ML20128E303

Discusses Requalification Program Evaluation & Senior Operator License Exam Scheduled for Wk of 930308.Encl Ref Info Should Be Furnished Prior to Exam

ML20128E303
Person / Time
Site:	Peach Bottom
Issue date:	12/02/1992
From:	Conte R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
NUDOCS 9212080047
Download: ML20128E303 (12)

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i Docket Nos. 50-277

! 50-278 hir. D. hi. Smith l Senior Vice President-Nuclear '

l Philadelphia Electric Company ,

j Nuclear Group Headquarters ,

! Correspondence Control Desk '

l P. O. Box 195

) Wayne, Pennsylvania 19087-0195

Dear hir. Smith:

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, SU10ECT: REQUALIFICATION PROGRAh! EVALUATION AND SENIOR  !

OPERATOR LICENSE EXAhilNATION  ;

I in a telephone conversation on November 17, 1992, hir. D. Florck and hir. D. hicClellan arranged to evaluate the requalification program and licensed personnel at the Peach Bottom Atomic Power Station. The evaluation is scheduled for the week of h1 arch 8,1993. NRC examiners and evaluators from your facility will conduct requalification examinations, and the i NRC will evaluate the facility licensee's requalification program in accordance with Sections i ES-601 through ES-604 of NUREG-1021, " Operator Licensing Examiner Standards,"

Revision 7. You are encouraged to ensure that your training staff and proposed examinees l are familiar with these standards. The operating examination for the senior operator is ,

scheduled for the week of February 22,1993, and will use Revision 6 of NUREG-1021.  ;

For the NRC to adequately prepare for this requalification program evaluation, the facility l will need to furnish the NRC the approved items listed in Enclosure 1, " Reference biaterial Requirements." You are also requested to submit, at your option, a proposed examination for use during the examination week. However, if you do submit a proposed examination, the personnel participating in its development may become subject to the security restrictions described in this letter.

To prepare for the operating examination for the senior operator, it will be necessary to furnish the reference material identified in Attachment 1 of ES-201 in NUREG-1021, Revision 6, by January 4,1992.

OFFICIAL RECORD COPY G:DFPB3893 9212000047 921202 PDR ADOCK 0500 7 I

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l Mr. D. M. Smith 2

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Please review the guidance promulgated in Revision 7 to NUREG 1021 on the content and scope of simulator examination scenarios. The scenatio examination bank should cover the entire spectrum of emergency operating procedures (EOPs), including alternative decision i

paths with various degrees of severity for the same type of ever'. Each scenario should contain simultaneous events that require the senior reactor operator (SRO) to prioritize their actions and to assign other crew members particular tasks. Each scenario should also require the SRO to prioritire their actions and to assign other crew members particular tasks. Each scenario should also require the SRO to decide when to transition between EOPs and decide i which actions to take within EOPs. ,

You are requested to designate at least one employee to be a member of a joint NRC/ facility examination team. The employee is expected to be an active senior reactor operator (SRO), '

as defined by 10 CFR 55.53(e) or (f)) from the Peach Bottom Atomic Power Station operations department. You are encouraged to designate a second employee from the training staff to be a member of the examination team. This employee should also be an active SRO, but may be a certified instructor. If desired and agreed to by the chief examiner, you may designate one additional employee from the training staff, with appropriate qualifications, to be a member of the examination team, in addition to these individuals, you will need to designate a simulator operator for scenario preview and validation during the on site examination preparation week, in some cases, you may need to designate a simulator operator during the test item review period. All of these individuals will be subject to the '

examination security agreement.

The NRC restricts any facility reprcsentatives, under the security agreement, from knowingly -

communicating, by any means, the content or scope of the examination to unauthorized persons and from participating in any facility programs such as instruction, examination, or tutoring in which an identified requalification examinec(s) will be present. These restrictions shall apply from the day that the facility representative signs the examination security agreement indicating that the representative understands that he or she has specialized knowledge of the examinatica. The chief examiner will determine when a facility representative has received specialized knowledge concerning the examination and will execute an examination security ugreement. In most cases, the examination team members will not be required to enter into an examination security agreement more than 60 days before -

the examination week. The simulator operator will normally become subject to the security .

restrictions during the examination preparation and validation week; however, this may occur 1

as much as 45 days before the examination week.

