ML22230A116
| ML22230A116 | |
| Person / Time | |
|---|---|
| Issue date: | 09/13/1979 |
| From: | NRC/OCM |
| To: | |
| References | |
| Tran-M790913 | |
| Download: ML22230A116 (67) | |
Text
RETURN TO SECRETARIAT RECORDS
NUCLEAR REGULATORY COMMISSION
IN THE MATTER OF:
PUBLIC MEETING
BRIEFING ON SECY-79-330E - REPORT ON CURRENT NRC.
REQUIREMENTS AND GUIDANCE TO LICENSEES FOR QUALIFICATION OF REACTOR OPERATORS
(See also SECY-79-330F)
Place -Washington, D. C.
Cate - Thursday, 13 September 1979 Pages 1-65
Telephone:
( 202) 347-3700
ACE - FEDERAL REPORTERS, INC.
Official Reporters 44.4. North Capitol Street
- Washington, D.C 20001
NATIONWIDE COVERAGE.* DAILY CR7035 1
DISCLAIMER
This is an unofficial transcript of a meeting of the United States Nuclear Regulatory Cormnission held on Thursday, 13 September 1979 in tJ1e Commissions's offices at 1717 H Street, N. W., Washington, D. C. The meeting was open to public attendance and observation. This transcript has not been reviewed, corrected, or edited, and it may. contain inaccuracies.
The transcript is intended solely for general informational
. purposes. As pro-vided. by 10 CFR 9.103, it is not part of the formal o:t inf.ormal record of decision of the matters. discussed~ Expressions of opinion in this transcript do not*necessarily reflect final determinations or beliefs. No pleading or other paper may be filed with the Commission in any proceeding as t.."le result of or addressed to any statement or argument contained herein., except as the Cormnission may authorize..
CR7035 2
UNITED STATES OF AMERICA
- 2 NUCLEAR REGULATORY COMMISSION
3
- 4 PUBLIC MEETING
5 BRIEFING ON SECY-79-330E - REPORT ON CURRENT NRC REQUIREMENTS 6 AND GUIDANCE TO LICENSEES.FOR QUALIFICATION OF REACTOR OPERATOR
7 (See also SECY-79-3J0F)
8
9 Room 1130 10 1717 H Street, N. W.
Washington, D. C.
11 Thursday, 13 September 1979 12 The Commission met, pursuant to notice, at 2:10 p.m.
13
- BEFORE:
14 VICTOR GILINSKY, Commissioner 15 PETER A. BRADFORD, Commissioner 16 JOHN F~ AHEARNE, Commissioner 17 PRESENT:
18 Messrs. Engelhardt, Case, Snyder, Bickwit, Chilk, Gossick, 19 and Malsch.
20
21
- 22 23
.24 Ace-Federal Reporters, Inc. -
25 035 01 01 3 COMMISS!Oi~ER GILINSKY: The Chairman will be
- 2. delayed for a little while and asked me to start the
3 meeting. Mr. Bradford will be in very soon.
4 So the subject is qualification of reactor
- ) operators. So Mr. Case, letJ' s proceed.
6 MR. CASE: Yes, D.r. Gilinsky.
~e are here today to discuss the staff 8 recommendations in SECY 79-330(E) 3nd the implementation
~ schedule related to those recommendations in 330(F). As you
10 know, as background information we prepared a number of 11 Commission papers on the subject and they are covered in the 12 other SECY series on this same number.
13 The first point I would like to make today is,
14 what we are recQmmending here are the first steps in
15 long-term programming. We do not represent that thase are 16 the only things that ought to be done to upgrade reactor
1, training and qualifications, but we do represent that these 18 are reasonable first steps, and we hope that you will agree
lY with us that they ought to be approved and implemented 20 promptly.
21 COMMISSIONER AHEARNE: In other words, to use a
22 phrase made famous, you believ~ these are not. necessary and 23 sufficient.
24 (Laughter.)
25 MR *. CASE: We believe they' re necessary, but not 035 01 02 4
MM mte t necessarily sufficient.
2 Further studies in this area are expected to b3 3 conducted. As Commissioner Ahearne knows, we are working
4 with his st~ff on the scope of some studies on Navy
.:J comparisons
- 6 We have other recommendations in this area that
7 have been received and are under consideration by the staff a now. For example, the Director of Standards provided us a
9 memoranda, I believe yesterday or the day before, with some
10 further recommendations. I do have and recently received a
11 recommendation from a reactor inspector at Region II, which
12 I personally think his recommendations have considerable
13 bearing. Those are under consideration.
14 Other recommendations are expected in this area.
- 15 The lessons learned long-term studies.will have something in
16 this area.
l ' COMMISSIONER GILINSKY: Whatever happened to the
18 suggestion that the representative of the Navy program tell
19 us --
20 MR. CASE: My under standing of that, Commission er
21 GilinskY, was that Admiral Rickover was awaiting a call from
22 some Commissioner on the subject if there was that much
23 interest~
24 _COMMISSIONER GILINSKY: Well, we-~11 give him a
- 25 call.
035 01 03 5
.MM mte COMMISSIONER AHEARNE: I thin'< it was a specific
2 Commissioner he was interested in.
3 MR. CASE: Obviously, I think the Presidential
4 Commission may have* some recommendations here on the special
- ::> inquiry *. Also, there are some possible Congressional
6 studies that may have to be conducted. In the Hart
I Committee's version of the appropriation bill, there is a
8 requirement for a six-month study on operator training,
';) retraining and licensing.
10 All this to point out that this is the first step.
11 COMMISSIONER AHEARNE: Vic, _we did get a pap.er.
12 MR
- CASE: Yes.
13 COMMISSIONER AHEARNE: On the Navy system.
14 MR. CASE: With that background, I'll turn it over
15 to Paul, w.ho. wi 11 go over the recommendations one by one and 16 the implementation schedule for your benefit. Any
1 1 questionsr he will be glad to answer.
18 MR., COLLINS:* In the SECY 79-330(E), we discuss 23 19 options, and of the 23 options we recommended, we made 16 20 recommendations.
21 May I have the* first slide, please?
22 CS 1 ide. )
23 ( In my* _discussion with you. on April. 20, we talked 24 about requirements. to *sit for* the* examination and* we
- 25 reviewed*,ttiese,,. and we* think that for the. reactor
.. *.*,,-. * *>** -:.. *** * * ** * *,.,* *. r,_~***** * '* *.* :.*
- ~1:J~~[!M:~~,~:~illf.:,(;::;i;,fat.;,.
033 01 04 6 MM mte operator there need be no changes, out for the senior
-.2 reactor operator we thought that we had to increase the
3 requirements to four years of operating experience, two
4 ye.ars of which should be nuclear, and six months of this
- ) experience should be gained at the site that seeks the
- S l icen sing.
l ifa define' 11 operating experience-11 as a nuclear
8 plant staff engineer or control room operator, and we-"11
,) giva two years of credit for academic work.
10 (At 2:12 p.m., Commissioner Bradford entered the 11 room. )
12 COMMISSIONER AHEARNE: Could you comment on how
13 You believe that contrasts with the NavyJs requirements for
14 its selection of people?
- 1:5 MR. COLLINS: If you would indicate -- if you 16 would equate the senior operator
1 I CO MMISS !ONER AHEARNE: The basic opera tor.
18 MR. COLLINS: The bas i~ operator, I would have to
19 re f:ff to the. paper on it. I-" m not sure, since we are 20 talking about a senior operator and we, left the other 21 opera tor* out -
22 COMMISSIONER AHEARNEz I know, but you reached a
23 conclusion* that you wouldn't make any changes in the 24 qualifications of the operators. So I am asking you,
- 25 because I want to ask you what - for what reasons you 7
'035. 01 05
Mivl mte chos~ not to provide more qualifications tor the basic
2 operator?
3 Mr1. COLLINS: In the Navy pro9ram, the operator-s
-t would go through a pre-nuclear training program and then
~ they would-go through ac~demic* instr-uction and operational 6 training on the DOE Army-Navy reactor prototypes.
l. CO MMI SS I ONER AHEARNE:. How would they be chosen
8 or igi nall y?
9 MR. COLLINS:. They take the top ten percent, I
10 believe, out of the craft schools or the rating schools that 11 thes~ people attend.
12 MR. CASE: I think the basic requirement is high
13 school or equivalent.
14 toMMISSIONER AHEARNE: They do have a screening where they take a certain selected subset, and I wondered,
16 in.our.review~ what were the arguments that convinced us
1, that we shouldn't place some similar type of quality
18 screening.
19 MR. COLLINS: We didn't - we didn-' t even consider
20 ge*tting into the screening of people to enter into training
21 programs.*.
22 *. COMMISSICJNER AHEARNEz. Why?
23 MR. COLLINS: We felt this *was the responsibility
24-of the uti1ities, to _select and hire people and bring them
2:5 along_ in the' selection* procedures *.
035 01 06 8
]vfa( mte. I C_OMi\\HSS IDN!;R AHEAKNE: So we concluded there was
,2 no raason for us to place a~y kind of requirement as to who 3 might be *eligible for the training?
4 MR. COUINS: No -- yes. We felt that there was
.:) no need to get that deeply involved in the selection of
6 people.
7 COMMISSIONER AHEARNE: I see.
g TVA,. when they were here, mentioned and their
9 report ~ehtioned that they were considering placing on some
)J a ddi t iona l screening requirements, for ex amp.le, using an IQ*
11 -test. And I don't know if they also were going to go into 12 any other kind of skill test.
