Information Notice 2004-20, Recent Issues Associated with NRC Medical Requirements for Licensed Operators
| ML042510509 | |
| Person / Time | |
|---|---|
| Issue date: | 11/24/2004 |
| From: | Hiland P NRC/NRR/DIPM/IROB |
| To: | |
| Trimble D C, DIPM/IEHB/IOHS, 415-1017 | |
| References | |
| TAC M3722 IN-04-020 | |
| Download: ML042510509 (9) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
November 24, 2004
NRC INFORMATION NOTICE 2004-20:
RECENT ISSUES ASSOCIATED WITH NRC
MEDICAL REQUIREMENTS FOR LICENSED
OPERATORS
ADDRESSEES
All holders of operating licenses for nuclear power reactors and research and test reactors, except those who have permanently ceased operations and have certified that fuel has been
permanently removed from the reactor vessel.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to
highlight concerns related to the conduct and documentation of medical examinations for
applicants and holders of reactor operator and senior operator licenses (hereafter referred to
collectively as licensed operators). It is expected that recipients will review the information for
applicability to their facilities and consider actions, as appropriate, to avoid similar problems.
However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response is required.
DESCRIPTION OF CIRCUMSTANCES
The NRC depends on facility licensees to ensure that the personnel who perform and evaluate
licensed operator medical examinations understand the regulatory requirements, the applicable
medical standards, and the physical demands of the operators duties, thereby ensuring that the
examinations are performed correctly and any medical defects are accommodated with
compensatory license restrictions or, if necessary, by removal from licensed duties. Failure to
detect a disqualifying medical condition could adversely affect an operators ability to perform
assigned duties under stressful and demanding accident conditions, thereby distracting the rest
of the crew and increasing the possibility of operational errors that could endanger public health
and safety.
The NRC also depends, in large part, on facility licensees to ensure that their licensed
operators are familiar with and adhere to the individual license conditions specified in
Section 55.53. Licensed operators should understand that they are responsible for meeting all
the conditions of their license and for promptly informing their employer if they develop any
medical condition, such as needing to wear glasses or taking a prescription or over-the-counter
medication, that could affect their fitness to safely operate the facility.
BACKGROUND
The NRCs requirements related to the conduct and documentation of medical examinations for
operators are contained in Subpart C, Medical Requirements, of 10 CFR Part 55, Operators
Licenses. Specifically, Section 55.21, Medical examination, requires every operator to be
examined by a physician when he or she first applies for a license and every two years
thereafter. The physician must determine whether the operator meets the requirements of
Section 55.33(a)(1), i.e., the operators medical condition and general health will not adversely
affect the performance of assigned operator duties or cause operational errors that endanger
public health and safety.
Every time an operator applies for a license pursuant to Section 55.31, How to apply, or
Section 55.57, Renewal of licenses, an authorized representative of the facility licensee must
complete and sign Form NRC-396, Certification of Medical Examination by Facility Licensee, attesting, pursuant to Section 55.23, Certification, that a physician has conducted the required
medical examination and determined that the operators medical condition and general health
meet the requirements of Section 55.33(a)(1). The facility licensee must also certify which
industry standard (i.e., the 1983 or 1996 version of ANSI/ANS-3.4, Medical Certification and
Monitoring of Personnel Requiring Operator Licenses for Nuclear Power Plants, or the 1988 revision of ANSI/ANS-15.4, American National Standard for the Selection and Training of
Personnel for Research Reactors) or other NRC-approved method was used in making the
fitness determination.
The ANSI standards describe a number of specific operator health requirements and
disqualifying conditions. If an operators health does not meet the minimum standards, the
facility licensee must request a conditional license in accordance with Section 55.23(b) by
submitting the appropriate medical evidence with Form NRC-396. Pursuant to Section 55.33, Disposition of an initial application, and Section 55.57, as applicable, the Commission will
review the license application based on the facility licensees certification and include any
conditions in the license that might be necessary based on the supporting medical evidence.
