ML20035F341
| ML20035F341 | |
| Person / Time | |
|---|---|
| Issue date: | 02/26/1993 |
| From: | Rogers K NRC COMMISSION (OCM) |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| NUDOCS 9304210173 | |
| Download: ML20035F341 (11) | |
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RESPONSE SHEET
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SAf4UEL J. CHILK, SECRETARY OF THE C0!44ISSION FROM:
C0124ISSIONER R0GERS
SUBJECT:
SECY-93-021 - A14ENDMENTS TO 10 CFR PARTS 50 AND 52 ON TRAINING AND QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL mu APPROVED cox e DISAPPROVED ABSTAIN n
NOT PARTICIPATING REQUEST DISCUSSION C0bf4ENTS:
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ENTERED ON "AS" YES NO V
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CORRESPONDENCE PDR qj J
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1 Comments of Commissioner Rogers on SECY-93-021 The staff has done an excellent job in responding to the public j
comments on the proposed rule and in explaining and clarifying the intent of the rule.
I have enclosed pages of the proposed Federal Register notice that suggest some editorial changes of either a minor or clarifying nature.
I also suggest a more significant change in the last sentence of l
f 50.120 (Page 35) regarding recordkeeping by the licensee.
The rule as written states that the records are to be kept available "for the licensee to maintain program integrity" rather than, l
as previously stated in the proposed rule, "for NRC inspection to j
verify the adequacy of the program."
I believe that both reasons are valid and have suggested an appropriate revision.
This l
comment is related to my next comment regarding the inspection j
philosophy.
The staff responds (Pages 3-4) to the 12/24/91 SRM regarding the need for a balanced inspection philosophy.
In my opinion, the main point of the SRM was the concern that reviewing a training i
program only for cause would result in the inspection of only l
poor programs ultimately causing biased findings since high i
quality training programs would not be inspected.
The staff l
believes that there is no need for proactive training inspections i
because of monitoring of licensed operator requalification training programs and maintenance review activities, and j
oversight of the INPO accreditation of training programs.
I believe it will be difficult to judge the effectiveness of the j
j systems approach to training (SAT) process by only looking at poor plants.
There will be no benchmarks from good performing plants to permit accurate measures of a poor performance.
For example, review of licensed operator training will not necessarily provide.a picture of the effectiveness of training-for the radiological protection technician, which is not.
I administered and tested in the same manner as for licensed
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operators.
Furthermore, the staff has said (Page 2 of SECY !
l 432) that it will use the licensed operator requalification t
inspection procedure to primarily assess implementation only of the fourth element of the SAT (i.e., trainee evaluation).
This will not provide an adequate evaluation of the complete SAT process.
With reactive inspections the staff will identify only the problems with training and not get a true picture of the status of SAT implementation for the industry as a whole.
It will be difficult to objectively revise and update the NRC l
inspection guidance and procedures for training programs if the
-j staff does not have an accurate measure of where the industry is.
i Therefore, I believe that the staff should perform random l
proactive inspections of the training programs in each region each year.
This will ensure that the staff has a more extensive picture of the industry training programs as well as providing l
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2 licensees an incentive to continually inprove their-programs.
The staff should decide just how many inspections of this nature should be done, but we understand that the number would be'on the order of two annual inspections per region. E O l
[7590-01]
NUCLEAR REGULATORY COMMISSION l
10 CFR Parts 50 and 52 RIN 3150 - AD80 Training and Qualification of Nuclear Power Plant Personnel i
AGENCY:
Nuclear Regulatory Commission.
ACTION:
Final rule.
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SUMMARY
- The Nuclear Regulatory Commission (NRC) is amending its regulations f
l to require each applicant for and each holder of a license to operate a j
nuclear power plant to establish, implement, and maintain a training program for nuclear power plant personnel based on a systems approach to training 1
(SAT). The training program will provide qualified personnel to operate and Se maintain nuclear power plant,sbn a safe manner in all modes of operation.
V This action is being taken to meet the directives of Section 306 of the Nuclear Waste Policy Act of 1982.
[ 30 cl1y.t fo00<~ing f*Nk h
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EFFECTIVEDATE:]roreachnuclearpower t applicant, by [180 days af r the effective date of the rul or 18 months prior to fuel 1
, whichever is later, and for each ear power plant licensee, by 0 days after the j
effective dat of the rule)
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ADDRESSES:
Copies of all referenced NRC documents are available for public f
inspection and copying for a fee at the NRC Public Document Room, i
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-2120 L Street, NW. (Lower Level), Washington, DC 20555.
