NRC Generic Letter 1982-13
0.,.a RIGA,
- 0 4' UNITED STATES
NUCLEAR REGULATORY COMMISSION
WAHINGTON. D. C. 20555
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June 17, 1982 TO ALL POWER REACTOR LICENSEES, APPLICANTS FOR AN OPERATING LICENSE AND
HOLDERS OF A CONSTRUCTION PERMIT
Gentlemen:
Subject: Reactor Operator and Senior Reactor Operator Examinations (Generic Letter 82-13)
Enclosed are the results of a meeting held in Bethesda, Md. on January 6, 1982, to discuss changes to the examination used to license Reactor and Senior Reactor Operators. The questions and comments raised during that meeting are discussed in the enclosed summary.
This letter is for your information only and requires no response or action.
Sincerely, Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation Enclosure:
1. Response to Questions/-
Comments
2. List of Attendees
8204210387
820421037 820617 PDFR ADOCK O5o0OOO3 V PDR
General Topic: Examination Administration Ouestions/Suqqesticns:
What responsibilitfes/authority do proctors, especially when it is the Resident Inspector, have?
Will questions be made available to allow trainers to know what areas should be covered?
The exam should be open book, allowing access to the materials the operator i..uld have in the control room (i.e., Tech Specs).
Will NRC guidance be updated to reflect the new exam format?
What options are open for taking the written exam? AM/PM sessions? One sitting? And what options for splitting sections are available if a split period used?
Reducing the number of questions (time) increases the importance of each question.
Formula/Equation sheet should be standardized.
Can the utilities get copies of questions submitted by other utilities?
NRC should recommend a list of standard texts.
A firm date for implementing the new format should be set.
Reoorting results should be standardized. Some people get summary sheets, some don't know results until licenses or denials Arrive. Results should be in faster.
Why not leave a copy of the exam after it has been taken?
Can the utilities get a copy of the exam in advance to allow for a thorough review.
Why establish a time limit? The exam should find out what you know, not how fast you can write.
Why not use Qualified industry people to administer exams at other facilities?
Better guidance is needed on what will be covered in the exam ind better informa- tion on grading criteria and granting waivers should be available. There is no way to check on the results of oral exams.
Are machine prepared, machine graded exams possible? Probable?
Better clarification of the March 28, 1980 letter on qualifications is needed.
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ENCLOSURE 1 Genertl Topic: Reactor Theory, Heat Transfer, and Thermodynamncs Questions/Suggestions:
CombinelRO and SRO sections since a distinction cannot be made on what is RO
and what is SRO level of knowledge.
Response:
At the January 6 meeting a poll was taken at the round table discussions.
Approximately 42% preferred separate categories and 57% preferred combining the two. Comments on the subject were:
1. Could have union problems, if operator candidates are required to answer questions at senior level.
2. Combining categories is appropriate since the distinction cannot be made between SRO and RO knowledge level.
3. Categories should not be corbined at this time since this change will delay implementation of new formats.
4. Some individuals believed it is appropriate to keep categories separate, as proposed, since SRO and RO level can be determined.
5. Some individuals were neutral and had no strong feelings either way.
Since there was not clear consensus and since there could be additional problems the created, we will maintain the current format until sufficient feedback from This is new exam format is available to support a move in the other direction.
an area where specific comments on the exams will be useful in evaluating general statements.
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ENCLOSURE 1 General Topic: Reactor Theory, Heat Transfer, and Thernodynamics Questions/Suggestions:
Combine RO and SRO sections since a distinction cannot be made on what is RO
and what is SRO level of knowledge.
Response:
At the January 6 meeting a poll was taken at the round table discussions.
Approximately 42% preferred separate categories and 57% preferred combining the two. Comments on the subject were:
1. Could have union problems, if operator candidates are required to answer questions at senior level.
2. Combining categories is appropriate since the distinction cannot be made between SRO and RO knowledge level.
3. Categories should not be combined at this time Oince this change will delay implementation of new formats.
4. Some individuals believed it is appropriate to keep categories separate, as proposed, since SRO and RO level can be determined.
5. Some individuals were neutral and had no strong feelings either way.
Since there was not clear consensus and since there could be additional problems created, we will maintain the current format until sufficient feedback from the new exam format is available to support a move in the other direction. This is an area where specific comments on the exams will be useful in evaluating general statements.
