NRC Generic Letter 1982-13
0.,.a RIGA,* 0 4'.wCUNITED STATESNUCLEAR REGULATORY COMMISSIONWAHINGTON. D. C. 20555June 17, 19820TO ALL POWER REACTOR LICENSEES, APPLICANTS FOR AN OPERATING LICENSE ANDHOLDERS OF A CONSTRUCTION PERMITGentlemen: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 ReactorOperators. The questions and comments raised during that meeting are discussedin the enclosed summary.This letter is for your information only and requires no response or action.
Sincerely,Darrell G. Eisenhut, DirectorDivision of LicensingOffice of Nuclear Reactor Regulation
Enclosure:
1. Response to Questions/-Comments2. List of Attendees8204210387820421037 820617PDFR ADOCK O5o0OOO3V PDR General Topic: Examination AdministrationOuestions/Suqqesticns:What responsibilitfes/authority do proctors, especially when it is the ResidentInspector, have?Will questions be made available to allow trainers to know what areas shouldbe covered?The exam should be open book, allowing access to the materials the operatori..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? Onesitting? And what options for splitting sections are available if a splitperiod used?Reducing the number of questions (time) increases the importance of eachquestion.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, somedon'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 thoroughreview.Why establish a time limit? The exam should find out what you know, not howfast 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 noway 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..1 ENCLOSURE 1Genertl Topic: Reactor Theory, Heat Transfer, and ThermodynamncsQuestions/Suggestions:CombinelRO and SRO sections since a distinction cannot be made on what is ROand 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 combiningthe two. Comments on the subject were:1. Could have union problems, if operator candidates are required toanswer questions at senior level.2. Combining categories is appropriate since the distinctioncannot be made between SRO and RO knowledge level.3. Categories should not be corbined at this time since thischange will delay implementation of new formats.4. Some individuals believed it is appropriate to keep categoriesseparate, 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 problemscreated, we will maintain the current format until sufficient feedback from thenew exam format is available to support a move in the other direction. This isan area where specific comments on the exams will be useful in evaluatinggeneral statement ENCLOSURE 1General Topic: Reactor Theory, Heat Transfer, and ThernodynamicsQuestions/Suggestions:Combine RO and SRO sections since a distinction cannot be made on what is ROand 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 combiningthe two. Comments on the subject were:1. Could have union problems, if operator candidates are required toanswer questions at senior level.2. Combining categories is appropriate since the distinctioncannot be made between SRO and RO knowledge level.3. Categories should not be combined at this time Oince thischange will delay implementation of new formats.4. Some individuals believed it is appropriate to keep categoriesseparate, 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 problemscreated, we will maintain the current format until sufficient feedback from thenew exam format is available to support a move in the other direction. This isan area where specific comments on the exams will be useful in evaluatinggeneral statement General Topic: Future MeetingsQuestions/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 industryrepresentatives a chance to understand and commient on proposed changes. Could alist of attendees be provided? Smaller meetings between training staffs andexaminers should be held.Response:We were as enthusiastic as you about the meeting. We intend to repeat the processand 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 toresource limitations.A copy of the attendance list of the meeting is attached. Please bring additionsor corrections to our attentio General Topic: Written Examination QuestionsQuestions/Suogestions:Questions should not require lengthy calculations that are not done on the-ob..Questions should not be taken from the FSAR since it is worst case and maynot be up to date.Technical Specification questions should not require knowing actions afterone hour since the SRO can look these up.More short answer or multiple choice questions should be used.Health Physics questions should concentrate on operating information nottime-distance-shielding type Questions.Mitigating core damage should be included in exams.RO Exams should not include Tech Specs or Emergency Plan since these are nother responsibility.If new topics are to be included in the exams, the utilities should be notified.In addition to submitting good questions, utilities should be able to identifyquestions they feel are bad.Response:As indicated