ML19308B723
| ML19308B723 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/12/1979 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19308B699 | List: |
| References | |
| FOIA-81-131, RTR-REGGD-01.008, RTR-REGGD-1.008, TASK-TF, TASK-TMR SECY-70-330E, NUDOCS 8001160795 | |
| Download: ML19308B723 (4) | |
Text
v m,
p a aicoqk UNITED STATES q
gw g NUCLEAR REGULATORY CGMMISSION .:: E WASHINGTON, D. C. 20555 O.Y' (4l l c,gv f SEP 121979 MEMORANDUM FOR: H. R. Denton, Director, Office of Nuclear Reactor Regulation FROM: Robert B. Minogue, Director, Office of Standards Development
SUBJECT:
QUALIFICATION OF REACTOR OPERATORS Your paper SECY 79-330E, dated July 30, 1979, recommends to the Commission improvements in the operating licensing program. I recognize that these recommendations, which reflect many comments and sugaestions discussed among NRR and SD personnel during preparation of the paper, are first steps in a lon@-term program to uograde operator proficiency and are not intended to identify and address all areas of concern nor, as your paper points out, are they intended to provide final word on subject areas which are covered. As you note on page 2 of SECY 70-330E, we are in the process of revising Regulatory Guide 1.8, " Selection and Training of Personnel" and have requested additional public comment in view of the Three Mile Island (TMI) accident. Together with a special Federal Register Notice, these additional public comments have been solicited by a special mailing to more than 5,000 persons on the Division 1 Regulatory Guide Distribution List. The cognizant standards committee of the standard endorsed by R. G.1.8, ANS-3, is also revising its standard to reflect the experience learned from TMI. The ultimate resolution of the issue of qualifications of reactor operators should take into account this broad-based public review and the effort of the national consensus standards committee in this area. Any decisions made by NRC should be considered interim decisions pending this broader review. Recognizing that this is a complex subject that has been escalated to a very high level of importance as a result of the TMI-2 accident, I believe that SD views in this area should be identified now for resolution during our on- ~ going work to improve operator competency. I am also aware of the efforts of the utility industry to establish an Institute for Nuclear Power Operations (INPO) which I support and wh'ch has the potential for instituting improve-ments in many of the areas of our concern. As of now, our observations are as follows:
- 1. We should require licensee management to become more involved in the training and qualification of operating personnel.
Because of its paramount importance to safety, top management at each utility must become involved with operator competency in detail. I believe at a I relatively early stage we should identify, require and enforce the necessary levels of management involvement in our standards, licensing, and enforcement actions. 8001160 7 [ ATTACHMENT "F"
To: H. R. Denten SEP 12 B79 2. We should provide for keeping track of operator errors by operator name or coded symLSl. Every operator error <nould be traceable to the name or coded symbol 9f the operator respons
- ole and this information should be used for training, requalification or license suspension or revocation.