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General Topic: Future Meetings Questions/Sum estions:
The meeting was useful and should be repeated regularly. The meeting announce- rent with a proposed agenda should be available sooner. The meeting gave industry representatives a chance to understand and commient on proposed changes. Could a list of attendees be provided? Smaller meetings between training staffs and examiners should be held.
Response:
We were as enthusiastic as you about the meeting. We intend to repeat the process and will provide more notice in the future. We will consider small meetings, especially as the OLB staff is regionalized, but do not plan any now due to resource limitations.
A copy of the attendance list of the meeting is attached. Please bring additions or corrections to our attention.
General Topic: Written Examination Questions Questions/Suogestions:
that are not done on the Questions should not require lengthy calculations
-ob..
since it is worst case and may Questions should not be taken from the FSAR
not be up to date.
require knowing actions after Technical Specification questions should not one hour since the SRO can look these up.
should be used.
More short answer or multiple choice questions on operating information not Health Physics questions should concentrate time-distance-shielding type Questions.
in exams.
Mitigating core damage should be included Plan since these are not RO Exams should not include Tech Specs or Emergency her responsibility.
the utilities should be notified.
If new topics are to be included in the exams, should be able to identify In addition to submitting good questions, utilities questions they feel are bad.
Response:
in the exam will be on operational As indicated in the January 6 meeting, emphasis are in line with the guidelines given information. To ensure that exam questions deleting or modifying ones that do not to you, we are reviewing the questions and topic, we are developing a computer- comply. As discussed in the exam consistency and reviewed, we will make ized bank of exam questions. When fully developedsubmission of questions for the this bank available to the public. We encourage bank and comments on questions that you feel are not valid. In this effort we that are not generally the responsi- are eliminating the Health Physics questions Tech Spec questions concentrate on bility of the RO or SRO, and arranging that of what actions are required understanding of the bases, general knowledge what systems have tech spec limits and immediately (within one hour) and why, and ability to find and use the tech why. In the operational exam the candidate's still include calculations to specs will be examined. Ouestion contentofmay the principles involved in nuclear determine the candidate's understanding of calculations will be avoided.
plant operation, but calculations for the sake choice question formats and have We are investigating short answer and multiple We will not, however, shift entirely used both in exams that have been given. questions present a fair opportunit:
to this format until we have assured that the and we have notified the industry for the candidate to show his or her knowledge that we will be changing exam style.
from the training material provided.
We are continually developing new questions of information, but we recognize We will continue to use the FSAR as'a source information should be pointed out in its limitations. As always, out of date answers can be updated. We hope in the the exam critique so that questions and letter to inform the public of new near future to develop a regular information areas of interest in the exam.
Response:
Your concerns fall into several areas. First, the exam may be taken either at one sitting or broken into two parts. The utility has the option, but all candidates rust take the exam the same way. The exam will be given, as indicated, section 1, 2. and 3 or 6. 7, and 8 in the first three hours and 4, S,-or 9, 10
in the second three hours if a split sitting is elected. The examiners or proctors have the authority to allow individual breaks during the exam, but the exam must still be finished within the allowed time. The examiner or proctor will keep track of elapsed time.
Second, only examiners are authorized to mwdify an exam. Proctors, even resident inspectors, are not authorized to rake changes. Proposed changes should immediately be called to the attention of the assigned chief examiner.
Third, ai discussed in the exam questions topic, we are reviewing the questions, invest1gating rultiple choice and short answer questions to allow more areas to be covered in the limited amount of time, however, a time limit will remain.
We are investigating machine generated/machine graded formats but have no imnediate plans for implementing such a system. Before a change like that will be adopted, the approach will be validated and your comments solicited prior to any action being taken. Once fully developed, we will consider iaking the questions contained in the exam question bank available'to assist you in your training program and In keeping the questions current.
Fourth, we do not intend to go to an open book exam. We are working to ensure that the written exam tests for infornation that the candidate should know with- out aids and the operational exam tests his ability to use aids such as procedures and Tech Specs.
Fifth, we are in the process-of developing updated guidance on exam content, objective and subjective grading criteria, exam administration and application content. We will not endorse a set of reference texts. This guidance, coupled with greater accessibility of exam questipns, should improve information availa.
ble on what the exam will cover. Any texts-that suitably cover the Vaterial are acceptable.
Sixth, we are implementing a system to allow automatic, computer-aided tracking of applications and exam results. Our goal is to have all results reported to the Individuals and utilities within two months of completion of the examination.