in the January 6 meeting, emphasis in the exam will be on operationalinformation. To ensure that exam questions are in line with the guidelines givento you, we are reviewing the questions and deleting or modifying ones that do notcomply. As discussed in the exam consistency topic, we are developing a computer-ized bank of exam questions. When fully developed and reviewed, we will makethis bank available to the public. We encourage submission of questions for thebank and comments on questions that you feel are not valid. In this effort weare eliminating the Health Physics questions that are not generally the responsi-bility of the RO or SRO, and arranging that Tech Spec questions concentrate onunderstanding of the bases, general knowledge of what actions are requiredimmediately (within one hour) and why, and what systems have tech spec limits andwhy. In the operational exam the candidate's ability to find and use the techspecs will be examined. Ouestion content may still include calculations todetermine the candidate's understanding of the principles involved in nuclearplant operation, but calculations for the sake of calculations will be avoided.We are investigating short answer and multiple choice question formats and haveused both in exams that have been given. We will not, however, shift entirelyto this format until we have assured that the questions present a fair opportunit:for the candidate to show his or her knowledge and we have notified the industrythat we will be changing exam style.We are continually developing new questions from the training material provided.We will continue to use the FSAR as'a source of information, but we recognizeits limitations. As always, out of date information should be pointed out inthe exam critique so that questions and answers can be updated. We hope in thenear future to develop a regular information letter to inform the public of newareas of interest in the exa Response:Your concerns fall into several areas. First, the exam may be taken either atone sitting or broken into two parts. The utility has the option, but allcandidates 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, 10in the second three hours if a split sitting is elected. The examiners orproctors have the authority to allow individual breaks during the exam, butthe exam must still be finished within the allowed time. The examiner orproctor will keep track of elapsed time.Second, only examiners are authorized to mwdify an exam. Proctors, evenresident inspectors, are not authorized to rake changes. Proposed changesshould 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 tobe covered in the limited amount of time, however, a time limit will remain.We are investigating machine generated/machine graded formats but have noimnediate plans for implementing such a system. Before a change like that willbe adopted, the approach will be validated and your comments solicited prior toany action being taken. Once fully developed, we will consider iaking the questionscontained in the exam question bank available'to assist you in your trainingprogram and In keeping the questions current.Fourth, we do not intend to go to an open book exam. We are working to ensurethat 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 proceduresand Tech Specs.Fifth, we are in the process-of developing updated guidance on exam content,objective and subjective grading criteria, exam administration and applicationcontent. We will not endorse a set of reference texts. This guidance, coupledwith greater accessibility of exam questipns, should improve information availa.ble on what the exam will cover. Any texts-that suitably cover the Vaterial areacceptable.Sixth, we are implementing a system to allow automatic, computer-aided trackingof applications and exam results. Our goal is to have all results reported tothe 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 resultsor submitting FOIA requests until after the two months have passed. Exam resultsare not final until all portions of the exam have been completed and internalaudits for consistency-and fairness are done. At that points exam summary sheetswill be sent to the utility, and licenses or denials and a copy of the writtenexam will be sent to the individual.Finally, almost all old format reexaminations have been completed and suffil.ientexperience has been gained in preparing new format exams. Therefore, only siewformat exams will be given for examinations scheduled after July 1, 19g'.
