ML20112E308
| ML20112E308 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 08/15/1983 |
| From: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Christenbury E NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| Shared Package | |
| ML20105B226 | List: |
| References | |
| FOIA-84-250 NUDOCS 8501150091 | |
| Download: ML20112E308 (8) | |
Text
UNITED STATES
.[pafic.
o
'o NUCLEAR REGULATORY COMMisslON
[)e<
g REGION I 3
f
$31 PAmm AvtNut UG 1 5 BB3
,,f er,1NG OF Pmyss:A, PENN5' Lv aNI A 19.x I '
g, v.....f Docket No. 50-322 fEMORANDUt1 FOR:
Edward S. Christenbury, Director and Chief Counsel Hearing Division, Office of the Executive Legal Director FROM:
Richard W. Starostecki, Director, Division of Project and Resident Programs, Region I
SUBJECT:
SHOREHAM BACKGROUND INFORMATION In response to the discussion of Governor Cuomo's Comission relative to Operator Licensing for Shoreham, the, staff has prepared a narrative description of the process used by the Regional examiners and management.
Prior correspondence to licensees regarding overtime policy and the NRC Publication Policy is also enc s
Richard W.
tarostec i. Director Division of Project and Resident Programs
Enclosures:
As stated cc:
R. Caruso, NRR (w/ attachments)
E. McCabe R. Keller J. Higgins 8501150091 840518 PDR FOIA BELAIR84-250 PDR
[L N.
M///
DESCRIPTION OF REACTOR OPERATOR LICEN5ING PROCEDURES The Reacter Operator Licensing program starts several yea s prior to the liters-ing examination.
Candicates uncergoing :ne Doerator Licensing exam will have completec a training program concucted oy the Applicant's training staff A
description of this training program is contained in Chapter 13 of the Final Safety' Analysis Report.
Accroximately nree months prior to the licensing ex-amination, the cancicate will suomit an apolication for licensing as a Reactor Operator. This standard application form (NRC Form 398) describes the candi-date's training, experience, and other qualifications which are used by the NRC in evalueting that person's qualifications to take the examination. The requirements in training, education and other experience are further defir.ed in NUREG-0737, " Clarification of TMI Action plan Requirements." In general, a
- candidate is required to have completed the approved training program and have
. several years of power plant experience or formal education as well as a signi-ficant amount of training at the particular site for which the candidate will be licensed.
The applications are reviewed by the NRC Examiner concucting the exam. When the
-examinations are scheduled, the training organization is requested to suomit in-formation which will be used by the NRC in developing the particular examination at that facility. This information will incluce training material such as course outlines, lesson plans, system descriptions, and flow diagrams on all safety related systems in the plant. Other information will include copies of the Technical Specifications, administrative procedures and radiological and radiochemistry procedures used by the plant operating staff. This information is reviewed and studied by the Examiner wnen the examination is being developed.
When the application is submitted, the candidate is required to submit a report of medical conditions to demonstrate the proper physical and psycnological make-up to perform as an cperator. This' report is completed by a doctor and includes such items as suitability for the stress conditions exerted on an operator and
- examines the hearing, eyesight anc general. physical concition of the candidate.
At the same time the application is submitted, the plant management will submit a certification attesting to the fact that the candidate has completed the re-quired training program, that all requirements have been met,'anc there is a need for services of the candidate in operating the plant and that in the judge-ment'of the plant management _and canaidate meets all requirements. This certi-fication 'is signed by the highest Corporate official responsible for operations of the plant, normally-a Vice President.
The medical report is reviewed by a medical censultant to the NRC staff for-suitability.
Such items as diminished eyesight, hearing, colorblindness or color perception deficiencies may require that restrictions be placed on the license. Other medical conditions which may lead to incapacitation such as a continuing' diabetes-condition, high blood pres-sure, or hypertension may require that a restriction be'put on the license that the candidate may only perform licensed duties while another person is available in the control room.
si'#
2 The Operator Licensing Examination consists of two parts; a ritten exam nation anc a practical examination.
Tne written examination for a Reactor Operator cove-s tne following areas:
Principles of Nuclear Power P'. ant Operations, inermocynamics, Heat T-ansfer and Fluic Flow 2.
Plant Design, including Safety ana Emergency Systems 3.
Instruments and Controls 4
Procedures - Normal, Abnormal, Emergency, and Radiological Control The written examination for a Senior Reactor Operator addresses areas relevant to plant operations and administration which require the candidate to demon-strate other skills, involving a deeper understanding of theory and background of reactor operation.
Subjects included are:
5.
Theory of Nuclear Power Plant Operation, Fluids and Thermodynamics 6.
Plant Systems:
Design, Control and Instrumentation 7.
Procedures - Normal, Abnormal, Emergency and Radiological Control 8.
Administrative Procedures, Conditions and Limitations Each examination is prepared so that it can be completed within the alotted timeframe of six hou,rs.
The examination requires the candidate to write answers to questions using brief essays or brief answers, normally running from a few sentences to several paragraphs.
During the written examination, the cancidates are proctored to ensure that all work done on an examination is only by the cancidate anc that there is no sharing or collusion.
Candidates are spaced throughout the examination room anc are not allowed to have any other materials with them while they take the examination.
Tne written exams are collectec at the end of the allotted time period and kept in the possession of the examiner.
The second part of the examination consists of a practical exam which may be conducted on a plant specific simulator (if available) or in the operating plant. When a plant is under construction, or in a stage before hot operations are begun, and where no plant specific simulator is available, Operator License examinations are conducted in the partially completed facilities.