As more examiners are certified this goal will be reviewed to see if we can .
reduce it even further. You can assist us by refraining from calling for results or submitting FOIA requests until after the two months have passed. Exam results are not final until all portions of the exam have been completed and internal audits for consistency-and fairness are done. At that points exam summary sheets will be sent to the utility, and licenses or denials and a copy of the written exam will be sent to the individual.
Finally, almost all old format reexaminations have been completed and suffil.ient experience has been gained in preparing new format exams. Therefore, only siew format exams will be given for examinations scheduled after July 1, 19g'.
General Topic: Examination Consistency Questions/SuQgestions:
Some examiners lack the knowledge and training necessary to give oral exams.
They use poor methods and intimidate the candidates.
Some examiners are too academically oriented. There are large inconsistencies between examiners. You almost have to know who is preparing your exam so you can prepare the candidates in the proper areas.
Sore examiners will not accept an operating method that differs from a Ocookbooka method even though the alternate method may be equally acceptable. Therefore, correct answers are marked wrong.
There are no standards for required level of knowledge for oral exams. Therefore, the depth required varies between examiners.
Response:
As discussed in other sections, we are working on guidelines for exam content and developing a question bank of valid questions. Since these will include plant specific, as well as generic questions, the operating philosophy of each facility can be reflected in their exam questions.
For oral exams we are preparing guidelines for the examiners. Appropriate portions will be made publicly available.
We have also established a training and certification program for contract examiners. This will ensure that a minimum competence has been obtained prior to conducting exams. To ensure competence and consistency, all examiners, NRC and contractors, will be audited periodically by the OLS Section Leader.
We are sensitive to the issue of competency and consistency because we are actively transferring examiner functions to the Regional Offices. Any specific feedback from an examination is welcome and will be kevt confidential.
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Aeneral Topic: Simulator Exams OuestionsfSuqgestions:
Plant specific simulators should be mandated by NRC.
What are fRC's future plans for simulator exams? More guidance is needed on what will be covered in simulator exams, especially-for non-plant-specific simulators.
Response:
A Commission Paper has been prepared.recomnuending that the requirement for non-plant-specific simulator exams be removed. We have studies underway to develop valid operational exams, Including simulator exams. At this time we feel that dynamic transient operation is an important aspect of the exam but that the limitations imposed by non-plant-specific simulators and the scheduling problems encountered reduce the effectiveness of the exam and do not justify the resources required. Therefore, we are considering returning to the old exam method of performing power transients, startups and shutdowns on those facilities that do not have a plant speci'fic simulator available. Any change in the exam will be discussed before it is iiplemented. Until the need for operating tests on the facility or other testing methods being studied by the staff are validated, the operating examination will continue to follow the existing guidelines in NUREG 0094. Therefore, there is a continued need for simulator training to comply with the guidance in NUREG 0094. The Coimmtssion has not acted on the staff recommendation at this time. The CoMnMssiOn paper does not include any requirements for actual plant operations at this time.
As discussed under the exam administration topic, we are developing guidelines for simulator exams. We are also modifying the operational exam suffrrary sheet to facilitate the simulator exam and to ensure that areas examined at the simulator are not duplicated in the plant walk-through.
Miscellaneous Ovestion:
Where are guidelines for medical applications?
Response:-
Basic requirements are in Part SS. Aioltfying guidance in Regulatory Guide 1.134 which endorses ANSI/ANS 546.
Suggestion:
Fallback to RO on instant SRO failure isn't worth much since engineers or supervisors aren't in the union and cannot perform RO duties.
Response:
We agree that fallback has little value. When a candidate is certified to need an SRO license to perform his or her duties, we don't see how having an RD will help. Under the new format exam, this problem should disappear.
Suggostion:
KRC should put certification of training instructors on high priority since this could have a real impact on training.
Response:
We agree entirely. Our highest priority, as always, is licensing new operators.
As more examiners are trained and certified, we will be pursuing the area of instructor certification more vigorously. All Operating License applicants are required to have certified instructors prior to fuel load and we have certi- fied instructors at several operating plants. We are monitoring the INPO work on training program accreditation and are investigating means to certify vendor and consultant instructors that teach systems and operations courses. More inforrmation will be available on this subject in the near future.
(uestion- What are NRC's plans for requalification exams?