13 Did we consider doing anything like that?
14 MR~, COLLINS: No, we didn't.
- )j COMMISSIONER AHEARNE: Any particular reason?
16 MR. COLLINS1 The main reason is our regulations
I I at present address the final product, rather than go back
1a into the selection of the initi~l people. *Many u~ilities do
19.* use selection procedures right now. They do give IQ tests, 20 mechanical aptitude tests, and I'm not sure whether they
21 give psychological tests or personality testing or not, but 22 they do have selection.
23* *
- COMMISSIONER AHEARNE: But. we concluded it was not
. '24 s*omething, that* we* thought *nec.e.sscfry?
-- 2:5 MR. COLL INS:.. Yes, sir.
9 035 01 07 COMMISSIONER AHEARNE:
- Now, we are also going to
2 con~rast these senio~ operator requir~ments?
3 MR. COLLINS: Yes. All right, the senior operator
4 Versus the officers from aboard ship. The officers aboard
5 ship are normally college graduates, and then they proceed 5 through training programs that are similar in scope, to the training programs that the senior operators have to have.
a I think that we are different in that we hav3 four
~ years of operating experience, whereas the officers or the 10 junior officers, at least, they come out of the Academy
JI right into the training program, and then aooard nuclear 12 subs.
13 COMMISSIONER AHEARNE: And your arguments as to
14 why our approach is better?
15 MR. COLLINS: Well, in our recommendations in SECY 16 330(:E), we were not attempting to benchmark that paper 17 against the 330(E), the Navy paper.
18 COMMISSIONER AHEARNE: I recognize that. But in 19 some sense, I think you were saying that you have evaluated 20 the requirements we placed on operators.
21 MR.. COLLINS: But not from the foe us of how does
22 the Navy do it.
23 COMMISSIONER 'AHEARNE: I understand that. But
24 there is an organization that has had at least some
25 reasonable amount of success with its system. And IJm not
~,.-*.
- ~:,_s:*~~.:c*i*({,;. ~:,:~. -~:*:.,;>_;
- 035 01 08 10
.'AM 'Tlt-9 saying it snould oe used as a benchmark, but it certainly is
- 2 a s;stem that ought to be examined to see whether or not
3 ther9 are facets of it which we ought to be following. I"m
- not saying we should be following in this particular one.
~ I-'m just merely raising the question: Have you considered
5 it?
l MR. COLLINS: No, we did not.
- When we went
8 through our recommendations in 330CE), we took a look at
--) present practices and saw where we thought there were
10 weaknesses and said, here are the areas where we can improve
11 the practices. ~e did not benchmark it to any degree
12 against any other government agency or any other plans and
13 programs.
14 COMMISSIONER AHEARNE: l'lhen you say you looked at
- 1 :5 and found weaknesses, against what were you determining you
16 hav& weaknesses? -~hen you mentioned the Navy program as a
I ' benchmark, was it then a suojective evaluation?
18 MR. COLLINS: We took a look at the applicants
19 being put up for senior operator and we took a look at the
20 requirements for senior operator,. and we felt that some of
21 the applicants just were not measuring up to these
22 responsibilities, and that in a good many cases utilities
23 were putting up people for senior licenses as a matter of
24 convenience, so they could meet certain port ions of the
- 25 regulation. But they really weren"t going to use them in a 035 01 09 11
full senior capacity.
So we decided that, since the senior operator was 3 going to tak~ on and should indeed have this command
4 responsibility, and since our examination should be geared
~ in that direction, then we felt that indeed the requirements
.S that. would allow these other people to sit for an
/ examination were too weak. And so we decided that requiring
- 8 four-years of operating.experience, two nuclear, as this
9 indicates, that this would give us this assurance that 10 people that were put up for senior operator wouid be the.
11 command-type person we-~ re looking for.
12 COMMISSIONER AHEARNE: Did you give any thought to
13 changing the current requirement that has high school
14 graduate or equivalent?
J:j. MR. COLLINS: No, we didn~ t. We have* no evidence
16 that indicates that *these people, based on their education,
1, were not able to assume this command responsibility.
18 COMMISSIONER AHEARNE: I was really focused more
1~ upon the equivalent.
20 MR. COLLINS:* We have changed the equivalent to 21 require the state certification in lieu of or.th Army-Navy
22 certifications in lieu of the high school education, but
23 nothing else. Ona or the other.
24 COW,{! SSIONER AHEARNE: The Army-Navy, about three
25* years ago,. three and a half years ago, dropped the 035 01 10 12 MM mte 9quivalent of high school.
- 2 MR. COLL INS: I
- was unaware of that.
3 MR. CASE:. For enlistees or
4 COMM! SS I ONER AHEARNE: Well, where they used to
J have a requirement of high school diploma or equivalent for
6 their better program, they shifted to high school diploma.
I It was Just past evidence indicating that - it wasn't if
8 you don't get a diploma it means there's something wrong.
9
- It more means that the discipline required to get the
10 diploma was another added attribute to the screening.
I I And I just wondered whether we had ---
12 MR. COLLINS: Abo.ut 70 percent of the senior
13 opera tors do have some co.llege. 35 or 40 percent are
14,' college graduates.
-fbrl. IS
16 II
18
19
20
21
22
23 24
2:5 035.* 02.1 13 gsh MR. COLLINS: Next slide,,o lease.
2.(Slide.)
- 3 Now*-the second recommendation also involves the
4 senior operators. With the exception of those applicants that
~ maka initial application for the cold examinations, the
6 initial crew, we felt it would be best if in addition to
, previous experience we showed that oefore they applied for
8 a sanior operator license, they have six months as an
9 operator.
10 So~* in effect, after a plant becomes operational,
11 we will no longer administer instant senior examinations.
12 - CO MM ISSI C)NER GIL INSKY: I don't understand how that
13 relates to the first recommendation, where you-'re talking
- 14 about two years' nuclear experience.
I :5 That would not have to be as an operator. Is that
16 the - i de a?
I ' MR. COLLINS: That's-correct. We indicate that that 18 could be g~ined solely as a nuclear plant staff engineer.
19 COMMISSIONER GILINSKY: I see. - Is it a good idea 20 for someone to go cold into a position of senio~ operator?
21 MR. COLLINS: Yes, it's an absolute* essential.
22' _ COMMISSION_ER GILINSKY:- Why is it essential?
23 ** MR. COLLINS: There's 'no way you can load fuel at 24 a new-power *plant unTess you have senior operators present.
2::5 -
- So it's necessary for them when - they sit at that plant -
035.02.2 14
C0MMISS"I0i~ER GILINSKY: A senior operator for that
- ')lant. But. you -could have a.senior operator who is -
3 C0MMISSIDl'iER AHEARNE: Had operating experience.
COMMISSIONER GILINSKY: Has had.operating experience,
~ has had senior operating experience *
.5 MR. COLLINS:. 1ie feel the cold training program
7 theY go through are designed to give them this type of
8 experience ~'."'" the simulator, the three--months simulator
-J training program, the basi*cs, design lectures, the simulator
10 program.
I 1 COMMISSIONER GILINSKY: Is it possible to go to the
12 senior operator status without ever ~aving operated a plant
13 before?
14 MR. COLLINS: The cold itatus?
13 COMMISSIONER GILINSKY:. Yes.
16 MR. COLLINS: A person could go through our training
11 program and now he*'s going - he's still going to have to 18 meet the four years of operating experience, one year. nuclear
19 expeiience, will be given credit for this particular training
20 that he goes through, and the other year nuc 1 ear power pl ant 21 experience can come during the first-year of power plant -
22 during the last year of power plant construction when he*'s
23 checking. out the.equipment
- 24. COMMI.SST0NER AHEARNE: What _would be the problem if
25 we al so required 12 months.* of actual holding. operator 035.02.3
licensing?
Ma. COLLINS: Numbgr one, you would have to get the 3 sister utilities that are operating these p6wer plants to
4 agree to take on all these trainses.
J That.was on~of the pfime reasons why we developed
(
6 the cold training programs used in the.simulator, was that
l therg were no -- that the utilities did not want to use the
power plants as training facilities~*
COMMISSIONER GIL INS KY: But you can't go to -- you
10 can't become*a captain.of a 747 without ever having flown an
11 airplane. It sounds to me l.ike there's something wrong--with 12 this approach, to tell you the truth.
13 COMMISSIONER AHEARNE: Is that the principal reason.
14 that the other utilities.were -
1s* MR. COLLINS: Yes, I"'d*say it is, that a.one thousand
16 megawatt plant is designed to be base-loaded, produce a
11 thousand megawatts of electricity, and to put trainees into 18 that atmosphere.
19 COMMISSIONER AHEARNE: Why is it necessarily a
. 20 trainee? If a person is an operator and if the requirement is 21 to be a* senior operator, you must have b.een an operator for
22 a year.. L would think -
23 MR. COLLINS:: Then you would be* encouraging pirating 24 from other ut.i li ties" wouldn" t you?
25 COMMISSIONER AHEARNE: *or promotion.
035.02.4 16 COMMISSIONER GILINSKY: What you are.saying is the way the utilities are organized has mada it difficult to 3 train operators i~ a way that we might otherwise have trained them.
~ Mct. SNYDER: Paul, I just wonder, have you taken 6 into account the recent EPRI organizational moves?
COLLINS: No.
3 MR. SNYDER: There is a proposal before their 9 organization now to establish a training orga~ization Which 10 would be across~the-board for utilities and could very well 11 solve the 12 MR. COLLINS: We have curriculum and i terns of that.
13 *I have not heard anything that would lead me to believe that
14 they're going to establish a school.
