ML21051A000

Comment (4) of Tim Riti on NUREG-1021, Operator Licensing Examination Standards for Power Reactors

ML21051A000
Person / Time
Site:	Nuclear Energy Institute
Issue date:	02/12/2021
From:	Riti T Nuclear Energy Institute
To:	Office of Administration
References
85FR77280 00004, NRC-2020-0227, NUREG-1021 R12
Download: ML21051A000 (17)

Text

2/20/2021 blob:https://www.fdms.gov/339fbb64-006d-44f3-a77e-f706226d4038 SUNI Review Complete Template=ADM-013 As of: 2/20/21 11:53 AM E-RIDS=ADM-03 Received: February 12, 2021 PUBLIC SUBMISSION ADD: Maurin Scheetz, Christian Cowdrey, Status: Pending_Post Tracking No. 1k5-9lr3-16lc Mary Neely Comments Due: February 16, 2021 Comment (4)

Publication Submission Type: Web Date:12/1/2020 CITATION 85 FR Docket: NRC-2020-0227 77280 NUREG-1021, Operator Licensing Examination Standards for Power Reactors" Comment On: NRC-2020-0227-0001 Operator Licensing Examination Standards for Power Reactors Document: NRC-2020-0227-DRAFT-0005 Comment on FR Doc # 2020-26460 Submitter Information Name: Tim Riti General Comment See attached file(s)

Attachments 02-12-21_NRC_NEI Comments on draft NUREG-1021 blob:https://www.fdms.gov/339fbb64-006d-44f3-a77e-f706226d4038 1/1

TIMOTHY RITI Senior Project Manager, Regulatory Affairs 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8137 txr@nei.org nei.org February 12, 2021 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Program Management, Announcements and Editing Staff Submitted via Regulations.gov

Subject:

Comments on Draft NUREG-1021, Revision 12, Operator Licensing Examination Standards for Power Reactors [85 FR 77280; Docket ID NRC-2020-0227]

Reference No: 689

Dear Program Management,

Announcements and Editing Staff:

On behalf of our members, the Nuclear Energy Institute (NEI), 1 submits the attached comments on draft revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors. The purpose of this letter is to provide the attached list of detailed comments which recommend several changes to improve clarity of the draft guidance and to reinforce feedback that was shared with your staff during a recent public meeting. 2 NUREG-1021 provides important guidance that the industry uses to ensure methods used to examine incumbent licensed operators and prepare initial licensed operator candidates for their NRC exam is, at a minimum, equivalent to the methods and guidance used by the NRC.

NEIs Licensed Operator Focus Group (LOFG) has appreciated the opportunity to engage with the NRC staff through a series of public meetings as early as October 2019 to help identify opportunities for improvement in the areas targeted in this revision. The NEI LOFG coordinated two industry led efforts to pilot proposed 1

The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

2 Public Meeting with Industry Operator Licensing Representatives - January 21, 2021 (ML21019A008)

Office of Administration February 12, 2021 Page 2 changes as they were being developed to best inform the industry feedback. The first of these pilots focused on the reintegration of generic fundamental concepts into the final written license examination.

Feedback from the pilot was provided to the NRC staff in an NEI letter 3 dated March 4, 2020. The second pilot activity was tied to the industry review and application of proposed simulator operating test guidance changes. Feedback from this pilot was shared with the NRC staff at a public meeting 4 on October 22, 2020.

The following summarizes comments from NEI and its members on the proposed NUREG-1021 draft revision:

• Reorganization of the NUREG into chapters is logical and improves the user interface

• Changes to the generic fundamentals testing approach will improve efficiency and add flexibility for license class start dates while ensuring operator proficiency in fundamental concepts

• Improved clarity exists around licensed operator eligibility and waiver requirements to support the selection and licensing of competent license operator candidates

• Some elements of simulator operating examination development and grading guidance offer improved grading consistency while better aligning the significance of performance deficiencies.