3. As a fundamental part of the operator training program, we should ensure that there is a detailed look into what is being taught trainees. Preferably, this detailed look should be independent of the normal process for reviewing and approving operator training and requalification programs, and should concentrate on reviewing texts, schematic diagrams, lesson plans, workbooks, assignment sheets, and other tools essential to proper training of personnel. This review either should be done by NRC persornel or NRC sponsored personnel or, possibly, by INPO with NRC oversight. In any event, it should be a thorough, critical review to ensure adequacy of training. 4. If the recommendation in SECY 79-330E is adopted, reactor operator instructors would be required to hold senior operator licenses. Although this would help in assuring that instructors have the required technical competence, we need to ensure that the instructors are also competent in the art of instructing and have the experience to impart their knowledge with authority. 5. With regard to the proposal in SECY 79-330E to deputize utility people as NRC part-time examiners, called " Check Senior Operators", we believe that certain limitations should be imcosed on their use. First, they should be carefully selected by the utility employer and the NRC to ensure that only the most experienced and knowledgeable individuals perform this task. Secondly, they should not examine operators of their own utilities when acting as an NRC " Check Senior Operator". And thirdly, they should be used only as part of a team which is headed by an individual from the NRC. 6. 10 CFR Part 55 presently allows waivers' of reactor operator examinations. Because such waivers give the appearance of a degradation of the requirements, I believe that we should look closely at this practice to confirm that there have been no abuses and to reassess whether the practice is worthwhile. 7. SECY 79-330E provides a recommendation regarding the required performance of casualty drills on simulators. In addition, we need to require the performance of casualty drills of a type which the simulator cannot handle -- those which affect more than just the control room. In addition to emergency planning drills and fire drills, we need to require sufficient casualty. drills run on the actual plant to ensure that the operators are trained to handle casualty action outside of the control room. Perhaps this can be accomplished by requiring that sufficient time be allocated each quarter so that all the operating personnel receive the necessary training. t l l i
Tc: 'H. R. Denton SEP 121979
- 8. As a result of the TMI-2 experience, more reliance will be placed en simulators.
Thus, NRC should become more involved in assuring that the simulators accurately reproduce conditions of the plant for which the operator is being trained and that the simulators are being used effectively for such training. It may be worthwhile to contract for detailed simulator checkout based on actual plant parameters measured during acceptance test programs,
- t. With regard to the use of part-time examiners,we believe that there is an
?rgument for the use of part-time examiners who have recent nuclear power plant experience rather than obtaining such examiners from universities and national laboratories with no power plant experience. It also may be helpful to assign technical personnel from the various NRC technical branches to periodically examine licensed reactor operators from the utilities in the technical area of expertise of the NRC person.
- 10. Under the present operator licensing system, the NRC conducts no further examinations after the, initial license exam since follow-up requalification exams are performed by the licensee. We should consider examining the licensee orally in detail at least every two years in such subjects as thermodynamics, heat transfer, fluid flow, fluid systems, instrumentation and control and reactor protection.
Not only would this provide a strong basis for continued confidence in operator performance obtained directly by NRC, but would also provide a strong incentive for all reactor operators to maintain their necessary skills. We recognize that the resources required for this effort would have to be examined to determine the feasibility and suggest that the " Check Senior Operators" (see item 5) could be used to supplement NRC personnel in this effort. 11.10 CFR Part 50.55 presently requires that only one licensed operator or senior operator be present at the controls during operation of the facility. This same section also requires that a senior licensed operator only be readily available on call (not present at the facility). This senior operator is required to be present at the facility during certain conditions such as start-up and approach to power. We need to upgrade our require-ments to ensure that the number of personnel on watch, including those required to be in the control room, are sufficient to handle casualties and other abnormalities. In this regard, we have received specific recom-mendations with regard to watch manning in response to our request for public comments on Regulatory Guide 1.8, " Personnel Selection and Training". Many of the foregoing observations suggest an attention to detail beyond . current practice and which require resources which are not currently assigned to this work. However, I believe that if we are to make significant progress in upgrading reactor plant operation, such redirection and reallocation of resources must be done if we are to provide the necessary assurance that accidents such as that which occurred at TMI-2 will not recur.
To. H. R. Denton SEP 121979 In addition to the SD views expressed above regarding qualifications for reactor opera
- ors, a member of my staff, M. S. Medeiros, has provided additional views which, in some cases, are at variance with the SD views.
His views are enclosed for your consideration. I /f $ b. Y/b-h* R. B. Minogue, Director Office of Standards Development
Enclosure:
Additional Views Concerning Reactor Operato'r Qualification CONTACT: M. S. Medeiros, Jr. 443-5913 cc: L. V. Gossick, EDO (w/ encl.) E. G. Case (w/ encl. ) D. B. Vassallo (w/ encl.) D. J. Skovholt (w/ encl. ) P. F. Collins (w/ encl.) l l 4}}