1:5 MR.* SNYDER: I wasn't saying that.* I was saying that 16 it-seems to me fro~ what I have seen on the subject, at 17 least a more cooperative atmosphere, and IJm not sure that 18 we're taking advan~age of that.
19 COMMISSIONER AHEARNE: I think the question we have 20
- to ask ourselves is whether or.not this would be the 21 appropriate thing* to do. And that should be independent of*
22 whether or not the utilities feel cooperative about it *.
- 23. MR. COLLINS: Well, we used to at the very-first of 24.our certificatipn. programs, we used to use Saxton facilities, 25 which was a small BWR facility". West,inghous e.. used.it for their
- 035. 02. S 17 training program, ~nd then they went into the simulator
2 training program for the same accomplishment.
J Th~ thing you,run into when a man goes into an
4 operating plant to do all of his training is that they ar~
~ sitting there base-loaded in a steady state and a man just 5 doesn't learn as much.
We still, in our cold training program, require 3 a person to participate and be an observer at a nuclear power
-J plant for two-months.
10 COMMISSIONER AHEARNE: I gu*ess I.,m* going to have to
11 think. more about 1 t, but I tend to oe.lieve that having the
12 person actually be an operator for something like a year
13 seems to be _a reasonabl~ requirement.
14
- C0MM.ISSI0NER GILINSKY: It seems like that to me. I
15 have to say it.
MR. CASE: Before he becomes a senior?
I I COMM! SSI0NER AHEARNE: Yes.
I
I 18 COMMISSIONER GILINSKYz We., 11 have to get our
19 chairman back* if we're going to get him*qualified under 20 a simulator.
21 MR~ CASE: This*- would not be in 1 ieu of or a change 22 to one - of the other requirements.
23 COMMlSS IC)NER AHEARNE1 Oh,. no, it would be in 24 addition-to.
- MR *. COLLINS: Chart 3, please~
0-35. 02. 6
- 18
.(Slide.)
2 The third recommendation that *involves th9 training
3 pro gr ams is to be more specific on training re qui reme nts for the hot license applicants.
- J For the operator presently under our regulations -
6 COMMISSIONER GILINSKY: A hot license applicant is -
7 MR. COLLINS: After the plant is operational. Sorry.
8 Three months on shift as an extra man in the control room
J learning how to be an operator.
10 This is for the - this is to prevent a man being 11 an au xi li ary operator on shift -doing his normal job and then 12 on a catch-as-catch-can basis, trying to get the requirements
13 to be an operator.
14
- COMMISSIONER GILL\\lSXY: Let me. just take you back to
IS Recommendation 2.
16 You seem to think that a senior operator ought to
- 1, have some operator experience-.
18 MR. COLLINS: 1Yes.
19 COMMISSIONER GILINSKY: Because for those other than, 20 what is the right terminology?
21 MR *. COLLINS: The cold or pre-critical operator.
22 COMMISSIONER GILINSKY: The ones who get training
23 before -.the plant comes into. operation. For those other than 24 that;. first group,* you would:. require - holding an operator license -
25 for six months.
035.02.7 19 gsh. l Now could you go over again the difference
- 2. between the training that ~his person receives as opposed to
- 3 the training that is received by the group which is trained
4 before. the reactor goes ~ritical?
- J -. MR. COLLINS: The previous group r~ceives two years.
6 It goes through a training ~rogram of approximately two years. I,
1 fhe post-critical, or the hot applicants, go through a
- 8 training program that lasts somewheres between 6 and 9 months.
9 So it's* an abbreviated training program. And this 10 is based on the man more than likely having. worked at that
11 particular plant as an auxiliary operatoi or. in some capacity
12 to where he is getting familiar with the plant. And he
13 *doesn't come in as a neophyte, if you would, as some of the
14 people*do*in the cold. training programs as far as nuclear
- - 15 power goes.
(
1.5 So it's a shorter training program.
1 ' MR.* CASE: Are your prerequisites any higher for
18 the cold op~rators in terms of needed experiehce and
19 educ a ti on?
20 MR. COLLINS 1. No. Normally, most of the people that 21 go through.the cold ~rograms ara senior operators, shift
- 22. supervisors~ the watch f6remen and so forth.
23
- So* we are. saying on the training program for the
24 operators after* the plant becomes operational,* three months
. 25 on shift as *an extra man so that we are a.ssured that he is 035.02.8 20 going to be trained in the control room in a formalized
- 2. manna r.
3 Based on recommendation 2, where we required the 4 senior operator to hold an operator's license, he would get
~ three months of training on shift as an extra man. And his 5 principal job at that time would be to accompany the present shift supervisor on his rounds and find out how that shift a should be run.
9 This is after he has his operator's license and now
10 he is in training for a senior operator~s license.
11 COMMISSIONER GILINSKY: You know what concerns me a
12 little bit just listening to you? l get the* feeling that 13 you have taken the present requirements and sort of cranked 14 them up a few turns in the various categories rather than
- 1::S saying, what is it that a man ought to know and what sort 16 of experience ought he to have before he gets control of
1/ one of these plants?
18 MR. COLLINS: We have already pretty much established 19 that the trairiing programs -- the training program is going
20 to have to be altered, b~t we're not recreating the training
21 programs. When we see these areas where the training is
22 not formalized,. people are being put up without the necessary
23 experience and we. are trying to make the corrections in those 24 areas on these first three recommendations *--*
25 COMMISSIONER AHEARNE: Let. me ask a question which 035.02.9 21 relates somswhat to that.
2 If you were to be* ~sked, would you expBct_ 10 percent
3 of the applicants who try to go through this to make it, 4 20 percent, 50 percent*, 80 percent,.what would your answer
~ be? Have you looked at it from that point of view?
6.MR. COLL INS: I would expect once the requirements
1 are known, once the new training is placed in effect, that
8 when we see the Lndi v idual, we should get about the same 9 pass/fail rate as we had in the past.
10 COMMISSIONER AHEARNE: Do you think it's appropriate?
II MR. COLLINS:. There may be some recycling of people
12 befor~ they take our ~xamination.
13 COMMISSIONER AHEARNE: Do you think that-'s an
appropriate.pass/fail rate?
15 MR. COLLINS:* Yes, I do.
16 COMMISSIONER AHEARNE: Why?
11 MR. COLLINS:.. Before the facility management must, 18 as part of the application, certify to the competence of 19 this individual *. And if he certifies and we go to his 20 facility and fail a good number of applicants, we go after
21 him and question the means used to certify these people *.
- 22 COMMISSIONER AHEARNE: Maybe I asked 'the wrong*
23 quest ion. Of. the number of people that start in the
- 24. licensee's* program, what -percentage would you* expect to
25 actually make it all the-way. through?
035.02.10 22
~.m. COLLINS: That start in the ;Jrogram? I wou 1 d
2 say about 80 percent.
3 COMMISSIONER AHEARNE: Do you think that that-"s
4 appropriate?
'.) M~. COLLINS: Yes.
6 COMMISSIONER AHEARNE: It seems pretty high for a demanding program. If you are constructing a program to end 8 up with someone that you would expect to be placed in a 9 very responsible position over something that you feel
1J requires a reasonably close amount of supervision, I would
11 think 80 percent would be a high percentage.
12 MR. COLLINS: I have no statistics on other training
13 programs to benchmark this against.
14 MR. CASE: John, isn"t the answer to your question
1:5 more how stable are the requirements?
16 COMMISSIONER AHEARNEz No. What I was thinking, in
1, another location I spent a fair amount of time I.coking at
18 training programs and screening out individuals and raising
19 and lowering the thresholds to try to get certain categories, 20 and in some cases, to try to fill blocks of people. *In other
21 cases, to try to squeeze down to make sure that you had 22 individuals who could pass a fairly significant ski.11 23 requirement.
24 And it always -- at least the people there that I
2:5 was working. with - always started out with an estimate of
- t::.. :*:*-~--~~~-y;;;~: (< <~:o;.~-<:::}.<.
035.02. l l 23
. gsh now approximately ~hat perc3ntage were they gbing to be
- 2. -satisfied with getting through?
- 3 _That was their W'fJ.Y of benchmarking.whether they
4 would be
- tough enough or too tough. And on this kind of an
. :) *operation, I guess.offhand I would guess somewhere around
- 5 ' ~0 ~ercent would be.the number that you would expect.
7 MR. CASE: Where they ~omparable type things in
8 length of training and things like that?
9 COMMISSIONER AHEARNE: Some of them were two-to
10 three-year long programs and that was even with a threshold
11 filter at the beginning.
12 I would have expected without a threshold filter I
13
- at the beginning, which we donJt have -* in other words, we
14 don" t really have that tight a cutoff at the beg inning -- I
- 1 5 ** would* have.expected a much higher percentage.
16.MR. CASE: Were the qualifications objective versus
I ' subjective?
18 COMMISSIONER AHEARNE: A combination. Variety of
19 programs --
20 MR. COLLINS: Any more specific questions on this
21 particular slide?
22 (No response.)
23 MR., CCJLL.INS:
- These recommendations l, 2 and 3, we 24 would expe<:=t to be implemented for applicants who file their
- ZS application six. months t*rom the dee is ion date to adopt them 035.02.12 24 so changes can be made in the training programs.
May I have the next slida, please?