These include defining performance deficiency (PD), developing new significant performance deficiency (SPD) criteria and changing the scram/actuation PD from critical to significant.

Additional comments and recommendations to further improve guidance in these areas are provided in the attachment.

Additionally, the industry has concerns with some aspects of proposed simulator operating examination guidance specifically tied to changes in critical task (CT) development and grading criteria.

• Increasing the grading significance of missed CTs or critical performance deficiencies (CPD) from a 3-point scoring deduction to an automatic failure of the simulator operating examination is not tied to any identified performance gaps with newly licensed operators. Based on studies conducted by the industry and the NRC, this is expected to result in at least a 2.4% increase in initial licensed operator failure rate4 of simulator operating examinations. These losses of competent operators from talent pipelines will negatively impact organizational staffing and no clear safety issue exists to warrant the NRCs imposition of this burden.

• The proposed changes to CT criteria may inadvertently result in increases in performance deficiencies such as procedure usage and place keeping errors or intervention by other crew members to be classified as a CPDs resulting in exam failure, even if the associated CT element was accomplished. Since many procedures have verifications and follow up actions to ensure critical 3

NEI Letter to NRC OL branch dated March 4, 2020, Generic Fundamentals Reintegration (ML20083F400) 4 Public meeting with Industry Operator Licensing Representatives - Oct 22, 2020 (ML20282A237)

Office of Administration February 12, 2021 Page 3 functions are met, the industry expects this subjectivity will result in an unintended increase in failures and ultimately increase examination appeals. Additionally, control room teams are trained and are expected to immediately coach and correct behaviors when standards are not being met or errors are identified. An unintended consequence of this proposed change may result in reduced challenge between control room team members during simulator operating examinations.

• The draft guidance eliminates a significant amount of CTs (e.g., scrams) that are currently acceptable to the NRC while maintaining a requirement for at least two CTs per scenario. This may result in the unintended consequence of longer and more complex scenarios and additional difficulty in meeting exam overlap requirements. Because the studies conducted by the LOFG and NRC staff used previously graded exams as the subject matter, the potential consequences of this change could not be assessed.

• The revised criteria that support the development of CTs would require the industry to analyze and modify their systematic approach to training based licensed operator training programs including CT lists, training scenarios and simulator exam banks thus increasing the already significant change management workload tied to this revision and adding expense. We strongly encourage the staff to reconsider these significant changes to the CT guidance, in particular if the NRC decides to make missed CTs or CPDs automatic failure criteria during simulator operating examinations.

In conclusion, while the industry is aligned with many of the proposed changes in this revision that will improve clarify and consistency, there are concerns with the impacts tied to certain aspects associated with proposed CT development and grading criteria associated with the simulator operating examination. The attached table contains detailed comments and recommendations to address these concerns as well as other recommendations to help improve the content of the NUREG.

Thank you for your consideration of NEIs comments on behalf of the NEI LOFG and the industry. If you have any questions or require additional information, please contact me at (202) 739-8137 or txr@nei.org.

Sincerely, Timothy Riti Attachment c: Mr. Chris Miller, Director, Division of Reactor Oversight, NRC Mr. Christian Cowdrey, Branch Chief, NRR/DRO/IOLB, NRC Ms. Maurin Scheetz, NRR/DRO/IOLB, NRC Mr. Brian Tindell, NRR/DRO/IOLB, NRC

NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation Section 1, GENERAL Missing statement "and the licensee shall first notify the NRCs regional Confirm if NRC contact is required during ES-1.2 step 3, page 1 of office to ensure that a point of contact remains available to respond to written exam and ensure it is added back in 1

6 (line 41-46) questions." Is contact no longer required or not allowed? the section if so intended.

Indicates that applicants tablets, cell phones or other communication devices Add similar wording to the operating test are not allowed into the examination room for the written exam. There is no section if they are not allowed or add a ES-1.2 step 4, page 2 of corresponding statement about them not being allowed during the operating statement that they cannot be used if that 2

6 (line 10-12) test. is the intent. Another option would be to place the statement in the overall section covering all aspects of the exam.

