ML19323B864
| ML19323B864 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/29/1979 |
| From: | Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| REF-SSINS-0182, TASK-TF, TASK-TMR NUDOCS 8005140361 | |
| Download: ML19323B864 (6) | |
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UNITED STATES 800514036/
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A 'l AN I A. Gi oftG tA 30103 JUN 2 0 579 SSINS 0182 MIBORANDUM FOR:
James P. O'Reilly, Director, Office of Inspection and Enforcement, Region 11 TitRU:
g R. C. Lcwis, Acting Chief, Reactor Operations and Nuclear Support Branch, Region II FI:0M:
W. A. Puhlman, Acting Chief, Nuclear Support Section No. 2, RONS BRANCH
SUBJECT:
REGIONAL OFFICE NOTICE NO. 2212, RECOMMENDATIONS FOR CHANCES IN IE PROGRAMS Ir the subject Regional Of fice Notice, you solicited comments on additions or deletions to IE programs considered necessary following TMI. Although 1 previously y epared virtually these same recommendations (9/77) when in Region I and even t1ough they were subsequently forwarded to Mr. Skovholt by Mr. Grier, 1 feel that i
it is ac,ain necessary ta inform my management of my recommendations in this area.
MT. P. Iayloc of NSS#2 is currently collecting data to submit proposed changes to licensees requalification programs as a result of the intensified training ir.spections which you directed for all RII licensees.
Mr. Taylor will also be pt eparing a summary of these inspections which will contain additional conclusions ar.d recommendations in tbis area of training.
NSS#2 is currently commenting on AFSI/ANS 3.1-1978 and the proposed Regulatory Guide 1.8 revision which is to erdorse the revised standard (formerly designated ANS1 N18.1). The recommendations ir this me.norandum are in addition to these other two ef forts.
Scsed upon e/idence I have obtained from direct inspections, and my review of 1.fceusec eveat reports (LER's), allegations, and internal Government audits ard studica, the performance of individuals at nuclear power reactor facilities le. deteriorating as the complexity and number of facilities increase. This decrease la performaire is attributed to both the increasing complexity of the plant systema and the timinished pool of trained and experienced personnel.
Per sonnel sha were initially involved in development of commercial reactors luve been pramoted, retired, or otherwise displaced.from'the day-to-day operation of the facilities and have been replaced by less t'xperienced snd less knowledgeabic petsonne}.
Pirsonnel initially performing operator, maintenance, control, core physics, atd health physics functions were degreed personnel with vast engineering nr.d/or screntific backgrounds. As these personnel were replaced with younger,
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JUN r p g79 less experienced operators and craft personnel, the competence level of these p(isitions declined. The NRC(AEC) first recognized this decline in the area of plant operators. The Commission moved to stabilize the competence of plant -
operators at an acceptable level with the introduction of reactor operator licensing requirements in 1958 (10 CFR 55). These requirements were further subdivided into Senior Operator and Operator requirements with amendments to 10 CFR 55 in 1963. The need to assure that suitable proficiency was maintained, it. addition to being initially achieved, was recognized and covered with the.
Itsuance, in 1973, of requalification requirements. While the record of operator errors is not perfect, far fewer errors are attributable to-licensed operators (proportionate to the number of critical activities performed) than te non-licensed operators.
At a result of the benefits realized through implementation of a licensing program for ceactor and senior reactor operators, and based on the similarities in the initial problems, it would seem prudent to pursue similat action for pctsonnel engaged in the areas of radiation protection, maintenance, and instrument ard controls based on public and NRC concerns as a result of TMI.
The rationale ard implementation concerts are defined in Appendices A and B to this memorandum.
f 07v W. A.
uhlman, Acting Section Chief s
Nucle r Support Section No. 2 9
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P APPENDIX A I_.T_ CENSING / CERTIFICATION OF llEALTil PHYSICS PERSONNEL R\\TIO:lALE The concept of licensing / certifying the individuals involved with protection of haalth and safety against radiation is embraced in-the definition (55.4 l
('))' of controls in Part 55.
This proposal'is specifically aimed at only those individuals making decisions or taking actions which could adversely affect the rcJiation exposure of either plant personnel or. members of the general p.sbl i c.
