ML20149D989
| ML20149D989 | |
| Person / Time | |
|---|---|
| Issue date: | 05/19/1994 |
| From: | Allison D NRC |
| To: | NRC |
| References | |
| NUDOCS 9405260101 | |
| Download: ML20149D989 (2) | |
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NUCLEAR REGULATORY COMMISSION iy* . i W ASmNG TON. D. C. *0555
\.l . . l JUL 2 21991 MEMORANDUM FOR: James M. Taylor Executive Director for Operations FROM: Edward L. Jordan, Chairman Committee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 201 The Committee to Review Generic Requirements (CRGR) met on Tuesday, February 26,1991 from 8:00 a.m. to 1:00 p.m. A list of attendees at the meeting is enclosed (Enclosure 1). The following items were discussed at the meeting:
- 1. E. Rossi and T. Collins of NRR provided a briefing on the status of staff actions to address potential problems with net positive suction head for pumps in the standby liquid control systems of boiling water reactors. This matter is discussed in Enclosure 2.
- 2. B. Morris and S. Bahadur of RES provided a discussion of a proposed rule on selection, qualification and training of nuclear power plant personnel. The CRGR provided a number of comments and it was agreed that the staff would return with a completed package for completion of the CRGR review in the near future. This matter is discussed in Enclosure 3.
- 3. E. Rossi and T. Dunning of NRR presented for CRGR review a draft generic letter requesting (1) revised technical specifications and (2) exceptions to 10 CFR 50, Appendix J. Such requests would be'for the purpose of extending surveillance and testing intervals for consistency with a (longer) 24 month fuel cycle. The CRGR recommended in favor of the letter, subject to some revisions which were to be coordinated with the CRGR staff. This matter is discussed in Enclosure 4.
- 4. The CRGR briefly discussed a draft generic letter on licensee's programs for procurement and dedication of commercial grade equipment. Review of this matter had begun at Meeting No. 197. A revised package had been received on February 25, 1991. NRR requested and it was agreed that the CRGR and its staff would make an expedited determination on whether the revised package could be handled by negative consent, rather than by discussion at a meeting. If so, it might be feasible to issue the letter prior to scheduled Congressional hearings on March 6. If not, it would be considered at a regular meeting in the future.
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.O Questions concerning these meeting minutes should be referred to Dennis Allison (49-24148).
OriginalSigned by:
Denwood F. Ross Edward L. Jordan, Chairman Committee to Review Generic Requirements
Enclosures:
As stated cc w/ encl:
Commission (5)
SECY J. Lieberman P. Norry D. Williams W. Parler Regional Administrators CRGR Members Distribution:
Central File w/o encl.
PDR (NRC/CRGR) w/o encl.
S. Treby J. Calvo P. Kadambi A. Thadani M. Taylor L. 8. Marsh J. Sniezek 8. Grimes J. Heltemes U. Potapovs E. Rossi E. Greenman, RIII T. Collins W. Schaeffer, RIII B. Morris B. Burgers, RIII S. Bahadur M. Peck, RIII T. Dunning T. McIntyre D. Allison D. Ross J. Conran E. Jordan CRGR S/F CRGR C/F T
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,9-ENCLOSURE 1 ATTENDANCE LIST CRGR HEETING NO. 201 February 26, 1991 CRGR Members NRC Staff D. Ross (for E. Jordan) T. Collins E. Rossi G. Arlotto J. Carter J. Moore R. Lobel F. Miraglia P. Kadambi S. Newberry R. Blough F. Costanzi J. Murphy (for B. Sheron) S. Bahadur M. Fleishman S. Collins (for L. Callan) M. J. Roe J. Roe CRGR Staff J. Wermeil M. Malsh D. Lange M. L. Roe J. Conran N. Hunemuller I. Schoenfeld S. Treby D. Michaels D. Allison T. Dunning J. Pulsipher A. Droz H. Conrad
o Enclosure 2 to the Minutes of CRGR Meeting No. 201 Briefinq on Status of Staff Actions to Address a Potential Problem with Net Positive Suction Head for Pumps in the Standby Liquid Control System for Boiling Water Reactors February 26, 1991 TOPIC E. Rossi and T. Collins of NRR provided a briefing on the status of. the subject actions. A design problem had been found at Quad Cities by testing.