States; Note that answers to questions you asked during the examination are Consider modifying the statement to documented and taken into consideration during the grading process. include questions and answers will be ES-1.2 step 7, page 2 of 3 documented.

6 (line 30)

To improve clarity and intend, ensure that questions asked and answers provided will be documented.

The following statement was removed: Many of the questions will require Add statement back in from Rev. 11 if the you to use plant reference material, while others should be answered without intent is still for applicants to request the use of references. If you need to consult a reference to answer a question, permission to use a reference.

ES-1.2, step 10, page 4 4 ask the examiner if it is acceptable to do so.

of 6 (lines 34-35)

Should that guidance be added back for clarity?

Section 2, INITIAL PREEXAMINATION ACTIVITIES Is there any time limit on previous employment? Example, if an examiner Add a time limit to this restriction.

ES-2.1 page 10 of 20 worked at a utility 10 years ago when the candidates were in initial non-5 (line 9-15) licensed operator training are they allowed to be part of the license exam?

Section references ACAD 10-001, Revision 1. Revised eligibility requirements Revise to reference ACAD 10-001, Revision ES-2.2, page 3 of 22 6 are contained in ACAD 10-001, Revision 2, which will be released soon. 2 or make a general statement to reference (starting on line 10)

Additionally, the ACAD may be revised more frequently than NUREG 1021 to the latest revision of the ACAD 10-001 or 1

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation update programmatic requirements for initial license program content. A latest revision of NANT academy guideline revision stating to reference the latest revision of ACAD 10-001 or latest since the NRC participates in the revision revision of the NANT academy guideline for operator eligibility and selection process per INPO guidance.

would be more accurate.

Form 2.3-2 (revised op A bullet has been added under Walkthrough Criteria, that states specific Provide clarification if the added bullet test QA form), ES-2.3, designation if it meets alternate path criteria. results in new/additional requirements for page 10 of 19 alternate path JPMs.

7 JPM cover sheets typically designate alternate path. This information is also typically in the body of the JPM.

Section 3, INITIAL OPERATING TESTS ES-3.1, page 4 of 5 Steps 13.b and 13.c cover the same topic, using JPMs to test knowledge of the Consider combining the two steps into one 8 differences between plants on multi-unit sites. step.

(lines 35 and 38)

ES-3.2, B.3.a. lists examples for Conduct of Ops Topics, including access Access controls for vital/controlled plant controls for vital/controlled plant areas. However, Rev 3 of NUREG-1123 areas should no longer be used as an ES-3.2, page 2 of 18 9 deleted KA 2.1.13, Knowledge of facility requirements for controlling example. Recommend replacement with a (line 29) vital/controlled access. Thats the only KA statement that was applicable to new example.

that example.

ES-3.2, page 3 of 18 Bullet formatting is different than 3.a and 3. b. Consider closing bulleted lines (i.e., no 10 space in between each bulleted line).

(lines 26-32)

ES-3.2, B.3.c. lists examples for Radiation Control Topics, including radiation Radiation work permits should no longer ES-3.2, page 3 of 18 work permits. However, Rev 3 of NUREG-1123 deleted KA 2.3.7, the only KA be used as an example. Recommend 11 (line 31) that was associated with radiation work permits. replacement with a new example.

ES-3.2, page 9 of 18 Definition/standard of alternate path JPM should be clearly stated in this Add clarification to this section.

12 section since the term is introduced.

(line 20)

ES-3.2, page 12 of 18 The phrase senior reactor operator is spelled out, unlike RO, even though it Consider using SRO vice senior reactor 13 is a standard abbreviation (on list of abbreviations). operator for consistency.

