ML20062K114
| ML20062K114 | |
| Person / Time | |
|---|---|
| Issue date: | 12/07/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-93-333, NUDOCS 9312150126 | |
| Download: ML20062K114 (55) | |
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RULEMAKING ISSUE December 7, 1993 SECY-93-333 (Aff.irmat. ion)
FOR:
The Commissioners FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
FINAL AMENDMENTS T0 10 CFR Part 55 ON RENEWAL OF LICENSES AND REQUALIFICATION REQUIREMENTS FOR LICENSED OPERATORS PURPOSE:
l To obtain Commission approval for publication of the subject final amendments l
in the Federal Reaister.
BACKGROUND:
On May 20, 1993, the proposed amendments to 10 CFR Part 55 on Operators' Licenses were published in the Federal Reaister for a 60-day comment period (58 FR 29366).
The amendments included (i) deletion of s 55.57(b)(2)(iv) that required licensed operators to pass a comprehensive requalification written examination and operating test conducted by the NRC during the 6-year term of the license; (ii) a requirement that facility licensees submit copies of their operating tests or comprehensive written examinations to the NRC 30 days prior to conducting these tests ar.d examinations for operator requalification; and (iii) a revision to the " Scope" of Part 55 to reflect that requirements pertaining to operators' licenses will also be applicable to facility licensees.
The proposed amendments will not affect the regulatory or other appropriate guidance as required by 9 306 of the Nuclear Waste Policy Act of 1982.
In accordance with direction in the Staff Requirement Memorandum dated April 27, 1993, the Federal Register Notice included comments of the Chairman and Commissioners Remick and de Planque with separate views of
Contact:
NOTE:
TO BE MADE PUBLICLY AVAILABLE Anthony J. DiPalo, RES WHEN THE FINAL SRM IS MADE 301-492-3784 AVAILABLE Frank Collins, NRR 301-504-3173 25 m s
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0 The Commissioners 2
Commissioners Rogers and Curtiss. The comment period ended on July 20, 1993, with 42 comments having been received from power and non-power reactor licensees, industry advocates, public citizen groups, and the States.
DISCUSSION:
The first proposed amendment would delete 155.57(b)(2)(iv) that requires each licensed operator to pass an NRC-conducted requalification examination during the term of a licensed operator's 6-year license.
A large majority of power and non-power reactor licensees and industry advocates that chose to comment on the proposed rulemaking were in favor of deleting this requirement.
The results of NRC requalification examinations and inspections (using Temporary Instruction (TI) 2515/117, " Licensed Operator Requalification Program Evaluation") continue to support the staff's proposal to eliminate this requirement.
However, there were some respondents who disagreed with the staff's proposal.
The principal opposition came from the States of Vermont and Illinois. The State of Vermont pointed out that the Vermont Yankee requalification program would not have been evaluated as unsatisfactory if the facility licensee's grading had been used and stated that it does not have confidence that the program's deficiencies would have been detected and corrected if the proposed rule change were in effect. The proposed NRC inspection program includes reviews, observations, and parallel grading of selected operating tests and written examinations by NRC examiners, reviews of operational performance, interviews of facility personnel, and a general inspection of the facility licensee's implementation of its requalification training program. Application of the inspection program in the case of Vermont Yankee would have disclosed discrepancies in evaluation of operator performance and also would have allowed insight to other, more programmatic deficiencies. The State of Illinois contended that the current regulations provided incentive for licensees to maintain quality operator training programs and that the likelihood of further improving or even maintaining that quality without the periodic independent involvement by the NRC is unlikely.
The State of Illinois recommended a combination of routine NRC inspections of crew examinations on a plant simulator and a periodic independent test administered simultaneously to all licensed operators every 6 years.
The requalification inspection program implements routine NRC inspections as recommended by the State of Illinois as well as "for cause" examinations. The inspectors and observers who participated in the pilot inspections generally agree that the guidance in the TI was appropriate and enabled the inspectors to conduct adequate assessments of the facility licensees' operator requalification programs. Using the TI, the staff was also able to identify j
several issues that would have been undetected during previous NRC-conducted examinations.
This staff experience indicated that the proposed inspection program could, therefore, improve facility requalification programs.
The staff recommends no change in the final amendment to delete 9 55.57(b)(2)(iv).
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The Commissioners 3
The second proposed amendment would require that facility licensees submit copies of each annual operating test or comprehensive written examination used for operator requalification to the NRC at least 30 days before conducting the examination or test.
Comments from power reactor licensees, non-power reactor licensees, the Nuclear Management and Resources Council, and the Professional Reactor Operator Society were opposed to this proposal. Most respondents believed that submitting copies of all examinations and tests to the NRC 30 days prior to their administration would place additional burden both on the facility licensees and the NRC without any increase in safety.
Several respondents offered alternatives such as shortening the lead time, requiring that the examinations and tests be submitted after they are administered, submitting to the NRC the question banks from which the examinations are i
developed, or simply having the examinations available for on-site inspection.
The staff recommends that 9 55.59(c) be revised to require facility licensees to submit to the Commission written examinations or operating tests (which may include selected proposed examinations) uDon reouest Consistent with the Commission's insoection oroaram needs.
The NRC would review these examinations for conformance with 10 CFR 55.59(a)(2)(i&ii).
The third amendment would broaden the scope of Part 55 to reflect that the provisions of operators licenses as specified in 10 CFR Part 55 are also applicable to facility licensees. Only one of the 42 respondents to the FRN commented and endorsed this provision. The staff recommends that this j
1 amendment remain unchanged.
Finally, the Federal Register Notice invited specific comments on the applicability of the proposed amendments to research and test reactor facilities. A total of 13 non-power reactor licensees, the National Organization of Test, Research, and Training Reactors (TRTR), and a former research reactor director agreed with the deletion of 6 55.57(b)(2)(iv) as a condition for license renewal.
Several respondents suggested that the NRC return to the policy that was in effect prior to the 1987 rule change (i.e.,
facility-conducted examinations with periodic NRC inspections), and some respondents endorsed the NRC's intent to conduct requalification examinations "for cause" only.
This same group of commentors opposed the provision to have facilities submit copies of all their examinations and tests to the NRC 30-days prior to their administration.
The staff recommends that the final amendments to Part 55 apply to both power and non-power reactor licensees. When SECY-92-430 was developed, the NRC had conducted relatively few requalification examinations at non-power reactor facilities, so the technical justification for applying the amended rule to those facilities was not as strong as for power reactors. The staff has subsequently conducted requalification examinations at a majority of non-power reactor facilities.
Currently, the results of completed requalification examinations at non-power reactors indicate a 97 percent pass rate which is consistent with the rate at power reactors.
4 The Commissioners 4
INSPECTION PROGRAM IMPLEMENTATION:
Requalification program inspections will be conducted at each facility once per SALP cycle.
The inspections will normally be scheduled to coincide with the annual operator licensing tests that the facility licensee conducts in accordance with 9 55.59(a)(2).
Significant requalification program deficiencies identified during an inspection may prompt inspection of additional activities to perform a detailed evaluation of the program.
In addition, the staff will retain the authority to conduct requalification examinations "for cause" at any facility where the staff believes that ineffective training caused operators to commit errors.
RESOURCES:
If this rule is promulgated, the NRC will no longer be required to routinely conduct requalification written examinations or annual operating tests for the purpose of renewal of operator licenses.
The resources thus saved can be directed to inspect and oversee facility requalification programs to improve operational safety at each facility. The resources applied to each program inspection may also be adjusted on the basis of the staff's observation of the quality with which the facility is implementing its program. No additional NRC resources are required for implementation of this rulemaking.
COORDINATION:
The Office of the General Counsel has no legal objection.
RECOMMENDATION:
That the Commission:
1.
Acorove publication of the final rule as set forth in Enclosure 1.
2.
In order to satisfy the requirements of the Regulatory Flexibility Act, 5 U.S.C. 605(b), certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities.
This certification is included in the enclosed Federal Register Notice.
3.
Note that:
a.
A regulatory analysis will be available in the Public Document Room (Enclosure 2);
b.
A public announcement will be issued (Enclosure 3);
c.
The appropriate congressional committees will be informed (Enclosure 4);
1 l
l The Commissioners 5
d.
The chief Counsel for Advocacy of the Small Business 1
Administration will be informed of the certification and the reasons for it as required by the Regulatory Flexibility Act; e.
The final rule contains infc mation collection requirements that are subject to the Paperwork Reduction Act of 1980 (U.S.C. 3501 et seq.)
The staff is in the process of obtaining OMB approval for these requirements.
The rule will not be published in the Federal j
Reaister until that approval has been obtained; and f.
Copies of the Federal Register Notice of final rulemaking will be distributed to all Commission licensees. The notice will be sent to other interested parties upon request.
l
[ - J James M.
ylor fxecutiveDirector
/
for Operations
Enclosures:
1.