When standby liquid control system operations were begun with low allowable tank levels and high allowable tank temperatures, a situation was reached in less than 20 minutes where there was inadequate NPSH for the pumps and they began to cavitate.
An information notice had been issued on February 15, 1991. An industry regulatory response group had been activiated. Partial information had been received regarding the potential applicability of the problem to other BWR's and further information-was being developed. Further action might be needed, depending on the nature of additional information being gathered.
Copies of the handouts used by the staff in its briefing are provided as an attachement to this enclosure.
BACKGROUND There was no review package since this was a briefing.
CONCLUSIONS / RECOMMENDATIONS Because this was a briefing rather than a review, there were no conclusions or recommendations.
However, the CRGR believed the staff's actions and plans were fully appropriate. The CRGR also believed that the inspector responsible for uncovering the problem (Micheal Peck) deserved credit for pursuing the issue.
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Adequacy of Testing for SLCS NPSH 1
Tim . Collins
, Reactor Systems Branch j Division of Systems-Technology -
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Feb. 26,1991. a
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't NOTES FOR CRGR BRIEFING ON- SLCS SLCS FUNCTION-In the event of control rod failure, inject !
sufficient liquid. poison to shutdown the l reactor and maintain it shutdown under- !
cold xenon-free conditions '
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SYSTEM CONFIGURATION Two positive displacement pumps Single poison storage tank Separate d 1 min water test tank Explosive (squib) valves in discharge line Three differor+ suction configurations i J
"Y" (Common suction line)
"H" (Two suction lines)
- cross-connect valve locked open
- cross-connect valve locked closed
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SYSTEM REQUIREMENTS DETERMINED BY ATWS ]
RULE-1 Capability toLinject solution equivalent in- !
control. capacity to 86.gpm of 13 wt %
i naturally enriched sodium pentaborate j solution l
f Requirements met by either single pump j p operation with higher concentration and/or isotopic enrichment; or, dual . pump l t
operation i I
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! OUAD CITIES PROBLEM i '
Inspector questioned adequacy of.available .
L NPSH for 2- pump operation -needed to j satisfy ATWS Rule '
e -
Licensee hired a consultant to review-
- calculations and concluded that.NPSH was
! marginal and planned a test-Test was a single pump test with suction from test tank Test tank-level was lowered to simulate minimum. level.in. poison tank '
Pump showed: signs of-cavitation at temperatures less.than the maximum allowable for-the solution-a
, a _ _ _ _ . . . n . . . - . - y e
- ' l rSTAFF CONCERNS 1 Pump mayl fail prior to injection of !
adequate volume-of solution as a result of R Cavitation from inadequateL NPSH I Purnp-to- pump effects in common suction line during two-pump operation :
y RRG was therefore activated to assess adequacy of NPSH testing INFORMATION PROVIDED BY RRG AT 2/21 MEETING i
Four configurations in industry:
- 1) single pump operation with; isotopically ;
enriched boron;-pumps Interlocked to prohibit 2 pump: operation-(21 units); j y
- 2) two pump,2 suction line operation;with. l cross-connect valve normally closed (3- 1
- 5. units) u
- 3) two pump, 2 suction lineLoperation with.
I cross-connect valve normally open (5-7 units) i
- 4) two pump one suction line operatiop-(5 units) i i
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TEST- RESULTS TO DATE:. !
Category 1 plants:
Monticello ran test from poison tank down to zero tank level at max temp River Bend: Ran pre-op test at max temp and min level to demonstrate adequate NPSH t All plants perform NPSH tests at limiting temp and level as part of pre-op testing -
Category 2 Plants: J l
Limerick pre-op test (poison tank to vessel) at minimum level and maximum temp to verify NPSH adequacy l
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! Category 3 Plants:
Dresden ran two pump test from poison '
tank-to'other on site tanks down to.
suction line- uncovery at maximum permissible temperature Quad Cities ran single pump test for NPSH - cavitation experienced NMP-2 ran single pump NPSH tests-during pre-op. Two pump FLOW RATE ONLY tests were not at limiting NPSH conditions but showed -no interactions Category 4 Plants: '
t Brunswick did a two pump test for 10 minutes at temp and level simulating limiting. conditions Grand Gulf did single pump NPSH test during pre-op. Two pump tests.were FLOW RATE ONLY tests (not at limiting NPSH conditions) and showed no interaction problem.
