ML19250B373
| ML19250B373 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/1979 |
| From: | Collins P Office of Nuclear Reactor Regulation |
| To: | Deboer T NEW YORK, STATE OF |
| References | |
| RTR-REGGD-01.008, RTR-REGGD-1.008 NUDOCS 7910300058 | |
| Download: ML19250B373 (2) | |
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'o UNITED STATES i,
NUdLEAR REGULATORY COMMISSION
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Mr. T. K. DeBoer Director, Nuclear Operations New York State Energy Office 9
Rockefeller Plaza Albany, New York 12223 i
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Dear Mr. DeBoer:
This is in reply to your letter to Harold R. Denton dated September 25, 1979.
Your letter infonned us of a study your office had made regarding unlicensed personnel training programs at nuclear facilities in New York State.
The standard 'you referred to, ANSI N18.1-1979, " Selection and Training of Nuclear Power Plant Personnel," is presently being revised.
I have taken the liberty to forward a copy of your letter to the Chairman of the ANS Committee that is revising t'e standard.
Further, we assure you that your cor.ments will be considered when-we revise Regulatory Guide 1.8, " Selection and Training of Personnel."
It may,0f interest to you that the Commission has requested the staff to per-form a feasibility study regarding licensing of other power plant personnel.
As part of the study, we will review and make recommendations regarding training programs for other personnel.
Thank you for your informative letter.
I will assure that you receive a copy of revised Regulatory Guide 1.8 when it is issued for comment.
Sincerely, I
Paul F. Collins, Chief Operator Licensing Branch Division of Project Management 885
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.APCCCA. CCMVSS CNEP September 25, 1979 Earold R. Dent:n, Director Office of Nuclear Reacter Regulations U. S. Nuclear Regulatcry Ccesissicn Washingten, D. C.
Oear Mr. *enten:
Re: New York State Energy Office Evaluation of Cnlicensed Cceratcr Training Programs
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Scre of the significant centributcrs to the Three Mile Island accident in March, 1979 were human /cperater er:crs. Further investigatiens into the causes for the errers are shcwing that inadegaate training and a lack cf understanding for everall plant operations were the prize facters which led tc the improper personnel decisiens during the incident.
The safe and efficient cperation of a nuclear pcwer plant is the respen-sibility cf the persennel in the cperating organicatien.
It is necessary that these persennel be adequately trained to cceprehend the ce=plexities of s.istem c.cerations, maintenance cf clant equi =ent and the i portance cf safety e
related systems.
This is necessary to ensure that their actions are not detri-rental to the reactor plant, equipr.ent, persennel, and ultimately to the health and safety of the public.
The New Ycrk State Energy Cffice's Bureau cf Nuclear Cperations ccnducted an evaluation Of the established training programs for the unlicensed persennel in the cperating organizaticn cf -he five cperating facilities in New Ycrk State.
This analysis focused en the unlicensed persennel who are external to the centrci
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Also, the pregrams were evaluated for ccmpliance with the current Nuclear Regulatcry Ccemission's Guidelines fer unlicensed cperatcr training.
S'.XV.ARY The primary conclusion reached during the evaluation was that the NRC Guidelines do not establish minimum training program requirements for un-licensed operators, technicians and maintenance persennel. The current NRC guidelines which address unlicensed cperator training are very general and delegate the authcrity and responsibility fer unlicensed personnel training to the individual facility.
Each facility reviewed has pregrams that meet th: NRC puidelines; hew-large variances were noted in the specific qualificatien requirements.
- ever, Major differences were apparent in the individual utility training philesophy tcwards systems crientation and indcctrination for the unlicensed personnel.
All programs address systems training for the auxiliary operaters, but, only cne of the five programs delineates systems crientation fer the I&C and
=aintenance persennel; these are administered en a time and manpcwer avail-ability basis.
RECCMMENDAT!CNS It is reccemended that the NRC revise the Regulatory Guidelines for unlicensed personnel training and include minimum requirements which wculd upgrade the. awareness and knowledge _ level cf unlicensed operators in the areas of system crientation and systems interrelatienships and stress the ts-portance of safety related systems and asscciated functions. The cbjective of these efforts should be the upgrading and standardiratics of the unlicensed epbratar training programs to ensure that the personnel who are in frequent contact with the plant fully understand the significance and implications of their actions.
DISCUSSICN This evaluatien primarily consisted of a review of the requirements and training pregrams that were in effect pricr to the T.M.I. accident and did not address any prcgram upgrading resulting frem pcst T.M.I. reappraisals.
The scurces of infcrmation for the study were the individual utility's ad-ministrative procedures related to unlicensed persennel training, their respective training manuals, NRC Regula: cry Guides and the American Natienal 5:anfaris Instit::e (ANS!! ruife for selecti:n and training cf nuclear pcwer plan perscenei.
The endersed ANS: guide ANSI-N13.1-1971; has :eneralif been sed as
- ne standard f r the established pregrams, but it dces nct =ive substantive
- uldance f er deve'.
- ping a pregram f:: unlicensed personnel training.