3
4
6
7
8
1 I 12 13
14
15
16
1 /
18
IY 20
21
22
23
24,
25 7035 03 01 25
- mte C Slide. )
2 COMMISSI01\\JER GILINSKY: Let"s see. Why vwuld you 3 insert the six-month period there?
4 MR. COLLINS: Well, there are people right now in 5 the mill training, in various stages of the training o program, and we feel that we should allow them to complete 7 the training program, administer our examinations to them, 8 because later on you will be seeing the new criteria on the 9 examination, which we are going to make immediate, which we
10 are recommending be made immediately.
.11 COMMISSIONER GILINSKY: So when you say file
12 applications for a license, that comes at the end of the 13 training program?
14 MR. COLLINS: Yes, it does. We feel now the 15 utilities we know are hearing new requirements, they can go
16 out and select different people and start them out in a
17 different training program.
18 MR. SNYDER: Paul, would there be any attempt to
lY look back at those people who already have been qualified 20 under some of these new requirements?
21 MR. COLLINS: In our recommendations, we are 22 recommending that we administer some of the requalification 23 examinations.
24 MRs SNYDER: Periodic requalifications?
25 MR., COLLINS: Yes. They requalify every year now.
7035 03 02 26
- 1 mte ;,..rn. Si~YuER: I understand.
2 MR. OlLLINS: But facility management administers
3 the examination.
4 COMMISSIONER GILINSKY: Every year or every other 5 year?
6 MR
- CO LL I NS : E very ye a r
- 7 COMMISSIONER GILINSKY: For all operators?
b MR. COLLINS: Yes, sir. There are annual
~
- requalification examinations.
10 MR. SNYDER: At that point, would you pick up any
11 more stringent requirements? Would that be the point at 12 which you would do this?
13 MR. COLLINS: Yes.
14 MR. CASE: I'm not sure you two are
- 15 communicating.
16 MRo COLLINS: Grade requirements. We wouldn't go 17 back and say, you don't have four years of experience, you 18 only had three, and therefore you can-'t be a shift
19 supervisor.
20 MR. SNYDER: There are some of these 21 requirements - maybe there are later on recommendations
22 that lend themselves more logically to be backfitted, if you 23 want to use that term, as I recall. Is there any intent to 24 do that with a whole batch of _operators out there?
- 25 MR~ COLLINS: No, I don't know 7035 03 03 27
- mte COMiviISSIONER GILINSKY: Let"s take them one at a
2 time, as we take up the individual recommendations.
3 COMMISSIONER AHEARNE: Bernie, why don"t you raise
4 them when we get to the specifics?
5 MR. SNYDER: Okay.
6 MR. COLLINS: On the next three recommendations,
7 4, 7, and Jl, they all involve the same subject, and that is
i::3 required use of simulators. WeJre going to require the use
9 of simulators in the hot training programs.
10 COMMISSIONER GI LINSKY: To what extent?
11 MR. COLLINS: To at least a week program, one-week
12 program.
13 COMMISSIONER GI LINSKY: What would be the training
14 that persons who are getting trained before the reactor goes
- 15 critical
16 MRo COLLINS: They go to the simulator training
17 program for a three-month period, two to three months on the
18 simulator and one to two months at an actual-operating
19 plant.
20 COMMISSIONER GILINSKY: And you regard one week in
21 the hot training program a satisfactory?
22 MR *. COLLINSz* These people have six months at
23 their plant. three* months in the control room as a trainee 24 as a minimum, and then they go to simulator for a week.
25 While they are at their plant, they-'re doing whatev-er 7035 03 04 26
, mte
- manipulations that are taking place at the plant.
2 C(JMMI SS I ONER GIL IN SKY: What would they be doing
3 dUring that week?
- 4 MR. COLLINS:. At the simulator?
5 COMMISSIONER GILINSKY: Yes.
6 MR. OJLLINS: We address that later on. We are
7 going to develop ~pecific criteria and training programs
8 fore those simulator sessions.
9 C0MMISS !ONER GI LINSKY: And you regard a week as
10 sufficient?
11 MR. COLLINS: I ;m not gotng to lock in on a week.
12 We are thinking of a week. When we get through looking at
- 13. all the exercises and the ite~~ we want to do, then we will
- e. 14 come down on* a time.
1,5 MR. CASE:
- It might be a week or two.
16 MR. OlLLINS: Something of that nature, yes.
17 COMMISSIONER AHEARNE: You mention in your paper
18 that. there are* a few of the older plants for which -<
ls.> simulators.wouldn;t. be availa~le. How many are there?
20 MR. OlLLINS: About four, I would say: Big Rock,
21
- Lacrosse, Humboldt Bay, Yankee. These are -- I don*'t.know
22 if we~ll ever see Humboldt B~y again, but it's one of the
23 older plan.ts *. These are the type of thing.
24 C0MM*ISSI0NER AHEARNE: A very small number.
- 25
- MR. COLLINS: Yes, a very small number" extremely 7035 03,05 29
- mte. small *. Righr. now about 90 percent of the utilities are 2 sending these. hot applicants to training programs, so we"re
3 not really imposing too much
4.COMMISSIONER* GILINSKY: Are you con.strained by 5 resistance to go to. simulator sites on the part of 6. employees?*
7 MR. COLLINS: No. We have a program now that sort 8 of fosters and encourages the use.of simulators, and most of 9 the utilities have opted to use that program.
10 MR. CASE:* Ba~ically, we"ie changing into a
Jl requirement. This is the st~p that~s being taken.
12 COMMISSIONER GILINSKY: How would you use the 13 simulators in requalification programs?
14 MR. COLLINS: Once*again, we would make. them 15 mandatory. We'.would do the same thing on the 16 requalification program. We.aie developing a list of 17 exercises. We are going to insist that each licensee 18 perform them while he"s at the simulator.
Iii COMMISSIONER GILINSKY: So every year, an operator
20 Would return to the simulator for some period?
21 MR. COLLINS: For some period of training, yes.
22 <>nee again; I have got to go down the list of 23 *. exercises and work it out with my staff as to what is a
- 24 *. reasonabte time for a man to. perform these,* not only to 25
- perform, but.. to learn. what's happening, too *
.r.
7035 03 06 30
., mte C0i'-AMISSI0NER GILINSKY: Presumably, there would be
2 new exercises each year, as we learn new things.
3 MR. OlLLINS: We're looking at a combination of a
- 4 certain standard number that we want them to be able to cope 5 with, plus,. as you say, each year there would be some
6 different ones, also.
7 COMMISSIONER GILINSKY: How would you use these
8 simulators for administering NRC examinations? This is for
9 the initial.examination?
10 MR. COLLINS: This is for the initial
.l I examination.
12 Yes, we would probably go to the simulator. And 13 we haven't thought om: all the details on this, but we would 14 probably go to the simulator, administer that part of the
- 15 exam that we could, and then that would be a separate exam, 16 and then the balance of the exam would be administered at 17 the man's.facility, probably two to thr.ee weeks later.
18 COMMISSIONER AHEARNE: Do we currently certify 19 that a simulator is an adequate 20 *MR.*. COLLINS: Yes, without any specific criteria 21 and *without any specific mandate in the. regulations to do 22 so.
23 COMMISSIONER AHEARNE: Do we, revi.ew the particular
.24 software* programs that are written for-the simulator?
-,25-MR *. COLLINS:* No, we do not review-the programs.
31 I mte 1 We do, as a final check on the simulator, have the startup
2 test data from the plant after which the simulator is
3 modeled, and we reproduce the startup tests on the simulator
4 to verify the accuracy.
5 COMM! SS !ONER-AHEARNE: Do we do a test run of 6 accident frequencies to see whether the simulator responds
7 in a way..:__ the *software responds in some way that we feel 8 is satisfactory?
9 MR. COLLINS: Yes, we do. We observe that.
10 COMMISSJONER AHEARNE: So we do have. some test
J I - runs.
12 MR. COLLINS: We do get involved with 13 simulators with the original specifications. Then, *as the
14 simulator is being ~onstracted, we visit the* facilities
15 being constru~ted*and participate in-acceptance tests. We 16 participate-in the acceptance test at the site, and then we 17 make a.final check on the simulator against the startup 18 tests of the plant after which it is modeled.
19 All of these recommendations are going to require 20 rulemaking to implement.
21 MR.:. ENGELHARDTs. I think. that statement may be.
22 slightly overly broad~ But where *there are requirements,
23 specific* tequirements mandating that an individual must meet
I.e 24. a s.tandard o.r a standard is set that must be a required 25 qualification, those. would be necessary to include' in 7035 03 08 32
- rnte R-55, so that the rules would be set in place
- 2 There are some of these procedures, however, that
3 have been mentioned in the pa per, in 330 CF), which wi 11 not
4 require a rulemaking and can be established as a matter of
5 procedure and policy.
6 We, of course, as attorneys would prefer that, to 7 the maximum extent, the requirements and the standards be 8 set forth in regulations, because that is always the
() conservative, safe approach. There are, however, a number
10 of things that can be done without the necessity of
11 rulemaking. But rulemaking is essential where requirements
12 are levied on what a person must do in order to establish I
13 qualifications for a license, and that is what we~re doing.
14 Part 55 says what is required now *. Some of the
15 current or.. proposed requirements were, if anything,
16 improved. And a licensing program must, of course, also be
17 reflected in these regulations.
18 COMMISSIONER BRADFORD: You were talking about
19 just 4, 7 and i1, Paul?
20 MR. COLLINS: Yes,, so far. I have these
21 recommendations grouped, or I had them grouped at one time,
22 based on the implementation, recommended implementation.
23 Some has changed since talking 24 MR. CASE: But there are others that require 25 rulemaking?
7035 03 09 33
- mte MR. COLLINS: Yes, there are others that require 2 rulemaking besides these three.