Clinton .ran single . pump NPSH tests at limiting, conditions. Two pump tests showed no interaction problems but'were-not at limiting conditions.
.._a _-m - _ _-.. m _w,i es w. 9iTh*
k STAFF ACTION PLAN ;
Review RRG submittal on all plant test results - Due on March 1 ,
Issue Bulletin as appropriate based upon test information Bulletin would request demonstration based upon test data of adequacy.of available. .
NPSH under the .most limiting conditions !
including two pump operation.
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Enclosure 3 to the Minutes of CRGR Meeting No. 201 Proposed Rule on Selection, Qualification, and Training of Nuclear Power Plant Personnel February 26, 1991 TOPIC B. Morris (RES) and S. Bahadur (RES)sedson-nel. present Briefing slides used by the staff to guide their presentation and discussion with the Committee at this meeting are enclosed (Attach BACKGROUND ment 1).
1.
transmitted by memorandum dated FebruaryThe were docum 14, 1991, C.J. Heltemes, Jr to E.L. Jordan; that initial review package included the following s:
docu a.
Draft Commission Paper (undated), " PROPOSED RULEMAKING FOR PERSONNEL", and attachment as follows: SELECTION i.
draft rule and statement of considerations.; aft Fede 2.
At Meeting No. 201, as a part of their presentation of the proposed ru thedraft the staffFRN provided revised transmitted pages initially (reflecting NRR and OGC to CRGR rom comments)
(Attachment 2).
CONCLUSIONS / RECOMMENDATIONS ~
because the supporting Regulatory Analysis had not yet been provided to CRGR.
. 201, and im ry Guides i
comments on the portions of the overall package received to dat j number of recommendations for improvement of the package to be coi the staffonfor thisincorporation in a revised package to be discussed at th meeting item.
e next follows: The principal CRGR comments and recommendations were as 1.
Although the circumstances giving rise to this proposed action raised to this proposed action, the Committee felt that th ,
i generic positions on training and qua'.fication (e.g. , i accident management and quality assurmce) should ce evaluated as in accordance with CRGR Charter. i that the package be revised to include additional discussion m clearer the need and/or justification for those provisions of the propo rule identified (in the draft Cctmission Paper) as going teyond current guidance of the Commission's Policy Statement on Training and Quali! .
.. justification for those provisions of the proposed rule identified (in the draft Commission Paper) as going beyond current guidance of the Commission's Pol;cy Statement on Training and Qualification.
2.
As a specific item of concern, the Committee recommended that the staff clarify their intent with regard to what is expected of licensees in developing and implementing training for severe accident management. On its face, the proposed 180 day implementation schedule for this rule does not seem consistent with the projected date for completion of the NUMARC severe accident management effort.
This raised the concern that licensees simply could not comply with the accident management training provision of the proposed rule as written and would be required to seek exemptions from this provision, at least initially.
3.
Noting that Section 306 of the Nuclear Waste Policy Act (NWPA) addresses training of nuclear- power plant " operating personnel", the Committee had the following questions regarding the scope of the rule as currently written:
a.
Should contractor personnel as well as utility employees be included under the rule, as is done in the current version?
b.
Should training for construction phase activities (e.g., quality control personnel) be included under the new rule?
The Committee recommended that the staff obtain OGC legal opinions on these questions for discussion when the revised rule package is presented to CRGR at a future meeting.
4.
The Committee recommended that the proposed rule not address " selection" .
requirements for training programs. This seems to go beyond both NWPA requirements Training and the Commission's guidance in their Policy Statement on and Qualification.
