ML13330B258

Concludes That 860620 Ltr Re NRC Request for Evidence That Each Reactor Operator Candidate Had Completed Five Reactivity Manipulations on Actual Plant Not Considered Improper Backfit

ML13330B258
Person / Time
Site:	San Onofre
Issue date:	10/31/1986
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Baskin K Southern California Edison Co
References
GL-84-014, TAC-61842 NUDOCS 8802010047
Download: ML13330B258 (4)

Text

DISTRIBUTION Central Files NRC PDR/Local PDR OLB R/F WTRussell/LMiller (869437 & OLB-8)

OLB Branch Chief (2) 3 1986 JNHannon DKirsch, RV OCTRBEaton JMartin, RV Mr. Kenneth P. Baskin, Vice President T 69437 V~telSo Southern California Edison Company HRDenton/RHVollmer HRood P. 0. Box 800 JWClifford NudIey7 2244 Walnut Grove Avenue TMurley/WFKane, RI FMiraglla Rosemead, California 91770 JGrace/AGibson,-RII JKeppler/CPaperiello, RIII

Dear Mr. Baskin:

RMartin/EJohnson, RIV Your letter dated June 20, 1986. claimed that NRC had imposed a new requirement on reactor operator candidates to be eligible for NRC license examinations. Specifically, Southern California Edison (SCE) was requested to provide evidence that each reactor operator candidate had completed five reactivity manipulations on the actual plant. You stated that this request was a change from applicable NRC regulations and past NRC practice and, therefore, constituted an improper backfit. For the reasons described in this letter and its enclosure, we conclude that this request is not an improper backfit.

The regulations, specifically 10 CFR 55.10(a)(6), require that applications for licenses contain "[ejvidenet~tthiftheapp-icant has learned to operate the controls in a competent and safe manner ." "The Commission may' (emphasis added) accept as proof of this a certification of an authorized representative of the facility licensee where the applicant's services will be utilized. This certification must include details on courses of instruction administered by the facility license, ... and for reactors, the startup and shutdown experience received." NRC practice has been to requiree such a certification if a facility startup is not performed as part of the operating test identified in 10 CFR 55.23.

In October 1974, the NRC notified SCE of an alternate training program for applicants for an exaiiiiatfion wi-thout a facility startup which required, among other items, five reactivity manipulations on the facility for which the license was sought. Accordingly, certification by SCE of completion of this alternate training program which included the five fad l-ity- reAct v-tI y

,ar wpu I.atians was a-c -~~~ i -o~ - -~ t i -+ ale6did~f 5 rned to operate, the controls and need not be tested for startup.

Since recent license applicants presented by SCE were not scheduled to conduct facility startups as part of the examinations, the NRC requested evidence that each applicant had conducted a minimum of five control manipulations on the actual plant. Such a request for evidence to permit the NRC to reach a conclusion regarding the need for a facility startup demonstration as part of the NRC examination is consistent with the regulations and staff practice and is not a backfit.

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NRC FORM 318 (10/80) NRCM 0240 OFFICIAL RECORD COPY *U.S. GPO 1983-400-2,d

Mr. Kenneth P. Baskin OCT 3 1 1986.

Applicants that fall under the special provisions of 10 CFR 55.25, so called "cold" license candidates, may utilize a simulator to perform required control manipulations. This exception is permitted because: (1)-the plant the candidates are licensing on is not available for reactivity manipulations prior to staff licensing requirements and (2)NRC approved cold license training programs are tailored to include special requirements such as extended simulator training and observation training at similar plants. The additional requirements and experience gained during startup testing are intended to compensate in some measure for the experience missed by the lack of operational availability of the plant they are being licensed on.

However, 10 CFR 55.25 does_notapply to "hogt" license candidates; i.e.,

applicantsfor operati icenses after initial criticality. The staff reads the Commission's decision in Pacific Gas and Electric Company (Diablo Canyon Nuclear Power Plant, Units 1 and 2), CLI-84-5, 19 NRC 953 (1984), likewise to be limited in application to "cold" licenses. We can find no documentation that the AEC or NRC ever approved an SCE training program for operator or senior operator applicants after irtial _criticality of San 0nofreJ,_ . r3, that permits use of a simulator in 1 o the plant to meet_.the_ reactivity manipulat requiremets an A inig gram for "hot"_license canidates. However, we did grant temporar verbal relief from these requirements_ii1983-when'Unit 1 was n an extended shutdown period which prevented license applicants from obtaining the reactor control manipulations during their licensed operator training program. On August 14, 1986, NRC reviewed the records for the first applicants after San Onofre 1 startup; i.e., the October 1984 license applicant training class. These applicants participated in the Unit 1 startup in November/December 1984. We found evidence of the required reactivity control manipulations in their training records.