If, at any time during the term of an operators license, the operator develops a permanent
physical or mental condition that causes the operator to fail to meet the requirements of
Section 55.21, the facility licensee must notify the Commission, in accordance with 10 CFR
50.74(c), within 30 days of learning of the diagnosis. If a conditional license is requested, the
facility licensee must, again, provide medical certification on Form NRC-396, as described in
Section 55.23.
For additional information on this subject, refer to NRC IN 91-08, Medical Examination for
Licensed Operators (issued February 5, 1991), IN 94-14, Failure to Implement Requirements
for Biennial Medical Examination and Notification to the NRC of Changes in Licensed Operator
Medical Conditions (issued February 24, 1994), and IN 94-14, Supplement 1 (issued April 14,
1997).
DISCUSSION
Given the importance of the operators role in maintaining reactor safety, the NRC staff
becomes concerned whenever inspection results, facility audits, and other indicators suggest
that facility medical programs may not be receiving sufficient management oversight to ensure that the
fitness of licensed operators is being maintained at the required level. The following recent
examples indicate a potential problem in this area:
The checklist that one facility used to track the ANSI testing requirements specifically
noted discrepancies for a number of operators, but the examining physician
nevertheless signed the overall physical examination as satisfactory. One operator was
noted to have disqualifying cardiovascular conditions (arrhythmia and peripheral
vascular insufficiency) and an unsatisfactory electrocardiogram that should have
warranted a no-solo license restriction, but when the inspectors questioned the
physician who had completed the checklist, he simply changed the unsatisfactory
conditions to satisfactory in front of the inspectors without evaluating the medical record.
Other examples included a skin condition affecting the ability to wear protective clothing, abnormalities related to the endocrine system, blood, and blood-forming organs, and
various laboratory tests.
While following up on concerns raised by an NRC inspector, a facility licensee found
that some tests specified in the ANSI standard (e.g., nose sensitivity and neurological
testing) had not been completed for any of its licensed operators. The facility licensee
implemented immediate corrective action by testing its operators before they were
allowed back on shift.
During an audit of its medical records, a facility licensee discovered that two of its
recently licensed operators had preexisting medical conditions (histories of myocardial
infarction and coronary heart disease) that had not been reported on their original
NRC-396 forms. The facility licensee submitted new NRC-396 forms with the required
medical evidence but again failed to recommend any license conditions to
accommodate the operators medical defects, which preclude solo operation of a
nuclear power plant per the ANSI standard. Upon review, the NRC amended both
operators licenses to include no-solo license restrictions.
As a follow-up corrective action, the facility licensee audited the medical records at other
sites and identified two additional operators who had potentially disqualifying medical
conditions but did not have restrictions on their licenses. The licensees root cause
review of this problem identified a company-wide flaw in the training provided to doctors
and nurses contracted to perform the medical evaluations. The licensee found that the
doctors had been trained that the site nurse or licensed nurse practitioner would inform
the doctors if there were any requirements for a regulatory restriction based on the
results of the physical exam. However, the nurses were not trained to point out the
regulatory restrictions to the doctors and did not question the doctors decisions when
no regulatory restrictions were recommended.
Several other facility licensees, while performing routine or reactive audits of their
licensed operators medical records, have recently identified various medical conditions, including heart attacks and poor vision, that should have been reported to the NRC
pursuant to 10 CFR 55.25. The most egregious case involved an operator who should
have been restricted from solo operation since suffering a heart attack in 1996; the
facility licensee was unable to determine why the condition went unreported. *
In one instance, as the result of an unclear facility procedure, a licensed operator waited
for seven months before informing the site nurse that his personal physician had
prescribed a medication that could adversely affect his ability to perform licensed duties.
The site nurse compounded the problem by waiting another month before informing
facility management so the operator could be removed from licensed duties and the
NRC could be notified.