The sentiment was expressed that it is sufficient for NRC to judge the adequacy of licensees' training programs based on the results of the program (i.e., demonstrated qualifications of operating personnel) without trying to mandate the criteria / qualifications of those entering the training programs.
5.
The Committee recommended that the staff clarify and make consistent the references to ". .all modes and conditions. of operation.." where that term appears 11, and 26in of thethe package FRN), (e.g., at p.5 of the Commission Paper and pp. 6, between " abnormal", " emergency", and " accident" conditions; an clearer explicitly whether " accident" refers design basis accidents or '
severe accidents or both.
6.
The Committee recommended that-the staff make clearer the meaning of the term " vendor" in the discussion of vendor-developed training programs in the package. .
Specifically, does this refer to vendors generally, to NSSS '
vendors, or is it intended (by context) to refer only to Part 52 vendors?
Whatever the case, the staff should add a cautionary note to the discus-sion in the FRN that, although the proposed 50 120 does not prevent a vendor from training power plant personnel or from developing a training and qualification process for licensees, the licensees are ultimately
r j
,. responsible for adequate training of their employees and, therefore, vendors are not included explicitly in the proposed rule.
7.
For clarity, in listing the categories of nuclear power plant personnel for whom training must be provided, the Committee recommended that the ;
terms reactor operator and senior reactor operator be used, rather than simply operators and senior operators.
{
8.
In the draf t Commission Paper at p. 5, in the discussion of contractor personnel covered by the rule, the Committee recommended that the staff replace by covered thethe words "equivule proposed rule". :t position" with the term " job categories 9.
The Committee requested that the staff provide to CRGR the guidance that is being prepared for use by inspectors in the implementation reviews planned in connection with this proposed rule.
- 10. .
As a final point, the Committee requested that the staff be prepared to address pertinent next meeting safetyongoal with CRGR this considerations matter. for the proposed rule at the The staff agreed to consider these comments and recommendations, and to address them in the next meeting with the Committee on this item.
The staff will also prepare a revised package incorporating, as appropriate, comments and recommendations.
CRGR's Regulatory Analysis and implementing Reg. Guides; an Environme finding of no significant impact, it is expected to be very b '
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BRIEFING FOR THE COMMITTEE TO REVIEW GENERIC REQUIREMENTS (CRGR)
THE PROPOSED RULE ON SELECTION, TRAINING, AND QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL
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BY DIVISION OF REGULATORY APPLICATIONS OFFICE OF NUCLEAR REGULATORY RESEARCH i
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BILL MORRIS X 23750 SHER BAHADUR X 23775 MORT FLEISHMAN X 23794 FEBRUARY 26,1991 !
A 44ac.L men f 1 Yo Encleture 3
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r OBJECTIVE OF THE PROPOSED RULE l
TO MEET THE DIRECTIVE OF SECTION 306 '0F THE NUCLEAR WASTE POLICY ACT;0F 1982, AS INTERPRETED.
BY THE U.S. COURT OF' APPEALS FOR THE DISTRICT OF:
4
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. COLUMBIA CIRCUIT, THAT. REQUIRED.NRC TO ESTABLISH 3
REQUIREMENTS FOR THE -TRAINING AND QUALIFICATIONS 0F NUCLEAR-POWER' PLANT-PERSONNEL. ;
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PERSONNEL CATEGORIES COVERED'BY"THE RULE OPERATORS AS DEFINED IN 10-CFR 55.4.
. SENIOR OPERATORS ' AS DEFINED IN 10-- CFR 55.4. ,
NON-LICENSED OPERATORS.
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MECHANICAL MAINTENANCE.
h' .
ELECTRICAL MAINTENANCE.
INSTRUMENT AND CONTROL.
HEALTH PHYSICS AND RADIATION PROTECTION.
CHEMISTRY AND RADIO-CHEMISTRY. '
\ SHIFT TECHNICAL ADVISORS.
PERSONNEL WITH OTHER PLANT SPECIFIC TITLES-I I WHO PERFORM FUNCTIONS-ASSOCIATED WITH THE AB0VE CATEGORIES.