Conditions are hypothesized and scenarios are improvised as necessary to determine the individual Operator's specific knowledge of competence. When a plant specific simulator. is available, the simulator exam consists of observing the candidate in the simulator, as part of a team, which is conducting operations on the simu-lator.
During the course of operation, a number of abnormal occurrences or emergency conditions will be inserted into the simulator to evaluate the'candi-date's performance under emergency c'onditions. An important part of the exami-nation evaluates the communications among the operators in the control room o
3 during a stress situation.
The senior operator's ability to evaluate off normal conditions or concitions wnich appear to Deesent conflicting infer ation is also evaluated.
Tnus, the senior operator will be recuirec tc icor for many sources of information anc reacn a cecision as to recuirec actions casec on :ne response of the plant simulator.
The examination in the olant will consist of an oral examination conducted by one examiner directly on a candidate.
Tne examination will consist of oues-
'tions posed by the examiner electing verDal or written response from the candi-date.
Questions may require that the candidate observe plant instrumentation, refer to reference material available to the operator in the control room, or go to a particular location in the plant and describe operation of the equip-ment, procedures, and emergency actions.
No actual manipulation of plant con-trols is conducted during the oral examination.
A standard form is used by the examiner in this examination to ensure tnat all required areas of knowledge are covered. The major areas covered during the practical examination include the following:
~1.
Plant Operation, including Console Operations and Instrument Checks 2.
Facility Equipment, including Major and Auxiliary Equipment and Engineered,
Safety Feature Systems 3.
Instrumentation, including Nuclear and Process Instrumentation 4.
Plant Protection Systems 5.
Procedures, including Normal, Abnormal, and Emergency Procedures 6.
Theory, including Reactivity Effects, Thermodynamics and Hydraulics 7.
Administrative Recuirements and Procedures 8.
Radiation Protection and Safety
-10.
Plant responsibilities, including Security, and Plant Safety The checklist is completed by the examiner and made part of the examination record.
Each exam is conducted by a team headed by a certified Operator License Examiner who is designated " Chief" Examiner.
His duties include overall responsibility for the examining cycle, from original scheduling through issue of either denial letters or Operator Licenses. At the completion of these examinations, the Chief Examiner will grade or review the grading c the written exam and complete
-an overall evaluation of the practical examination.
Both the written exam and practical exam must be satisfactory for the candidate to receive a license.
If either is unsatisfactory, the license will be denied,
- s..
4 After the w*itter exam anc oral exar nave been evaluatec, they are reviewe: by NRC management for consistency anc fo-tecnnical content.
If all recuirements have been met for tne license, a license will ce preparec anc signec by NRC management.
If all recuirements a*e not met, a cen'al letter will be preparec.
Ine cenial letter specifies the areas in wnich the candicate exhibitec weakness anc a copy of tne written exam anc the crai evaluation sneets are returnec to tne cancicate.
A copy of tne results of each examination is sent to the train-ing staff so tnat specific areas of wea(ness can be upgraced for each operator.
This will be mace part of the recualification program for the operators during the annual requalification cycle.
The recualification program conducted by each plant is reviewed and approved by the NRC staff.
Each operator or senior operator is required to maintain pro-ficiency in emergency procedures, administrative recuirements, plant procedure changes, or significant operating events which occur in that plant or other similar operating plants.
As plant operations continue, operation experiences occur; these are documented, in accordance with their relative significance, in Resident Inspector reports, License Event Reports, and even in Civil Penalty description.
The Licensed Operators are required to be cognizant of these events on both their own and on similar power plants.
The curriculum of the continuing Requalification program, therefore, includes these events, as does the NRC Audit exams of the Requalification programs.
Further, the requalifi-cation program requires that each operator participate in simulator training, classroom lectures, and that each operator take a written exam on an annual basis on the subjects covered in the training program.
The requalification program is audited by the NRC staff on a regular basis..The NRC staff may also participate in the requalification examination either through observing or con-ducting examinations at'the simulator or written and oral examinations at the plant site. A record is kept of each licensed operator's participation in the
.requalification program to ensure that all requirements are met.
sp 4
^
l M
Federal Register / Vol. 47. No. 33 / Thursday. February 18.19s:' / Nouce.
IOoseine asse SMts anal ENiel For the Ner.laar Esplemry Cmasussiert was fded by the Authoney.The Steven A. Versa.
Department of Ene gy, by letter of amt W h N Chief. Opemuny Asocwes smd.A Nc. 2.
February 10.1982. advised the lesauence of Amenomanta to Facmty p,vmon*/Lcansas Commmion that it has no obtection to l
Operwung usenses
,,, o. e om raw w-an a the issuance of the requested
{
""== rwom amendmmt.
i hU.S. Nuclest Reguletory Commission (the Commissten) ha.
In accordance edth to CFR 2.108.
{
issued Amendment No. 52 to Facility Ipecast No,50-2t11.
n tace is hereby given that the Oper: ting Ucense No. DPb6E and Commission has today issued an i
Amrndment No. 37 to Facdtty Operstmg Nucteer Fuel Serv 6ces. Inc. and New amecdment to Ucenae No. CSF-1.
IJcense No. DPb74 issued to Indians Yort State EnerTy Reeeeref". and substantiell' as requested by NF3.
cnd Michigsn Electne Company (the Deve4opment Authortty (Western New which provi a for termmation of the j
licensee). which rensed Technical Yorti Nucieer Servies Center) laauence authortry anu responsibility of NFS I
Specifications for operation of Donald C.
of Amendment to Faculty Uconee No.
under said license. effecuve upon 1) 1 acceptance d su.wnder of the fady Cook Nuclear Plant. Umt Nos. I and 2 (the !ccilities) located in Berrien County, Nuclear Fuel Services. Inc. (NFS) and by the Authonty from N75,2) DOE ~s i
aes a
us o of Michigan. The amendments are effective New York State Energy Research and g
4 as of the date ofissuance.