Federal Register Notice of Final Rulemaking 2.
Regulatory Analysis 3.
Public Announcement 4.
Congressional letters Commissioners' comments or consent should be provided directly to the Office of the Secretary by COB Wednesday, December 22, 1993.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Wednesday, December 15, 1993, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
This paper will be scheduled for affirmation at an Open Meeting once the OMB clearances are obtained.
Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.
DISTRIBUTION:
Commissioners OPP OGC EDO OCAA ACRS OIG ASLBP OPA SECY OCA
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l FEDERAL REGISTER NOTICE i
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[7590-01]
NUCLEAR REGULATORY COMMISSION 10 CFR Part 55 RIN-3150-AE39 RENEWAL 0F LICENSES AND REQUALIFICATION REQUIREMENTS FOR LICENSED OPERATORS AGENCY:
Nuclear Regulatory Commission.
ACTION:
Final rule.
SUMMARY
The Nuclear Regulatory Commission (NRC) is amending its regulations to delete the requirement that each licensed operator at power, test, and research reactors pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal. The final rule requires that facility licensees shall have a requalification program reviewed and approved by the Commission and shall, upon request consistent with the Commission's inspection program needs, submit to the Commission a copy of its annual operating tests or comprehensive written examinations used for operator requalification for review by the Commission.
In addition, the final rule amends the " Scope" provisions of the regulations pertaining to operators' licenses to include facility licensees.
The amendments will improve operational safety at each facility by redirecting NRC resources to administer 1
h the requalification program by inspecting and overseeing facility requalification programs rather than conducting requalification examinations.
This, in turn, will reduce both licensee and NRC costs related to the program.
EFFECTIVE DATE:
(30 days after publication in the Federal Reaistgr.)
FOR FURTHER INFORMATION CONTACT: Anthony DiPalo, Office of Nuclear Regulatory Research, telephone: (301) 492-3784, or Frank Collins, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 504-3173.
SUPPLEMENTARY INFORMATION:
Background
Section 306 of the Nuclear Waste Policy Act (NWPA) of 1982 authorized 1
and directed the NRC "to promulgate regulations, or other appropriate Commission regulatory guidance, for the training and qualifications of civilian nuclear power plant operators, supervisors, technicians and other appropriate operating personnel." The regulations or guidance were to
" establish simulator training requirements for applicants for civilian nuclear power plant operator licenses and for operator requalification programs; requirements governing NRC administration of requalification examinations; requirements for operating tests at civilian nuclear power plant simulators, and instructional requirements for civilian nuclear power plant licensee personnel training programs." On March 25, 1987 (52 FR 9453), the Commission 2
accomplished the objectives of the NWPA that were related to licensed operators by publishing a final rule in the Federal Register that amended 10 CFR Part 55 and became effective May 26, 1987.
The amendment revised the licensed operator requalification program by establishing (1) -simulator training requirements, (2) requirements for operating tests at simulators, and (3) instructional requirements for the program (formerly Appendix A to 10 CFR Part 55). The final rule also stipulated that in lieu of the Commission accepting certification by the facility licensee that thE. li.cnsee has passed written examinations and operating tests given by the facility licensee within its Commission approved program developed by using a systems approach to training (SAT), the Commission may give a comprehensive requalification written examination and an annual operating test.
In addition, the amended regulations required each licensed operator to pass a comprehensive requalification written examination and an operating test l
conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
Following the 1987 amendment to Part 55, the NRC began conducting operator requalification examinations for the purpose of license renewal. As a result of conducting these examinations, the NRC determined that the existing regulations have established a high standard of licensee performance and that the NRC examiners were largely duplicating tasks that were already required of, and routinely performed by, the facility licensees.
The NRC revised its requalification examination procedures in 1988 to focus on performance-based evaluation criteria that closely paralleled the training and evaluation process used for a SAT based training program.
This revision to the NRC requalification examination process enabled the NRC to 3
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conduct comprehensive examinations for the purpose of renewing an individual's license and, at the same time, use the results of the examinations to determine the adequacy of the facility licensee's requalification training program.
Since the NRC began conducting its requalification examination program, the facility program and individual pass rates have improved from 81 to 90 percent and from 83 to 91 percent, respectively, through fiscal year 1991.
The NRC has also observed a general improvement in the quality of the facility licensees' testing materials and in the performance of their operating test evaluators. Of the first 79 program evaluations conducted, 10 programs were i
evaluated as unsatisfactory.
The NRC issued Information Notice No. 90-54,
" Summary of Requalification Program Deficiencies," dated August 28, 1990, to 1
describe the technical deficiencies that contributed to the first 10 program failures.
Since that time only 6 programs, of 120 subsequent program evaluations, have been evaluated as unsatisfactory.
Pilot requalification examinations were conducted during the period August through December 1991.
The pilot test procedure directed the NRC examiners to focus on the evaluation of crews, rather than individuals, in the simulator portion of the operating test.
In conducting the pilot examinations, the NRC examiners and the facility evaluators independently evaluated the crews and compared their results.
The results were found to be in agreement.
Furthermore, the NRC examiners noted that the facility evaluators were competent at evaluating crews and individuals and were aggressive in finding deficiencies and recommending remedial training for operators who exhibited weaknesses. The performance of the facilities' evaluators during the pilot examinations further confirmed that the facility 4
i licensees can find deficiencies, provide remedial training, and retest their licensed operators appropriately.
)
l In June 1992, the Commission agreed with the staff to proceed with initiation of rulemaking to eliminate the requirement for each licensed operator to pass a comprehensive requalification written examination and operating test administered by the Commission during the term of the operator's 6-year license.
On December 28, 1992, proposed amendments to l
10 CFR Part 55 on renewal of licensees and requalification requirements for i
licensed operators were submitted to the Commission for approval.
On May 20, 1993 (58 FR 29366), the Commission published a proposed rule in the Federal Register to amend 10 CFR Part 55. The proposed amendments were to:
1.
Delete the requirement that each licensed operator pass an NRC-administered requalification examination during the term of his or her i
I license.
2.
Require that facility licensees submit to the NRC their annual requalification operating tests and comprehensive requalification written examinations at least 30 days prior to the conduct of these tests and examinations.
i l
3.
Include " Facility Licensees" in the " Scope" of Part 55.
l The period for public comment on the proposed amendments ended on l
July 20, 1993.
Summary of Public Comments The NRC received 42 comments on the proposed rule.
Based on analysis of these comments, several changes have been made in the final rule.
A l
5 l
summary of the public comments and, where appropriate, a description of the changes that resulted from them is discussed for each of the proposed amendments to 10 CFR Part 55.
1.
Procosed Amendment: Delete the requirement that each licensed operator pass an NRC-administered requalification examination during the term of a licensed operator's 6-year license.
General Statement:
Of the 42 comments received, 36 favored this proposed amendment and 6 opposed its adoption.
Most of the respondents who favored the proposed change based their support on the expectation that this change would reduce the regulatory burden on licensees and would improve operational safety at nuclear facilities. One respondent indicated that while the NRC's involvement has had a positive impact on the content and conduct of license requalification, utilities have proven their ability to develop and administrator requalification examinations that meet the requirements of 10 CFR 55.59(a)(2)(iii).
Another respondent representing the utility industry stated that, "We believe the performance-based inspection process will be an effective means for ensuring high quality operator requalification programs."
This respondent further stated, "The proposed rule change will also afford better operating crew continuity.
Because personnel changes occur over time, operating crews may be configured with individuals who have or have not had an NRC administered exam.
In the past, it has been a common practice to reconfigure crews to accommodate the NRC administered requalification examination by putting together individuals whose 6 years is about to end.
Use of this practice to facilitate the conduct of requalification exams may not be in the best interest of crew coordination and teamwork."
The six comments in opposition to the proposed change to delete the NRC-6
conducted requalification examination varied in content.
For example, two public citizen respondents were against a rule change of any kind on the basis it would give the public the perception that the NRC's authority over the operation of power and non-power reactor plants would be weakened. Two respondents, one representing a State public service department with over-l sight of a nuclear power plant and a second representing a State nuclear safety department, urged that from a defense-in-depth standpoint to reactor safety the proposed rule should be reconsidered. The State of Vermont, in two separate comments, indicated that it was because of the current regulation that the NRC was able to detect the unsatisfactory requalification program at l
l l
Vermont Yankee and identify corrective actions to ensure safety of the plant.
l The State of Illinois contended that the current regulations provided incentive for licensees to maintain quality operator training programs and 1
that the likelihood of further improving or even maintaining that quality without the periodic independent involvement by the NRC is unlikely.
The State of Illinois recommended a combination of routine NRC inspections of crew examinations on a plant simulator and a periodic independent test administered simultaneously to all licensed operators every 6 years.