The purpose of this IN is to remind facility licensees (1) that licensed operators and the
personnel who perform and interpret their medical examinations need to be familiar with the
regulatory requirements and guidelines; (2) that any time a licensed operator fails to meet any
of the medical standards outlined in the applicable version of ANSI/ANS-3.4, the failure must be
reported to the appropriate NRC regional office on Form NRC-396; and (3) that Form NRC-396 must include a copy of all supporting medical information and, if deemed necessary, the
specific recommended wording for the conditional license to be issued to the affected operator.
CONTACT
S
This information notice requires no specific action or written response. Please direct any
questions about this matter to the technical contact(s) listed below or to the appropriate Office
of Nuclear Reactor Regulation (NRR) project manager.
/RA/
Patrick L. Hiland, Chief
Reactor Operations Branch
Division of Inspection Program Management
Office of Nuclear Reactor Regulation
Technical Contacts: David C. Trimble, NRR
Richard J. Conte, RI
301-415-2942
610-337-5183 E-mail: dct@nrc.gov
E-mail: rjc@nrc.gov
James H. Moorman, RII
Roger D. Lanksbury, RIII
404-562-4637
630-829-9631 E-mail: jhms2@nrc.gov
E-mail: rdl@nrc.gov
Anthony T. Gody, RIV
Patrick M. Madden, NRR
817-860-8159
301-415-1188 E-mail: atg@nrc.gov
E-mail: pmm@nrc.gov
Attachment: List of Recently Issued NRC Information Notice
ML042510509 DOCUMENT NAME: C:\\MyFiles\\Checkout\\cdp edit MEDICAL ISSUES RIS 2004-XX.wpd
OFFICE IROB:DIPM
TECH EDITOR
SC:IOHS:DIPM
PMAS
NAME
SGuenther
PKleene
DCTrimble
CNolan
DLMcCain
DATE
09/09/2004
09/01/2004
09/09/2004
10/04/2004
10/05/2004 OFFICE OCIO
IROB:DIPM
NAME
BShelton
CHolzle
AWMarkley
DATE
10/05/2004
10/18/2004
10/18/2004
11/09/2004
11/10/2004 OFFICE A:SC:OES:DIPM
C:IROB:DIPM
NAME
THBoyce
PLHiland
DATE
11/22/04
11/24/2004
______________________________________________________________________________________
OL = Operating License
CP = Construction Permit
Attachment LIST OF RECENTLY ISSUED
NRC INFORMATION NOTICES
_____________________________________________________________________________________
Information
Date of
Notice No.
Subject
Issuance
Issued to
_____________________________________________________________________________________
2004-19
Problems Associated with
Back-up Power Supplies to
Emergency Response
Facilities and Equipment
11/04/2004
All holders of operating licenses
for nuclear power reactors, except those who have
permanently ceased operations
and have certified that fuel has
been permanently removed from
the reactor vessel.
2004-18 Recent Safety-related Event at
Panoramic Wet-source- storage Irradiator
10/26/2004
All licensees authorized to
possess and use sealed sources
in panoramic wet-source-storage
irradiators, and irradiator vendors.
2004-17 Loose Part Detection and
Computerized Eddy Current
Data Analysis in Steam
Generators
08/25/2004
All holders of operating licenses
for pressurized-water reactors
(PWRs), except those who have
permanently ceased operations
and have certified that fuel has
been permanently removed from
the reactor.
2004-16
Tube Leakage Due to a
Fabrication Flaw in a
Replacement Steam Generator
08/03/2004
All holders of operating licenses
for pressurized-water reactors
(PWRs), except those who have
permanently ceased operations
and have certified that fuel has
been permanently removed from
the reactor.
2004-15 Dual-Unit Scram at Peach
Bottom Units 2 and 3
07/22/2004
All holders of operating licenses
for nuclear power reactors except
those who have permanently
ceased operation and have
certified that fuel has been
permanently removed from the
reactor vessel.
Note:
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