Development Authority (as successor to oh Settlem' nt Agmmnt in peding,
the New York State Atomic and Space civil actions in the United States District I
' " " " " " * ""8' Development Authority)(the Authority)
'*"P"* '"" "9"""'** " I" 8' hold Provisional Operating Ucense No.
Court for the Western District of New
. refueling water storage tank and make CSF-1. De lim. inued under action York. De Commission has determined l smraleditwialclianges.
104b.of the Atomic Energy Act.had that the application for the amendment h application for the amendments authorized the operation of a spent complies with the requirements of the
- A with the standards and nuclear fuel repmcessing and Atoaue Energy Act and the regulations I requirement of the Atomic Energy Act radioactrve waste disposal facility at the of the Commission (10 CFR Chapter I).
of1954.ce amended (the Act), and the Western New York Neclear Service
' Die Commission has determined that Commission's rules and regulations. The Center in West Valley. New York (the this amendment involves no significant r'a===== ion has made appropriate Center).
hazards consideration. Copies of the
- findags as regered by the Act and the Under the West Valley Demonstration amendment to the hcanse and the NRC
' Casanussion's rules and mgulations in 10 Project Act. Pub.L.96-3647he staffs safety evaluation are available CFR Chapter L which are set forth in the Department of Energy has been for public inspection at the i bconse amendments. Price public notice authonzed to carry out a high-level Commission a Public Document Room.
! of these amendments was not required redioactive wastemanagemeng 1717 H Street. NW. Washington. D.C.
since that==wnd===its do not involve e demonstration protect at the Center for and at the Local Public Document sismBoast hazards considention.
the purpose of demonstrating Rooms maintamed at the Buffalo and solidification techniques which can be Erie County Public Ubrary. Iafayette h Comunission has determmed that used for prepanns high-levelliquid
' Saluare. Buffalo. New York. and the es issuance of &m amodmna wul radioactive waste for disposal Town of Concord Public Library 23 not woult in any agm5 cant On September 30.1981, the U.S.
North Buffalo Street. Synnsvula. New environmental impact and that pursuant Nuclear Regulatory Coremission (the York.
to 10 CFR 51.5(d)(4) an environmental Commission) issued an amendment to Deted at Silver Sprina. Maryland. this itth impact statement or negative the license which would permit transfer day of February 19er.
declaestion end environmentalimpset of the facility to the Department of For the Nuclear Regulatory thmimon.
cppraisal need not be prepared m Energy for purposes of the project (46 FR taland C asuna, connection with issuance of these 4s2371
""O#
. caendrnene.
On October 8,1981, the Commission Por further details with respect to this received from NF3 an application for NN cetion. see (1) the application for amendment of Ucense No. CSF-1 to cmendments dated May 28.1981. (2) rebeve NFS of all operational l
~^
Amendment Nos. 52 and 37 to License responsibdity under the license. Noti-of receipt of this application was Nos. DPbas and DPR-74. and (3) th, publiahad in the Federal Resister on l l
F=====We related Safety Evaluation.
Nucdear Power plant Staff Working Allaf esse items are semilable for Novesiber 13.13e1(48 FR 5e066).De Hours public inspection at the Commission's Comnaissian denied the application on Public rane===nt Room 1717 H Street.
January it test;without prejudice. In aossev: Nuclear Regulatory NW. Washington ELC, and at the order to avoid adjudication before the Commission.
Maade Reason P=1===1= Mamorial P-ofissues of law and fact acnosc Publication of Policy Regarding bat am beinginigand betwun NFS Nuclear Power Plant Staff Waridag Ubrary, sco Market Street. SL }oseph.
and the Aachority in the Federal courd Hours.
Michigan 4sosE. A copy ofitems (2) and I
["[,"**I submitted a further application to sunsaiasry: The Nuclear Regulatory the t'a====iaa om Pebruary L iss2.
Commission has been concerned that Washingtas.
The new apphantion requests that the excessive work hours by Iat Attentiom h. Mon authority and responsibility of NFS nuclear power plants to under the Lcease be terminated upon situations where fatigued personnel Dneed ct Betheeds. Maryland this 10th day the oce.trrence of certain events. A might not be alert might use poor of February.1ssa, supporting letter, dated February 9.
judgment. or might make poor decisions l
Federal Register / Vcl. 47. No. 33 / Tbursday. February ta.19a: / Notices 7353 cffectmg the safety of the nudscr plant.
R-~"~e that wry unusua!
neutron absorber. Thz guids was revised which could pot:ntially jeop:rthze th, circumstane may anse mguirtas dntence after cddluonal st:ff revi:w to endorse 1
health and safety of the public. In I'm se ebm guideum. wh devsati" ANS!/ANS 45-1979. "Use of
- U P
attempts to aaaure that utdl!y BorDedicato-Class Raschts Rings ae a d
n la e
Neutron Absorber in Solut2ons of Ftas.;e orgeruaabons avoid situabons where
.be parunount considersoon in such fatagued personnel nught be on shift, the authoruaDon shaU be that significant Matenal" NRC has tasued previous guidance reducuens to the effec rwoen of opereung Comments and suggestions in regarding overtime restnctions.
persannel would be hashly an.kely.
connection with (1) items for indusion However, the policy has been evolving in addition. Pr** durn are encouraged that in guides currently being developed or and it appears that earber guidance would allcw hernsed operatore at th*
(2) improvements in all published guides should be revised.