Finally, one respondent was opposed to this amendment, especially its application to test and research reactors and suggested the existing rule be deleted because the regulatory analysis for the 1987 rule stated that the rule would not apply to i
non-power reactors (NPR).
This same respondent believed it important to maintain NRC staff competence in relation to NPR operator licensing and felt this could be accomplished by maintaining a nucleus of specialized qualified personnel, either as part of or in conjunction with the NPR directorate, and through specialized training and administration of initial examinations, which 7
t occur rn her frequently.
Response: After reviewing the six comments opposing the proposed regulation, the Commission has concluded that the basis for this requirement remains sound and that it should be adopted. This determination is based on the following considerations:
(i)
The NRC believes that since the beginning of the requalification program, experience indicates that weaknesses in implementation of facility licensee's programs are generally the root cause of deficiencies in the l
performance of operators.
(ii) The NRC believes if its resources were directed towards inspection and oversight of facility licensee's requalification programs rather than continuing to conduct individual operator requalification examinations, the l
operational safety at each facility will continue to be ensured and in fact, 1
will be improved.
A routine inspection frequency of once per SALP cycle will ensure consistency between inspection scheduling and licensee performance. A minimum inspection frequency of at least once every 2 years will ensure active NRC oversight of facility licensee's requalification programs.
(iii) The NRC believes that the facility requalification programs have been demonstrated to be basically sound during the pilot examinations.
Given the broad range of possible approaches built into the inspection process, the NRC would only conduct examinations when they are the most effective tool to evaluate and understand the programmatic issues, or if the NRC loses confidence in the facility licensee's ability to conduct its own examinations.
Examples which could result in a regional management decision for a "for I
cause" requalification examination include:
a.
Requalification inspection results which indicate an ineffective 8
i l
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licensee requalification program; b.
Operational problems for which operator error is a major contributor; I
c.
A SALP Category 3 rating in plant operations attributed to operator performance; and d.
Allegations regarding significant training program deficiencies.
When conditions such as these exist, the NRC may initiate planning to conduct requalification examinations during the next annual examination cycle scheduled by the facility.
Regarding the comments from the State of Vermont, the proposed inspection program includes reviews, observations, and parallel grading of selected operating tests and written examinations by NRC examiners, reviews of 2
operational performance, interviews of facility personnel, and a general inspection of the facility licensee's implementation of its.requalification training program. Application of the inspection program in the case'of Vermont Yankee would have disclosed discrepancies in evaluation of operator performance and also would have allowed insight to other, more programmatic, l
deficiencies.
The requalification inspection program. implements routine NRC l
inspections as recommended by the State of Illinois as well as "for cause" examinations.
The Commission believes the existing regulation should not be deleted in the case of non-power reactors, as recommended in the public comments.
A i
continuing need exists for the regulation to apply to operators of all types of reactors. The proposed amendment will continue to ensure operational i
safety at non-power reactors by inspecting facility requalification programs l
l rather than conducting requalification examinations. The NRC will maintain 9
t I
examiner proficiency by conducting examinations for initial license applicants.
2.
Prooosed Amendment:
Require that facility licensees submit to the NRC their annual requalification operating tests and comprehensive requalification written examinations at least 30 days prior to conducting these tests and examinations.
General Statement:
Of the 42 comments received, only I respondent favored the amendment as proposed.
This response came from a university I
l operated research reactor, stating that submitting requalification examinations by the facility to the NRC for review prior to administering the examination was less burdensome, by comparison, than retaining the existing regulation. On the other hand, most respondents stated that submitting all examinations and tests to the NRC 30 days before their administration would i
place an undue burden on facility licensees and the NRC with little return on the investment. Several respondents offered alternatives that included shortening the lead time, requiring that the examinations and tests be submitted after they are administered, submitting the question banks from which the examinations are developed, and simply having the examinations available for on-site inspection.
Response
This requirement was included in the proposed regulation so that the NRC could evaluate the proposed examination materials, in conjunction with other information already available to the NRC, to determine the scope of the on-site inspection.
However, the pilot inspection program has demonstrated that a facility's proposed examinations are not an absolute necessity in preparing for the on-site activities.
In addition, those facility licensees' examination and simulator scenario banks that were 10
evaiuated were found to be adequate for an effective requalification program to be managed by the licensees' staffs. Although being able to review the proposed examinations at the NRC did save some on-site inspection eff at, the i
l inspectors were still able to complete the Temporary Inspection procedures within the time allowed (i.e., two inspectors on-site for 1 week).
i The NRC believes that it will be advantageous to have selected examinations (which may include proposed examinations) available for review at NRC offices in addition to other documentation customarily provided, 1
consistent with the Commission's inspection program needs to prepare for the on-site portion of the inspection. Therefore, the NRC will delete the 4
amendment to 6 55.59(c) as proposed from the final rulemaking and will require instead that comprehensive written examinations or operating tests be submitted upon request consistent with the Commission's inspection program needs and sustained effectiveness of the facility licensee's examination and i
simulator scenario banks.
During the SALP cycle for each licensee, the NRC expects it will request examinations or tests in advance for every on-site inspection.
l 3
l 3.
Proposed Amendment:
Include facility licensees in the scope of 10 CFR 55, specifically 9 55.2, will be revised to include facility i
l licensees.
General Statement:
Only 1 of the 42 respondents to the FRN addressed and endorsed this provision of the proposed rulemaking.
Response: The NRC believes the absence of comments regarding this e
proposal substantiates the NRC's position that this is simply an administrative correction and does not materially change the intent of the regulation.
The NRC considers this amendment as an administrative addition to 11 4
these regulations.
The NRC proposed this change to eliminate the ambiguities between the regulations of Parts 50 and 55.
Section 50.54(i) through (m) already imposes Part 55 requirements on facility licensees, and Part 55 already specifies requirements for facility licensees.
On this basis, the NRC has determined that the requirement should be adopted.
Finding of No Significant Environmental Impact: Availability The Commission has determined that under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in Subpa-t A of 10 CFR Part 51, that this rule is not a major Federal Action significantly affecting the quality of the human environment and therefore, an environmental impact statement is not required.
Paperwork Reduction Act Statement This final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
i These requirements were approved by the Office of Management and Budget, approval number 3150-0101.
The rule will relax exi iag.nformation collection requirements for the separately cleared, " Reactor Operator and Senior Reactor Operator Licensing Training and Requalification Programs." The public burden for this collection I
of information is expected to be reduced by 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> per licensee.
This reduction includes the time required for reviewing instructions, searching 1
12 l
~
existing data sources, gathering and maintaining the data needed and l
completing and reviewing the collection of information.
Send comments regarding the estimated burden reduction or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch (MNBB-7714), U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and to the Desk Officer, Office of Information and Regulatory Affairs, NE08-3019, (3150-0101), Office of Management and Budget, Washington, DC 20503.
s Regulatory Analysis The Commission has prepared a regulatory analysis on this regulation.
The analysis examines the values (benefits) and impacts (costs) of implementing the regulation for licensed operator requalification.
The analysis is available for inspection in the NRC Public Document Room,-
2120 L Street, NW (Lower Level), Washington, DC.
Single copies of the analysis may be obtained from Anthony DiPalo, Division of Regulatory Applications, Office of Nuclear Regulatory Research, U. S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 492-3784.
Regulatory Flexibility Certification As required by the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b),
j the Commission certifies that this rule will not have a significant economic impact upon a substantial number of small entities.
This rule primarily affects the companies that own and operate light-water nuclear power reactors 13
j 4
and non-power research reactors.
The companies that own and operate these reactors do not fall within the scope of the definition of "small entity" set forth in the Regulatory Flexibility Act or the Small Business Size Standards set out in regulations issued by the Small Business Administration in 13 CFR 4
Part 121.
I Backfit Analysis The staff believes that it could ensure and improve operational safety
}
at each facility by directing its resources to inspect and oversee facility
)
requalification programs rather than conducting requalification examinations.
The staff's experience since the beginning of the requalification program indicates that weaknesses in the implementation of the facility programs are generally the root cause of significant deficiencies in the performance of licensed operators.
The staff could more effectively allocate its resources to perform on-site inspections of facility requalification examination and 4
]
training programs in accordance with indicated programmatic performance rather than scheduling examiners in accordance with the number of individuals
^
requiring license renewal.
By re-directing the examiner resources, the staff expects to find and correct programmatic weaknesses earlier, and thus improve operational safety.
Currently, facility licensees assist in developing and coordinating the NRC-conducted requalification examinations.
The assistance includes providing to the NRC the training material used for development of the written examinations and operating tests and providing facility personnel to work with the NRC during the development and conduct of the examinations. The 14
l Commission has concluded on the basis of the analysis required by 10 CFR Part 50.109, that complying with the requirements of this final rule would reduce the regulatory burden on the facility licensees by reducing the effort expended by the facility licensees to assist the NRC in developing and conducting NRC requalification examinations for licensed operators. A smaller increase in regulatory burden is anticipated due to a need for the facility licensee to provide data and support for periodic requalification program inspections.