1 ON-SITE MANAGERIAL, SUPERVISORY , .
PROFESSIONAL,'AND TECHNICAL STAFF.
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STAFF PERFORMING QUALITY. ASSURANCE
'y FUNCTIONS AS' DESCRIBED IN 10-CFR-U PART 50, APPENDIX.B. .
[. PERSONS RESPONSIBLE FOR. ACCIDENT ASSESSMENT.AND MITIGATION.
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1 RECORDS RETENTION REQUIREMENTS 1
EACH APPLICANT AND LICENSEE WOULD BE ,
REQUIRED TO-RETAIN FOR'51 YEARS, MATERIALS AND RECORDS RELATED TO SELECTION REQUIREMENTSLAND TRAINING PROGRAMS, QUALIFICATION RECORDS SHOULD BE RETAINED DURING THE PERIOD 0F AN INDIVIDUAL'S EMPLOYMENT.
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a IMPLEMENTATION / CERTIFICATION 4
EACH APPLICANT, Ir/ (180 DAYS AFTER THE1 EFFECTIVE DATE OF THE RULE) OR 18 MONTHS PRIOR TO FUEL .
LOAD, WHICH EVER IS LATER, AND1EACH LICENSEE, BY :
(180 DAYS ~AFTER THE EFFECTIVE DATE OF THE RULE)
WOULD.BE REQUIRED TO SUBMIT <TO THE COMMISSION A CERTIFICATION BY A DULY AUTHORIZED 0FFICER.0F'-
THE APPLICANT 0R LICENSEE 1THAT THE PERSONNEL SELECTION, TRAINING, AND QUALIFICATION 1 PROGRAMS' HAVE BEEN IMPLEMENTED.- (NRC FORM AS ATTACHED) 6 i
f:TsC FORM 393 2 90) L'.S. !TJCIJAR FI:L'1AREY C2ti!SSIC 10 CFR i 10.120 Approved by OME e
) COO (-XXXX Expares 7.X 4X-A SELECTION, TRAINING, AND OUAllFICATION PROGRAM CERTIFICATION INSTRUCTIONS.
10 CFR l 50.120.
This fem is to be filed for initial certification of selection, training, and qualification prcgrams pursuant t Provide the following information and check the appropriate boxes.
IACILITY LOCKET NUMBER 50-APFLICANT/ LICENSEE LATE that ma st the requirainents of 10 CFR S 50.120This as to certif y that the above named f acility appincant/ licensee has ample For your information, as andicated belcm. the above named applicant's/ licensee's selection, training, and qualification programs have been implemente SELECTION TRAINING FROGRAM QUALIFICATICH PROGRN1 FROCW.M For the checked programs to the right, we conform -
to the guidance contained in Revision , to Regulatory Guide 1.8.
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.or the checked programs to the right, we conform to the guidance contained in Revision _ to Tsegulatory Guide 1.6 with exceptions as described below. w for the checked programa to the right, we have i treplemented the program with the method descr3 bed )
below.
CESCRIPTION OF EXCEPTIONS AND/OR MET!!ODS TO BE USED ECR IMPLEMENTATION (Attach additionalas pagets) necessary)
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Any f alse statement or caission in this ecument, including attacnments, may be subject to cav11 and criminal sanctacns cu tat under penalty of perjury that the information an this document and attachment is true and correct.
SIGNATUTJ - AJTHORIZIO RIFRESENTATIVE TITLE DATE ln accorcance with 10 CFR l 50.120, Selection, training, and qualification of nuclear power plant personnel, Ents form snati t, submitted to the NRC as follows:
' ?Y t'All AOORESSED TO: Director. Office of Nuclear Reactor Regulation EY DELIVERY IN PERSON.
U.S. Nuclear Regulatory Commission Washington, DC 20555 TO THE NRC CFFICE AT: 13145 Rockvtlle Pike Rockville. Marylana
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ASSOCIATED REGULATORY GUIDE l
j THE-PROPOSED RULE ON SELECTION, TRAINING, AND ,!