mais to be periodicaDy mueved and are encouraged at any time. Comments I
On July :* 1961. the NRC staff M
th,'rE should be sent to the Secretary of the n
uty submitted a paper. "Nudear Power
- Utiltry bolders of operstme henne and Commission. U.S. Nudear Regulatory Plant Staff Working Hours." SECY 81-construenon permits am bases advised of this C-= Mon. Washington. D.C. 20555.
i 440 for considerston by the r--ion pahey. Utihnes who hold Attention: Docketing and Service l
Commissioners.The paper was intended operenns hoenses will be regnested to amend Branch.
to resolve the inconsistencies in the se Admuseetta Secum of the Techmcal Regulate:y guides are available for previous guidance and to serve the EP'C2AC'#"8 I" **" 'P*"88 P *"t* **
Inspection at the Commission's Public l
purpose of the NRC in protecting public'
,"M9 "h"*""
,,",g,,
Document Room.1717 H Street NW.
8*
health and safety while recognizmg the se new c_..i..u-poucy. Appucants for Washington. D.C. Copies of active practical aspects of working hour opersung licensa win be regmted to guides may be purchased at the current i
amitations as they affect nudsar power develop appropnats edadaistreon Government Printing Office price. A plant operation.
procedures and Technical 5pectScations subeciption sereice for future guides in After consideration of this NRC staff
- w m W W At ee same ume.
speci5c divisions is available through
. " " ' ' * *'8"I* *"7 0*'d* *'"
0""D the Government Printing OfBee.
b
,,,'Y ^** uran" paper, the Nudear Regulatory Inf rmation on the subscriptimi service Commission has now issued the revised and current prices may be be obtained following policy statement concernin8 to inwrporate the guidance of the pohey by writing to the U.S. Nudear fatigue at nudear plants:
statement.
For Further Information Contact Mr.
Regulatory Comminaion. Washington.
Pelicy en Facters Caesing Fatigue of lawrence P. Crocker. (30t14e2-4157 D.C. 20555. Attention: Publication Sales Opernahs Pereussel at Nacieur Rascaer.
Dated at Bethesda, Maryland, this 11th day Manager.
t 1===--e of operating plants and of February 1 sat.
(a UAC EE2(a))
appheants for operettng hosenes abaD For tbs Neclear Regulatory r=====t=
Deted at Silver Spring. Md. this 10th day of establish controls to prewns siteetions where Inwsomes F. Crosser.
Februrpes2.
l fatigue could reduce the ability of opereting W Secesooleader.?- At
% w gg e-m per-a==al to keep the reactor in a safe Tecimdegy Sec tion. lJonasse M#cedoar Robert megen, condition. The anetrole should focus on shift ArnacA Dirasson ofNuman Factor Sofety.
staffing and the ese of
.m 6; job-Duecsor. Opios of#aclear Angulosory i
solated factore thet infloane fatigue.
pn ami. an.eus m s.as.et mes am!
Assearc/L The objective of the controls woeld be to saamuso m mis m p, p_,
,,,g,,
neeure that, to the extent practicable, peron===1 are not assigned to abift duties whue in a fatigued condison that could Regulatory Guides;leensence and significantly reduce their mental alertnese or Availability eeir dec sions making capabitity.n.
.nie Nudear Regulatory Cnemission OFFICE OF SCIENCE AND controls shau apply to the plant staff who has issued a revision to a guide in its TECHNOLOGY POLICY perform safety.related functions (e.g. senaar reactor operators teactor operators. bealth Regulatory Guide Series.This series has physicists. ausuhary ope.ators, and key been developed to descibe and make maini===ar. personnell.
available to the pubbe methods Enough plant opereeng personnel should acceptable to the NRC staff of Pursuant to the Federal Advisory be employed to maintain adequate shift implementing specific parts of the Committee Act (Pub. I.92-463), it is comage without routine heavy use of Comt.ussion's regulations and,in some hereby determined that the emuara. Howewr,in the event that cases to dehneate techniques used by establishment of the White House
""I""*en problems requtn substantial the staff in evaluating specific problems Science Councilis necessary,
' I 7,,,,*ry bn f Ilowing g'uadehna or postulated accidents and to provide
.approprists. and in the public interest in aball be fouowed; guidance to applicants nanimening connection with the performance of
- a. An individual abould not be permitted to certain of the information needard by the duties imposed upon the Director Office work mon than se hours straaght (excluding staffin its review of applications for of Science and Technology Policy, by abift tornover tunel.
permits and licenses.
the Presidential Science and Tocanology
- b. As ladividual should be not permitted to Regulatory Guide 3.1. Revision 1. "Use Advisory Organization Act of1975 and work more than is bours la any 24.bour of Borosilicate-Class Raschig Rinse as a other applicable law. This determination Penosi. aor men than 24 houn la any es.bour Neutron Absorber in Solutions of 7"issile follows consultation with the General pened. mer som een 72 hoen la any sma Material." describes procedures Services Administretion, pursuant to day eB 8Cceptable to the NRC staff for Section g(a)(2) of the Federal Advisory uf e gh boere abould l
I'tP ementing the r==i==laa's Committee Act and OfBoe of auswed betoneen overk periods (including
'. sheh terne,ver unne).
regulations concerning the prevention of Sdan - -t and t (OMB) Circular d.'the use of esorteme sinald be Witicality accidents in solutions of Number A.03.
eensidered as as individual beeis and not for Sesile materialby the use of L Name of Group: White House the emetre staff as a shift.
borosilicate. glass raschis rings as a Science Council L,-.-..
.... 4.
S lent..] ret S d.:.;. $
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reir td.* ; p. i t:.