Copies of NUREG l
documents may be purchased from the Superintendent of Documents, U.S.
a Government Printing Office by calling (202) 275-2060, or by writing to the
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Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082,
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Washington, DC 20013-7082. Copies are also available from the National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161.
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- l FOR FURTHER INFORMATION CONTACT: Dr. Rajender Auluck, P.E., Office of Nuclear 1
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Regulatory Research, telephone:
(301) 492-3794 or Mary Ann Biarronte, Office of Nuclear Reactor Regulation, telephone:
(301) 504-1073, U.S. Nuclear l
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Regulatory Commission, Washington, DC 20555.
_ j l SUPPLEMENTARY INFORMATION:
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Background
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I Nuclear Waste Policy Act of 1982.
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l In Section 306 of the Nuclear Waste Policy Act of 1982 (NWPA), Pub. L.
I 97-425, the NRC was " directed to promulgate regulations, or other appropriate Comission regulatory guidance for the training and qualifications of civilian
. nuclear power plant operators, supervisors, technicians and other operating 1
l ElsCh if personnel p regulations or guidance shall establish... instructional requirements for civilian nuclear power plant licensee personnel training i
i programs."
In order to meet this directive, on March 20, 1985, the 4
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Comission published a Policy Statement on Training and Qualification of a
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i used by licensees to demonstrate compliance of a training program that _is not accredited by the INPO-managed training accreditation program.
(a) General Concerns.
Coment.
Numerous comenters expressed concerns regarding the manner in which the NRC will monitor implementation of the rule to ensure that it is consistent with the Comission's intentions and that the guidance provided by l
g c, f) the NRC and INPO is consistent. Specifically, it was recomended that the
[A Comission carefully monitor the implementation of the final rule to ensure
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.a consistency with the principles established by the Comission in response to Id j the Regulatory Impact Survey. Applying the principles in the Staff 4hS 4 tw Requirements Memorandum for the Systematic Assessment of Licensee Performance
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! %d d (SALP) program would ensure that there is intra-and inter-regional con:;istency in the requirements, evaluation criteria, and results, and would preclude the imposition of additional requirements based on rising i
expectations. Comenters indicated that the NRC should clarify the process that INP0 and the NRC will use to avoid giving licensees conflicting guidance.
Commenters indicated that the NRC should explicitly state that maintenance of f
an accredited training program will be construed as complete compliance with t
these training requirements. Other comenters indicated that NRC should consider delaying the effective date of the rule until it has completely reviewed implementing guidance (e.g., Reg. Guide 1.8, Rev. 2) and made it consistent with the final rule.
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Similarly, many believed that the requirement in f 50.120(b) that applicants
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must have established and implemented the required training program 18 months prior to fuel load is not reasonable, given that the accreditation process for training programs provides for verification and revision of training programs based on experience gained from operations.
It was recommended by several i
comenters that applicants simply be required to have training programs I
established and ready for accreditation prior to initial fuel load. Finally, l
t several comenters noted that linking the required program review and revision cycle to the industry's current 4-year schedule is unnecessarily prescriptive.
i Resoonse. The NRC has considered the issues raised by the commenters regarding the appropriate implementation time periods for both licensees and r
applicants. For licensees, the Commission believes that the 180-day
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t implementation period is sufficient, because all licensees-have developed, j
implemented, and are maintaining accredited programs. Implementation of the j
new " Engineering Support Personnel" program, which replaces the current I
" Technical Staff and Managers' program or other future accredited program changes, does not negate the fact that SAT-based training is continuing for i
the personnel covered by the rule, therefore; compliance with the regulation f
I would be maintained.
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The requirement that applicants establish and implement the training i
i The NRC
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program 18 months prior to fuel load is also considered appropriate.
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realizes that an applicant would not have training program accredited n
18 months prior to fuel load, and this rule does not require accreditation.
The rule only requires that a training program be established for those portions of the plant programs necessary to support ongoing activities covered i
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i Develop training programs to ensure-that each licensee.has trained (2) and qualified personnel to operate and maintain the facility in a safe manner; and (3)
Implement and maintain these programs effectively on a continuing basis.
Paragraph (a), " Applicability," indicates that the rule applies to each applicant for and each holder of an operating license for a nuclear power plant.
g Paragraph (b), " Requirements," requires that each applicant or licensee establish, implement, and maintain a program for training nuclear, power pl_ ant personnel which addresses all modes of operation and is deriv _ed from a systems approach to training (SAT). The SAT process was selected because it has the following characteristics:
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(1) Training design and content are derived from job performance I
requirements; e
(2) Training is evaluated and revised in,tems of job performance requirements and observed results on the job;
, t (3) Success in training can predict satisfactory on-the-job performance; and
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(4) A aining program can be audited because it involves clearly v
delineated process steps and documentation.