As part of the final rule, facility licensees shall have a requalification program reviewed and approved by the Commission and shall, upon request consistent with the Commission's inspection program needs, submit a copy of its comprehensive written examinations or annual operating tests to the Commission. The NRC has determined that the pilot inspection program demonstrated that the facility's proposed examinations are not an absolute necessity in preparing for the on-site activities. Therefore, the NRC would request test submittal on a case-by-case basis consistent with the Commission's test inspection program needs and review these examinations for conformance with 10 CFR 55.59(a)(2)(iii).
The NRC would continue to expect each facility to meet all of the conditions required of a requalification program in accordance with 10 CFR 55.59(c).
Licensed operators would not have to take any additional actions.
Each operator would be expected to continue to meet all the conditions of his or her license described in 10 CFR 55.53, which includes passing the facility requalification examinations for license renewal.
Each licensed operator would be expected to continue to meet the requirements of the facility requalification training program.
However, the licensed operator would no 15 l
i i
longer be required to pass a requalification examination conducted by the NRC 1
during the term of his or her license in addition to passing the facility i
^
licensee's requalification examinations, as a condition of license renewal.
]
The " Scope" of Part 55,10 CFR 55.2, would be revised to include
]
facility licensees.
This is an administrative addition to these regulations.-
It eliminates currently existing ambiguities between the regulations of Parts j
50 and 55.
Part 50, in 950.54(i) through (m), already imposes Part 55
)
requirements on facility licensees, and Part 55 already specifies requirements for facility licensees.
The Commission believes that licensed operators are one of the main components and possibly the most critical component of continued safe reactor operation, especially with respect to mitigating the consequences of emergency conditions. Two-thirds of the requalification programs that have been evaluated as " unsatisfactory" had significant problems in the quality or implementation of the plant's emergency operating procedures (EOPs).
In some of these cases, the facility licensees did not train their operators on challenging simulator scenarios or did not retrain their operators after the -
E0Ps were revised.
The Commission believes that it could have' identified i
these problems sooner by periodic inspection of facility requalification training and examination programs.
Facility licensees could have then corrected these problems and improved overall operator job performance sooner.
This final rule will improve operational safety by providing the staff direction to find and correct weaknesses in facility licensee requalification programs. The experience gained from conducting NRC requalification examinations indicates that the NRC is largely duplicating the efforts of the facility licensees to maintain a high standard of operator performance. The 16 j
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.....j
NRC could now, by amending the regulations, more effectively use its resources i
to oversee facility licensee requalification programs rather than conducting individual operator requalification examinations.
In FY92 the NRC resources committed to this program for NRC staff and contractor support were approximately 12 FTE and $1.3 million (equivalent to 8 FTE), respectively.
The staff projects that a slightly larger average number of examinations, requiring approximately 1.5 additional staff FTE and an additional $200,000 contractual support (equivalent to 1.25 FTE), would be conducted in future years if the NRC continues conducting requalification examinations for all licensed operators.
Thus, if it is assumed that without the rule change, this program would continue into the future, the relevant baseline NRC burden would approximate $2.85 (1.35 NRC + 1.5 contractor) million per year in 1992 dollars for FY93 through FY97.
The 13.5 (12 + 1.5) NRC staff years (FTE) were I
converted to $1.35 million ($100,000 per staff year) based on allowances for i
composite wage rates and direct benefits.'
t Under the final rule change, NRR's analysis indicates that NRC staff could perform all necessary inspections of requalification exam programs with 11 NRC FTEs and $300,000 in contractor support, equivalent to 1.85 contractor FTEs, per year. At $100,000 per NRC FTE and $162,000 per contractor FTE, this converts to an annual cost in 1992 dollars of $1.4 million. Thus, the annual
'NRC labor costs presented here differ from those developed under the NRC's license fee recovery program.
For regulatory analysis purposes, labor costs are developed under strict incremental cost principles wherein only variable costs that are directly related to the development, implementation, and operation and maintenance of the proposed requirement are included. This-approach is consistent with guidance set forth in.NUREG/CR-3568, "A Handbook for Value Impact Assessment," and general cost benefit methodology.
Alternatively, NRC labor costs for fee recovery purposes are appropriately designed for full cost recovery of the services rendered and, as such, include non-incremental costs (e.g. overhead and administrative and logistical support costs).
17
- - ~ - -
i i
savings in NRC operating costs is estimated to be on the order of j
j
$1.45 million ($2.85 million less $1.4 million).
Over an assumed 25-year i
remaining life, based on a 5% real discount rate, the 1992 present worth savings in NRC resources is estimated at about $20.25 million in 1992 dollars.
Each facility licensee would continue in its present manner of conducting its licensed operator requalification program.
However, this final rule reduces the burden on the facility licensees because each facility J
licensee would have its administrative and technical staff expend fewer hours than are now needed to assist in developing and conducting the NRC j
requalification examinations.
Facility licensees are expected to realize a combined annual operational cost savings of approximately $1.24 million.
Over an assumed 25-year remaining life, based on a 5% real discount rate, the 1992 present worth industry savings is estimated at about $17.48 million in 1992 dollars.
In summary, the final rule will result in improved operational safety by providing more timely identification of weaknesses in facility licensees' requalification programs.
In addition, the final rule would also reduce the resources expended by both the NRC and the licensees.
The Commission has, therefore, concluded that the final rule meets the requirements of
[
j 10 CFR 50.109, that there would be a substantial increase in the overall 1
protection of public health and safety and the cost of implementation is justified.
i i
J List of Subjects 10 CFR Part 55 Criminal penalty, Manpower training programs, Nuclear power plants and 18 1
I
reactors, Reporting and record-keeping requirements.
For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended; the Energy Reorganization Act of 1974, as amended; the Nuclear Waste Policy Act of 1982; c,d 5 U.S.C. 552 and 553; the NRC is adopting the following amendments to 10 CFR Part 55 as follows:
PART 55 - OPERATORS' LICENSES 1.
The authority citation for 10 CFR Part 55 continues to read as follows:
AUTHORITY: Secs. 107, 161, 182, 68 Stat. 939, 948, 953, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2137, 2201, 2232, 2282); secs. 201, as amended, 202, 88 Stat. 1242, as amended, 1244 (42 U.S.C. 5841, 5842).
Hs 55.41, 55.43, 55.45, and 55.59 also issued under sec. 306, Pub. L.97-425, 96 Stat. 2262 (42 U.S.C. 10226).
6 55.61 also issued under i
secs. 186, 187, 68 Stat. 955 (42 U.S.C. 2236, 2237).
2.
In 5 55.2, paragraph (c) is added to read as follows:
1 1 55.2 Scope (c)
Any facility licensee.
1 55.57 IAmendedl 3.
1 55.57(b)(2)(iv) is amended by removing paragraph (b)(2)(iv).
4.
In 1 55.59 the introductory text of paragraph (c) is revised to read as follows:
19
4 4
s 55.59 Reoualification
{c)
Requalification program requirements. A facility licensee shall have a requalification program reviewed and approved by the Commission and shall, upon request consistent with the Commission's inspection program needs, submit to the Commission a copy of its comprehensive requalification written examinations or annual operating tests.
The requalification program must meet the requirements of paragraphs (c)(1) through (7) of this section.
In lieu of paragraphs (c)(2), (3), and (4) of this section, the Commission may approve a program developed by using a systems approach to training.
Dated at Rockville, Maryland, this day of
, 1993.
For the Nuclear Regulatory Commission.
Samuel J. Chilk, Secretary of the Commission.
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00C. FILE NAME:
G:\\DIPALO\\PT55\\FRN55.FNL LONG DISPLAY:
Operators' Licenses CREATED:
AUTHOR:
A. DiPalo REVISED:
7/29/93 7/30/93 7/30/93 8/5/93 8/12/93 TYPIST:
jw jw jw jw jw TIME:
2:30pm ll:30am 5:30pm 2:45 pm 10:10am 8/16/93 9/1/93 10/1/93 10/4/93 11/5/93 jW jW jW jW jW 9:45 am 2:10pm 5:30pm 1:50pm 10:30am
[7590-01]
NUCLEAR REGULATORY COMMISSION 10 CFR Part 55 RIN-AE 39 Operators' Licenses AGENCY: Nuclear Regulatory Commission.
i ACTION:
Final rule.
j
SUMMARY
- The Nuclear Regulatory Commission (NRC) is proposing to amend its regulations to delete the requirement that each licensed operator pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a condition for license renewal.