Section
5.2 iTrainin
Of 7erscanel Sc Requiring AE 11:enses) o f ANS I -:u s. 1 -19 1,
spe: ft: ally s:stes tha; a suitable training cr: gram te estaclished f::
mana:ers, super :scrs, prcfessi:nals, :pera: Ors, techni:ians and repairmen, 885 298
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Harold R. Denten, Director Page Three the requirements to preperly prepare them for their assignments and to meet established by the facility licensee. Other paragraphs of Section 5.3 refer the tt:Hnicians and professionals should co the skills related training that
,have and addresses methods for acquiring this training, participation in equipment vendcr's ccurses, initial equipment calibratien and equipment They address the need for perscanel who are ccmpetent acceptance pregrams.
in technical specialties but are noticeably deficient in requirements for any level of training that relates their specialty to the overall plant operatien and how their individual efforts may effect the safety of the reacter.
cf ANSI N19.1-1971 Section 5.4 (General Employee Training Guidelines) cutlines the necessary training fer all persons regularly empicyed in a nuclear pcwer plant. The subjects addressed are:
- Appropriate plans and Precedures (administrative and crgani:ational)
- Radiclogical Health and Safety Industrial Safety
- plant Centrolled Access Areas and Security 7:ccedures
- Use of Protective Clothing and Equipment Training in these areas is intended to acquaint the new e=ployee with the How-necessary informaticn to allcw safe execution of their specific duties.
this training dces not provide the new employee with an everview of the
- ever, facility or indcctrination in the basic system cperations.
In afdition to the General Employee Training, each utility has established I&C technician and the maintenance specific programs for the auxiliary cperater, personnel.
Auxiliary Ceerater Training The auxiliary cperaters are responsible for cperatien and surveillance
'cf equip =ent external to the centrol recm and each utility has established The programs are programs fer training ncnlicensed. auxiliary operaters.
developed wath the cbjective of providing qualified individuals to staff the auxilia. y operat:r positiens in the cperating crganizatien.
review of the auxiliary operater training, we noted varying re-In en:
The program develcped by one utility quirements in the individual programs.
has a detailed qualification that requires the trainee to be knowledgeable in the system, basic principles of cperations for various system c mpenents, and specific component locaticns. The trainee must also perferm system evalua-tiens, practical facters, reading assignments, and surveillance tests to This particular pr: gram requires
- ceplete the auxiliary operater gualificatien.
chtain his check:uts en the varicus subjects frem a licensed the trainee ::
revisu
- crpcrated Lnt: thas program is a scheiule i:r frequent
- erater.
- d the trainee's pr:gress by the training crganization.
A program devel: ped by ancther utility is significantly less fetailed in specifying the inf:rmati:nal requirements for the auxiliary cperater usi;fi:stian-This pr:gra: Onl/ lists the sistems to be studied withcut gulfance for the trainee in the,erf:r:ance of system ev:1 tiens, decen-strati:n :f pra:tical fact:rs cr discussi:n of basic principles cf selected ani qm m
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- Earold R. Denton, Director Page Fcur This program does not have periodic progress reviews, but regaires ccmpenents.
a walk-through of th systems by a training instructor to determine kncwledge level pric: to final gaalification; the system checkouts are given
- y the training instructer er by the shift supervisor.
Both of these programs ccmply with the NRC guidelines and illustrate the wide spectrum of training that exists because of minimal standardi:atien.
It should be noted that the scre general program has the potential of being egaally as thercugh as the more defined program, but relies very heavily upcn the persen administering the checkcuts to ensure all important material was discussed.
Instrumentation A.d Centrol (!&C) Technicians The instrumentation and centrol technician is respcnsible fer the elec-trenics and centrol systems associated with the unit.
These technicians werk en a reutine basis with the safety related systems.
The training pregrams in the State fer the &C technician include the General E=picyee indoctrination and supplemental technical training which may be previded by fernal en-the-jcb experience, egaipment vender courses and/cr IEC depart...ent training programs. Only one utility has regairements for previding fermal everall syste=s orientatien as part of'the !&C training The other programs do not specify systems indectrinatien; hcwever, program.
seme training crganizatiens do enceurage the I&C technician to attend system lectures that are given to the licensed operators.
.v.aintenance Persennel The mainte' nance group is respensible for the repair of the mechanical and electri:;al ecuipment in the plant. This group has direct involvement with safety related systems and egaip=ent. The training regaire=ents for these individaals are the mandated General Employee training and each facility's provisiens for additional skills related training. The skills related training is intended to increase preficiency in a particular skill er trade.
Cur review of maintenance training indicates that enly ene utility has regairerents for systems crientatien as part of the initial indectrination fer maintenance persennel. Cthers have policies regarding safety systems that are similar to the &C training.
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The lack cf sufficient system training can u. pact en the safety of the reacter a d its asscciated protective systems. The LicensenEvent ?eperts (LIR) are decu ented examples cf safety system degradatiens caused by un-licensed persennel errtrs.
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Harold R. Denton, Directer 7.ge Five A reduction in the number of LER's could be achieved through the es-tablishment cf minimum training requirements which emphasize the importance cf safety related systems. This additional training shculd previde the unlicensed personnel who are in frequent contact with systems with a better understanding of hew their individual actions may effect the systems and uit.:.mately the safety of the public.
The NRC guidelines are so general in substance that minimal standardi:a-tien is present in the established programs; hence the sccce and depth of the unlicensed training pregram is individually structured by each utility. The prcgram centent is the respcnsibility of the utility and is net influenced by the NRC regulatory process. Because the unlicensed training programs are not part of the regular NRC cversight functions, var ing degrees of quality may be designed inte the programs. With this type cf structure, the questien of adequacy of training lies wl-W the purview cf the licensee.
It is hoped that the NRC will promptly revise the Regulatory Guidelines fer unlicensed perscnnel training and include minimum requirements which wculd increase the awareness and kncwledge of unlicensed cperators in the areas cf system crientatien and systems interrelationships and stress the importance of safety related systems and asscciated functicns.
Sincere' -
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