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nor psl 8 hwr d.. O 'nt-s <. 5 wVe
- do..crir.a v s die $u. *,1 fe.. nth Cn-2 n C., I.
- r. f.la.c=.eks t.
th: plant i= cyrittig IMwever. Iri I P
...es.vy :n in /;puward eva fit thet un't,r-:.e*~ er:bl ms r..qu.tr b:ti) !-- thi:.1 te-.. :-c..-i g substant.al e nuu=ts cf ourtim: to lie
/ gree.,rnt ate 1* c fr d : It)The o used. or d.ma; er.te-ded periods of of the T.v.erut:ve Lc;.! Dire: tor. N[n t ow r. u roec mt us :
. <.c ceu noe as shutCarn in r&-Lng major rcci nth d.:t-.L.c d thct.nf.,rme.,.,
rust. ton.:-:e or in br p:aot pct' crct'l.v S:cth Car-:ma f: ate.
L..s ;;;r Po.ver Plant Statt '.vor'ung mod.".u,nern en a te:npora y busk. thP In9e:t s ten be urd by t!.e NRC i"-
.dd.nes sh :1 be fol: owed enterrrr:en: cete.s e;airet Np.C followiny div::m! shou d not be l* urs AO:: cy: Ne:! ear Kr; latory heer,3ee;; i:) p.: scam to t'.e preg'..,.
l
' AL u:
Ca*.t assf un.
paq k, gh more thsr 16 houn of the Sote O roh:. F..d.: ac::v, strr 4 Mdu
- a s.h;[t turnover t.me.
w "i:. *..
E ". A
- .nt:: Pu... ation ef revised pel;:7 b' /' ' ' "
"d * 'h 'Id - b#
CII M LA ! N O 40h 6 5 Stale
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r.ic
-" -"-. r. : lear powe P aot sta!.'
per= tted to wc:k c: ore than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> m.
e t.ance.i. eent.i. over t e sh::.me'- gg s
i g - *k t ; ' *-J*-
aoy 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> peried. not mere than 24 ndicadve v.m i-a o.d.4'l '.
h :n in c y u-bour peno: cor. tore Stal and m*d.d i' ab' N*"" w: On Fab.. ary 11.15id. th:
Nu:L - Pa r.:h.torv Comminic:
6:.2,co,u : i:. any se s en day period acticas.
- '.'.nedg".:Pohd on Facters Causing I*f,Q 2
[{0ic firo
[
,eg,,,;
,,cn,n g, c
_m ue << w m.tr.:: Persen el at should be allowed betwe$n work
. Rovert E.Trojanowsb. R:;/snal 3.a e IJaisen OI!ie:r. Telephe.e <ca..:.._
..+ar ne ctors. 47 FR,3.
periods Uncluding shift turn a e-time)k 5!.o7. U.S. N.cle t.: n.gr.:...,arv l
C n..ents :cuivert rince pub.::rtjen d.Except duri.sg extended shutdove.
Commissica. FJI.1a.Wth. St..' f.;'
, avc r:v+2:cd quc>tacns con:ctning.ne period:. the use of everene should be
- p. cy striement.,Aucrin ngly, the ccesidered on an individual bu ds and Suite 31co. Ada:ta. Gre:. ia %c;;.
3,:,hef st,*cment nss been rev.se., and not for the en: ire stai! en a s :ft.
Dated at /.tlanta, Geerg: b in gfc k
- t. e tv.!.es *{er::en is reprod;.l:ed below.
Recogni:i=:: that very unu:ual ofM8YIDC.
~
C..:ng32 i:cride:(1)The ad aca cf a circumstances msy arise reg.Qin; For the Nuclear Re;;ct::c Cir.: rna.c.
w.
ta.c= which ul!.ic.itly states that the such, deviation shall be.su.t.uidelines, sr.nie.
devtst:en from the clove g Ja:nes P. 0 RetLy.
c.
ve c.,.s.e woriun*a hour po!!cy is notized b -
i 5
T.ep.onc!Atu.. tict:.. I'~;.~a 11.
nu sc 1.av.:"cpearu.ng personnel work an S-the p..snt c:2na;er or h.s ceputy, cr L.*: r w. 0-hour week:(2) Toe addition h S erlevels of 2:snase:nent.The Me:2 ra: dam of A;;;etn ent Betwaen h
sf'.P.' a-to indi: ate that the stated parar:ount considea stion in such the U.S. Nud:ar Re$.da'or e Cam- ;u --
r Environmental Contrel. oi.l cud the S.C. Depar ant i
v.a:.an,..our restn. tions are pph. cable authorimstion shallbe that sl*anificant c
i
'g[,, y, c2 tended periods of shutdown for
..weated to :.
c..mr reductions in the effectiveness of r;M,'"g",'
- $"*I '
Operating personnelwould be higBly Use of Third Party Data and the l
t unlik Regulation of NRC lacensee.Sh,rpe.s e,I r
p; g l"
'. ** procedures are Radioactive Waste to the Bamwail s.,dition of a phrase exemptm.g extend ~ ' :hutdown periods frem the
.e,"
. thit would allow EcensedFacility:Back;round 8
enf; s:u en in.,,to cons,ider u. se of everine scrsar ments opi.raton... the controls to be Time Chem.Neelear Sys. ems. Inc.
,)
.h idua. basis.
Periodically relieved and assi;ned to (CNST)lowlevel radioactive wape
- Pelicy on Factoes Causics Fatigue of other duties away from the centrol disposal facitty located at Sne,J:ng.
c 0 crating Personnel at Nuclear Reacters board during their tour of duty, South Carolina, has been in coetanec
?
F m mman twomanose comen since 1C 1.Both the U.S.Nu: fear l !
