed in bullet 2.
(line 39)
ES-3.4, B.1, third bullet conflicts somewhat with the example immediately The example after the third bullet should after. Third bullet says SRO-I needs to be evaluated in either the BOP -OR- say while the SRO-I applicant is in a ES-3.4, page 3 of 9 25 ATC position. There are no conditions similar to the 301-5 in Rev 11 (Form reactor operator position.
(line 2) 3.4-1 in Rev 12). The example immediately after seems to specify ATC position since lead operator was defined as the ATC in the bullet before.
Scenarios and written exams are performed in different contexts and are Remove written exam check.
ES-3.4, page 3 of 9 separated in time. To exclude and cross-check thirty to fifty (or more) 26 (line 19) scenario elements against 100 written exam questions will be very time consuming and provide very little benefit in exam quality.
ES-3.4, page 3 of 9 This is essentially that same as, and redundant to, what is one page 2, lines Eliminate redundancy.
27 22-26.
(lines 25-29)
Regarding use of surrogatesregional management should have the authority Eliminate need to consult with NRR on use to permit the use of surrogates in order to streamline performance of the of surrogates to streamline performance of ES-3.4, page 3 of 9 28 operating test without NRR involvement. Some chief examiners are reluctant the operating test. Recommend (lines 31-33) to contact NRR and therefore unnecessarily limit operating test efficiency. replacement with regional branch chief concurrence.
Rev. 11 includes a broad category which will no longer be CTs per Rev. 12 Recommend changing CT criteria to at criteria (failures which lead to trip conditions if not properly and promptly least 1 (versus 2) per scenario since the ES-3.4, page 4 of 9, addressed). This leaves only EOP-Based CTs available to meet the at least 2 population of events in a typical scenario 29 Table 3.4-1 criteria. Maintaining the requirement to have 2 CTs per scenario while that can result in a critical task have been removing a large batch of what constitutes a CT will make scenarios reduced.
potentially longer and more complicated. In addition, considering a CT failure 5
No. Section Comment/Basis Recommendation will result in a critical performance deficiency (CPD) and an automatic failure Additionally, limiting the maximum number of the operating exam, existing CTs that are not commensurate with a penalty of CTs to 2 would reduce the likelihood of of this severity will likely not be applied in future initial licensing having scenarios that are too long or examinations. For example, at some BWR stations, inserting a manual scram complex and may help in consistency in on a 2nd control rod drift is used as a critical task. The safety significance is scenario development.
avoiding potential fuel damage due to an unanalyzed control rod pattern.
This seems likely to be omitted as a CT on Rev. 12 based exams due to the severe penalty not aligning with the safety significance (i.e., potential fuel damage).
There is no definition as to what constitutes a scenario set as it applies to Recommend adding a statement identifying ES-3.4, page 4 of 9, contingency EOPs. The requirement is for one contingency EOP per scenario a scenario set means the scenarios the 30 Table 3.4-1 set, but theres nothing that clarifies if that means each operator must be individual operator will see and not the set (line 3) evaluated with a scenario that contains a contingency EOP. of scenarios selected for the overall class.
Having at least 1 Manual Control of Automatic Function event for RO and Develop a list of new requirements and SRO-I applicants represents a new requirement as compared to Rev. 11. It process changes being implemented in Rev.
would be helpful to the industry for the NRC to specify any other new 12.
ES-3.4, page 4 of 9, requirements in Rev. 12 (other than the obvious ones the industry and NRC Additional guidance on what qualifies as 31 Table 3.4-2 have already discussed). This will help ensure the industry is fully aware of manual control of an automatic function any new requirements when Rev. 12 is implemented and can conduct proper may also be required. For example, does change management for corresponding station exam development placing the backup EHC pressure regulator procedures/processes. in service qualify?
The last sentence in this paragraph states the ODCM cannot be used to meet Clarify whether the TRM can be used to ES-3.4, page 5 of 9 32 the minimum TS evaluation requirement. Can the TRM be used to meet the meet minimum TS evaluation requirements.
(lines 38-40) minimum TS evaluation requirement?
ES-3.5, Page 1 of 13 The term error is used in several cases in ES-3.5. Should performance Clarify/modify as necessary.
(line 40) deficiency be used instead?