Form 3.2-1, step 3 2

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation Text states the guidelines also apply to requalification examinations. It is Clarify how simulator testing guidelines unclear what specifically applies to requalification programs and what is specifically apply to requalification ES-3.3, page 1 of 17 inspectable per IP 71111.11, if anything. programs, if at all, and if IP 71111.11 will 14 (lines 5, 6 and 22, 23) change to incorporate those specific Clarify if the guidelines only apply when the NRC writes a requalification exam requirements.

per ES-6.

Step 2 states the IC should be representative of a typical plant status with Revise to state: the IC should be various components, instruments, and annunciators out of service. Although representative of a typical plant status, ES-3.3, page 1 of 17 15 this is not a change from Rev. 11, it seems to denote an unnecessary which may include various components, (lines 42 and 43) requirement by not allowing clean ICs instruments, and annunciators out of service.

The last sentence of the paragraph states: As such, the operating test should Add unless between events and they not include such events they are necessary to set the stage for subsequent in the sentence to correct the statement.

ES-3.3, page 2 of 17 16 events or to test the SRO applicants knowledge of TS actions. It appears the (line 18) word unless should be included before they.

The word with does not seem to belong in the following sentence. Remove with or revise to clarify intent.

ES-3.3, page 5 of 17 If this jump is used, the crew must receive with a turnover or cue 17 (line 10) addressing any relevant plant conditions that changed due to the time compression.

This states a component/instrument failure that occurs before the major Provide a positive example of using this event could be credited for actions before AND after the major event allowance to add clarity of acceptance.

provided the actions to deal with the failure are different when comparing the response before and after. The provided example of excess letdown ES-3.3, page 8 of 17 18 demonstrates when this could NOT be used since excess letdown actions are (starting at line 8) the same both before and after the major event. Is it acceptable to count the same malfunction twice, once before and once after the major, provided the actions to address the failure are different?

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation ES-3.3, page 10 of 17 Formatting is different for the Combustion Engineering PWR as compared to Close bulleted lines (i.e., no space in item 3, the others (double spacing between bulleted lines). between each bulleted line).

19 (lines 42, 43) and page 11 of 17 (line 1)

Recent changes to the BWR Owners Group guidelines have changed the setup Consider adding statement that the on some contingency procedures. Specifically, Alternate Level Control is no identified contingency procedures need not ES-3.3, step 5, page 10 longer a separate contingency procedure and has been added to the RPV be standalone EOPs and may be included in 20 of 17 Control EOP. It is still an EOP contingency path/procedure and should be the base EOPs.

treated as such.

All of these sections describe a missed CT or CPD as UNSAT or resulting in an Recommend maintaining a missed CT or automatic failure of the simulator operating test. CPD as a 3-point deduction.

Previously, a missed CT or CPD resulted in a 3-point deduction versus an automatic failure. Additionally, a single error in any of the other portions of the NRC examination will not result in an automatic failure.

Raising the grading threshold (i.e., making it harder for an applicant to pass)

ES-3.3, step k, Page 11 should be limited to closing gaps with licensing applicants that were of 17 (line 45) determined to not display the minimum requirements necessary to be ES 3.6, page 4 of 27 licensed as competent licensed operators.

21 (line 43)

Table 3.6-1, page 6 of There is no evidence that the current grading criteria is inadequate to license 27 competent applicants and the change was made as one of the actions to improve grading clarity and consistency. Many of the other changes, including the new SPD category will help improve grading clarity and consistency without the need for increasing the significance to automatic failure for a missed CT or CPD.

NRC evaluation of 417 previously examined licensed operator candidates graded with the proposed NUREG-1021, Rev. 12 grading criteria resulted in a 2.4% increase in failure rate (11 additional failures, 1 additional pass).

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation The industry also performed a study of a smaller population and determined that there will be increased failures of licensed operator candidates during the simulator operating examination.

Additionally, the elimination of a broad category of items contained in Rev. 11 that can constitute a critical task (e.g., scrams) while maintaining the requirement of at least 2 preidentified critical tasks will potentially make scenarios longer, more complex and increase difficulty due to the need to make CTs EOP based similar to Rev. 10. Because the studies conducted by the LOFG and NRC staff used previously graded exams as the subject matter, the potential consequences of this change could not be assessed.