Licent.ees cf operaticg plants and Mr. Lawrence P. Cro:xer. (301) 4D2-8357. Re;ulato y Cem:r.ission (NRC) a:d ::e eppli: nts for operatinglicenses shan cinMish controls to prevent situations Dated at hthesda. Mr.ryland, this :sth day S.C. Department of Health and s.here fatyue could red:::e the ability of of May.2m Envitent:: ental Cont o] (D*-!FCl ha*.e 4+.atin; persont :) to keep the reactor Far the Nuclear Regulatcry Co==issic:/
responsib;lities for the regulauen Lf In x s fc cendition.The controls <hould John A.ZwotinsM.
NRC heensees who ship radioactive f::w cn shift st ling and the use cf Actic C':!rf.I.icensee Quo!!ficofions Branch, waste to the disposal f:cility.NRC s c":'rti:n% hey job-related fatters that Division ofHume.fer: cts sefety.
regulatory authority is de-ived item thr Atomic Ene ;y Act cfIE.:s metriti in'luxnce fatigue.
Fu om. s:-sve: r:;.4 s-a c. us as:
Tb cl js:.tive of the contrels would be an.w:s ccce 7.,w,-4:
the Esar;;y Rect;u '- tien Act of 5L to cesere that. to the extent pr..ctienbie.
as aruend:d. and the regu!ations pas senaul cre act a:. signed to shif t imph m.e. tin;; these Acts centaind i-M South Care!:na Depsrt:nent of He:itth C7 M1.5. Scui Cer:lic:. an aper:. '
0dfis wh ie in a fatigued condmon thr.
and Em, runmentti Cent-o! and the cavid si;;nific:ntly red::ce their rnental State. d:nves its ry.datery su;hori:$
cia-*n:::: c Q.ir deci:Jon n:M.anj
((uc!1:r RNutrtoaf Commission; from the.ipplicab e Cic: rae ster.
up:hiS:7.Th: controls shs!! spp!f to emorsne m ol t.;: ret;rnant th! tact to wh!ch : : comp::ibN with tix Feli 4 thr p;i nt ::.fiwho peric :n rifety-UcopThird F2rty ?.st: nn 1 F:er.a 4 tion r N.atim did h.a t
o, r.n,. L!:ar 26e-Rh! ;ers of ge o.,
s.
r [.'..k :_b
. rear.: r c;eraters.Lenith 39,8: live Vir ':e 1:, tii, f tr..wat:
both$g r.:.'.:.' f :.cti:.. (e.g., senior ret:ter E
I v: c.g::7. e ux;1: cry cremtors. enJ le ey. a.of h en:e,ed : h'.O h.s....i.:;n f.n:.r.c.:
The Memor.mdu:n at A; :eement nut irize: the ree:t; t und h::ri.d.!
c..,.at':n7>nce p ersonnel).
publ'ahed Selcw descr!bn the spec!:1 nu::ent tr.atefd p. :. !?
I:-au;- plant operating perunn:1 sh~.dd ha e 41nyed to mainu!n coep.t.tive regulatory p::'.!-j beln; c;unnSifes grea ct than cu:hc.N..G **
3:letirtu shift coversge v.ithout routine incp!r:.n ed by 1.he NRr: and the Stata b!ct:juri:di: tion. t:th DH2Lnd th8 h:nry use of overtime.The objc::lve IS of Sad Carelina with r ; rd to Nf!C cuaduct routinu periodic i:";. ;~
in have operuting perscnnel work e enfor:ese.ent activiiles c' the low. level for these po:tior:s ofit operatica f
I
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'fi,c4. %9(0, UNITED STATES NUCLE AR REGULATORY COMMISSION y
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z wAsmwoton. o. c. rosss S-June 15,1982 g
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TO ALL LICENSEES OF OPERATING PLANTS, APPLICANTS FOR AN OPERATING LICENSE, AND HOLDERS OF CONSTRUCTION PERMITS Gentlemen:
SUBJECT:
NUCLEAR POWER PLANT STAFF WORKING HOURS (Generic Letter No. 82-12)
On February 8,1982, we forwarded to you a copy of a policy statement issued by the Comission entitled " Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors." That policy statement has now been slightly revised and the revised version is attached to this letter. The forwarding letter (Generic Letter 82-02) stated that actions were underway to incorporate the Comission policy on working hours into Regulatory Guide 1.33 and into NUREG-0737 (Item I.A.1.3).
Publication of Regulatory Guide 1.33 is now anticipated in June 1982, following release of ANS 3.2.
Revised pages of NUREG-0737 that incor-porate the Comission policy on working hours are enclosed.
Our letter of February 8,1982 requested that you take action as necessary to revise the administrative section of your technical speci-fications to assure that your plant administrative procedures follow the revised working hour guidelines, including a provision for docu-mentation of authorized deviations which should be available for NRC review.
You should review your past actions to assure that they are consistent with the attached revised policy statement. Note that the revised guidelines are to be incorporated by October 1,1982.
Sincerely.
[ p e-l M)4ai y <- -
D 4
Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation
Attachment:
Revision to Item I.A.1.3 of NUREG-0737 8206161341 ls l
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1.A.1.3 SHIFT MANNING Pages I. A.l.3-1 through I. A.l.3-3 are replaced in their entirety by the following.
A bar in the margin indicates changes from che material originally included on these pages.
Position This position defines shift manning requirements for normal operation.
The letter of July 31, 1980 from D. G. Eisenhut to all power reactor licensees and applicants (copy attached) sets forth the interim criteria for shift staffing (to be effective pending general criteria that will be the subject of future rulemaking).