OFFICIAL RECORD COPY G:DFPB3893 L .

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Mr. D. M. Smith 3 Sixty days before the examination administration date, please provide the NRC regional of0ce with a list of proposed licensees, including crew composition, for the examination and the current mailing address for each proposed licensee, if different from that listed on the most recent Form 398 submitted to the NRC. The facility training staff should send this information directly to the NRC's chief examiner, ensuring thM cach licensee address is sent in a manner to ensure privacy.

The facility may request that the NRC chief examiner or another NRC representative meet with the licensees to be examined and the licensee managers during the examination preparation week, norrc ally 2 weeks before the examination. However, if the schedule does not allow them to meet during the preparation weck, they may meet at any mutually agreeable time. The NRC examiner will explain the examination and grading processes and will respond to any questions that licensees may have about the NRC's examination procedures. The facihty licensee training staff should schedule this meeting, if it is desired, i

with the NRC chief examiner.

The facility licensee is requested to distribute the "Requalification Examination Feedback Form," attached as Enclosure 3. This feedback form may.be completed by all operators, evaluator, and facility licensee managers participating in the NRC requalification examination. The feedback from this form will be used to measure the success of the NRC.

and facility licensee's efforts to reduce undue stress during the requalification examination.

The facility licensee staff is responsible for providing adequate space and accommodations to properly develop and conduct the examinations. Enclosure 2, " Administration of Requalification Examinations," describes our requirements for developing and conducting the examinations. Also, a facility operaticns management representative, above a shift supervisor level, should observe the simulator examination process at the site.

Your staff should submit the preliminary senior reactor operator license application and waiver request at least 30 days before the first examination date so that the NRC will be able to review the application and the medical certification and evaluate any requested waivers. If the application is not received at least 30 days before the examination date, a postponement may be necessary, Final, signed applications certifying that all training has been completed d

should be submitted at least 14 days before the first examination date, OFFICIAL RECORD COPY G:PB3893 i

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hir. D. ht. Smith 4 This request is covered by Office of hianagement and Iludget Clearance Number 3150-0101 which expires October 31,1995. The estimated average burden is 7.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per response, includes gathering, xeroxing, and mailing the required material. Send comments about this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Records and Reports hianagement Ilranch, h1NBB 7714 Division of Information Support Services, OfDee of Information Resources hianagement, U.S. Nuclear Regulatory Commission Washington, D.C. 20555; and to the Paperwork Reduction Project (3150-0101), OfDee of Information and Regulatory Affairs. NEOll-3019, OfDec of hianagement and lludget, Washington, D.C,20503.

Thank you for your consideration in this matter, hir. hicClellan has been advised of the NRC guidelines and policies addressed in this letter. If you have any questions on tho evaluation process, please contact me at (2!5) 337-5210.

Sincerely.

lLft ,hfur Richard J. Conte, Chief IlWR Section Operations Branch Division of Reactor Safety

Enclosures:

1. Reference hiaterial Required

2. Administration of Requalification Examinations

3. Requalification Feedback Form OFFICIAL RECORD COPY G:DFPB3893

. . , . . _ _ _ , _ . _ _ . . _ _ _ . . _ . _ _ _ _ . .. _.)

Mr. D. M. Smith 5

- cc w/encis:

R. N. Charles, Chairman, Nuclear Review Board D. B. Miller, Vice President, Peach Ikittom Atomic Power Station G. Rainey, Vice President, Nuclear Services Department G. Cranston, General Manager, Nuclear Engineering Division C. Schaefer, External Operations - Nuclear, Delmarva Power & Light Co. ,

i K. P. Powers, Plant Manager, Peach Bottom Atomic Power Station A. A. Fulvio, Regulatory Engineer, Peach Bottom Atomic Power Station G. J. Beck, Jr., Manager, Licensing Section D. McClellan, Operator Training Supervisor J. W. Durham, Sr., Senior Vice President and General Counsel J. A. Isabella, Director, Generation Projects Department, Atlantic Electric B. W. Gorman, Manager, External Affairs R. McLean, Power Plant Siting, Nuclear Evaluations  ;

D. Poulsen, Secretary of 11arford County Council R. Ochs, Maryland Safe Energy Coalition J. H. Walter, Chief Engineer, Public Service Commission of Maryland Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident inspector Commonwedth of Pennsylvania TMI - Alert (TMIA) bec w/encis:

Region 1 Docket Room (with concurrences)

E. Wenzinger, DRP C. Ancerson, DRP R. Conte, DRS' D. Florek, DRS DRS/EB SALP Coordinator V. McCree, OEDO J. Shea, NRR OL Facility File DRS Files (2)

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ENCLOSUltE 1 ItEFERENCE A1ATERIAL ltEQUIREN1ENTS

1. Provide test items to support all aspects of the requalineation examination to the NRC 60 days before the examination date.