3 COMMISSIONER BRADFORD: I and 2, though, in your
4 view do not?
j MR. alLLINSi No, they did not.
6
- MR. CASE: I. assume OELD agrees?
7. MR *. ENGELHARDT: Yes.
8 COMMISSIONER BRADFORD: Could these be put into 9 place before'you are in a rulemaking?
10 MR. COLLINS: Well, I indicat.ed that the use of
- J J the training programs, simulators in the hot training
12 program, about 90 percent of the utilities are doing it 13 now. About 85 percent of the utilities are using
14 requalificaticn programs. So it's not too serious a 15 situation in saying that they are not going, because they
16 are going to the simulator *.
17 COMMISSIONER BRADFORD: What I would like to 18 understand, though, is what the time scale for putting these 19 r~commendations into etfect heie is. How long will it take?
,20 MR. COLLINS: I will have to defer.
,21
- MR. CASE:* I. have heard this many times, and I
22 think you have. Norm.al rulemaking.is two years.
23 24
25
.. - *,:: ~--;;:
- c
- x}1*Wciiz ~~itiltlt&~;,{\\,1,2,lL:,ci//.. *.. ;;/t....
7035 04 01 34 COMlvlISSIONER Bf?ADFORD: Do \\tfe consider these 2 requirements can be put into place before the rulemaking? I 3 know yoy find a high percentage are doing them anyway.
4 MR. COLLINS: What I have from ELD right now is
5 that rulemaking will be required.
6 COMMISSIONER GILINSKY: We cannot make these 7 requirements immediately effective?
d MR. COLLINS: No, I can't say.
-; COMMISSIONER BRADFORD: Would you like to make 10 them immediately effectivel if you could?
.I I MR *. COLLINS: I would like to be able to start 12 administering the NRC examination on the simulator. This is
13 going to take time also, because it's going to require a
. 14 larger staff o That's one area
- 15 COMMISSIONER AHEARNE: Do we have some other legal 16 opinion?
17 (Laughter.)
ltl MR. ENGELHARDT: The problem here is the 19 requirements for health and safety. I mean, thatJs the core 20 of this whole thing.. If these requirements are considered 21 essential to health and safety and they must be mandated now 22 to be done now so we are sure health and safety is
23 protected" we can do that._ We* can find the mechanism for
24 doing that *.
25 we~ra saying rulemaking is the preferred course of 7035 04 02 35 action to assure that we aon't run into the procedural
2 complications. If you don't have rules established that you
3 can meet. But there is always a decision to be made by the
4 administration as to whether or not there is a health and 5 safety prevailing and prevalent, an overwhelming requirement 6 in the interest of health and safety that has got to be done 7 now, in which case it can be ordered to be done now and b could be done in the sense that is being done.
9 Apparently, a number of operators are already in 10 the process, and the others could be encouraged to follow 11 that process while we go through a formal rulemaking. If 12 that isn't good* enough, then we just order it and have* it 13 done in the sense of -- in the interest of public health and
14 safety.
15 MR~. COLLINS: We also have the problem of how many 16 simulators are available. We have made some very 17 preliminary estimates of their availability, and we see some 18 problems, if we extend our programs more than what the 19 programs are now. And I really believe the programs are 20 going to be extended. So, we're going to run up against the 21 construction of new simulators in full implementation of 22 using the simulators for everybody.
23 COMMISSIONER AHEARNE: That's 24-hour operation?
24 MR. COLLINS: Yes. We know we are definitely 25 having problems on BWRs. We think -- we think we look
. -.: -. :~. - :.:,_,* _, ; - '
7035 04 OJ 36
- "~1i\\l fairly good on the PWR simulators, but we haven't made a
- 2 total analys.is having called in the people who own the
3 simulators to see what they would make it available for.
4 So, even if we come right out with an immeditely
5 effective rule, we are still going to be possibly stopped by
6 the hardware. I checked with people --
7 COMMISSIONER GILINSKY: Wait a minute. Stopped in
8 what sense?
9 MR. COLLINS: In that there isn*'t the
10 availability, the time available
l I COMMISSIONER GI LINSKY: It may just take longer to
12 qualify some of the operators.
13 MR. COLLINS: Well, they have their programs --
14 *.well, I would think probably the requalification programs
- 15 would be the ones that su+/-fer. You have got to keep a
16 supply of operators going. We have technical specifi~ations
17 that require people, a certain number of licensed people, at 18 every plant. We can't stop the process.
19 COMMISSIONER AHEARNE: You don't have timely
20 renewal for operators?
21 MR. CASE: I suppose that applies, timely renewal.
22 MR. COLLINS: Yes. But they leave the job, and
23
- they have to get rBplacement of people.
24 COMMISSIONER GILINSKY:. In the extreme, if we
25 believe ther& are not qualified operators, sufficiently 7035 04 04 37
\\ilv\\ trained operators, then the plant just ca~'L operate.
- 2 MRo COLLINS: 'Ne would have to make that finding,
3 yes.
4 COMi\\\\ISSI01\\JER AHEARNE: I think that's what Tom s meant when he talked about health and safety.
6 MR. CASE: What is the finding you have to make to
7 make a rule immediately effective?
6 MRo MALSCH: Public health, safety requirements y are required. It's a fairly strong finding. You really
10 have to find the advantage of getting full participation
11 outweighed by the need to have the regulation replaced right 12 away.
13 COMMISSIONER AHEARNE: Somebody wi 11 probably ask
14 if we believe it's absolutely essential for simulators.
- 15 Why, it may be.
16 MR *. MALSCH: The problem that agencies frequently 17 run across in putting out regulations in effect immediately, 18 there's b.een a debate for a year and they put it out right
lY away, su.ddenly, assuming the problem is recognized and there 20 is prompt action, I think there wouldn,t be any problem 21 with immediately effective regulation.
22 MR. COLLINS: The next slide, please.
23 (Slide.)
24 Recommendations 5and 9 at one time I thought 25 could be implemented immediately.,. It turns out that audit
I, i
7035 04 J5 38
IvllA of the training programs can be immediately im~lemented
- 2 COiv[MISSI01"JER GILii~SKY: This is NP.C audit?
3 MR. OlLLINS: NRC audit of training programs,
- 4 particularly the cold training programs, including
5 administration of certification programs, some of the
6 certification exams.
7 COMMISSIONER GILIN.SKY: Certification exams are
8 which ones?
<.J MR. COLLINS: They are the examinations given tot
10 cold applicants at the completion of their off-site training
11 programs. That certifies they have ex.tensive actual 12 operating experience. At the conclusion of the off-site 13 training program, they then go on site where they go through
14 the on-site training program, construction check-out, 15 writing of procedures, technical specifications; and about a 16 year to two years after they receive this certification
17 exam, we give them an NRC exam.
18 Now, we are recommending that we do some of the
19 certification examination as a benchmark against the
20 training programs that are going on.
21 COMMISSIONER AHEARNE: Why shouldn't we do all of
22 them?
23 MR *. COLLINS: We feel if we make our presence
24 known and we have a good auditing program, we can accomplish
- 25 just as much, pick up weaknesses in the training program in I - --- ---
1
7035 04 06
I ** Jc\\M as gooc a manner or almost as good a manner as a hundred i
2 percent of the students.
3 The purpose -of us.going there is to audit the
4-training programs, not to certify the individual.
5 MR. CASE: I would more put it I would start out 6 this way and if it turned out that we're doing 10 percent 7 determines you can do a lot better by doing 15 or 20, I 8 would prograss that way, rather than start out at 100. In 9 other words, I'm not sure that *10 percent is the best 10 direction, but I think it would be worthwhile to start out
.11 that way, rather than starting at 100 percent._ We do have 12 manpower problems, t.oo.
13 COMM! SS IONER AHEARNE: Oh, yes, it would
14 defini.tely be a switch. it wouldn't be audit. It would be 15 certification.* My question really is why shouldn't we be 16 the ones doing certification?
1 7 COMMISSIONER GILINSKY: You're talking about NRC 18
- administrator requalification exams?
- 19. - ~MR. COLLINS: Yes~ we are, NRC administration of 20 some of the requal.if ica tion exams *.
21 COMMIS~IONER AHEARNE: And I am really saying why
- 22.don-' t we...
23 COMMISSIONER GILINSKYt
- I have the same que.stion.
24 I want to*ask you another question. Let me take you back to 25 the-B&W examinations that we gave - we did not* give - we I 7035 04*07 40
- 1 required be given to the operators at the B&W plants.
- MM 2 I am informed -- in fact, during my deposition by
3 the President's Commission that you recomm~nded that the 4 NRC administer all these examinations. But, were overruled,
5 and t:he result was we simply audit* the process. Is that
6 correct?
7 MR. COLLINS: I don't want to use as harsh a word
8 as we were 11 overruled. 11 I did make the recommendation that
9 we administer the examinations. It was felt that we would 10 accomplish just as much by conducti~g this audit program on
I I them.
.12 COMMISSIONER AHEARNE: What made that different 13 thari the question I just asked?
14 MR. COLLINS: Because the certification
- 15 examination -- we 11, mainly,. because the* man-' s training
16 program on the certification programs is not complete, and 17 he's not ready for an NRC *examination~ The dLffer,ence here 18 on the Ocon.ee exams at B&W is that their training program
19 was complete, but this man, he-'s only about halfway through 20 hi~ training program.
21 COMMISSIONER' AHEARNE: How about when h.e' s 22 finished with hts
- training program, should we then do a
- 23 hundred percent af them?.