Overtime restrictions were also included in the July 31, 1980 letter.
)
Changes to Previous Requirements and Guidance Errors were discovered in the last colunn qf the table attached to the letter of July 31,1980. A corrected table is enclosed; a bar in the margin indicates the correction.
(See p. I.A.l.3-4.)
The overtime requirements have been rewritten to incorporate the provisions of a Commission policy statement on working hours and operator fatigue.
Clarification Licensees of operating plants and apolicants for operating licenses shall include in their administrative procedures (required by license conditions) provisions l
governing required shift staffing and movement of key individuals about the plant.
These provisions are required to assure that qualified plant personnel to man the operational shifts are readily available in the event of an abnormal or energency situation.
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These administrative procedures shall also set forth a policy, the objective of which is to prevent situations where fatigue could reduce the ability of operating personnel to keep the reactor in a safe condition.
The controls established should assure that, to the extent practicable, personnel are not assigned to shift duties while in a fatigued condition that could significantly reduce their mental alertness or their decision making ability.
The controls shall apgly to the plant staff who perform safety-related functions (e.g., senior reactor operators, reactor operators, auxiliary operators, health physicists, and key maintenance personnel).
IE Circular No. 80-02, " Nuclear Power Plant Staff Work Hours", dated February 1, 1980 (copy attached) discusses the concern of overtime work for members of the plant staff who perform safety-related functions.
The guidance contained in IE Circular No. 80-02 was amended by the July 31, 1980 letter.
In turn, the i
cvertime guidance of the July 31, 1980 letter was revised in Section I.A.1.3 cf NURG-0737. The NRC has issued a policy statement (attached) which further i
revises the overtime guidance as stated in NUREG-0737. This guidance is as l
follows:
Enough plant operating personnel should be employed to maintain adequate shif t coverage wichout routine heavy use of overtime. The objective is to have operating personnel wark a nomal 8-hour day, 40-hour week while the plant is operating.
However, in the event that unforeseen problems require substantial amounts of j
cvertime to be used, or during extended periods of shutdown for refueling, major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed:
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. An individual should not be permittec to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight a.
(excluding shif t turnover time).
b.
An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period (all excluding shift turnover tine).
A bgeag of at least eight hours should be allowed between work periods c.
(including shift turnover time).
d.
Except during extended shutdown periods, the use of overtine should be considered on an individual basis and not for the entire staff on shift.
Recognizing that very unusual circumstances may arise requiring deviation from the above guidelines, such deviation shal1 be authorized by the plant manager or his deputy, or higher levels of management.
The paramount consideration in such authorization shall be that significant reductions in the effectiveness of operating personnel would be highly unlikely.
Authorized deviations to the
]
working hour guidelines shall be documented and available for NRC review.
In addition, procedures are encouraged that would allow licensed operators at the controls to be periodically relieved and assigned to other duties away from
(
the control board during their tours of duty.
Operating license applicants shall complete these administrativ-aancedurr.s i
l before fuel loading.
Development and implementation of the administrative j
procedures at operating plants will be reviewed by the Office of Inspection I
and Enforcement beginning Oct.1,1982.
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4 52e Section III. A.I.2 for minimum staffing and augment capabilities for emergencies.
Aeolicability This requirement applies to all licensees of operating reactors and applicants for operating licenses.
- a Inplementation (1)
Overtime administrative procedures shall be established for operating reactors by Oct.1,1982 and by fuel loading for applicants for operating license.
(2)
Staffing requirements shall be completed by July 1,1982 for operating reactors and by fuel load for operating license applicants.
Type of Review A post. implementation review will be performed on operating reactors.
Applicants for operating licenses will be reviewed prior to implementation.
Dccumentation Reauired Tne documentation required is as noted in the letter of July 31, 1980.
Tcchnical Specification Changes Recuired Changes to Technical Specifications will be required for overtime administrative procedure and staffino requirements.
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5-References NUREG-0660 IE Circular No. 80-02, " Nuclear Power Plant Staff Work Ho rs," February 1,1980 Letter f rom D. G. Eisenhut, NRC, to All Power Reactor Licensees, July 31, 1980 Policy on Factors Causing Fatigue of Operating Personnel at Nuclear Reactors.
Ge S
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1 POLICY ON FACTORS CAUSING FATIGUE OF OPERATING i
PERSONNEL AT NUCLEAR REsCTORS Licensees of operating plants and applicants for operating licenses shall establish controls to prevent situations where f atigue could reduce the ability of operating personnel to keep the reactor in a safe condition.
The controls should focus on shif t staffing and the use of overtime--key job-related factors that influence fatigue.
l The objective of the controls would be to assure that, to the extent practicable,
]
personnel are not assigned to shift duties while in a fatigued condition that could significantly reduce their mental alertness or thei-decision making capabili ty. The controls shall apply to the plant staff who perform safety-related functions (e.g., senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel).
i
~
Enough plant operating personnel should be employed to maintain adequate shift l
c verage without routine heavy use of overtime.
The objective is to have (perating personnel work a normal 8-hour day, 40-hour week while the plant is operating.
However, in the event that unforeseen problems require substantial amounts of overtime to be used, or during extended periods of shutdown for refueling, major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed:
a.
An individual should not be permitted te work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight (excluding shift turnover time).
b.
An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period (all 4
excluding shift turnover time).
c.
A break of at least eight hours should be allowed between work periods (including shift turnover time).
i d.
Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift.
R2 cognizing that very unusual circumstances may arise requiring deviation from the above guidelines, such deviation shall be authorized by the plant manager or his deputy, or higher levels of management.
The paramount consideration in such authorization shall be that significant reductions in the effectiveness of operating personnel would be highly unlikely.