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4 9
y-REGULATORY ANALYSIS
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REGULATORY ANALYSIS of FINAL RULE CHANGE to 10 CFR Part 55 RENEWAL OF LICENSES AND REQUALIFICATION REQUIREMENTS FOR LICENSED OPERATORS October 30, 1993 1
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TABLE OF CONTENTS
SUMMARY
i ABBREVIATIONS ii
1.0 INTRODUCTION
1.1 BACKGROUND
I 1.2 STATEMENT OF THE ISSUE 1
1.3 OBJECTIVES..............................
2 2.0 REGULATORY ALTERNATIVES 3
2.1 TAKE NO ACTION............................
3 2.2 PROPOSED ACTION 3
3.0 CONSEQUENCES.............................
5 3.1 ESTIMATION OF VALUES (SAFETY-RELATED CONSEQUENCES).......
5 3.2 ESTIMATION OF IMPACTS (ECONOMIC CONSEQUENCES)
.........6 3.2.1 Onsite Property and Industry Implementation Costs 6
3.2.2 Industry Operation Costs................ 6 3.2.3 NRC Development Costs 10 3.2.4 NRC Implementation Costs...............
11 3.2.5 NRC Operation Costs 12 3.3 VALUE-IMPACT ASSESSMENT
SUMMARY
12 3.4 IMPACT ON OTHER REQUIREMENTS.................
12 4.0 DECISION RATIONALE.........................
12 5.0 IMPLEMENTATION SCHEDULE......................
13
6.0 REFERENCES
13
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i
SUMMARY
In 1987, the NRC amended 10 CFR Part 55 to add requirements for the requalification and renewal of operators' licenses. The regulations required i
licensed operators to pass facility requalification examinations and annual i
operating tests.
In addition, the avended regulations required licensed operators to pass a comprehensive requalification written examination and operating test conducted by the NRC during the term of a 6-year license.
Prior to 1987, NRC regulation did not require facility licensees to conduct continuous and rigorous examinations and training regulations programs for operators' licenses.
t This additional requirement was.added because at the time the regulation.was t
amended, the NRC did not have sufficient confidence that _ ears facility would conduct its annual operating tests and written examinations in accordance with the NRC's expectations. The lack of confidence was due to the implementation of new aspects of the operator requalification program with which neither the l
NRC nor the industry had very much experience.
The new aspects included.
- 1) changing from a 2-year to a 6-year license term resulting in license renewal applications being submitted for NRC review much less frequently;
- 2) requiring operating tests on simulators when most of the industry's simulators were either new or still under construction; and 3) permitting i
requalification programs to be based on a systems approach to training when i
the indusuy had not implemented the process for accrediting these programs.
After conducting these examinations over a 3-year period, however, NRC now has the confidence that facility licensees can successfully implement their own requalification programs. As a result, the NRC is amending the current requalification regulations in 10 CFR Part 55.
It is now believed that rather than requiring NRC-conducted requalification examinations, NRC can ensure safety and more nffcetively use its resources by periodically inspecting the licensee's requalification program.
The final rulemaking, which would eliminate the need for each licensee to pass an NRC J
requalification examination, is intended to ensure and improve the continued effectiveness of the Part 55 requalification requirements.
The NRC is expected to incur one-time costs associated with development and implementation of the final rulemaking.
These one-time NRC costs are estimated to total approximately $200,000.
If the NRC' continues conducting requalification examinations for all licensed operators, the staff estimates that it would require 22.7 FTE (13.5 NRC + 9.2 contractor) each year.
Implementing the final requalification inspection program would save 9.9 FTE (2.5 NRC + 7.4 contractor), equivalent to $1.45 million each year.
Facility licensees are expected to realize a combined annual operational cost savings of $1.24 million. On a 1992 present wortt basis, assuming an average 25-year remaining lifetime and a 5% real discount rate, the NRC and indetry savings are equivalent to $20.25 million and $17.43 million, respectively.
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f ABBREVIATIONS CFR - Code of Federal Regulations FR - Federal Register FY - Fiscal Year i
NRC - U.S. Nuclear Regulatory Commission d
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]
l.0 INTRODUCTION The NRC is amending the current requalification regulations for nuclear power reactor operating personnel contained in 10 CFR Part 55.
Section 1 of this Regulatory Analysis includes background information, a discussion of the existing operator requalification examination requirements in 10 CFR Part 55, a statement of the issue, and the objectives of the final rulemaking.
Section 2 identifies and discusses the proposed action and the alternative actions.
Section 3 discusses the projected benefits and estimates the costs i
associated with adopting the final rulemaking.
Section 4 provides the decision rationale and Section 5 discusses the implementation schedule.
1.1 BACKGROUND
i Section 306 of the Nuclear Waste Policy Act of 1982 (42 USC 10226, Public. Law 97-425, January 7, 1983) authorized and directed the U.S. NRC to promulgate regulations or other appropriate regulatory guidance for the training and qualifications of civilian nuclear power plant operators.
The regulations or regulatory guidance were required to establish, among other things, requirements governing the NRC's administration of requalification examinations.
The NRC accomplished this objective by revising 10 CFR Part 55, to add i 55.59(a)(2)(iii) to provide that the NRC could conduct a comprehensive requalification written examination and operating test in lieu of accepting certification that the licensee had passed written examinations and operating tests conducted by the facility.
The NRC also developed guidance for examiners to conduct NRC requalification examinations.
In SECY-86-348, dated November 21, 1986, the NRC described the revisions that it made to 10 CFR Part 55 in response to Section 306 of the Nuclear Waste Policy Act.
On February 12, 1987, the Commission approved the proposed amendments in SECY-86-348, adding the requirement in 10 CFR 55.57(b)(2)(iv) for each licensee to pass an NRC-conducted requalification examination during the 6-year term of the individual's license.
1.2 STATEMENT OF THE ISSUE In 1987, the NRC amended 10 CFR Part 55 to add requirements for the requalification and renewal of operators' licenses.
In accordance with 5 55.57(b)(2)(iii), licensed operators are required to pass facility requalification examinations and annual operating tests.
In 9 55.57(b)(2)(iv), licensed operators are also required to pass a comprehensive requalification written examination and operating test conducted by the NRC during the term of a 6-year license.
These regulations establish requirements that impose a dual responsibility on both the facility licensee, i
which assists in developing and conducting its own as well as NRC requalification examinations, and the NRC which supervises the facility licensee requalification program and conducts a comprehensive requalification i
examination during the term of an operator's 6-year license.
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Before 1987, NRC regulations did not require facility licensees to conduct continuous and rigorous examinations and training and requalification 1
l
programs. As a result, the Commission did not have confidence that each facility would conduct its annual operating tests and written examinations in accordance with the staff's expectations.
The lack of confidence was due to which neither the NRC nor the industry had very much experience.
The new the implementation of new aspects of the operator requalification program with aspects included: 1) changing from a 2-year to a 6-year license term resulting in license renewal applications being submitted for NRC review much less frequently; 2) requiring operating tests on simulators when most of the industry's simulators were either new or still under construction; and 3) permitting requalification programs to be based on a systems approach to training when the industry had not implemented the process for accrediting these programs.
As a result, the NRC determined that during the first term of a 6-year license issued after the 1987 amendment to Part 55, the NRC would conduct requalification examinations of operators for the purpose of license renewal.
As a result of conducting these examinations over a 3-year period, it has been determined that the NRC examiners are largely duplicating the tasks already required of, and routinely performed by, the facility licensees. The final rulemaking is therefore being considered to ensure and improve the continued effectiveness of the Part 55 requalification requirements.
If the NRC adopts the final rulemaking and deletes the requirement for each licensed individual to pass an NRC requalification examination during the 6-year term of the individual's license, the regulations in 10 CFR 55.57,
" Renewal of Licenses," and 10 CFR 55.59, "Requalification," will continue to meet the requirements of Section 306 of the Nuclear Waste Policy Act (I C A).
The regulations will continue to require facilities to have requalification programs and conduct requalification examinations.
The NRC will administer these programs by providing oversight for the programs through inspections.
In addition, 9 55.59(a)(2)(iii) provides that the NRC may conduct requalification examinations in lieu of accepting the facility licensee's certification that a licensed individual has passed the facility requalification examination.
The NRC will use this option if warranted after conducting an onsite inspection of the facility's requalification program. The final rule would not affect the regulatory and other appropriate guidance required by Section 306 of the NWPA and described in s 55.59(a)(2)(iii) for administering NRC requalification examinations in lieu of facility examinations.
1.3 OBJECTIVES The objective of the final rulemaking is to improve the effectiveness of the current regulations for operator requalification and renewal of operators' licenses.
The current regulations, which were amended in 1987, require licensed operators to pass a comprehensive requalification written examination and operating test administered by the NRC during the term of a 6-year license.
At the time the regulation was amended in 1987, the NRC did not have confidence that each facility would conduct its annual operating tests and written examinations in accordance with the NRC's expectations. The lack of 2
confidence was due to the implementation of new aspects of the operator requalification program with which neither the NRC nor the industry had very much experience.