These losses of competent operators from talent pipelines will negatively impact organizational staffing and no clear safety issue exists to warrant the NRCs imposition of this burden.

Critical Task Methodology is described and discussed in this section. Step C.1 Proposed Replacement Language for Page is Identifying Scenario-Specific Critical Tasks and directs scenario developers 13 of ES-3.3:

to apply guidance to IDENTIFY and DESIGNATE CTs. The developer should apply the following guidance to identify and designate CTs in The list of items provided mainly describe applicant actionswhat applicants conjunction with facility CT lists or in the must do or not do when responding to plant conditions to satisfactorily absence of such a list:

address the CT. When developing CTs, the author can only know what actions Do conditions exist which represent ES-3.3, page 12/13 of the applicants SHOULD take, based on the procedural guidance and projected significant safety challenges? Examples 22 17 (line 38) plant response. The author CANNOT know, at this point in the process, what include the following:

actions the applicants WILL take when they perform the scenario. The list of

• Conditions that warrant initiation of bullets on page 13 appear to be a description of how to determine if a post- emergency depressurizations (BWR) scenario CT has been created. Rev. 11 CT methodology describes how to

• Conditions requiring orange or red determine whether a proposed malfunction is a safety-significant CT. path CSF response (W and AP1000)

• Conditions that warrant Recommend replacing these bullets with similar content to Rev. 11 describing performance of FRG transition (CE) how to determine safety-significance and moving these bullets to the post-5

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation scenario CT discussion. The proposed guidance cannot be followed as written

• Conditions that warrant declaration since the authors and examiners cannot know what actions an applicant may of SAE or GE take in the future. Conditions which are beyond the control of the crew or which are irreparably introduced by the scenario should not be designated as CTs.

This paragraph uses the term examination developers. Other text uses Recommend using examination authors ES-3.4, page 1 of 9 23 examination authors and examination writers. For consistency and clarity, throughout.

(line 9) using a common term is suggested.

ES-3.4, page 1 of 9 Bullet 3 regarding Scenarios extracted should be deleted since this Consider deleting bullet 3 or combine with 24 requirement is encompassed in bullet 2. bullet 2.

(line 39)

The bullet states; The scenario should not duplicate operator tasks that Recommend removing written appear on the JPM portion of the operating test or on the written examination check or add flexibility similar examination unless the operator actions for the same task are different for to Rev. 11 that had within acceptable the related simulator event. limits.

Also see sections; ES-3.1 page 2 & ES-2, page 15, step 3 on form 3.2-2. Consider wording such as; Efforts should be taken to minimize tasks that are the ES-3.4, page 2 of 9 25 Scenarios and written exams are performed in different contexts and are same on the both the operating test and (line 18-20) separated in time. As currently written, this could cause a significant level of written examination.

increased effort to cross-check thirty to fifty (or more) scenario elements against 100 written exam questions with very little benefit, and risk to Also, consider specifically calling out that examination quality. As discussed at the recent public meeting held on Oct 21, this is intended for tasks associated with 2021, it appears that the intent of this requirement is for tasks that result in malfunctions.

actions taken when due to malfunctions.

ES-3.4, B.1, third bullet conflicts somewhat with the example immediately The example after the third bullet should after. Third bullet says SRO-I needs to be evaluated in either the BOP -OR- ATC say while the SRO-I applicant is in a ES-3.4, page 3 of 9 26 position. There are no conditions similar to the 301-5 in Rev. 11 (Form 3.4-1 in reactor operator position.

(line 2)

Rev. 12). The example immediately after seems to specify ATC position since lead operator was defined as the ATC in the bullet before.

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation ES-3.4, page 3 of 9 This is essentially that same as, and redundant to, what is on page 2, lines 22- Eliminate redundancy.