24
- MR~ COLLINSt we. do; We give.the NRC examination,
- 25 and the man gets his License..
7035 04 08 41
C0!10i1I SS I OiffR AHEARNE: I nde pendent of any 2 licensing
3 MR. COLLINS: Independent of how many initial
4 examinations.
5 COMMISSIONER AHEARNE: How about the 6 requalification examinations?
7 MR. COLLINS: On requalification, the programs
8 were and are. in the regulations set up to be 9 facility-administered.
10 COMMISSIONER AHEARNE: Why shouldn"t we? I mean, 11 wasn--'t the B&w**a form of requalification?
12 MR. COLLINS: No. I think it was learning
13
14 COMMISSIONER AHEARNE: And therefore requalifying-15 somebody who was already qualified, there were new things 16 learned,.. __ you wanted to make sure. rsn" t that, to some 17 extent, what a requalification does, is to make sure not 18 only that you knew what you used to know, but anything new*;-
19 MR. COLLINS: That you-'ve kept your knowledge up 20 to date with new exchanges.
21 COMMISSIONER AHEARNE: Right. So, why shouldn-'t 22 we do. everybody"s requalification?
23 MR. COLLINS: Once again, we were looking at it 24 from the standpoint of auditing the program,. rather than 25 looking at each individual.
035 04 0Y 42
- UM COAHISSION!::P. AHE.'\\RNE: v**/hat I am really asking,
2 Paul, if it was appropriate in that recant B&W case, why
3 isn't it then appropriate in the requalification?
- 4 MR. OlLLINS: I can't correlate the two.
5 COMMISSIONER GI LINSKY: I was going to make a
0 different point, which is, A, I am surprised we were not
7 infotmea of that recommendation; and I am also curious as to
8 what led to the decision not to have NRC administer all of
'-;) the examinations. Is there an explanation for that?
10 MR. CASE: I have tried to recall my involvement,
11 if any, in the situation that Paul described, before the 12 presidential commission. I talked to Denny Ross about it, 13 too.
14 First, with regard to your question, and your
- 15 surprise that the Commission wasn't informed. I don"t think
16 it was of that character or caliber of difference of opinion
17 between the recommender and the resolver, if you will. It 18 was one of the hundreds of decisions that are made in the
19 course of something like that returning part of the B&W
20 reactors. In any event, as I remember the situation - and 21 Paul can correct me if I am wrong -- he was in the midst of 22 a discussion with Dr. Ross in Dr. Ross' office, and I
23 believe that representatives of I&E were there, and we were 24 contr:asting the _situation. then with the previous situation
- 25 on B&W pla~ts, when~ you wilL recall, we issued a number of 7035 04 IC 43 instructions via bulletin, and the I&E resiaent inspector
2 performed the function of det8rmining whether the people
3 were adequately trained in their new procedures.
4 COMiiI SS I ONER GI LINSKY: You're talking about early 5 April?
() MR. CASE: Early.April. We felt at this stage we
7 would ratchet, if you will, those requirements a bit to do
8 better verification by having the operator licensing branch 9 audit, as distinguished from having the on-site inspector do 10 it, because they were more qualified in this area. Having 11 the reactor inspector check the rest of the people. So, it 12 was a ratchet over what we previously had done.
13 The question was how far should you go in such an 14 audit. And I think the answer, our feeling at the time, was 15 let's try 10 percent or whatever, the few that we audited ',
16 were to see how the thing came out to determine whether 100 17 percent audit was necessary. And if I remember, there
18 wasn't a strong disagreement or strong recommendation. It 19 was just one of those things that you consider and make a 20 decision on. I believe I was called on the telephone, and 21 in the midst of the discussion, said, *"What do you think ?*11
22 COMMISSIONER GI LI NS.KY: I raise this, not be cause 23 the Commi.ssion should be informed of every difference 24 between a branch chief and assistant director.. Obviously, 25 the answer is not. But this happened to be a particularly 7035 04 11 44 crucial el s1112n t in our pro,;;ram of assuring the safety of
2 those r=lants. And therefore, if Mr. Collins thought he had
3 the resources and thought it was appropriate to have NRC
4 aaminister these examinations, I think that's of sufficient 5 importance that the Commissioners ought to know about.
0 MR. CASE~ Well, a large part of tha, 7 Commissioner Gilinsky, depends on the feeling of the d recommender after he has made such a recommendation and it Y doesn't carry. And I can only gather that Paul didn't feel
10 ~oo strongiy about it, because in time I didn't hear any
11 strong outcry or reverberations, and if there were we
12 certainly would have brought it to the Commission's
13 attention. I think Paul was here and we discussed it.
14 MR. COLLINS: I will agr.ee. I made the
15 recommendations, but the audit was a very comprehensive
16 audit, and it fit in.
17 COMMISSIONER GILINSKY: So, you were satisfied
18 with that kind of approach, the alternative approach?
19 MR. COLLINS: Yes.
20 COMMISSIONER AHEARNE: I will have to* say that
21 that 0as the conclusion, certainly I reached when the same
22 gentleman raised the same point to me, that I felt that Paul
23 was here, and if he really felt strongly he would have
24 raised it at that point and the issue would have been
25 raised, it seemed to me.
703'5 04 i 2 45 It seeffied to be a very consistent approach~ very
2 frankly, with the previous way.
3
4
5
b
7
8
10
11
12
o--'~ 13
- 14 15
16
17
18
20
21
22 23
24 25 7035 O:i 01 46
- mte MR
- CO LL I NS : on th e re q u al i f i c at ion exam i n a ti on,
2 some or all, and we are recommending we administer some.
3 Once again, rulemaking has been recommended. I-e's my
4 understanding that the regulation presently does not
5 interject _NRC into the requalification examinations without
6 cause, and therefore rulemaking would be nBeded to put us
7 into the qualification programs.
8 COMMISSIONER AHEARNE: Did you end up choosing
Y your option 12 instead of option 11?
1 0 MR
- CO LL INS : Y e s
- 1 I COMMISSIONER AHEARNE: Could you explain why?
12 MR. OlLLINS: The main reason is, we look at the
13 requalification program, although indeed it is an individual
14 certification, we want to look to see that the program
15 itself is being administered properly, rather than honing in 16 on each individual. Once again, I think you can detect 17 weaknasses in programs, and in this case, since there are so 18 many plants being operated and so many audits to be 19 conducted, probably come up with problem areas a lot faster 20 by conducting audits than you would if you had to schedule 21 in 100 percent of the examinations.
22 COMMISSIONER AHEARNE: But in the arguments you 23 give in your* paper on the for and against, the arguments for
24 s.eem to be*.that the-NRG's concern -- you would assure NRC*'s 25 concerns 'frnre addressed, this would serve as a measure of 7035 05 02 47
ri1te the training programs" effectiveness as well as individual I *
') competency.
3 And the only argument against it is it would
4 require some additional Licensing Branch personnel. That's
5 page 28.
6 MR. OlLLINS: Thank you.
7 Not necessarily. We find in our audit
8 requalifica~ion programs right now that individuals that
y have a grade 80 or above, when we grade those exams we find
10 that we come down fairly close to the facility's grading.
1 I When we get below 80 and we are heading towards the present
12 cutoff point of 70, where a man would have to go into
13 accelerated training, we find a tendency for the grader to
14 be a little more generous than he should,.than we are when
- 15 we grade the examinations.
16 So if we go to a facility --
17 COMM I SS !ONER AHEARNE: All the more reason to do
. 18 it
- 19 MR. COLLINS: So if we go to a facility and select
20 for our sampling the lower grade, I think we are
21 accomplishing just as much as had we gone in and done 100
22 percento
23 COMMISSIONER AHEARNE: Or if you audit every lower
24 grade.
25 MR *. COLLINS: In any audit procedure you start 7035 OS.OJ 48
- mte off. If you"re sa1:isfiec with the audit you stop. If
2 you"re not, you con1:inue on. You can always continue on.
3 COMMISSIONE::i AHEAR:\\/E: Could I ask you, Paul,
4 about a question which I admit I completely missed the
- i previous time you discussed the licensing examinations? On
6 page 2s., you say~
7 11 The examination is designed so the average
b applicant can* complete the examination in eight hours.
9 However, no time limit is imposed."
I
10 Is that really correct? There's no time limit on
l l how long it 1:ake s the individual to take the exam?
12 MR. COLLINS:* With one exception. If you have a
13 couple of people sitting there for a considerably long time
14 past the class average, then it"s common practice for the
15 examiner to say, all right, you have one more hour to
16 complete the examination.
17 But we feel that *- we have felt in the past that
18 imposing a time limit really doesn't accomplish that much.
19 And most people get through in eight - I guess some people
20 take ten. There was no time-~ there is no time limit.
21 COMMISSIONER AHEARNE: And then, similarly, on the
22 next page, where you talk about the exam, it is designed to
23 be completed in five hours, but no time limit is imposed.
24 Is that right?
25 MR. COLLINS: This is correct. We do not say, you 7035 0:5 04 49
- nte have five hours for this examination.
I
- 2 CO if.MI~:::, ION ER AHEARN E: That somewhat reduces the
3 significance of the grade, I guess.
4 COMMISSIONER BRADFORD: These also go to
5 rule making?
6 MR. alLLINS: The second one, for NRC to
7 administer the requalification exam. The auditing of the
b training program, including the administration of
9 certification examinations, we have always had that right to
10 go in and audit the programs, and then to administer the
11 certification exam. We have done it with the first few 12 groups of applicants at all these training centers, but we 13 have not done it on a continuous basis such as this 14 suggests.