The new aspects included:
- 1) changing from a 2-year to a 6-year license term resulting in license renewal applications being submitted for NRC review much less frequently; 2) requiring operating tests on simulators when most of the industry's simulators were either new or still under construction; and 3) permitting requalification programs to be based on a systems approach to training when the industry had not implemented the process for accrediting these programs.
The experience gained from conducting these examinations over a 3-year period indicates that the existing regulations have established a high standard of licensee performance and that the NRC is largely duplicating the efforts of the facility licensees.
Further, the industry has since developed criteria for accrediting licensed operator requalification programs at facilities.
Based on this experience, NRC now has the confidence that facility licensees can implement their own requalification program in accordance with 10 CFR 55.59(c)(4). As a result, it is now believed that rather than conducting these requalification examinations, NRC can ensure safety and more effectively use its resources by periodically inspecting the licensee's requalification program.
2.0 REGULATORY ALTERNATIVES This section discusses the reasonable alternatives considered for meeting the regulatory objective identified in Section 1.3.
2.1 TAKE NO ACTION One alternative to the final rule changes would be to take no action.
Taking no action would allow current licensed operator requalification practices to continue.
However, this alternative would disregard the insights gained from conducting the NRC requalification examinations over a 3-year period.
This alternative also neglects consideration of the industry-related progress that has been made over the past several years in the area of operator requalification programs.
2.2 PROPOSED ACTION The regulations must be amended in two places to implement the proposed rule change.
First, delete 10 CFR 55.57(b)(2)(iv) requiring each licensed individual to pass an NRC-conducted requalification examination during the term of his or her license.
Second, amend 10 CFR 55.59(c) to require a facility licensee to submit to the Commission, upon request consistent with the Commission's inspection program needs, a copy of its comprehensive written examinations or annual operating tests.
These actions will ensure that the level of safety for plant operations is maintained and even improved, and remove the dual responsibility of the facility licensee and the NRC for the conduct of licensed operator requalification examinations, i
3
I In addition, 10 CFR 55.2, " Scope," will be revised to include facility licensees.
This will eliminate the currently existing ambiguities between the regulations of Part 50 and 55.
Part 50, in ls 50.54(i) through (m), already
)
imposes Part 55 reqlirements on facility licensees and Part 55 already specifies requirements for facility licensees.
Licensed operators would not be required to take any additional actions.
Each operator would continue to meet all the conditions of his or her license described in 10 CFR 55.53, which includes passing the facility requalification examinations for license renewal.
However, the facility licensees would be required to submit, upon request consistent with the Commission's inspection program needs, a copy of its annual operating tests or comprehensive written examinations used for operator requalification to the Commission for review.
The NRC would review these examinations for conformance with 10 CFR 55.59(a)(2),i&ii).
The NRC would conduct this review and review other information already available to the NRC to determine the scope of an onsite inspection of the facility requalification program.
The NRC would continue to expect each facility to meet all of the conditions required for conducting a requalification program in accordance with 10 CFR 55.59(c).
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3.0 CONSEQUENCES This section discusses the benefits and costs that may result from the final i
4 rulemaking.
The benefits and costs of the final rulemaking are compared with those associated with the status quo using the current regulations as a 1
i i
baseline.
Table 3.1 identifies the potential effects associated with the l
final rulemaking.
)
As described in Section 2.2, the proposed action involves two distinct i
regulatory amendments.
However, the dominant consequences (both in terms of values and impacts) of the proposed action are associated with the amendment l
which eliminates the requirement for licensed individuals to pass NRC-conducted requalification examinations.
The consequences of the second i
amendment, which requires exams and annual operating tests, are considered relatively insignificant.
Therefore, although the proposed action involves j
two distinct regulatory amendments, the consequences of these two amendments are evaluated together.
As a result, the values and impacts identified in this Section and summarized in Tables 3.2 and 3.3 represent the consequences of the complete regulatory action.
Table 3.1. Checklist for Identification of Potential Effects No Quantified Qualitative Significant i
Potential Effect Chance Chance Chance I
Public Health & Safety X
Public Property X
1 Occupational Health & Safety X
4 Industry Property X
i Industry Implementation Costs X
Industry Operation Costs X
i NRC Development Costs X
NRC Implementation Costs X
NRC Operation / Review Costs X
i Regulatory Effectiveness X
Reauced Regulatory Burden X
1 2
3.1 ESTIMATION OF VALUES (SAFETY-RELATED CONSE0VENCES)
The benefits of the final rulemaking are evaluated in terms of the general objectives stated in Section 1.3, namely, to ensure safety and improve the effectiveness of the NRC examiner resources.
These benefits are not readily quantifiable and, as a result, are discussed here qualitatively. The primary qualitative benefits associated with the final rulemaking accrue from increased effectiveness of the NRC examiner resources.
The staff's experience since the beginning of the requalification program indicates that the weaknesses in the implementation of the facility program 4
are generally the root cause of significant deficiencies in the performance of 5
1 a
i licensed operators.
The performance on NRC-conducted examinations of licensed operators who have participated in comprehensive facility requalification l
programs has been very good.
The failure rate of individual licensed operators was 9% in FY91.
The FY92 failure rate of individual licensed i
operators was 7%.
Based on this experience, it is believed that NRC examiner resources could be more effectively used to perform onsite inspections of facility l
requalification examination and training programs in accordance with indicated programmatic performance rather than scheduling examiners in accordance with the number of individuals requiring license renewal.
By redirecting the NRC examiner resources toward facility programs rather than individuals, programmatic weaknesses should be identified and corrected more rapidly.
The final regulatory action directing the NRC examiners to inspect and oversee facility requalification programs rather than conducting requalification examinations would ensure that licensed individuals and operating crews are qualified to safely operate the facility and that operational safety would be improved at each facility.
3.2 ESTIMATION OF IMPACTS (ECONOMIC CONSE0VENCES)
The final rule would reduce the burden on the facility licensee because the administrative and technical staff would expend fewer hours than are now required to assist in developing and conducting the NRC requalification examination.
Similarly, a net savings would accrue to the NRC due to the elimination of most NRC requalification examinations.
In estimating the impact of the final regulatory action, the following types of costs were considered.
For the industry, costs include onsite property costs, implementation costs, and operation costs.
For the NRC, costs include development costs, implementation costs, and operation costs.
i 3.2.1 Onsite Property and Industry Imolementation Costs Because the final rule is expected to have no significant impact on the accident frequency, there is no expected impact on potential onsite property damage.
Similarly, since implementation of the final rulemaking does not i
require licensees to purchase special equipment or materials, nor does it involve additional facility labor requirements, there are no expected industry implementation costs.
3.2.2 Industry Operation Costs Under the current regulations, facility licensees provide assistance to the NRC in the development and conduct of the NRC requalification examinations.
This assistance includes providing to the NRC the training materials used for 1
development of the written and operating examinations.
In addition, the current regulations require that an examination team made up of NRC examiner and facility evaluators co-conduct, validate, and co-supervise the NRC examinations to ensure that the NRC examinations are valid and appropriate for the facility at which the examinations are being given.
6
The labor burden and amount of material that each facility licensee currently provides to the NRC for the routine NRC requalification examinations is expected to be larger than the amount projected under the proposed regulatory action.
Under the final rulemaking, each facility licensee is expected to continue in its present manner of conducting requalification training programs.
However, adopting the final rulemaking would reduce the regulatory burden on the facility licensees by removing the dual effort expended by the facility to assist the NRC in developing and conducting NRC requalification examinations for all licensed operators.
As a result, fewer hours would be expended by its technical and administrative staff which are now required to assist in developing and conducting the NRC requalification examination.
Table 3.2 provides a summary of the estimated current industry costs associated with the NRC requalification examinations.
Table 3.3 provides a summary of the estimated industry costs associated with the NRC requalification program inspections after implementation of the final rulemaking.
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l Table 3.2. Affected Current Industry Costs (per NRC examination) i
. Cost Element Best Estimate ($1 SALARIES AND BENEFITS Facility administrative staff 1,000' (to prepare reference materials for NRC)
Facility technical staff 28,800' (to assist NRC with developing and conducting the NRC examinations)
Facility administrative staff 1,000 (to assist NRC with conducting the NRC examinations)
Totdl Direct Salaries 30,800 l
MATERIALS AND SERVICES Expendable Supplies 100 (tc provide the NRC all the material used for development of the written
~
anc operating examinations)
Reproduction Expenses 100 Shipping Expenses 1,000 Total Materials and Services 1,200 j
TOTAL FACILITY COSTS TO SUPPORT NRC EXAMINATIONS 32,000 l
l
- 20 person-hours @ $50/ person-hour.
The value of $50/ person-hour is rounded from the standard labor rate of $48/ person-hour from the most recent draft of the Reaulatorv-Analysis Technical Evaluation Handbook.