27 26.

(lines 25-29)

Regarding use of surrogatesregional management should have the authority Eliminate need to consult with NRR on use to permit the use of surrogates in order to streamline performance of the of surrogates to streamline performance of ES-3.4, page 3 of 9 28 operating test without NRR involvement. This would increase efficiency. the operating test. Recommend (lines 31-33) replacement with regional branch chief concurrence.

Rev. 11 includes a broad category which will no longer be CTs per Rev. 12 Recommend changing CT criteria to at criteria (failures which lead to trip conditions if not properly and promptly least 1 (versus 2) per scenario since the addressed). Similar to Rev. 10, this leaves only EOP-Based CTs available to population of events in a typical scenario meet the at least 2 criteria. Maintaining the requirement to have 2 CTs per that can result in a critical task have been scenario while removing a large batch of what constitutes a CT will make reduced.

scenarios potentially longer and more complicated. In addition, considering a CT failure will result in a critical performance deficiency (CPD) and an Additionally, limiting the maximum number ES-3.4, page 4 of 9, 29 automatic failure of the operating exam, existing CTs that are not of CTs to 2 would reduce the likelihood of Table 3.4-1 commensurate with a penalty of this severity will likely not be applied in having scenarios that are too long or future initial licensing examinations. For example, at some BWR stations, complex and may help in consistency during inserting a manual scram on a 2nd control rod drift is categorized as a critical scenario development.

task. The safety significance is avoiding potential fuel damage due to an unanalyzed control rod pattern. This seems likely to be omitted as a CT on Rev. 12 based exams due to the severe penalty not aligning with the safety significance (i.e., potential fuel damage).

There is no definition as to what constitutes a scenario set as it applies to Recommend adding a statement identifying contingency EOPs. The requirement is for one contingency EOP per scenario a scenario set means the scenarios the ES-3.4, page 4 of 9, 30 set, but theres nothing that clarifies if that means each operator must be individual operator will see and not the set Table 3.4-1 (line 3) evaluated with a scenario that contains a contingency EOP. of scenarios selected for the overall class.

Having at least 1 Manual Control of Automatic Function event for RO and Add additional guidance on what qualifies ES-3.4, page 4 of 9, 31 SRO-I applicants represents a new requirement as compared to Rev. 11. as manual control of an automatic Table 3.4-2 function. For example, does placing the 7

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation There would be benefit to including additional guidance on what falls into this backup EHC pressure regulator in service category. qualify?

The last sentence in this paragraph states the ODCM cannot be used to meet Clarify whether the TRM can be used to ES-3.4, page 5 of 9 32 the minimum TS evaluation requirement. Can the TRM be used to meet the meet minimum TS evaluation requirements.

(lines 38-40) minimum TS evaluation requirement?

ES-3.5, Page 1 of 13 The term error is used in several cases in ES-3.5. Should performance Clarify/modify as necessary.

(line 40) deficiency be used instead?

Page 11 of 13 33 (lines 21 and 33)

Page 12 of 13 (lines 43 and 46)

The last sentence in section A.2 is missing some words. It should probably Modify as necessary by adding obtain and ES-3.5, page 1 of 13 state Obtain concurrence from the NRR operator licensing program office if if to the sentence as highlighted.

34 (line 29) more than 30 days will elapse between the completion of one and the start of the other.

Grammar/typoremove that Remove that from item #7.

ES-3.5, step 7, page 4 35 of 13 An applicant may request that the administration of his or her operating test (line 24) without 24 extraneous observers.

Grammar/typo in section 16.a - perform should be performed Change perform to performed.

ES-3.5, page 9 of 13 36 Verify that each examiner observed that his or her applicant perform the (line 20) required 20 number of transients and events to allow adequate evaluation of all required 21 competencies.

This states an SPD exists if an avoidable emergency action level entry or Consider a threshold of ALERT or higher for ES-3.5, page 9 of 13 escalation is reached. meeting the criteria of an SPD.