Response:
In the Commission paper on non-plant-specific simulators we discuss the subject of requalification at length. To summarize, as directed by the Commission, we will start giving requalification examinations in conjunction with scheduled visits for replacement exams. We are targeting at least one site visit to each facility this year and expect to administer requalification examinations to 20%
of the licensed operators. Our initial plans are to conduct the requalification exams during replacement exams; however, we will work out availability and schedules with each utility. Tn the Commission paper, the staff proposed that for utilities with a plant specific sirulator, the requalification exam will be given only on the simulator. Otherwise, a written exam and practical test vill be given. Failure of the exam will require accelerated retraining in weak areas, as is required now, and NRC reexamination. If significant weaknesses in the utility requalificatlon program are revealed by the exams, NRC administered requalification exams for all license renewal applicants will be likely until the requalification program has been sufficiently upgraded. Details of the.
program are in the Commdssion paper. No ComMission action has been taken at this time.
Suggestion:
NRC should periodically issue a listing of generic weak points.
Response:
When our automated system is operational, we intend to issue quarterly informa.
tion reports that will include observed weak areas. It will also include areas of concern at NRC that might affect the content of future exams and general information on the exams. We hope to be producing these reports in the very near future.
Suggestion:
Cold plants need amplification of R. Denton's March 28, 1980 letter regarding experience requirements.
Response:
It is difficult to provide better generic guidance than exists in the letter Task Action Plan Item I.A.2.1 NUREG-0737 and NUREG 0094. Specific cases can be discussed with the appropriate OLB Section Leader. The OLB policy is to grant exemtotlns or.walvers only In specific cases, not on a generic basis.
Therefore, the requirements should be discussed with the Section Leaders.
ENCLOSURE 2 LIST OF ATTENDEES
NAME & TITLE COMPANY
Hugh Thompson Acting Director, DHFS USNRC
Bruce Wilson OLB Examiner USNRC
Joe McMi1len Region III Examiner USNRC
Robert Campbell OLB Examiner USNRC
Ted Szymanski OLB Examiner USNRC
Bruce Boger OLR Examiner USNRC
Rcnald Eaton OLB Examiner USNRC
Rornald Maines OLB Examiner 11SNRC
Robert Keller OLB Examiner USNRC
John Munro OLB Examiner USNRC
Len Wiens OLB Examiner USNRC
Tom Hamrick Union Carbide - ORNL
Jim Evans Mgr. Training Westinghouse Ray Hallmark Director, Su Ops Energy Inc.
Ron Burdge Gen. Mgr. - Dev. Div. NUSTC
Dan F.. Moore Supv. - Nuclear Training Ga. Power Co.
Frank Thompson Supy. Oper. Fund, Trng. WPPSS
Lee Williams Trng. Supt. Ala. Power Co.
Paul Hobbs Sr. Trng. Supt. Union Electric Co.
R. J. Bursey Consultant NPO Inc.
J. F. Crosby Eval ItNPO
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- 2- P. L. Flncher Training Supv. Florida Power & Light Co.
J. R. Bynam TVA
R. G. Jones TVA
E. W. Merschoff NRC
J. G. Cook Tech Supervisor JPC
J. Macdonald CE
J. Barba CE
J. Yoe Baltimore Gas & Electric Co.
S. Jones Baltimore Gas & Electric Co.
Eugene Carlson Pennsylvania Power & Light Co.
Jay Wheeler PECO
Joe Zerbo General Physics Bill Landon Conn. Yankee Don Tall PASNY/FITZ
Fred Curling VEPCO
Larry Edmonds VEPCO
Andy Neufer PROS
Tom Houghton K34C, Inc.
Rick Zollitch Trng. Superintendent Niagara lIohawk Warren R. Forrest Sr. Trng. Supyr. Unin Electric Co.
Clyde Gilbert Trng. Supvr. Northeast Utilities Mark D. Shepherd Trna. Florida Power S Light Co.
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4 Terry L. Wood Trng. WPC
Harry L: Mathis Mgr. Nucl Trng. Southern Calf. Edison Co.
Jerry Scholand Mgr. WNTC Westinghouse Dr. Ron Bruno Supt. - Trng. Wisconsin Electric Co.
Ernest Chattfield *Trng. Mgr. Yankee Atomic Power Co.
Wendell H. Barron Trng. Sup. Carolina Power S Light John Gass Trng. Sup. Omaha Public Power District Michael Williams Trng. Mgr. SCE& -
H. T. Babb Trng. SCE&G
Fred Dacimo OSS Northeast Utilities Tim Martin Trng. Supv. Pacific Gas & Electric Co.