2576 staff-hours @ $50/ hour 8
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Table 3.3.
Affected Industry Costs (per NRC inspection) After final Changes Cost Element Best Estimate ($)
- SALARIES AND BENEFITS Facility administrative staff 750' (to prepare inspection materials for NRC)
Facility technical staff 14,400*
(to assist NRC in the inspection of the facility requalification program)
Facility administrative staff 1,000' (to assist NRC in the inspection of the facility requalification program)
Total Direct Salaries 16,150 MATERIALS AND SERVICES l
Expendable Supplies 50 (to provide the NRC all the material used for inspection of the facility requalification program)
Reproduction Expenses 50 1
Shipping Expenses 500 l
Total Materials and Services 600 TOTAL FACILITY COSTS TO SUPPORT NRC INSPECTIONS 16,750 l
'15 person-hours @ $50/ hour
'288 staff-brs @ $50/ hour
'20 person-hrs @ $ 50/ hour l
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There are 75 facility licensee requalification programs, each operating on a 2-year cycle.
This would imply on average 37 program inspections per year could be conducted.
However, current practice involves 1 NRC requalification examination per program-year for 65 of these 75 programs.
This would result in an annual industry cost of ($32,000/ program-year)(65 programs) - $2.08 million/yr.
As a third option, assuming that, after the proposed changes, NRC would administer the SALP program with an average cycle of 18 months, this would result in 50 requalification program inspections per program-year.
The annual industry cost of ($16,750/ program-yr)(50 programs) - $838,000/yr. This would indicate an annual industry cost savings of $1.24 million associated with the final rule.
This latter industry cost savings has been used in the value impact evaluation.
3.2.3 NRC Develooment Costs NRC development costs are the costs of preparations prior to implementation of the proposed regulatory action. These costs usually consist of labor costs and overhead within the NRC and the cost of procuring contractors to perform tasks not undertaken within the NRC. Only incremental costs resulting from adoption of the proposed action should be included.
Much of the development work has been completed on this action and, as such, is a sunk cost. These costs are not included in this analysis because they will be incurred both for this action and for the alternative.
It is expected, however, that additional NRC staff time will be required before implementation of the final rulemaking can occur. This staff time is primarily associated with the development of the new inspection program and inspection module.
Some of these costs will be incurred regardless of whether the proposed action is adopted or rejected.
For example, an NRC Tiger Team is presently developing a new inspection program. As a result, these costs are not included in this analysis.
It is estimated that the equivalent of 0.5 staff--
year will be required to complete all phases of the development process.
Based on an NRC labor cost estimate of $50/ person-hr, the above labor requirement results in an NRC development cost of approximately $50,000.'
3.2.4 NRC Imolementation Costs NRC implementaticn costs are those costs that the NRC will incur to implement the action once a proposed action is defined and the Commission endorses its application.
It is estimated that implementation of the proposed action will require one professional NRC staff person-year at a cost of $100,000/ person--
year.
'The value of $50/ person-hour is rounded from the standard NRC labor rate l
of $48/ person-hour from the most recent draft of the Reaulatorv Analvsis l
Technical Evaluation Handbook.
10
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In addition, the NRC will also incur one-time implementation costs associated j
with:
l training of NRC and contractor examiners on the new inspection module requirements conduct of pilot inspections modification of the inspection module The incremental, one-time costs associated with these three implementation activities are estimated to be $50,000. As a result, the total NRC implementation costs are estimated to be $150,000.
3.2.5 NRC Operation Costs The Office of Nuclear Reactor Regulation (NRR), the office responsible for administering and budgetary planning for the requalification examination program, has estimated the NRC cost implications of the final rule.
Their analysis focussed solely on NRC staff resources and contractor support because these were the only cost factors judged to be affected by the final rule.
In FY92, the NRC resources committed to this program for NRC staff and contractor support were approximately 12 FTE and $1.3 million, respectively.
i The staff projects that a slightly larger average number of examinations, requiring approximately 1.5 additional staff FTE and an additional $200,000 contractual support (equivalent to 1.25 FTE), would be conducted in future years if the NRC continues conducting requalification examinations for all licensed operators.
Thus, if it is assumed that without the rule change, this program would continue into the future, the relevant baseline NRC burden would approximate $2.85 (1.35 NRC + 1.5 contractor) million per year in 1992 dollars for FY93 through FY97.
For regulatory analysis purposes, the 13.5 (12 + 1.5)
NRC staff years (FTE) were converted to $1.35 million ($100,000 per staff year) based on allowances for composite wage rates and direct benefits.'
Under the final rule, NRR's analysis indicates that NRC staff could perform all necessary inspections of requalification exam programs with 11 NRC FTEs and $300,000 in contractor support, equivalent to 1.85 contractor FTEs, per year.
At $100,000 per NRC FTE and $162,000 per contractor FTE, this converts to an annual cost in 1992 dollars of $1.4 million.
Thus, the annual savings in NRC operating costs is estimated to be on the order of $1.45 million ($2.85 million less $1.4 million).
Over an assumed 25-year remaining life, based on
'NRC labor costs presented here differ from those developed under the NRC's license fee recovery program.
Ftr regulatory analysis purposes, labor costs are developed under strict incremental cost principles wherein only variable costs that are directly related to the development, implementation, and operation and maintenance of the proposed requirement are included.
This approach is consistent with guidance set forth in NUREG/CR-3568, "A Handbook for Value Impact Assessment," and general cost benefit methodology.
Alternatively, NRC labor costs for fee recovery purposes are appropriately designed for full cost recovery of the services rendered and, as such, include non-incremental costs (e.g. overhead and administrative and logistical support costs).
11
a 5% real discount rate, the 1992 present worth savings in NRC resources is estimated at about $20.25 million in 1992 dollars.
3.3 VALVE-IMPACT ASSESSMENT
SUMMARY
The overall objective of this analysis was to assess the values and impacts (costs and savings) expected to result from implementation of the final rulemaking.
Values were qualitatively discussed in Section 3.1.
Impacts were assessed for the proposed rulemaking in Section 3.2 relative to the status quo. These impacts are summarized in Table 3.4.
Table 3.4 Summary of Cost Savings to Industry and the NRC (1992 Dollars)
Lifetime Annual (1992 Present Worthi*
INDUSTRY SAVINGS Operation
$ 1,240,000
$17,480,000 NRC SAVINGS Development (one-time cost)
-550,000 Implementation (one-time cost)
-$150,000 Operation
$1,450,000
$20,445,000 TOTAL NRC SAVINGS
$20,250,000 3.4 IMPACT ON OTHER RE0VIREMENTS The principal impact of the final rulemaking would be on affected licensees and licensee employees.
The cost impact on licensees is discussed in Section 3.2.
Impacts on other government agencies are expected to be minimal.
The impacts on NRC programs and requirements are also expected to be relatively small.
The NRC has had existing personnel and procedures for conducting licensed operator requalification examinations since the program began in 1988.
It is not anticipated that the NRC would need to add any additional l
staff or administrative personnel as a result of this final rulemaking.
The l
'NUREG/CR-3568, A Handbook for Value impact Assessment 12
administration of the revised regulations would be absorbed by current NRC personnel and staff.
4.0 DECISIGN RATIONALE NRC staff has found that, in light of experience gained over the past several years, the proposed revisions would ensure the overall effectiveness of the regulations in Part 55.
This would be accomplished by eliminating the dual responsibility for the licensee and the NRC to conduct individual cperator requalification examinations for the purpose of -license renewal.
Resources of i
the operator licensing program would be used more effectively.
1 The final rule will continue to assure that licensed operators can operate controls in a safe manner and provide for direct inspection of the quality of 1
the facility licensees' requalification programs.
In fact, the NRC staff i
believes that the final rule will improve operational safety by allocating j
resources based on the performance of each facility, rather than on the number of individuals that need their license renewed.
The NRC staff believes that 4
I this action will result in earlier identification and correction of j'
programmatic weaknesses.
The staff has found that these are generally the t
root cause of individual operator performance deficiencies.
i 2
l 5.0 IMPLEMENTATION SCHEDULE It is assumed that all licensees will be able to implement the requirements of 1
the rule within 60 days after the effective date of the rule.
This assumption is based on the fact that no changes to the industry's existing operator requalification programs will be required other than to begin submitting upon request consistent with the Commission's inspection program needs, copies of the comprehensive written examinations or annual operating tests to the NRC for review,
6.0 REFERENCES
Gallucci, et al., Reaulatory Analysis Technical Evaluation Handbook. Draft.
November 1991.
Pacific Northwest Laboratories.
Richland, WA.
Auluck, R., ISSUE PAPER for Proposed Revisions to 10 CFR Part 55 --
Reaualification and Renewal of Ooerators' Licenses. 7/13/92. U.S. Nuclear l
Regulatory Commission.
Washington, DC.
