ML20137E310

Forwards Response to Questions Raised During Region II 1996 Training Managers Conference Re Requalification Hours & Requalification Training

ML20137E310
Person / Time
Site:	Browns Ferry
Issue date:	03/04/1997
From:	Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Greeman R TENNESSEE VALLEY AUTHORITY
References
NUDOCS 9703270150
Download: ML20137E310 (2)

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March 4, 1997 Tennessee Valley Authority ATTN: Mr. R. Greenman Training Manager  :

Browns Ferry Nuclear Plant .

P. O. Box 2000 Decatur, AL 35609 2000 i

SUBJECT:

RESPONSE TO QUESTIONS RAISED DURING THE REGION II 1996 U. S.

NUCLEAR REGULATORY COMMISSION (NRC) TRAINING MANAGERS

• CONFERENCE r

Dear Mr. Greenman:

This is forwarding the response to the four questions raised during our I conference. After consultation with headquarters, these responses were '

determined.

a) What is the basis for requalification hours having to be the same for  :

active versus inactive operators?  !

10 CFR Part 55.55(e) recognizes the difference between licensed omrators who are actively performing the function of an operator and t1ose who are not, and defines required periods of watchstanding under ,

instruction that must be completed in order to regain active status if  !

proficiency is not maintained. However Part 55.59, "Requalification,"

does not differentiate between active operators and inactive operators.  :

Each licensed operator is required by Part 55.59 to successfully complete a requalification prograin developed by the facility licensee in -

accordance with a systems approach to training. Logically the job '

tasks, and therefore the training requirements for a licensed operator .

do not depend on an inactive or active watchstanding status. NRC's  !

position on this issue was clearly stated in NUREG 1262, " Answers to Questions at Public Meeting Regarding Implementation of Title 10. Code of Federal Regulations, Part 55 on Operators' Licenses." The answer to question 335 states that the same requalification program applies to operators on shift as well as off shift.

b) Can an operator on-site be allowed to not be in requalification training if he is in a developmental. assignment, as an operator off site in a developmental assignment is allowed? 1 No. NRR's position is that individuals who are licensed will participated in a facility's continuous requalification program, as required by Part 55.53(h). Exceptions to this requirement are considered in accordance with Part 55.59(b), for personnel who relocated l' out of the vicinity of the facility for developmental purposes, such as a rotation at INP0, or for personnel who take a leave of absence to advance their education.

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4 c) Can the requirement be changed to allow reactivity manipulations for

, initial candidates to be accomplished on the simulator?

The present requirement reflects the Commission's view at the time of I the rule revision that candidates for operator licenses should have as a 4

minimum the practical ex>erience of performing reactivity manipulations

, on the plant for which t1ey seek a license. While it may be possible to i change the rule, depending on the views of the present Commission and of the staff, the requirement is not presently considered overly burdensome to the point that rulemaking at this time is warranted. For facilities in extended shutdowns, NRC has allowed candidates to take licensing examinations and then has held issuance of their licenses pending completion of the requirement. Under appropriate circumstance, NRR can

] exempt candidates from the requirement.

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, d) Was the recent GFES examination time validated and should it be ?

The October 1996 GFES examination was time validated. The examination '

is not intended to be time limiting, within reason. Based on industry feedback, we have increased the allowed time for the GEFS examination from 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

I trust these answers will be of assistance to you.

1 Also, please note we have a need to move the Training Manager's Conference to '

November 12 and 13, 1997.

Sincerely.

(Original signed by T. A. Peebles) ,

Thomas A. Peebles, Chief Operator Licensing and Human '

Performance Branch

! Division of Reactor Safety Docket Nos.: 50-259, 50-260, 50 296 i

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