(line 42-44) 37 ES-3.6, page 5 of 28 An error resulting in EAL entry or escalation at the Unusual Event level does (lines 12-13) not require staffing the emergency response centers or have increased safety consequences.

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation The note states that subsequent RPS/ESF actuations that do not alter Consider revising current note or add an ES-3.5, page 9 of 13 equipment alignments are not treated as additional significant performance additional note that single channel (line 32-40) deficiencies. Other examples that shouldnt be considered an SPD would be actuations or half scrams should not be 38 ES-3.6, page 5 of 38 single channel actuations or half scrams. These would not alter equipment considered an SPD.

(lines 5-10) alignments or only open reactor trip breakers that would not result in an automatic scram.

This states an SPD exists if performance deficiencies result in an unplanned Consider adding a statement that placing ES-3.5, page 9 of 13 power change of more than 10 percent rated thermal power. The intent is the plant at a lower power level as a result (line 46-47) that the SPD is due to inadequate power control. At times unit supervisors of conservative decision making would not 39 ES-3.6, page 5 of 38 could direct reducing or controlling power at a lower power level due to apply to this criterion.

(lines 15-16) conservative decision making. Conservatism is an operator fundamental that is strongly reinforced by the utility training programs.

As written, step 17 may cause confusion. To add clarity, consider modifying with the following wording; If a simulator scenario includes emergency plan event classification, because the simulator operating tests for the initial licensing examination are Since the simulator operating tests for the conducted with only one applicant in the SRO position, the NRC does not initial licensing examination are conducted ES-3.5, step 17, page require the SRO applicant to complete an emergency classification within the with only one applicant in the SRO position, 40 10 of 13 (lines 14-18) normal event classification period of time. The scenario does not need to the NRC does not require the SRO applicant include event classification. to complete an emergency classification within the normal event classification period of time. The scenario does not need to include event classification.

PD and PDs are used throughout this section, as is performance Add PD to Abbreviations and Acronyms for deficiency. CPD and SPD are included in the Abbreviations and Acronyms consistency.

41 ES-3.6, throughout section, but PD is not.

The paragraph states; Consider the following recommendations to ES-3.6, page 4 of 27 this area to reduce subjectivity to benefit 42 (lines 35-40) Applicants will be held accountable for CPDs corrected by other members of examiners and to account for the increased the control room team. If an applicant neglects to take an action or takes an safety significance.

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation incorrect action and is subsequently corrected by a team member, the examination team will determine the impact of that lack of action or incorrect A PD associated with performance of action on the scenario as it relates to a CT. The measurable performance actions in support of completing a CT standard for this type of CT depends on the consequence of the applicants requiring intervention by other crew lack of action or incorrect action if the crew had not corrected it. members to complete the CT would be an SPD if the applicant would not have been This introduces grading subjectivity, especially if the critical task was able to identify and correct the error in a met/completed. PDs such as procedure usage or place keeping errors or timely manner (i.e., before the CT would be intervention by other crew members may be graded as a CPD. In many cases, unrecoverable).

there may be no way to determine if the applicant would have caught and corrected the error in a reasonable amount of time during the scenario.

While we recognize that there will be a level of judgement by the examiner when evaluating a performance deficiency in this area, this will likely lead to additional candidate appeals if a CPD is assigned, resulting in automatic simulator examination failure even if the associated CT itself was completed.

There may have been an opportunity for the candidate to self-identify and correct the error without the intervention but control room teams are trained and expected to immediately coach and correct behaviors when standards are not being met or errors are identified. Additionally, this change may result in less challenge between control room team members.

ES-3.6 Page 6 of 27 The term error is used in several cases in ES-3.6. Should PD or Clarify/modify the use of error as desired (line 16) Performance deficiency be used instead? Or in some cases, error can be and remove the word for on page 6, line 43 Page 8 of 27 (line 6) eliminated from the sentence. 16.

