ML19209A090
| ML19209A090 | |
| Person / Time | |
|---|---|
| Issue date: | 09/11/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19209A091 | List: |
| References | |
| REF-10CFR9.7 SECY-79-330E, SECY-79-330E-01, SECY-79-330E-1, SECY-79-330F, NUDOCS 7910020279 | |
| Download: ML19209A090 (23) | |
Text
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SECY-79-330F September 11, 1979 COMMISSIONER ACTION For:
The Commissioners From:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation Thru:
Executive Director for Operations 72M h lN4
Subject:
QUALIFICATIONS OF REACTOR OPERATORS
Purpose:
To provide a supplement to the Commission Action Paper, SECY 79-330E, dated July 30, 1979, on the above subject. The supplement covers information for implementation and rule-making decisions for all recommendations.
- Category:
This paper covers a major policy matter. Resource estimates, Category 1, preliminary.
Discussion:
On July 30, 1979, SECY 79-330E was submitted to the Comissioners and contained (16) recomendations complete with various options to improve the Operator Licensing Program, in response to Samuel J. Chilk's request to Lee V. Gossick, dated April 30, 1979. That report considered the principal type of facility, i.e., nuclear power generating reactors, for which licensing of operators is required.
Recommendations for the time required to implement each of the (16) SECY-79-330E recommendations are addressed in.
Also, this enclosure provides staff proposals concerning implemention steps and whether rulemaking amend-ments or changes are required and/or desirable.
The infor-mation in Enclosure 1 is based on approval of the recommenda-tions in SECY-79-330E and this paper.
- SECY NOTE:
This paper and SECY-79-330E are currently scheduled for a briefing at an Open Commission Meeting on Thursday, September 13, 1979.
G s
The Comissioners The recomendations contained in SECY-79-330E and this paper address improvements to the operator licensing program for Nuclear Power plants only.
Staff recommendations regarding non-power reactors will be addressed in a separate paper.
Coordination:
The Lessons Learned Task Force concurs in these recommenda-tions. The Office of the Executive Legal Director has no legal objection.
[
d Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosures:
1.
Implementation Considerations for Operator Licensing Program Recomendations Commissioners' comments should beprovided directly to the Office of the Secretary by c.o.b.
Monday, September 24, 1979. -
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT September 18, 1979, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and coment, the Commissioners and the Secretariat should be apprised of when coments may be expected.
DISTRIBUTION Commissioners Commission Staff Offices Exec Dir for Operations ACRS Secretariat 103'i3d
Implementation Considerations Operator Licensing Program Recommendations Recommendations 1, 2 and 3 Recomendations 1, 2 and 3 all pertain to increased requirements that must be possessed by applicants for licenses. These provisions would provide for increased operating experience of applicants, price to NRC examination.
Since the implemantation considerations of all three are the same, they are considered together.
1.
The experience requirements regarding power plant operations for senior operator applicants should be increased.
2.
Establish requirements for applicants fo senior operator licenses after the plant. achieves criticality to be licensed as an operator for 6 months.
3.
Establish requirements for participation in plant shift operations prior to licensing.
A.
Implementation Rationale The requirements should be put in place at the earliest practicable date.
However, some notice to industry should be provided, so adjustments can be made to utility selection and training practices.
Requi ring this experience for all applicants who file applications 6 months after the Comission's decision date is recommended.
Further, in implementation of recommendation 1, provision for consideration of equivalent qualifications by the staff should be made.
1034347 B.
Implementation Steps 1.
Recormendations 1, 2, and 3 can be promptly implemented by the staff without the need for formal rulemaking. Utilities should be informed that applications filed 6 months or more from the date of Commission approval must reflect the revised experience requirements. The require-meat for powr plant operations experience should provide for accept-tance of other experience considered equivalent by the staff.
This experience would constitute part of the evidence that the individual has learned to operate the controls in a safe and competent manner, as required by 10 CFR 55.10(a)(6).
2.
Rulemaking should be initiated for the purpose of clarifying the Com-mission's interpretation of 10 CFR 55.lu(a)(6) and to call attention to the revised, experience requirements set forth in the initial recom-mendations approved by the Comission.
Recomendations 4, 7 and 11 Recommendations 4, 7 and 11 all pertain to requiring the use of power plant simulators for training and examining activities where their use to date has been encouraged, but optional. Since the implementation considerations are the same for all three, they are considered together.
4.
Establish requirements that simulators be used in training programs for hot applicants.
/6W3fj 7.
In addition to the present operator regi:alification program requirements, all licensees should be required to participate in periodic retraining and recertification on a full scope simulator representative of their facility.
- 11. Applicants for operator and senior operator licenses should be examined at a nuclear power plant simulator.