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- 3. proposed that persons with responsibilities in the following areas be required to obtain an NRC license or certification. This license /ccrtification would be issued following the successful completion of both an oral and a written test.
authorize entry into radiaticn, high. radiation, contaminated, or airborne activity areas; make decisions relative to evacuation, measurements, sampics,-
and other management decisions associated with site radiation I
emergencies; supervise or approve the results of surveys, air samples, contamination swipes; 4
I evaluate and decide on increasing allowable radiation exposures for individuals beyond established administrative guidelines; and have the authority to approve / disapprove radiation control and
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measurement ' procedures and/or radiochemistry analysis / sampling procedures.
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m APPEMDIX B ALTERNATIVE NO. 1
_ LICEMSINC O_F PLANT OPERATORS / PLANT CRAFT PERSONNEL RATJ uNo1.E 10 CPR 55.4(f) def f r,es controls as those apparatus and mechanisms the manipulation of which directly affects the power level or reactivity of the reactor. This det uilt uin does not preclude consideration of the direct action of one individual la conjunction with the direct action of a second individual. A licensed operator rea; sifect the power level / reactivity of the reactor through or following the d rect. action of a r:econd (unlicensed) individual whose performance is beyond the cont rol of the licensed person. As examples, an R0/SRO manipulates the controls et Lt.e f acility af ter:
ISC technicirn has improperly calibrated an instrument used to an nanitor the process and a safety limit is exceeded; a r.:echanic has r epaired a picnp, a blind flange is lef t in the flow path, the flow fails to be established when the system is required to operate; ni eparator incerrectly rixes a batch of boric acid by including a han of Nacl crp t als and the resulting mixture (tested only for boren conceritratton) is aligned to'the makeup system and subsequently inb eted into the primary system.
If the individuals responsible for the above actions were licensed by NRC, en force nent sanctions could be taken directly against the persons involved.
PROPOSAL rollowing the basic approach of 10 CFR 55, NRC would license plant operators /
plant crafx personnel performing the following types of functions on safety-
.related structures, systems, components, and/or consumables.
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4 APPENDIX B ALTERNATIVE NO. 2 CER1!PICATION OF PLANT OPERATORS / PLANT CRAFT PERSONNEL RATIONALU Regulatory Guide 1.58 and ANSI N45.2.6 require the certification of inspection /
en mination/ testing personnel.
These documents currently allow considerable latitude in estabitshing acceptable levels of' training / qualification necessary for certification.
If direct NRC licensing in accordance with Appendix B Alternative No. 1 is not considered desireable at this time, an interim method of certification, s.milar to FAA certification of aircraft mechanics, could be used.
PLOPOSAL Modity Regulatory cuide 1.58 to require that minimum certification programs would be specified by NRC.
Following OLB review and acceptance of the certification progran and OIE's review of the licensee's completion of the specified certification prof, ram, OIE would recomnend that NRR:0LB issue letters of certification to those inr.pection/ceamination/ testing personnel successfully having completed the licensees' courses.
NFC certif t(d personnel vould perform or direct all inspection (examination, of.servation, or measurement to determine the conformance of materials, supplies, components, parts, appurtenances, systems, processes, or structures to pre-dc t(rmined goality requirements), examination (a critical, investigation of items ny nondestructive methods), and testing (determination or verification of the l
capability of an item to meet specified requirements by subjecting the item to of physical, chemical, environmental, or operating conditions) operations.
a sct Since only NRC certified personnel could perform 'hese functions, and since-t this NRC certification could be suspended ~and/or revoked in cases where significant errors' in performance of assigned duties were detected, this certification would 3
provide an enforcement tool as well as increasing the competence of personnel performing,these functions.
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APPENDIX II Valve lineu[is ;
Operability checks / inspections; Calihrattons/setpoint adjustments; s
Pesin/ chemical additions, preparations, filling of systems; Post maintenance testing / inspection / examinations; and Surveillance tests.
An oral and written tr. amination, broken down into 3 categories (operator /I&C/
racch.inic) would be administered to journeyman level plant operators / control techalcians/mechanica.
Personnel working with/under the supervision of these jouracymen would not require licenses.
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