You also claim that requiring evidence of control manipulations would pose an extensive, new administrative burden. During a recent audit of your accredited training program, the staff noted that this program requires extensive on-the-job training (OJT) and retention of records related to this OJT. Although you may not be keeping adequate records to document the five (5)reactivity manipulations requirement, it appears that your accredited training program includes a mechanism that with no additional administrative-"

burden could document these practical factors during the candidates OJT.- '

In addition, as a result of your letter dated June O, 1986, we have reviewed your training program submitted on January_22.,_1985-10 res to Generic Letter 8A-,4. The SCE training program last reviewed by the NRC (Section T.Z.2.3.1.c. of Amendment 24 to the FSAR dated April 1981) required "hands on" facility operation as part of replacement training for licensed operators. However, your January 22, 1985 program no longer requires "hands on" facility operation. For example, Item 4.2.2.4 of the Senior Reactor Operator/Control Room Supervisor Training Program and Reactor Operator/Assistant Control Operator Training Program proposes the use of a simulator to meet all facility reactivity manipulation requirements.

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• ~4 Mr. Kenneth P. Baskin - 3 - UI 3 9 reactivity manipulations and allows simulator training to supplant power plant experience. In fact, your January 22, 1985 program no longer required any "actual hands on plant operating experience."

We understand that you may have made these January 22, 1985 program changes based on an NRC employee's incorrect response to a question regarding the use of simulators at an October 30, 1984 Region V Counterpart Meeting. However incorrect statements by NRC employees do not relieve licensees of the requirement to meet the regulations or the requirement to request review and approval of changes to their approved training programs. In addition, Generic Letter 84-14 requested submittal of SCE's current training program and stated that changes from the approved program were to be identified and the appropriate review fee submitted. Your January 22, 1985 submittal did not indicate any training program changes nor request NRC approval. However, as noted above, it appears that you have made changes that are not in accord with the previous NRC approved program.

In conclusion, NRC regulations require evidence that a license applicant has learned to operate the controls of the facility (i.e., change power or reactivity). The regulations do not specify a minimum number of control manipulations; however, staff practice has been to waive a reactor startup as part of the NRC examination if evidence exists that an applicant has performed five such control manipulations on the facility. As reflected above, the longstanding position is and has been specifically applicable to San Onofre. Your January 1985 change, made on the basis of a misunderstanding of NRC requirements or misinformation by an NRC employee, has not been accepted by the staff. Accordingly, the staff position about which your June 20, 1986 letter complains is not new or different from a previously applicable staff position.

Sincerely, Harold R. Dent co Office of Nuclear Reactor Regulation

Enclosure:

Eligibility Requirements for Replacement Operators to Sit for Examination Without Reactor Startup C H tons DW/EATON3/LTR TO BASKIN I / (/86 N DDT:D/DIR DHFT:DIR OFFICEO D0~A8T B5 R B a* a: -FJ n T s I BAoger WTRussell OGC JScinto N;R SURNAME I Rr..

DATE 10 /86 10/1/86 10/ 6 10/%A/86 10/ /86 10/ /86 10/ 7/86 NRC FORM 318 110/80) NRCM 0240 OFFICIAL RECORD COPY U.S. GPO 1983-400-24

HISTORY OF REQUIREMENTS FOR LICENSE APPLICANT'S EXAMINATION WITHOUT REACTOR STARTUP On October 3, 1974, in a letter to all licensees, the AEC established a procedure for license applicants to sit for examinations without requiring a reactor startup providing the applicant had met three eligibility requirements. These requirements include: five reactivity changes on the reactor facility which he/she seeks a license; participation in an approved training program which includes training at a nuclear plant simulator; and certification from the simulator training center that four additional criteria relating to simulated reactor startup had been met. This policy was again published in Rev. 1 of NUREG-0094, "NRC Operator Licensing Guide," in July 1976, Appendix F.

In response to the H. R. Denton letter of March 28, 1980, and Item I.A.2.1 of NUREG-0737 of November 1980, licensees were to add additional reactivity manipulations to the licensed operator requalification program. The manipulations (Enclosure 4 of the Denton letter) included normal, abnormal, and emergency conditions. The manipulations could be done on the plant or a plant simulator. This letter did not approve use of a simulator for reactivity manipulations for license applicants.

When NUREG-1021, "Operator Licensing Examiner Standards," was published in October 1983, Standard ES-109, Eligibility Requirements for Reactor Operator and Senior Reactor Operator Candidates, included five significant reactivity changes and referenced Sections C.3 and C.4 in Appendix F of NUREG-0094.

Revision 2 of ES-109 published in April of 1986 clarified that manipulations of the actual plant (not a simulator) for five significant reactivity manipulations as described in the operator requalification program is necessary for an NRC operating exam without reactor startup. It further states that manipulations are not required if the operating examination includes actual startup of the reactor.