A.
Implementation Rationale The requirements for use of nuclear power plant simulators should be put in place as saan as practicable. However, even though use of simu-lators for initial training and requalification is already widely practiced in the industry, it is not feasible for the Commission to establish r specific date for full compliance.
Reasons for this in-clude:
1.
The degree of similarity between each plant and the simulators available for training must be evaluated to determine the extent of the value of such training.
For some existing plants, (primarily older, smaller units) no existing simulator is a close replica and alternative proposals should be considered by the staff.
2.
For new simulator installations, suitable time for procurement 3.
There is uncertainty associated with the availability of existing simulators.
In the four training centers operated by NSSS Vendors, we presume that they would be willing to accept all customers (with preferential treatment to their NSSS customers) to the limits of their capacity. However, most existing simulators are owned by private utilities and were intended for their own corporate training needs.
The extent to which these simulators would be made available to train other utilities will need to be detennined.
4.
Contractual arrangements between utilities and training center owners will have to be executed, including provisions for NRC examinations.
B.
Implementation Steps 1.
Appropriate rulemaking proceedings should be initiated to amend existing regulations in order to provide for mandatory simulator training for both new license applicants and licensees under the provisions of requalification programs.
1031 35L Recommendations 5 and 9 These recommendations concern NRC involvement in auditing of training programs, including administration of examinations.
5.
NRC should audit training programs more closely, including administration of -:rtification examinations.
9.
An increased level of confidence in the effectiveness of requalification programs should be provided by NRC examiners administering annual re-qualification examinations.
A.
Implementation Rationale The degree of auditing and the extent to which NRC examiners administer certification and requalification examinations will be increased as additional OLB manpower becomes avialable until the degree reaches the recommended level. Complete implementation will depend upon the rule-making proceeding, approval of OLB manpower increases and obtaining qualified examiners.
B.
Implementation Steps 1.
Recommendation 5 can be promptly implemented by the staff witheut the need for formal rulemaking.
2.
Appropriate rulemaking proceedings should be initiated for the implementation of recommendation 9.
}.
i 3
Recommendation 6 Develop eligibility requirements for instructors.
A.
Implementation Rationale Comprehensive requirements are to be fully developed.
Impl ementation of the initial requirement for specified types of instructors (uld a senior operator license) should be completed pursuant to standard rulemaking procedures.
This will permit the staff time to detennine those instructors that will require licenses and to develop.ne necessary eligibililty requirements for examinations.
It will also allow industry time to make the necessary changes in their personnel selection and instructor training programs.
B.
Implementation Steps 1.
Rulemaking proceedings should also be initiated for the purpose of establishing as a requirement that specified types of instructors must hold a senior operator's license 2.
The staff will continue to develop comprehensive eligibility require-ments for instructors in cooperation with the American Nuclear Society Sub-Comittee ANS-3 and the newly created Institute of Nuclear Power Operations.
1031 3 4 Recommendations 8 and 15 These recomendations address simulator training program content and capability of the simulators.
8.
Establish more explicit requiremrts regarding exercises to be included in simulator requalification prog. ams.
15.
ANSI /ANS 3.5-1979, " Nuclear Power Plant Simulatcrs," should be reviewed and revised and a Regulatory Guide reflecting NRC endorsement be developed.
A.
Implementation Rationale The implementation 'of these recomendations will commence immedat ely after they have been considered and approved by the Comission.
The NRC guidance regarding simulator exercises should be developed within 3 months. The standard, currently undergoing revision by the ANS-3 standards comittee, should receive expeditious review after it is issued.
B.
Implementation Steps 1.
Recommendations 8 and 15 can be promptly implemented by the staff without the need for formal rulemaking.
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. 2.
No rulemaking changes are required. Authority for the recommended actions is contained in existing regulations.
3.
The staff should continue consultation with ANS-3 and INP0 in a cooper-ative effort to effect these and further improvements.
Recommendations 10, 12, 13 and 14 These recommendations address the scope, administration and grading of NRC examina-tions; and notification of facility management of the results.
10.
The scope of the written examinations should provide increased emphasis on understanding of thermodynamics, hydraulics, and related matters.
12.
Senior operator applicants who hold operator licenses should be required to take an oral test pursuant to 10 CFR 55.23 as well as the written examination pursuant to 10 CFR 55.22.
- 13. The passing grade of written examinations should be increased to 80".
or greater overall and 70". or greater in each category.
- 14. NRC should inform facility management of the results of each examina-tion so that remedial training of irdividuals may be instituted, as applicable.
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A.
Implementation Rationale These recommendations should be implemented immediately.
B.
Implementation Steps 1.