Page 11 of 13 33 (lines 21 and 33)
Page 12 of 13 (lines 43 and 46)
The last sentence in section A.2 is missing some words. It should probably Modify as necessary.
ES-3.5, page 1 of 13 state (Obtain) concurrence from the NRR operator licensing program office 34 (line 29) (if) more than 30 days will elapse between the completion of one and the start of the other.
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No. Section Comment/Basis Recommendation ES-3.5, step 7, page 4 Grammar/typoremove that from item #7. Remove that from item #7.
35 of 13 (line 24)
ES-3.5, page 9 of 13 Grammar/typo in section 16.a - perform should be performed. Change perform to performed.
36 (line 20)
This states an SPD exists if an avoidable emergency action level entry or Consider a threshold of ALERT for meeting ES-3.5, page 9 of 13 escalation is reached. the criteria of an SPD.
(line 42-44) 37 ES-3.6, page 5 of 28 An error resulting in EAL entry or escalation at the Unusual Event level does (lines 12-13) not require staffing the emergency response centers or have increased safety consequences.
The note states that subsequent RPS/ESF actuations that do not alter Consider revising current note or add an ES-3.5, page 9 of 13 equipment alignments are not treated as additional significant performance additional note that single channel (line 32-40) deficiencies. Other examples that shouldnt be considered an SPD would be actuations or half scrams should not be 38 ES-3.6, page 5 of 38 single channel actuations or half scrams. These would not alter equipment considered an SPD.
(lines 5-10) alignments or only open reactor trip breakers that would not result in an automatic scram.
This states an SPD exists if performance deficiencies result in an unplanned Consider adding a statement that placing ES-3.5, page 9 of 13 power change of more than 10 percent rated thermal power. The intent is the the plant at a lower power level as a result (line 46-47) SPD is due to inadequate power control. At times unit supervisors could direct of conservative decision making would not 39 ES-3.6, page 5 of 38 reducing or controlling power at a lower power level due to conservative apply to this criterion.
(lines 15-16) decision making. Conservatism is an operator fundamental that is strongly reinforced by the utility training programs.
As written, step 17 may cause confusion. To add clarity, consider modifying with the following wording; If a simulator scenario includes emergency plan event classification, because the simulator operating tests for the initial licensing examination are Since the simulator operating tests for the conducted with only one applicant in the SRO position, the NRC does not initial licensing examination are conducted ES-3.5, step 17, page require the SRO applicant to complete an emergency classification within the with only one applicant in the SRO position, 40 10 of 13 normal event classification period of time. The scenario does not need to the NRC does not require the SRO applicant (lines 14-18) include event classification. to complete an emergency classification within the normal event classification period of time. The scenario does not need to include event classification.
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No. Section Comment/Basis Recommendation PD and PDs are used throughout this section, as is performance Add PD to Abbreviations and Acronyms for deficiency. CPD and SPD are included in the Abbreviations and Acronyms consistency.
41 ES-3.6, throughout section, but PD is not.
The paragraph states; Consider the following recommendations to this area to reduce subjectivity to benefit Applicants will be held accountable for CPDs corrected by other members of examiners and to account for the increased the control room team. If an applicant neglects to take an action or takes an safety significance.
incorrect action and is subsequently corrected by a team member, the examination team will determine the impact of that lack of action or incorrect A PD associated with performance of action on the scenario as it relates to a CT. The measurable performance actions in support of completing a CT standard for this type of CT depends on the consequence of the applicants requiring intervention by other crew lack of action or incorrect action if the crew had not corrected it. members to complete the CT would be an SPD if the applicant would not have been This introduces grading subjectivity, especially if the critical task was able to identify and correct the error in a met/completed. PDs such as procedure usage or place keeping errors or timely manner (i.e., before the CT would be ES-3.6, page 4 of 27 intervention by other crew members may be graded as a CPD. In many cases, unrecoverable).
42 (lines 35-40) there may be no way to determine if the applicant would have caught and corrected the error in a reasonable amount of time during the scenario.
While we recognize that there will be a level of judgement by the examiner when evaluating a performance deficiency in this area, this will likely lead to additional candidate appeals if a CPD is assigned, resulting in automatic simulator examination failure even if the associated CT itself was completed.