The SAT process contains five major elements and is intended to require l
a training system that will ensure successful performance on the job by
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trained individuals. The elements are:
(1) Analysis of job. performance requirements and training needs; (2) Derivation of learning objectives; 23
Licensed operators', such as control room ' operators: and senior control I
- room operaters, are not 'c' overed by this rule. - They will continue to be covered by 10 CFR Part 55 for both initial and requalification training.
Because some senior control room operators may also be shift supervisors, only j
j those aspects of training related to their shift supervisor function would be I
covered by this rule.
l This rule would require that training programs be periodically evaluated and revised as appropriate, and also be periodically reviewed by management for effectiveness.
Current industry objectives in this regard involve the evaluation by management of individual training prograr.s on a continuing or periodic basis to identify program strengths, weaknesses, and effectiveness.
These evaluations are nomally completed within a'3-to 6-month' period
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following completior, of training within the programs. The sum of these 4
evaluations results in a comprehensive review.
Periodic evaluations of the i
overall training programs are being performed by the industry as_part of
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accreditation renewal. 'The Commission exiects lhis Ractice 'to" cont"inue.
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i Dett.rmination of job performance requirements and training needs is part of the analysis in the SAT orocess and is reflected in qualification requirements. The facility applicant or licensee will be responsible for l
ensuring that all personnel within the scope of this rule have the training and resulting qualifications commensurate with job performance requirements for their assigned tasks.
Initial and continuing training, as appropriate, is 4
expected to be provided to job incumbents in positions covered by this rule.
Each applicant and licensee is required to maintain and keep available for NRC inspection the materials used to establish and implement required training programs for the affected personnel. Current industry practice in u
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industry's program objectives and criteria.. Having seen such modifications, the NRC will review to determine if they warrant any modification in the Commission's position expressed above. The NRC will continue to monitor the industry accreditatinn process by:
(a) Nominating individuals who are not on the NRC staff to serve as members of the National Nuclear Accrediting Board with full voting privileges; (b) Having an NRC staff member attend and observe selected National Nuclear Accrediting Board meetings with the INPO staff or the utility representatives; 0
(c) Having NRC staff observe selected INPO accreditation team site visits;
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(d) Reviewing any subsequent revisions to the program objectives and criteria as currently described in the National Academy for Nuclear Training document "The Objectives and Criteria for Accreditation of Training in the Nuclear Power Industry" (ACAD 91-015); and
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(e) Verifying licensee programs through the NRC inspection process.
As noted above, the NRC has the ability to verify compliance with this regulation through the inspection program and will do so as appropriate.
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Jbefr inspections, the NRC staff will use Inspection Procedure 41500,
" Training and Qualification Effectiveness," which references the guidance in NUREG-1220, Revision 1,' " Training Review Criteria and Procedures." Based on NRC inspections conducted to date, the Commission believes that the objectives
' Copies of NUREG-1220, Rev. I may be purchased from the Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20013-7082.
Copies are also available from the National Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161. A copy is also available for public inspection or copying at the NRC Public Document Room, 2120 L Street, NW., (Lower Level), Washington, DC.
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periodically evaluated and revised as appropriate to reflect industry
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experience as well as changes to the facility, procedures, regulations, and
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quality assurance requirements. The training program must be periodically i
reviewed by licensee management for effectiveness. Sufficient records must be maintained b ept avak forthelicenseetomaintainprogramintegrity)
Nr FRC t'ny edionf a yerdY {he o.depcy Of 0efr*Brom.
PART 52 - EARLY SITE PERMITS; STANDARD DESIGN CERTIFICATIONS; AND l
COMBINED LICENSES FOR NUCLEAR POWER PLANTS 4.
The authority citation for 10 CFR Part 52 continues to read as a
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folicws:
AUTHORITY:
Secs. 103, 104, 161, 182, 183, 186, 189, 68 Stat, 936, 948, 2
953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244, as amended (42 U.S.C.
2133,.2201, 2232, 2233, 2236, 2239, 2282); secs. 201, 202, 206, 88 Stat. 1242, 1244, 1246, as amended (42 U.S.C. 5841, 5842, 5846).
5.
In 5 52.8, paragraph (b) is revised to read as follows:
l 5 52.8 Information collection reouirements: OMB aooroval.
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i (b) The approved information collection requirements contained in this part appear in 55 52.15, 52.17, 52.29, 52.45, 52.47, 52.57, 52.75, 52.77, 3
52.78, and 52.79.
6.
Section 52.78 is added to read as follows:
i 5 52.78 Contents of applications: trainino and oualification of nuclear power olant personnel.
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