Recommendations 10,12,13, and 14 can be promptly implemented by the staff without the need for formal rulemaking.
2.
Appropriate steps should be taken to amend the list of " routine uses" of this system of records under the Privacy Act so as to include remedial training as one of the uses for which examination results may be disclosed.
3.
Rulemaking should be initiated to explicitly call out recommendation 10 in 10 CFR Part 55; this is desirable to clearly indicate the scope of examinations in sections 55.21 to 55.23.
Recommendation 16 The present part-time examiners should be augmented by utility and vendor training personnel and formal training programs should be instituted for examiners.
to u 357
~ A.
Implementation Rationa'e 1.
Check Examiners The utilization of utility and vendor training personnel to conduct NRC examinations requires resolution of conflict of interest problem, develop-ment of specific personnel procedures, determination of contractual and funding problems and securing industry cooperation. Detailed investiga-tion of the FAA rules and practices in this regard should be made. The implementation proposed is performance of a feasibility study by the staff and a report to the Commission with further recommendations.
Exploration of these areas will start immediately after approval by the Commission.
2.
Part-time Examiners Formal training programs for all examiners will require program develop-ment and study to detemine the optimum methods of administering the proper training to them. Ten of the present part-time examiners have personal services contracts.
It is our understanding that there may exist prohibitions to the training of consultants. The remaining part-time examiners are employed at the National Laboratories. The feasibility of NRC providing training to these persons neec determina-tion. Also, arrangements would have to be made with DOE to pemit these individuals to devote the time required to perform their examining duties.
1034 353
. The fundamental issues to be considered are the following:
a.
What constraints exist on the NRC's ability to provide training to a) private consultants and b) 00E operating contractor personnel?
b.
If ample training cannot be provided, what future use of these personnel in the NRC operator licensing program should be made?
c.
If significant training is provided, what amount of cormiitment of service per year to NRC would be appropriate to justify such training?
d.
How many of the part-time examiners,. and their primary employers, would be willing to commit to the amount of annual service deemed necessary?
- Exploration of these matters will begin immediately after approval by the Comission.
B.
Implementation Steps 1.
The staff should perform a feasibility study of the viability of the check pilot concept and report, with recomendations, to the Comis-sion. The Executive Legal Director should provide NRR with an opinion concerning the conflict of interest question.
The Director of Administration should provide NRR with advice on contractual and personnel matters, as required.
03.4 3q
- 2.
The Director of Administration should provide NRR with advice con-cerning the NRC's authority to pro ide training to a) private consultants and b) 00E operating contractor personnel, related to their perfonnance of NRC activities.
3.
The staff should further investigate the issues associated with training of part-time examiners and report to the Comission.
1034 go
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RECOMMENDATION 1 INCREASE MINIMUM EXPERIENCE REQUIREMENTS FOR SENIOR OPERATOR APPLICANTS 4 YEARS OF OPERATING EXPERIENCE 2 YEARS NUCLEAR - 6 MONTHS ON SITE e NUCLEAR PLANT STAFF ENGINEER OR e CONTROL ROOM OPERATOR e 2 YEARS MAY BE ACADEMIC
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RECOMMENDATION 2 SENIOR OPERATOR APPLICANTS MUST HOLD AN OPERATOR LICENSE FOR SIX MONTHS
RECOMMENDATION 3 MORE SPECIFIC TRAINING REQUIREMENTS FOR HOT LICENSE APPLICANTS
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4 REQUIRE SIMULATORS TO BE USED IN HOT TRAINING PROGRAIVIS IN REQUALIFICATION PROGRAMS FOR ADMINISTERING NRC EXAMINATIONS 9
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g RECOMMENDATIONS 5 AND 9 AU DIT OF TRAINING PROGRAMS, INCLUDING ADMINISTRATION OF CERTIFICATION EXAMINATIONS ADMINISTER REQUALIFICATION EXAMINATIONS
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RECOMMENDATIONS 8 AND 15 ESTABLISH EXPLICIT EXERCISES' TO BE PERFORMED AT THE SIMU LATORS REVIEW AND REVISE ANSI /ANS 3.5 AND DEVELGP REGULATORY GUIDE
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INCREASE SCOPE OF EXAMINATION THERMODYNAMICS HYDRAULICS ORAL EXAMINATIONS FOR ALL SENIOR OPERATOR APPLICANTS INCREASE PASSING GRADE 80% OVERALL 70% EACH CATEGORY NOTIFICATION OF RESULTS
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q RECOMMENDATION 16 A. DEVELOP TRAINING PROGRAMS FOR NRC EXAMINERS B. USE INDUSTRY PERSONNEL AS PART TIME EXAMINERS
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