2. The following reference material:

• A minimum of 700 test items for use in the written examination equally diviued between the two sections of the written examination and which cover all safety related elements of the facility job task analysis (JTA). The facility licensee is expected to maintain a dynamic bank by reviewing, revising or generating at least 150 questions a year. New questions should cover equipment and system modifications and recent industry and licensee events and procedural changes.

JPhis to evaluate cach reactor operator and senior reactor operator safety-related task identiDed in the facility JTA, which meet the criteria in ES 603.

The JPhi bank should expand at a rate of at least 10 JPhis per year tmtil this goal is reached, it is estimated that 125 - 150 JPhis will be the final result.

A bank of at least 30 simulator scenarios which rencet all abnormal and emergency situations to which a licensee is expected to respond or control. At least 5 scenarios per year should be generated until all aspects of the emergency operating procedures are covered with suf6cient variation in the type and scope of initiating events and level of degradation.

These target levels are expected to be attained by the facility licensees on 10/1/95.

Ove years after the implementation of Revision 6 of NUREG-1021 (10/1/90),

3. For all licensee requalincation examination and program evaluation visits, the facility shall:

Submit an Examination Sample Plan which meets the requirements of ES 601, Attachment 2; Provide the associated examination banks (written, simulator and JPht) and associated reference material. At a minimum, this shall include Technical Specifications, abnormal and emergency operating procedures, and emergency plan procedures utilized in the requalification training.

Provide additional reference material as requested by the NRC chief examiner.

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ENCI.OSUltE 2 ADMINISTitATION OF ltEQUALIFICATION EXAMINATIONS

1. The NRC must evaluate at least 12 licensees to perform a program evaluation.

Normally, the crew scheduled for requaliftcation training during the period selected for the program evaluation should be selected. The evaluation will include other licensees who are not routinely performing shift duties or are not maintaining an active license as dermed in 10 CFil 55.53(c). The restrictions on crew composition in >

the simulator are described in 11S 001, Section C.2, and 11S 604.

2. The simulator and simulator operators need to be available for examination ~

development. The chief examiner and the facility representatives will agree on the dates and duration of time needed to develop the examinations.

3. The chief examiner will review the reference material used in the simulator. The NRC will not authorize the use of reference material that is not normally used for plant operation in the control room to be used during the simulator test.

4. The facility licensee will provide a single room for completing Section 11 of the written examination. The examination room and supporting restroom facilities will be located to prevent the examinees from contacting other facility and contractor personnel during the examination.

5. The chief examiner will inspect the examination room to see that it meets the minimum standard that will ensure examination integrity. The minimum spacing standards consist of one examince per table and a 3-foot space between tables. No wall charts, models, or other training materials are allowed in the examination room.

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6. The facility licensee is expected to provide a copy of each reference document for each examinee for Section 11 of the written examination. The material should include documents that are normally available to the licensees in the control room, such as the technical specifications, operating and abnormal procedures, administrative procedures, and the emergency plans. The chief examiner will review the reference material before the examinations begin.

7. The NRC requalification examination will attempt to distinguish between RO and SRO knowledge and abilities to the extent that the facility training materials allow the developers to make these distinctions.

8. Prudent scheduling of examination week activities is important to help alleviate undue stress on the licensees. The facilhy t~ tining staff and the NRC chief examiner should o attempt to formulate a schedule that will minimize delays while conducting the examination.

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Bring in licensees in accordance with their scheduled examination times, ,

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' It is better to segregate the group of licensees completing their examination, instead of the group of licensees that are scheduled to start their examination.-

Following simulator scenarios, the facility evaluators and NRC examiners should quickly determine whether follow up questioning is requhed so that the crew members may be released to talk among themselves about the scenario. >

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• Ensure that thne validation of JpMs, particularly those performed in the i simulator, is accurate. Establish a reasonable schedule to prevent the licensees. ,

from waiting for simulator availability to complete their JpMs.