Page 9 of 27 (lines 6 and 9)

CPDs should not be assigned to understanding RFs. The applicant needs to Recommend not allowing CPDs to be demonstrate the inability to take CT-level safety-significant actions to result in assigned to understanding RFs.

ES-3.6, page 6 of 27 44 a CPD. Should not be based on failing to provide a correct answer to a follow-(line 17) up question.

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation The departure from nucleate boiling TS example provided is PWR specific. Consider using a TS example that is ES-3.6, page 8 May be beneficial to use an example that applies more generically to other applicable to all reactor technologies.

45 (line 26) reactor types.

With only three RF points to work with, the allowance to assign multiple PDs Consider simplifying and adjusting grading for each TS in a single event is not proportional. Each TS event should be criteria described in this section.

46 ES-3.6, page 8, 9 limited to one PD normally.

The assignments of CPDs (or even SPDs) in Communications seems excessive. Consider simplifying communications ES-3.6, page 10 All communications errors should be assessed as a PD after the first one. This competency RFs.

47 (line 35) may make grading simpler and more consistent.

ES-3.7, page 1 Step A.4 - a period is missing from the end of the sentence. Add period.

48 (line 21)

Section 4, INITIAL WRITTEN EXAMINATIONS None Section 5, INITIAL POSTEXAMINATION ACTIVITIES AND OTHER LICENSING ACTIONS None Section 6, NRC-CONDUCTED REQUALIFICATION EXAMINATIONS ES-6.1, step 5, page 8 postexamination should be hyphenated. Change postexamination to post-49 of 33 (line 21) examination Regarding first and second retakes, the document does not specify whether a Consider adding a statement that a second ES-6.1, H.2.c and d, 50 second retake is required following passing the first retake. retake does not apply following successful Page 14 of 33 completion of the first retake.

11

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NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation Note that this is not a change from ES-605 (page 13), and it implies a second retake isnt necessary following passing of the first, but may be added in the interest of clarity.

ES-6.1, Page 15 of 33 Form 6.1 Has no title description Include form title.

51 (line 21)

ES-6.1, Page 15 of 33 Form 6.1 Has no title description Include form title.

52 (line 46)

Form 6.1-3, ES-6.1 Preexamination and Postexamination should be hyphenated. Change Preexamination and Page 20 of 33 Postexamination to Pre-examination 53 and Post-examination.

Under III. Quality, Exam Section goes from; A. Sample Plan to C. Move the guidance for written exam quality ES-6.1, Page 23 & 24 of Walkthrough from revision 11 to revision 12.

54 33 It appears that there should be another section for; B. Written Exam The page number shows 2 of 33 versus 26 of 33. Correct the page number to 26 of 33.

55 ES-6.1, Page 26 of 33 ES-6.3, page 2 of 7 The sentence systems that are the subject of NRC information notices is a Make sentence its own bullet.

56 (line 3) separate thought from the one above and should be a separate bullet.

Section 7, FUEL HANDLING EXAMINATIONS None Section 8, GLOSSARY None 12

© NEI 2021. All rights reserved.

NEI Comments on Draft Revision 12 of NUREG-1021, Operator Licensing Examination Standards for Power Reactors No. Section Comment/Basis Recommendation Appendix A: Overview of Generic Examination Concepts None Appendix B Examples of Written Examination Questions Tier 4 Theory is new to the written examination and previously used generic Add examples of plant-specific, examples of reactor and thermodynamic theory questions may or may not be operationally valid theory questions to acceptable on final licensing examinations. There would be a benefit to Appendix B to aid the facility Examination developing examples to include. Authors in developing satisfactory 57 Appendix B operationally valid theory questions (refer to NEI letter on Generic Fundamentals Reintegration, Appendix 1, Recommendation 1, dated March 4, 2020 (ML20083F400).

OTHER COMMENTS Revision 12 Recommend removing blank pages to 58 General Comment reduce document size.

Several blank pages 13

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