- 15 COMMISSIONER BRADFORD: But on the one.s that go to
16 rulemaking, then, full implementation would be two years
17 plus with rulemaking, as the normal course?
18 MR. COLLINS: Yes.
JS) MR. CASE: I must :Say, I'm really speaking for Bob
20 Minogue, but I have heard him answer that question enough 21 times that way that I think he would give that answer.
22 MR. COLLINS: Next slide, please.
23 (Slide.)
24 Re6ommendation 6~ require instructors to hold
-- 25 senior opeiator licenses as a first step in establishing 7035 05 05 50
- mte instructor qualifications.
2 COMUISSIONEH GILINSKY: Which instructors are you
3 speaking of?
- 4 MR. COLLINS: We presently are attempting to zero
5 in on which ones we want. CertainlV, the training
6 coordinator at the site, who is responsible for all of the
7.training. We don't envision~ for example, requiring the
B chemists and health physics supervisor Who might give
9 lectures on that subject to also hold a senior operator
10 license.
11 But we are trying to select which ones, as a first
12 step to establish technical competence. We are going to
13 work, also, closely with ANS-3 and the Institute of Nuclear
14 Power Operation on the development of comprehensive
15 requirements.
16 COMMISSIONER BRADFORD: But again, this first step
17 is.two.years, though?
18 MR. COLLINS: Yes, to fully implement it and to
19 make it a requirement -- many of these instructors do own
20 senior licenses. To make it a requirement would be
21 rulemaking, because it's not addressed at all in the
22 regulations.
23 Next slide,*. ple-ase...
24. (Slide. ).
25 COMMISSIONER AHEARNE: Paul, you did raise a 7035 05 '.)6 51 question about whe:cher or not you shouldnJ't have more than a
2 yearly re~examination, and you concluded that you did not
3 neeJ to do that?
4,1rn. COLLINS: More frequent.
5 COMMISSIONER AHEARNE: More frequent.
6 There, I gather, is a balancing at some point.
7 You feel there isnJ"t enough new information, a person has
b not become stale enough; but on the other hand, when you 9 stretch it out further, you could actually have more NRC 10 giving the exam rather than the licensee.
_JI What ends up having you conclude that~ year, with 12 an audit, is the best? Is this more subjective feel?
13 MR. COLLINS: Yes, it is a subjective feel.
14 Individuals that donJ't do too well in a articular area of 15 the examination go to lectura series during the yearly
I 6 p e r i o d
- I n order to g e t o u t o f the l e ct u re s er i e s c l a s s e s,
17 they have to exhibit that they have picked up the knowledge 18 in those areas. A year is a a reasonably short period of
19 time.
20 The recommendations 8 and 15 involve simulators.
21 I refer to the establishment of the explicit exercises 22 earlier. We plan to start on these exercises immediately 23 and - to be complete.within.* three months. No rulemak ing is 24 required.
25 I might add tha.t ANS-3 is also working on a 7035 05 07 52
IO 1:8 similar listing of exercises. We also want to review and
- -2 revise the ANSI/ANS Standard 3.5 that addresses nuclear 3 power plant simulators anc:i develop a regulatory guide along
4 the same lines.
5 Once again, we can start this review immediately.
0 If the ANS review is going slowly, we will just tome out
7 with our own regulatory guide on che matter. Neither of
6 those require any.rulemaking.
9 Next slide, please.
10 (Slide.)
Jl Recommendations 1 O, 12, 13 and_ 1 4 all involve the 12 examinations, the NRC examinations. None of these require 13 rulemaking to implement. The notification of results does
14 require a change to Part 9 of our regulations, simply 15 publishing in the Federal Register that one of the routine 16 uses of exam results will be to notify the facility 17 management of the results.
18 COMMISSIONER GILINSKY: Would you make those 19 results public?
20 MR. COLLINS: I don't see any --
21 COMMISSIONER GI LINSKY: Without the names?
22 MR. COUINS: Yes, we can, without the names.
23 COMMISSIONER GILINSKY: You have done it in the 24 past?
25 MR. COLLINS: Yes, we have. On the April 20th
--~r *, -.-.~--;'!-:_: ~>:
... ;_ *:**>_;-;,tiJI}[~){ )(:*,_
- 7035 05 08 53
!,G.-1 m te meeting we did.
2 The recommendations include increasing the scope 3 of examination. Pre sen tl y -- on this second option,
4 presently an operator who applies for a senior operator
- 5 license requests waiver of the operator written portion and
\\
6 waiver of the oral examination. And to date, unless we have 7 seen cause in the man's docket, we granted the waiver of
- s both the written eiamination and the oral examination.
9 We feel we have been too generous with the.waiver 10 provisions and ?re recommending that the senior operator 11 applicants also take an oral examination.
12 COMMISSIONER AHEARNE: I notice in your 13 description of the discussion of.the material question, how
14 muc~ material should be provided, whether or not this isn~t 15 going to be an overemphasis -- I was a little disturbed, 1 16 guess, by part of the flavor. It seemed to me at least 17 there might be some concern perhaps the technical material 18 might be'a little bit more than what the operator would ever
.1 9 need to know. And. it would seem to me that you want to make 20* sure the operator does have more technical information than 21 - he will ever ne~d to know,.because you want to make sure 22 that it isn't stretched beyond his knowledge, I would think.
23. MR *. - COLLINS: There are certain divisions betw_een
24 the operator and the senior operator. The requirements of 25 the ienior are more demanding.,
~
7035 05 OY 54
- MA rn te C0i,1MISSI0NEf~ AHE.Af~NE: Yes.
2 MR. COLLINS: Aiso, v1e"re recommending increasing 3 the Passing grade on the written examination to BO percent
4 overall and 70 percent the first time, establishing a
i:-- minimum grade in each category in the exam of 70 percent.
- l
6 COMMISSIONER AHEARNE: 0nlyone other line down
7 there, and that is fixed time of the exam.
8 MR. COLLINS: I think that-' s the only one.
9 MR. CASE: Paul, how much if we made this
10 change, how many people in the past would
- 11 MR. COLLINS: *If-this criteria had been in effect 12 over the last three years, 49 percent of the operators would
13 not have received licenses on the f-irst examination, and 40 14 percent of the senior operators would not have received
- 15 licenses.
16 I can-'t give you a breakdown on whether that was 17 because their overall grade was under 80 or because they had
18 faileq a particular category or had received less than 70 in
19 a category.
20 COMM I SS !ONER AHEARNE: There was al so an 21 in.teresting comment in your paper. You say if you had 22 required a grade of 70 percent in every category, 32 would 23 have passed the senior portion of the examination, but would
24 have failed the operator portion.
- 25 MR. COLLINS: Yes~ There were categories in that 7035 05 IO. 55.
Mi,\\ m1:.e group.
- 2 And, of course, the notification of results.
3 *MR.SNYDER:. Paul, the question I had earlier was,
4 which of these requirements would be backfit. I don't know
- 5* if that's quite the right term in this context.
6 MR
- CO LL INS_: We would _..;.
7 MR. SNYDER: It looks to. me possibly the first and
cl the third_ on that list are candidates for that.
9 MR. COLLINS: We have the requalification program 10 going, and it would be our intention that when a passing
II grade was approved, a new passing grade on the NRC 12 examination, we would make this the new passing grade on
. 13 requalification examination.
14 COMMISSIONER GI LINSKY: Let me ask you: What
- 15 opportunity does an* opera tor have to take another exam. if he
16 fails a. requalification exam?
17 MR *. COLLINS:. The programs call for putting him 18 into an acc~lerated. training program on the areas that he
19 has exhibited weakne.sses, and adrnini.stering another exam to 20 him. We didn't delve into the length of these training 21 programs because of the vaiious combinations that ~ould
22 result in* a man getting less than 70 percent on the
- 23. exam i na t.ton.
24 COMMISSIONER GILINSKY: How many operators have
- 25. ever been dropped out through failure* to meet.the 7035 05 I I 56
requalification requiremen~s?
2 MH. COLLINS: I think they're based on four-year
3 statistics. There are 25 operators and 28 senior
4 operators, out of about 2,000 total, 1400 seniors and.1100
5 operators.
6
7
8
y
10
JI
12
13
14
15
'i) ' 16
17
18
19
20
21
22
23
24
25 r
1035.06.1 57
gsh COMMISSIONER AHEARNE:. About 2 percent.
COMMISS !ONER GILINSKY: Now you said. befor9 that
- 3 about half the applicants would have failed the examination
I 4 if these tequirements were in force?
- ~ MR. COLLINS: Yes.
6
- COMMISS !ONER GI LINSKY: What opportunity do they
, then have to. take another examination, the initial examination?
8 MR. COLLINS: The initial examination, they may
9 make an application for second examination two months after
10 they failed the first exam. If they fail the re-examination,
11 then they must - there"s a six-months waiting period. If
12 they fail that examination,* thereJ' s a two-year waiting
13 -period.
14 COMMISS !ONER GILINSKY: Now are we going to pay
15 special attentiori to the requalification exams that are going
16 to be i.t seems to me* the initial group of requal if icat ion 17 exams is the most important because you have operators out 18 there with present.requirements but have not made it.
19 MR. COLLINS: We would intend to do the. same thing
20 that we did when we initiated* the requaiification program.
21 We did go to every plant within-. the f.irst year and audit
22 the requalification*.exam to make sure that the program was
23 being implemented,. as it was our intention that they be 24 - **implemented.