9. The NRC no longer requires the facility licensee to videotape dynamic simulator examinations. If the facility licensee requests to videotape the examination, any use of '

the tape must be completed before the NRC leaves the site at the end of the examination. If a disagreement over the grading of a licensee still exists at the end of the examination week, the facility liccusee may retain the tape for the purpose of-- i

' submitting it to support a request for regrade by the NRC. During the regrade, the NRC will review only the portion of the videotape under contention. After all I requalification examination geades are finalized, including the review of any regrade request, the facility licensee is expected to crase all video tapes made during the examination.  ;

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'l ENCIDSUltE 3 ItEQUAI.lFICATION EXAh11 NATION FEEI)llACK FOlth!

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The NRt. is requesting feedback regarding the conduct of requalification examinations. The information provided will be used to monitor, on a gencric basis, the effectiveness of the NRC's and facility licensee's efforts to minimite undue stress in the examination process. ,

This form is not intended as a means of resolving technical or process concerns pertaining to a specific examination. Such concerns will be resnived using the f,'uldance in NUREG-1021,

" Operator Licensing Examiner Standards."

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Completion of this form is voluntary, if you choose to provide feedback, please answer the questions in accordance with these in!,tructions:

• The questions in this form regard the requalification examination administered by Region I at the Peach 110ttom Atomic Power Station during the week of hlarch 8,1993. Although comparisons with previous examinations may be appropriate, responses to the questions should be based upon this requalification examination.

• Any examinee or individual involved in the developme or administration of this examination is encouraged to complete this form.

• hiail completca forms to:

U, S. Nuclear Regulatory Commission, Region I A'ITN: 1xe H. llettenhausen, Chief Operations 11 ranch, Division of Reactor Safety 475 Allendale Road King of Prussia, PA 19406 Your llackground Please check the boxes that describe your involvement in this examination.

_~ . . _

._ . . . . . ._ ~ _- _ _ . _ _ _ _ _ _ . _ . _ _ _ _. - - .

o Enclosure 3 2 I was:

an examinee involved in developing the examination involved in administenng the examination an examination observer other:

3 Please check the boxes that describe your current position. (Check all that apply)

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RO SRO Operating crew member training department operations department other:

Stress vs. Undite. Stress The following questions require you to make a judgment of whether there was undue stress _

durit.g the examination. Examinations are inherently stressful events; and, therefore, it is important that you make a distinction between stress and undue stress when making your judgments. Undue stress is unnecessary or inappropriate stress which can be practically climinated without compromising the validity of the examination. The distinction between stress and undue stress is not a matter of wheth:r the stress was c>1reme or mild. When making your judgments, you should follow these steps:

First, consider the cause of the stress. Wou'd it have been possible and practical to climinate the cause of the stress without compromising the validity of the examination? If our3 answer is no, then no undue stress was present, (See point #1 on the rating scale below.)

If your answer is yes, consider the magnitude of the stress. A source of stress may .

be unnecessary, but also sufficiently small in magnitude to be unlikely to affect an-individual's performance in the examination. (See point #2 on the rating scale below.) The alternative is that the source may be unnecessary and also of suf0cient magnitude to be likely to affect an individual's performance in the examination. (See point #3 on the rating scale below.)

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• l linclosure 3 3 IhthtgScale:

1. No undue stress. ,

2. Some undue stress.

Inappropriate stress was present that could have been practically avoided but would not likely affect an individual's examination performance.

3. Significant undue stress.

Inappropriate stress was present that could have been practically avoided, and it would likely affect an individual's examination performance, ihamination Feedback Halitig3: Please use the rating scale described on the preceding page to indicate your judgment of the degree of undue stress that was present in each aspect of the examination identified below. Write the number (1,2, or 3) in the space preceding the section.

Coimnents: Please comment about the source or cause of any undue stress, including who was affected (c.g., examinees, examiners) and suggested practical solutions.

Attach additional sheets if necessary.

Preexamination Interactions with NRC Comments: .

Adaduistrative Controls / Procedural 1.imits Comments: ._

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11nclosure 3 4 Plant and Control Systems Coraments:

Dynamic Simulator Comments:

Job Performance Measures Comments:

Please comment on any practices which you believed were successful in reducing undue -

stress.

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