13
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DOCUMENT NAME: G:\\DIPALO\\PT55\\REGANL.FNL AUTHOR:
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NRC AMENDED REQUIREMENTS GOVERNING RENEWAL 0F LICENSES OF NUCLEAR POWER PLANT AND NON-POWER REACTOR OPERATORS The Nuclear Regulatory Commission is amending it:; requirements governing the renewal of licenses of nuclear power plant and non-power reactor operators.
The amendment would eliminate the pr sent requirement for a licensed operator at power, test, and research *eactors to pass a comprehensive requalification written examination and operating test conducted by the NRC during the term of a six-year license as a prerequisite for license renewal.
Instead, requalification examinations would continue to be conducted by individual facility licensees who employ the operators.
The existing NRC resources would then administer these programs by inspection and oversight of required facility requalification activities.
The amendment reflects experience gained since the requirement was put in place in May 1987 when:
-- The term for operator licenses was changed from two years to six.
-- Operating tests had to be conducted on plant reference simulators when they either were new or still under construction.
-- Requalification programs were permitted to be based on a systems approach to training when the industry had not yet implemented the process for accrediting these programs.
Experience with this program has shown that NRC examiners largely are duplicating tasks already required of and routinely performed by the facility licensees as part of their requalification program.
In addition, in 1988, the NRC staff revised its requalification examination procedures to focus on performance-based evaluation criteria which enabled it to conduct comprehensive examinations for the purpose of renewing an individual operator's license and, at the same time, to use the results of the individual operator requalification examinations to determine the adequacy of a facility licensee's requalification training program.
Since 1987, the pass rates for individual operator requalification examinations have increased from 83 to 91 percent and the pass rate for facility licensees' requalification training programs have increased from 81 to 90 percent.
Further, the staff has seen a general improvement in the quality of the facility licensees' testing materials and in the performance of the facility test evaluators.
Of the first 79 programs evaluated, 10 were found to be unsatisfactory; since that time. an additional 120 programs have been evaluated and only 6 additional programs were found to be unsatisfactory.
4 The amendment also would require facility licensees to submit, upon request consistent with the Commission's inspection program needs, a copy of their annual operating tests or comprehensive written examinations used for operator requalification to the NRC so that the staff could ensure that they conform to
4
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NRC requirements. The tests and examinations would be used, together with other information already available to the staff, to determine the scope of an annual on-site requalification inspection.
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NUCLEAR REGULATORY COMMISSION 7
WASHINGTON. D.C. 20555 0001 s.....f Tne Honorable Richard H. Lehman, Chairman Subcommittee on Energy and Mineral Resources Committee on Natural Resources United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
Enclosed for the information of the subcommittee is a copy of a final rule to be published in the Federal Reaister that contains amendments to 10 CFR Part 55.
Section 306 of the Nuclear Waste Policy Act (NWPA) of 1982 directed the NRC to promulgate regulations or other appropriate guidance to establish
" simulator training requirements... and requirements governing NRC administration of requalification examinations." On May 26, 1987, the NRC amended 10 CFR Part 55 to require each licensed operator to pass a comprehen-sive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
At the time the regulation was amended, the Commission did not have confidence that each facility would conduct its required annual operating tests and written examinations in accordance with the Commission's expectations.
That lack of confidence was due to the implementation of new aspects of the operator requalification orogram with which neither the NRC nor the industry had very much experience. Therefore, the Commission determined that during the term of a 6-year license, the staff would conduct individual operator i
requalification examinations for the purpose of license renewal. As a result of conducting this examination, the staff has determined that the existing regulations have established a high standard of licensee performance and that the NRC examiners are largely duplicating tasks already required of, and routinely performed by, the facility licensees.
The final rule will delete the requirement that each licensed operator at power, test, and research reactors pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
The amendment will require facility licensees to submit, upon request consistent with the Commission's inspection program needs, a copy of its requalification written examinations or annual operating tests to the Commission for review.
In addition, the final rule will amend the " Scope" provisions of the regula-tions pertaining to operators' licenses to include facility licensees.
=.
The Honorable Richard H. Lehman 2
The staff believes that operational safety at each facility will be improved by directing its examiners to inspect and oversee facility requalification programs rather than conducting requalification examinations.
By redirecting the examiner resources, the staff expects to find and correct programmatic weaknesses earlier and thus improve operational safety.
Sincerely, Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosure:
Notice of Final Rulemaking cc: Representative Barbara Vucanovich Distribution:
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NUCLEAR REGULATORY COMMISSION UNITED STATES i(,dg~[
WASHINGTON. D.C. 20555-0001
\\.....f' The Honorable Joseph Lieberman, Chairman Subcommittee on Clean Air and Nuclear Regulation Committee on Environment and Public Works United States Senate Washington, DC 20510
Dear Mr. Chairman:
Enclosed for the information of the subcommittee is a copy of a final rule to be published in the Federal Reaister that contains amendments to 10 CFR Part 55.
Section 306 of the Nuclear Waste Policy Act (NWPA) of 1982 directed the NRC to promulgate regulations or other appropriate guidance to establish
" simulator training requirements... and requirements governing NRC administration of requalification examinations." On May 26, 1987, the NRC amended 10 CFR Part 55 to require each licensed operator to pass a comprehen-sive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
At the time the regulation was amended, the Commission did not have' confidence that each facility would conduct its required annual operating tests and written examinations in accordance with the Commission's expectations.
That lack of confidence was due to the implementation of new aspects of the operator requalification program with which neither the NRC nor the industry had very much experience. Therefore, the Commission determined that during the term of a 6-year license, the staff would conduct individual operator requalification examinations for the purpose of license renewal. As a result of conducting this examination, the staff has determined that the existing regulations have established a high standard of licensee performance and that the NRC examiners are largely duplicating tasks already required of, and routinely performed by, the facility licensees.
The final rule will delete the requirement that each licensed operator at power, test, and research reactors pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
The amendment will require facility licensees to submit, upon request consistent with the Commission's inspection program needs, a copy of its requalification written examinations or annual operating tests to the Commission for review.
In addition, the final rule will amend the " Scope" provisions of the regula-tions pertaining to operators' licenses to include facility licensees.
.._ j
1 The Honorable Joseph Lieberman 2
The staff believes that operational safety at each facility will be improved by directing its examiners to inspect and oversee facility requalification programs rather than conducting requalification examinations.
By redirecting j
the examiner resources, the staff expects to find and correct programmatic weaknesses earlier and thus improve operational safety.
i Sincerely, j
i Dennis K. Rathbun, Director
{
Office of Congressional Affairs j
Enclosure:
Notice of Final Rulemaking cc:
Senator Alan K. Simpson Distribution:
[CONGLTR.FNL]
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NUCLEAR REGULATORY COMMISSION y
WASHINGTON. D.C. 20555-0001 The Honorable Philip R. Sharp, Chairman Subcommittee on Energy and Power Committee on Energy and Commerce United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
Enclosed for the information of the subcommittee is a copy of a final rule to be published in the Federal Recister that contains amendments to 10 CFR Part 55.
Section 306 of the Nuclear Waste Policy Act (NWPA) of'1982 directed the NRC to promulgate regulations or other appropriate guidance to establish
" simulator training requirements... and requirements governing NRC administration of requalification examinations." On May 26, 1987, the NRC amended 10 CFR Part 55 to require each licensed operator to pass a comprehen-sive requalification written examination and an operating test conducted by-the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
At the time the regulation was amended, the Commission did not have confidence that each facility would conduct its required annual operating tests and written examinations in accordance with the Commission's expectations.
That lack of confidence was due to the implementation of new aspects of the i
operator requalification program with which neither the NRC nor the industry had very much experience.
Therefore, the Commission determined that during the term of a 6-year license, the staff would conduct individual operator requalification examinations for the purpose of license renewal. As a result of conducting this examination, the staff has determined that the existing regulations have established a high standard of licensee performance and that the NRC examiners are largely duplicating tasks already required of, and routinely performed by, the facility licensees.
The final rule will delete the requirement that each licensed operator at power, test, and research reactors pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for license renewal.
The amendment will require facility licensees to submit, upon request consistent with the Commission's inspection program needs, a copy of its requalification written examinations or annual operating tests to the Commission for review.
In addition, the final rule will amend the " Scope" provisions of the regula-tions pertaining to operators' licenses to include facility licensees.
]
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4 The Honorable Philip R. Sharp 2
The staff believes that operational safety at each facility will be improved by directing its examiners to inspect and oversee facility requalification programs rather than conducting requalification examinations.
By redirecting the examiner resources, the staff expects to find and correct programmatic weaknesses earlier and thus improve operational safety.
Sincerely, j
Dennis K. Rathbun, Director Office of Congressional Affairs
Enclosure:
Notice of Final Rulemaking cc:
Representative Michael Bilirakis Distribution:
[CONGLTR.FNL]
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