25 We* would do the same thing with this new passing 035.06.2 58 grade, a much closer audit than normally.
2 COWHSSIONER GILINSKY: It seems to me you-'ve rgally 3 got to be very firm because.while the utilities, on the one
- 4 hand, want to have qualified operators, on the other hand, don-' t want to lose their operators.
MR. COLLINS:* As I indicated, we do notice them get
7 more generous as the grades start getting between 80 and
8 70 percent.
9 COMMISSIONER AHEARNE: And when you come out with this
10 new, tougher r~quirement, they may even get more generous.
11 i\\fR. COLLINS: Possible, very possible.
12 COMMISSIONER AHEARNE: You have to really watch them.
. 13 MR. *COLLINS: The next slide, please
- 14 COMMISS !ONER GILINSKY: Well, in fact, it raises the
15. question whether the. entire requalif icati9n program ought not
16 to be NRC-administered *
. l I MR. CASE: At least until you get it rolling.
18 COMMISSIONER GILINSKY: ThatJs right.
19 MR. COLLINS: In what -
20 MR *. CASE: Until you're assured that everybody could 21 pass this new standard.* Your opportunity to find that is in 22 the requalification.
23.. COMMISS !ONER GILINSKY: Not necessarily administered
. 24.* by NRG'..employees~ but certainly NRC-run.
25 MR. COLLINS: The examination?
03:5.06.3' 59 gsh C.CJ.\\IMISSIOi'-IER GILINSKY: Yes, and not run by the
.!.2 utilities themselves.
3 MR. COLLINS: f'ihen you say NRC-run --
4 COMMISSIONER GILINSKY:,¥ell, we may be using
'.) part-time parsons for various other locations. But it seems
6 to me that to leave it entirely to the utility even with an
7 audit is qu3stionable.
8 MR. COLLINS: But if you audit -- when we audit, we
'-) audit each and every plant. IJm not talking about selecting
10 half a dozen utilities. We~re going to go to each and every
11 facility and.select certain tests to review.
12 Now we will review the scope of the examination to 13 make sure it is up to our new standards. And we will review
14 the answers to the examination to make sure that they are
- 15 expecting decent answers from the licensees.
16 Then we will select half a dozen or so examinations
I ' and actually grade them ourselves. And we intend to do this
18 in a rapid manner at the conclusion of the administration of
l J their next annual exam after the new criteria is in 20 effect.
21 MR. CASE: If you're not satisfied with half a 22 dozen --
23 MR. COLLINS: If weJ*re not satisfied with what we 24 see on the half dozen based on ~hat we see, we could take
- 25 any action we w.anted at that time. And JJ'm trying to indicate
03:3.06.4 60
gsh that if ~e u~e the audit approach, if we run into a problem
2 area, I can concentrate the manpower onto that problem area;
- 3 whereas, if you say, do it 100 percent, IJm spread thin
4 already and there is no way to really zero in on a problem
- > area.
6 (Slide~)
l The final recommendation we made was to develop a training programs for the present part-time NRC examiners
9 and also to explore the use of utility personnel as part-time
10 examiners or similar to the manner that the FAA users,
.11 commercial airline pilots, to a.ssist them on making their 12 pilot check-out program.
13 COMMISSIONER GILINSKY: Will you be setting specific
14 - requirements _for NRC examinefs?
1.3* *MR. COLLINS:* Yes, we would. We would be saying that
16 they _would have to give us X-amount of time* for training and,
11 of course, *1f we are going to go to that length to train them, 18 then we would expect X-more amount of time for examining.
19 COMMISSIONER GILINSKY: Would you expect them to 20 pass the* examination?
21 MR. COLLINS:. We, werewt contemplating an examination.
22 COMMISSIONER AHEARNE: Would you expect them?
23 MR.... COLLINS: I think they could.. I would expect a part:-time.* examination,-
25 COMMISSIONER' GILINSKY: Why not have - them --
035.06.5 61 MR. COLLINS: We hadn~t thought out the total training
2 program. I have no fears about them passing the examination.
3 COl,:fMISSIO>J'ER GILINSKY: Don-"t let them make up the
-+ que.5tionso 5 (Laughter.)
5 MR. COLLINS: ~le'd be satisfied with an audit.
, <Laughter.)
8 MR. COLLINS: I believe you raised the point last 9 Thursday, Commissioner Ahearne, that in this~study we will 10 address no part-time examiners.
II This recommendation really is to conduct feasibility 12 studies to see, number one, can the part-time examiners we 13 have now give us the time. we need from them; and two, what are
14 the problems, particularly conflict of interest, in using
15 utility personnel.
16 COMMISSIONER AHEARNE: In your consideration of
11 using utility personnel, even there, that would be on a 18 different utility.
- 1) MR. COLLINS: Oh, yes. They wouldn-"t be examining 20 their own people. And that concludes my prepared remarks.
21 COMM! SS !ONER AHEARNE: Could you say a few words 22 about the subject you brought up at the end of tne paper; 23 namely, the question of placing requirements on more than 24 just th~ operator? For example, the maintenance personnel,
2:5 the facility operator?
--- __ __J
035.06.6 62 gsh MR. COLLINS: This is being studied right now by
2 the Lessons Learned group. I talked with a couple of members
- 3 on the team. And what they are proposing at this time is
4 that each.utility furnish NRC with the tasks list.for each
5 auxiliary operator and support personnel at the facility.
6 And.then after this task list is developed, *to indicate to NRC what training is done to assure themselves that task is
8 going to be accomplished.
) The Congress,. in our appropriat1on legislation, I
- 10. believe, is going to ask for al study or report from the
11 commission on the feasibility of licensing other people in
12 nucl~ar power plants.
13 So this is-where we stand right now on that area.
14 COMMLSS]ONER AHEARNE: Have you read the report on
15 Three Mile.Island?
16 MR. COLLH{S: The NUREG 600? 1 read through it one
I, time as rapidly as I could. I havenJ t had a chance to re ally
18 get to it.
19 COMMISS !ONER AHEARNE: I thought Vic Stello, when 20 he -was introducing it, indicated that to a large extent,
21 *there was significant operator error.
- 22 MR. COLL.INS: Yes.
23 COMMISSIONER.AHEARNE: Now g.iven that, what
. 24..cone! us ions would you in charge of* the licensing branch,
2:5
- opera.tor licensing* b:i:-anch, conclude?
035.06.7 63 gsh Mii. COLLINS: Based on the items that I read, some
2 of the more important areas that we should be covering are
- 3 areas that really are not associated with knowledge of the
4 reactor as much as knowledge of how you conduct yourself
~ around the reactor; namely, how do you take shift turnov9r?
6 How do You use your logs? How do you recognize if something
1 is off-normal when you walk into the control room on shift?
8 I think there are an awful lot of precursors to this
9 accident that maybe any one of them could have prevented 10 performing~- well, the shift supervisor performing maintenancf 11 or having trouble on the feedwater system and not working up 12 some sort of a job plan on how to attack it.
13 And certainly, not even to the extent of checking 14 that the auxiliary feedwater would come on if you lost main 15 feedwater, areas of this as well as technical knowledge.
16 COMMISSIONER AHEARNE: Given those kinds of things, 1 I do you believe that these revisions that you recommended 18 a ddr'3 ss those issues?
19 MR. COLLINS: Yes, to some extent, and perhaps in 20 the categories and not addressed here specifically. But we 21 do have these types of questions readily available to use in 22 the existing categories of the exam and in the make-up of the 23 examination.
24, Pm thinking of normal emergency operating procedure 25 section, the* administrative controls during the conduct of 035.06.8 64 gsh the operating test~. We hav3 a sectioh on our checklist for
2 responsibilities.
- 3 So all of these areas can bs covered to more of
4 _ a degree than we _have - been covering.
5 COMMISSIONER AHEARNE: But you would -- I don-'t want
5 to put words into your mouth.
- Would you say that this paper,
I 330(_3}, represents from your standpoint the lessons to be
8 learned as far as changes in operator licensing?
9 MR. COLLINS: Not all of the lessons to be learned.
10 This is our first cut to you and there will probably be
11 others.
12 COMMISSIONER AHEARNE:* As far as you know at the.
1 3 - pres e n t t i me ?
14 MR. COLLINS: Yes.- I think this addresses several
15 weaknesses t_hat were in our program. I think_ we are going
16 to have a much better program with these* reco,rnmendations put
17 into effect.
18 COMMISSIONER BRADFORD: To the extent that you have
19 had to. study NUREG 0600, were you comfortable with the
20 allusions regarding operator error?
21 MR.. COLLINS: That the operators played a substantial
22 role,_ yes?
_- 23 - COMMISSIONER BRADFORD: And with the individual
24 des ignat:1:ons ot opera tor* *error?
25 MR. COLLINS: I can'." t go down each and every one of
035. 06.9 6:i gsh them, but, yes, the operators contributed t:J the ac::id9nt
- 2 No doubt ab::, ut that.
- 3 COMMISSIONER GILINSKY: Viell, the commission will r
4 review this paper and get back to you on this.
- ) MR. COLLINS: Thank you.
6 COMMISSIONER AHEARNE: I will provide a number of
I questions to you. On one set there, Admiral Rickover has l 8 ' recently gone throu;ih some recommendations as to what he
I I
f 9 thinks might be_ possibly appropriate. And I 1 d be interested f
10 - in hearing your comments on it.
l l MR. COLLINS: Yes, sir.
12 (Whereupon, at 3:30 p.m., the hearing on the
13 matter was concluded.)
\\.,
14 ev '
15
16
17
18
19
20
21
22
23
j 24
- 2S