In addition, procedures are encouraged that would allow licensed operators at the controls to be periodically relieved and assigned to other duties away from the c:ntrol board during their tour of duty.
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e UNITED STATES NUCLEAR REGULATORY COMMISSION e
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Septerrber 20, 1982
^
wasmwcvem. o. :. rossa TO ALL PRESSURIZED POWER REACTOR LICENSEES Gentlemen:
SUBJECT:
NUREG-0737 TECHNICAL SPECIFICATIONS (GENERIC LETTER NO. 82-16) e a NUREG-0737 " Clarification of TMI Action Plan Requirements" identifies those items for which Technical Specifications are required.
Technical Specifi-cations' are required to provide necessary assurance that facility operation is maintained within the limits detemined acceptable following implementation 4
at each facility.
The scope and type of specification should include appro-priate actions if a limiting condition for operation cannot be met, and for installed. equipment, relevant surveillance requirements.
A number of NUREG-0737 items which require Technical Specifications were scheduled for implementation by December 31, 1 981.
Each of those items is discussed in Enclosure 1.
Included in the discussion is guidance on the scope of a specification which the staff would find acceptable.
are samples in Standard Technical Specification fomat with blanks or
!~
parentheses appearing where the infomation is pfant specific.
It includes appropriate pages as background infomation for facilities thpt do not have
-Standard Technical Specification's.
These samples are for your information only.
We solicited comments on proposed Technical Specifications from all pressurized water reactor owners groups and Atomic Industrial Forum.
Appropriate coments l
have been incorporated.
We request that you review your facil.ity's Technical Specifications to detemine if they are consistent with the guidance provided r
I in Enclosure 1.
For those items where you identify deviations or absence of a specification, we request that you submit an application for a license l
amendment.
If some of the items are not yet implemented at your facility, you should submit an amendment request at the time they are implemented.
i l
Please respond within 90 days of receipt of this letter.
This request for infomation was approved by the Office of Management and i
Budget under clearance number 3150-0065 which expires May 31, 1983.
Coments on burden and duplication may be directed to the Office of Management and Budget. Reports Management Room 3208, New Executive Office Building, Washington, D.C. 20503.
Sincerely.
,nonwrf.
llW 1
nt 0D (
m,e r T.
sen Division of.icensing Y'_fo,0 Office of Nuclear Reactor Regulation 90p b0,
ENCLOSURE 1 STAFF GUIDANCE OF NUREG-0737 TECHNItAL SPECIFICATIONS (ITEMS SCHEDULED BY DECEMBER 31, 1981) j (1)
STA Training (I. A.1.1.3)
Our July 2,1980 letter provided model TSs for TMI lessons learned Category "A" items.
Included were TSs that spe 4
cations, training and on-duty requirements for gified the qualifi-i the Shift Technical l
Advisors (STA).
STA training requirements are under the consideration by the Commission.
Further guidance will be provided pending the decision on the requirements by the Commission.
(2)
Limit Overtime (I. A.1.3) i On June l'5,1982 we transmitted to licensees of operating plants a revised version of the Commission's Policy Statement on nuclear power plant staff working hours.
In the same letter we also transmitted revis' d pages of NUREG-0737 (Item..I.A.1.3).
The administrative sec-e tion of the technical specifications should be revised to require procedures that follow the policy statement guidelines.
An acceptable specification would be "the amount of overtime worked by plant staff 4
members performing safety-related functions must be limited in accordance with the NRC Policy Statement on working hours (Generic Letter No.
i 82-12)," or following the model TSs in Enclosure 2.
l (3)
Short Term Auxiliary Feedwater System Evaluation (II.E.1.1)
The objective of this item is to improve the reliability and performance of the auxiliary feedwater (AFW) system.
TSs depend on the results j
of the licensee's evaluation and the staff review, and are being developed L
separately for each plant.
The limiting conditions of operation (LC0's) and surveillance requirements for the AFW system.should be similar to other safety-related systems.
(4) Safety Grade AFW System Initiation and Flow Indication (II.E.1.2)
The AFW system automatic initiation system was to have been control grade by June 1,1980 and safety grade by July 1,1981; the AFW system flow indication was to have been control' grade by January 1, 1980 and safety grade by July 1,1981.
The control grade requirement was part of the short term lessons learned activities, and model TSs' were included with our July 2,1980 letter.
These TSs are considered adeouate as TSs for the safety grade requirement.
.s L
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.e 6.2 DRGANI ZATION UNIT STAFF 6.2.2 The Unit organization shall be as shown in Figure 6.2-2 and:
f.
Administrative procedures shall be developed and implemented to limit the working hours of unit staff who perform safety-related functions; e.g., senior reactor operators, reactor operators, health physicists, auxiliary operators, and key maintenance personnel.
Adequate shift coverage shall be maintained without routine heavy use of overtime.
The objective shall be to have operating personnel work a normal 8-hour day, 40-hour week while the plant is operating.
However, in the event that unforseen problems require substantial amounts of overtime to be use, or during extended periods of shutdown for refueling, major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed:
a.
An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight, excluding shift turnover time, b.
An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, non more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any
~
1 seven day period, all excluding shift turnover time.
c.
A break of at least eight hours should be allowed between work periods, including shift turnover time.
d.
Except during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entice staff on a shift.
Any deviation from the above guidelines shall be authorized by the (Plant Superintendent) or his deputy, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation.
Controls shall be included in the procedures such that individual overtime shall be reviewed monthly by the (Plant Superintendent) or his designee to assure that excessive hours have not been assigned.
Routine deviation from the above guidelines is not authorized.
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