Ken Beatty Trng. Supv. Florida Power S Light Corp.
J. R. Wzlkev Trng. Shift Eng. TVA
Robert L. Lewis WENP Asst. Supv. TVA
Rick Goodrick Certification Examiner General Electric S. D. Schile Trng. ATTS, Inc.
R. M. Koehler Duke Power Conpany R. J. Barrett Trng. Mgr. GPU
Dean Crawford BWR Sirulator Dir. Singer-Link Putch Colby Manager Singer-Link G. J. Ashworth Sr. Staff Supv. Consumers Power Co.
Dr. C. M. Overbey PQS Section Leader NRC/DHFS
- 4- A. Fullerton Research Associate ORNL
J. H. Reed Research Associate ORNE
David Nelson Trng. Coodinator IUM Elec.
G. Bockhold mgr./Nuc. Trng. Georgia Power J. Lloy6 Trng. Supervisor PSE&G
S. Crouch Sr. Trnq. Cons. ATTS, Inc.
Jim Hicky Trng. Mhgr. Toledo Edison Co.
Rob Anderson Trng. Coordinaitor Iowa Electric R. W. Bulver Supt. Nuc. Training Phila. Electric Co.
Jack Hau Trng. Sup SMUD
Chuck Maney Instructor Commonwealth Edison Brendan Moroney NUS
Joseph Gonyecu Mgr. - Prod. Jrng. NSP
Mike Sellman Trng. Supt. Pt Northern States Power Co.
Gene Earney Prog. Supt. PSP
Bob Jansky Shift Supv. Trng. NPD
Art Morris Asst. Trng. Coor. Rochester Gas & Electric Co.
Dick Morrill Trng. Supervisor Rochester Gas & Electric Co.
William T. Gott Trng. Director Cincinnati Gas & Electric Marty Langan Nuc. Inst. Louisana Power & Light Br#; E. Crane Nuc. Trng. Mgr. Florila Power Corp.
Bill Olsen Sr. Trng. Spec. Boston Edison Co.
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Charles Bogolin Operation Super. Gulf States Larry Vieder Prog. Spec. Ruc. Trng. Carolina Power & Light Saul J. Harris Nuclear Program Mngr. EEI
Ed Force Trng. Coordinator Arkansas Power & Light Co.
Bill Garrison Shift Supervisor Arkansas Power & Light Co.
Ed Thorndyke Trng. Supervisor Carolina Power & Light Co.
Art Shean Trng. Director Maine Yankee Atomic Power Co.
Dan McNeal Shift Supervisor Cincinnati Gas & Electric T. Lempges V.P. Nuc. Gen. Niagara Mohawk R. Joe Johnson Trng. Mgr. TVA
Dennis Ockernan Trng. General Electric Charles Cowan Trng. Coordinator Philadelphia Electric Dave Roth V.P. General Physics Corp.
A. Shauver Dir. General Physics Corp.
William Odell Mgr. Instruction B&W
Ray Wadas Trng. P.S.C. of Colo.
Martin Block Supt. Operation P.S.C. of Colo.
Jim Vassello Trng. DL Co.
Bob Clark Battel le Sam Newton Op. Trng. Ygr. GPU Nuc. TMI
Bob Ecam AP&L
Tom Higgins Trng. Sup. Commonwealth Ed.
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- 6- L. E. 'Al' Kanous Dir. Nuc. Trng. Detroit Ed.
Ken Rottkamp Trng. Inst. LILCO
Jon Rengston Trng. Sup. PUSTC
Zeinab Sabri Director - Nuc. Trng. LPAL
Richard P. Bogate Simulator Instructor Duke Power Co.
Norman Pgre fterations Duke Power Co.
Craig Kvafme NRC Contractor Operator Exam Branch, EG&G
R. M. Stallnan NRC Contractor Operator Exam Branch, EG&G
Tony Vinnola NRC Contractor Operator Exam Branch, EG&G
Don Neighbors NRC
Bob Martin ORB #3 NRC
Nick Corithard KG&E Mgr. Training Art Mah KG&E Training Supv.
Dave Fawcett Op. Trng. Supv. GPU
C. L. Turner Director Huc. Trng. Texas Utilities N. W. Hough Trng. Supv. Carolina Power & Light Co.
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