General Topic:Examination ConsistencyQuestions/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 inconsistenciesbetween examiners. You almost have to know who is preparing your exam so you canprepare the candidates in the proper areas.Sore examiners will not accept an operating method that differs from a Ocookbookamethod 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 contentand developing a question bank of valid questions. Since these will includeplant specific, as well as generic questions, the operating philosophy of eachfacility can be reflected in their exam questions.For oral exams we are preparing guidelines for the examiners. Appropriateportions will be made publicly available.We have also established a training and certification program for contractexaminers. This will ensure that a minimum competence has been obtainedprior 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 areactively transferring examiner functions to the Regional Offices. Any specificfeedback from an examination is welcome and will be kevt confidentia Aeneral Topic:Simulator ExamsOuestionsfSuqgestions:Plant specific simulators should be mandated by NRC.What are fRC's future plans for simulator exams? More guidance is needed onwhat will be covered in simulator exams, especially-for non-plant-specificsimulators.Response:A Commission Paper has been prepared.recomnuending that the requirement fornon-plant-specific simulator exams be removed. We have studies underway todevelop valid operational exams, Including simulator exams. At this timewe feel that dynamic transient operation is an important aspect of the exambut that the limitations imposed by non-plant-specific simulators and thescheduling problems encountered reduce the effectiveness of the exam and donot justify the resources required. Therefore, we are considering returningto the old exam method of performing power transients, startups and shutdownson those facilities that do not have a plant speci'fic simulator available. Anychange in the exam will be discussed before it is iiplemented. Until the needfor operating tests on the facility or other testing methods being studied bythe staff are validated, the operating examination will continue to follow theexisting guidelines in NUREG 0094. Therefore, there is a continued need forsimulator training to comply with the guidance in NUREG 0094. The Coimmtssionhas not acted on the staff recommendation at this time. The CoMnMssiOn paperdoes not include any requirements for actual plant operations at this time.As discussed under the exam administration topic, we are developing guidelinesfor simulator exams. We are also modifying the operational exam suffrrary sheetto facilitate the simulator exam and to ensure that areas examined at thesimulator are not duplicated in the plant walk-through.MiscellaneousOvestion:Where are guidelines for medical applications?Response:-Basic requirements are in Part SS. Aioltfying guidance in Regulatory Guide1.134 which endorses ANSI/ANS 546.Suggestion:Fallback to RO on instant SRO failure isn't worth much since engineers orsupervisors aren't in the union and cannot perform RO duties.Response:We agree that fallback has little value. When a candidate is certified to needan SRO license to perform his or her duties, we don't see how having an RD willhelp. Under the new format exam, this problem should disappea Suggostion:KRC should put certification of training instructors on high priority sincethis 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 ofinstructor certification more vigorously. All Operating License applicantsare required to have certified instructors prior to fuel load and we have certi-fied instructors at several operating plants. We are monitoring the INPO workon training program accreditation and are investigating means to certify vendorand consultant instructors that teach systems and operations courses. Moreinforrmation 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 subjectof requalification at length. To summarize, as directed by the Commission, wewill start giving requalification examinations in conjunction with scheduledvisits for replacement exams. We are targeting at least one site visit to eachfacility this year and expect to administer requalification examinations to 20%of the licensed operators. Our initial plans are to conduct the requalificationexams during replacement exams; however, we will work out availability andschedules with each utility. Tn the Commission paper, the staff proposed thatfor utilities with a plant specific sirulator, the requalification exam will begiven only on the simulator. Otherwise, a written exam and practical test villbe given. Failure of the exam will require accelerated retraining in weak areas,as is required now, and NRC reexamination. If significant weaknesses in theutility requalificatlon program are revealed by the exams, NRC administeredrequalification exams for all license renewal applicants will be likely untilthe requalification program has been sufficiently upgraded. Details of the.program are in the Commdssion paper. No ComMission action has been taken atthis 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 areasof concern at NRC that might affect the content of future exams and generalinformation on the exams. We hope to be producing these reports in the very nearfutur Suggestion:Cold plants need amplification of R. Denton's March 28, 