There may have been an opportunity for the candidate to self-identify and correct the error without the intervention but control room teams are trained and expected to immediately coach and correct behaviors when standards are not being met or errors are identified. Additionally, this change may result in less challenge between members of the operating crew.
ES-3.6 Page 6 of 27 The term error is used in several cases in ES-3.6. Should PD or Clarify/modify the use of error as desired (line 16) Performance deficiency be used instead? Or in some cases, error can be and remove the word for on page 6, line 43 Page 8 of 27 (line 6) eliminated from the sentence. 16.
Page 9 of 27 (lines 6 and 9) 8
No. Section Comment/Basis Recommendation CPDs should not be assigned to understanding RFs. The applicant needs to Recommend not allowing CPDs to be demonstrate the inability to take CT-level safety-significant actions to result in assigned to understanding RFs.
ES-3.6, page 6 of 27 44 a CPD. Should not be based on failing to provide a correct answer to a follow-(line 17) up question.
The departure from nucleate boiling TS example provided is PWR specific. Consider using a TS example that is ES-3.6, page 8 May be beneficial to use an example that applies more generically to other applicable to all reactor technologies.
45 (line 26) reactor types.
With only three RF points to work with, the allowance to assign multiple PDs Consider simplifying and adjusting grading for each TS in a single event is not proportional. Each TS event should be criteria described in this section.
46 ES-3.6, page 8, 9 limited to one PD normally.
The assignments of CPDs (or even SPDs) in Communications seems excessive. Consider simplifying communications ES-3.6, page 10 All communications errors should be assessed as a PD after the first one. This competency RFs.
47 (line 35) may make grading simpler and more consistent.
ES-3.7, page 1 Step A.4 - a period is missing from the end of the sentence. Add period.
48 (line 21)
Section 4, INITIAL WRITTEN EXAMINATIONS None Section 5, INITIAL POSTEXAMINATION ACTIVITIES AND OTHER LICENSING ACTIONS None Section 6, NRC-CONDUCTED REQUALIFICATION EXAMINATIONS ES-6.1, step 5, page 8 postexamination should be hyphenated. Change postexamination to post-49 of 33 (line 21) examination Regarding first and second retakes, the document does not specify whether a Consider adding a statement that a second ES-6.1, H.2.c and d, 50 second retake is required following passing the first retake. retake does not apply following successful Page 14 of 33 completion of the first retake.
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No. Section Comment/Basis Recommendation Note that this is not a change from ES-605 (page 13), and it implies a second retake isnt necessary following passing of the first, but may be added in the interest of clarity.
ES-6.1, Page 15 of 33 Form 6.1 Has no title description Include form title.
51 (line 21)
ES-6.1, Page 15 of 33 Form 6.1 Has no title description Include form title.
52 (line 46)
Form 6.1-3, ES-6.1 Preexamination and Postexamination should be hyphenated. Change Preexamination and Page 20 of 33 Postexamination to Pre-examination 53 and Post-examination.
Under III. Quality, Exam Section goes from; A. Sample Plan to C. Move the guidance for written exam quality ES-6.1, Page 23 & 24 of Walkthrough from revision 11 to revision 12.
54 33 It appears that there should be another section for; B. Written Exam The page number shows 2 of 33 versus 26 of 33. Correct the page number to 26 of 33.
55 ES-6.1, Page 26 of 33 ES-6.3, page 2 of 7 The sentence systems that are the subject of NRC information notices is a Make sentence its own bullet.
56 (line 3) separate thought from the one above and should be a separate bullet.
Section 7, FUEL HANDLING EXAMINATIONS None Section 8, GLOSSARY None Appendix A: Overview of Generic Examination Concepts None 10
No. Section Comment/Basis Recommendation Appendix B Examples of Written Examination Questions Tier 4 Theory is new to the written examination and previously used generic Add examples of plant-specific, examples of reactor and thermodynamic theory questions may or may not be operationally valid theory questions to acceptable on final licensing examinations. There would be a benefit to Appendix B to aid the facility Examination develop examples to include. Authors in developing satisfactory 57 Appendix B operationally valid theory questions (refer to NEI letter on Generic Fundamentals Reintegration, Appendix 1, Recommendation 1, dated March 4, 2020 (ML20083F400).
OTHER COMMENTS Revision 12 Recommend removing blank pages to 58 General Comment reduce document size.
Several blank pages 11