1980 letter regardingexperience requirements.Response:It is difficult to provide better generic guidance than exists in the letterTask Action Plan Item I.A.2.1 NUREG-0737 and NUREG 0094. Specific cases canbe discussed with the appropriate OLB Section Leader. The OLB policy is togrant exemtotlns or.walvers only In specific cases, not on a generic basis.Therefore, the requirements should be discussed with the Section Leader ENCLOSURE 2LIST OF ATTENDEESNAME & TITLECOMPANYHugh ThompsonBruce WilsonJoe McMi1lenRobert CampbellTed SzymanskiBruce BogerRcnald EatonRornald MainesRobert KellerJohn MunroLen WiensTom HamrickJim EvansRay HallmarkRon BurdgeDan F.. MooreFrank ThompsonLee WilliamsPaul HobbsR. J. BurseyJ. F. CrosbyActing Director, DHFSOLB ExaminerRegion III ExaminerOLB ExaminerOLB ExaminerOLR ExaminerOLB ExaminerOLB ExaminerOLB ExaminerOLB ExaminerOLB ExaminerMgr. TrainingDirector, Su OpsGen. Mgr. -Dev. Div.Supv. -Nuclear TrainingSupy. Oper. Fund, Trng.Trng. Supt.Sr. Trng. Supt.ConsultantEvalUSNRCUSNRCUSNRCUSNRCUSNRCUSNRCUSNRC11SNRCUSNRCUSNRCUSNRCUnion Carbide -ORNLWestinghouseEnergy Inc.NUSTCGa. Power Co.WPPSSAla. Power Co.Union Electric Co.NPO Inc.ItNPOI
-2 -P. L. FlncherJ. R. BynamR. G. JonesE. W. MerschoffJ. G. CookJ. MacdonaldJ. BarbaJ. YoeS. JonesEugene CarlsonJay WheelerJoe ZerboBill LandonDon TallFred CurlingLarry EdmondsAndy NeuferTom HoughtonRick ZollitchWarren R. ForrestClyde GilbertMark D. ShepherdTraining Supv.Tech SupervisorTrng. SuperintendentSr. Trng. Supyr.Trng. Supvr.Trna.Florida Power & Light Co.TVATVANRCJPCCECEBaltimore Gas & Electric Co.Baltimore Gas & Electric Co.Pennsylvania Power & Light Co.PECOGeneral PhysicsConn. YankeePASNY/FITZVEPCOVEPCOPROSK34C, Inc.Niagara lIohawkUnin Electric Co.Northeast UtilitiesFlorida Power S Light Co.;I 3 -I4Terry L. WoodHarry L: MathisJerry ScholandDr. Ron BrunoErnest ChattfieldWendell H. BarronJohn GassMichael WilliamsH. T. BabbFred DacimoTim MartinKen BeattyJ. R. WzlkevRobert L. LewisRick GoodrickS. D. SchileR. M. KoehlerR. J. BarrettDean CrawfordPutch ColbyG. J. AshworthDr. C. M. OverbeyTrng.Mgr. Nucl Trng.Mgr. WNTCSupt. -Trng.*Trng. Mgr.Trng. Sup.Trng. Sup.Trng. Mgr.Trng.OSSTrng. Supv.Trng. Supv.Trng. Shift Eng.WENP Asst. Supv.Certification ExaminerTrng.Trng. Mgr.BWR Sirulator Dir.ManagerSr. Staff Supv.PQS Section LeaderWPCSouthern Calf. Edison Co.WestinghouseWisconsin Electric Co.Yankee Atomic Power Co.Carolina Power S LightOmaha Public Power DistrictSCE& -SCE&GNortheast UtilitiesPacific Gas & Electric Co.Florida Power S Light Corp.TVATVAGeneral ElectricATTS, Inc.Duke Power ConpanyGPUSinger-LinkSinger-LinkConsumers Power Co.NRC/DHFS
-4 -A. FullertonJ. H. ReedDavid NelsonG. BockholdJ. Lloy6S. CrouchJim HickyRob AndersonR. W. BulverJack HauChuck ManeyBrendan MoroneyJoseph GonyecuMike SellmanGene EarneyBob JanskyArt MorrisDick MorrillWilliam T. GottMarty LanganBr#; E. CraneBill OlsenResearch AssociateResearch AssociateTrng. Coodinatormgr./Nuc. Trng.Trng. SupervisorSr. Trnq. Cons.Trng. Mhgr.Trng. CoordinaitorSupt. Nuc. TrainingTrng. SupInstructorMgr. -Prod. Jrng.Trng. Supt. PtProg. Supt.Shift Supv. Trng.Asst. Trng. Coor.Trng. SupervisorTrng. DirectorNuc. Inst.Nuc. Trng. Mgr.Sr. Trng. Spec.ORNLORNEIUM Elec.Georgia PowerPSE&GATTS, Inc.Toledo Edison Co.Iowa ElectricPhila. Electric Co.SMUDCommonwealth EdisonNUSNSPNorthern States Power Co.PSPNPDRochester Gas & Electric Co.Rochester Gas & Electric Co.Cincinnati Gas & ElectricLouisana Power & LightFlorila Power Corp.Boston Edison C S -IIICharles BogolinLarry ViederSaul J. HarrisEd ForceBill GarrisonEd ThorndykeArt SheanDan McNealT. LempgesR. Joe JohnsonDennis OckernanCharles CowanDave RothA. ShauverWilliam OdellRay WadasMartin BlockJim VasselloBob ClarkSam NewtonBob EcamTom HigginsOperation Super.Prog. Spec. Ruc. Trng.Nuclear Program Mngr.Trng. CoordinatorShift SupervisorTrng. SupervisorTrng. DirectorShift SupervisorV.P. Nuc. Gen.Trng. Mgr.Trng.Trng. CoordinatorV.P.Dir.Mgr. InstructionTrng.Supt. OperationTrng.Op. Trng. Ygr.Trng. Sup.Gulf StatesCarolina Power & LightEEIArkansas Power & Light Co.Arkansas Power & Light Co.Carolina Power & Light Co.Maine Yankee Atomic Power Co.Cincinnati Gas & ElectricNiagara MohawkTVAGeneral ElectricPhiladelphia ElectricGeneral Physics Corp.General Physics Corp.B&WP.S.C. of Colo.P.S.C. of Colo.DL Co.Battel leGPU Nuc. TMIAP&LCommonwealth E L. E. 'Al' KanousKen RottkampJon RengstonZeinab SabriRichard P. BogateNorman PgreCraig KvafmeR. M. StallnanTony VinnolaDon NeighborsBob MartinNick CorithardArt MahDave FawcettC. L. TurnerN. W. HoughS. G. Jones SEC. H. Noe SEDir. Nuc. Trng.Trng. Inst.Trng. Sup.Director -Nuc. Trng.Simulator InstructorfterationsNRC ContractorNRC ContractorNRC ContractorORB #3KG&E Mgr. TrainingKG&E Training Supv.Op. Trng. Supv.Director Huc. Trng.Trng. Supv.Detroit Ed.LILCOPUSTCLPALDuke Power Co.Duke Power Co.Operator Exam Branch, EG&GOperator Exam Branch, EG&GOperator Exam Branch, EG&GNRCNRCGPUTexas UtilitiesCarolina Power & Light Co.TVATVAi