QUALIFICATION.0F NUCLEAR POWER PLANT PERSONNEL WOULD. 1 BE ACCOMPANIED BY A REGULATORY. GUIDE:- I i
. SELECTION, TRAINING, AND QUALIFICATION FOR NUCLEAR POWER 1 PLANTS PERSONNEL (REVISION TO REGULATORY GUIDE 1.8) ,
THIS REGULATORY GUIDE (I) PROVIDES GUIDANCE ON DEVELOPING JOB SELECTION, TRAINING,lAND' QUALIFICATION ,
DETERMINATIONS FROM A1 SYSTEMATIC J ANALYSIS OF; JOB: PERFORMANCE REQUIREMENTS, (II) ENDORSES THE RECENT ;
VERSION OF1 ANSI /ANS-3.1- ,
SELECTION, j QUALIFICATION, AND TRAINING 0FiPERSONNEL H FOR NUCLEAR POWER PLANTS.
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l RULEMAKING MILESTONES CRGR REVIEW -(PARTIAL) FEBRUARY 26 ACRS REVIEW MARCH 6.AND 7- ;
CRGR COMPLETED REVIEW MARCH 15 1
SUBMIT TO EDO APRIL 1 "
SUBMIT FOR COMMISSION REVIEW AND APPROVAL APRIL 16 !
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2/ec.l91 List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Criminal penalties, Fire prevention, Incorporation by reference, Intergovernmental relations, Manpower training programs, Nuclear power plants and reactors, Occupational safety and health, Radiation protection, Reactor siting criteria, Reporting and recordkeeping 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, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Part 50 as follows:
PART 50 - DOMESTIC LICENSING OF PRODUCTION AND UTillZATION FACILITIES
- 1. The authority citation for 10 CFR Part 50 is revised to read as follows:
Authority: Secs. 102, 103, 104, 105, 161, 182, 183, 186, 189, 68 Stat, 936, 937, 938, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244, as amended (42_ U.S.C. 2132, 2133, 2134, 2135, 2201, 2232, 2233, 2236, 2239, 2282); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246, -1 (42 U.S.C. 5841, 5842, 5846).
Section 50.7 also issued under Pub. L.95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851). Section 50,10 also issued under sets. 101, 185, 68 Stat. l 23 A tta c h men i 1 he Enclo s wre 3
936, 955,. as amended (42 U.S.C. 2131, 2235); sec. 102, Pub. L.91-190, 83 Stat. 853 (42 U.S.C. 4332). Sections 50.13, 50.54(dd), and 50.103 also issuea-under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138). Sections 50.23, 50.35, 50.55, and 50.56 also issued under sec.185, 68 Stat. 955 (42 U.S.C.
2235). Sections 50.33a,- 50.55a, and Appendix Q also issued under sec. 102, Pub. L.91-190, 83 Stat. 853 (42 U.S.C. 4332). Sections 50.34 and 50.54 also issued under sec. 204, 88 Stat. 1245 (42 U.S.C. 5844). Sections 50.58, 50.91, and 50.92 also issued under Pub. L.97-415, 96 Stat. 2073 (42 U.S.C. 2239).
Section 50.78 also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152).
Sections 50.80 through 50.81 also issued under sec. 184, 68 Stat. 954, as
/ amended (42 U.S.C. 2234). ppendix F also issued under sec.187, 68 Stat. 955 (42 U.S.C. 2237).
Q d.,n go./2o a d ^ u Ml4 4 h eb 3*'of U S'b Wade folict Acf*0 M z W2U'M / M -
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273);
C< *w( $ 0. t 2 0
/ ll50.46(a) and (b), 50.54(c)3are issued under sec. 161b, 161i and 1610. 68 Stat. 948, 949, and 950 as amended (42 U.S.C. 2201(b), 2201(i), and 2201(o));
sl50.7(a), 50.10(a)-(c), 50.34(a) and (e), 50.44(a)-(c), 50.46(a) and (b),
50.47(b), 50.48(a), (c), (d), and (e), 50.49(a), 50.54(a), (i), (i) (1), (1)-
. (n), (p), (q), (t), (v), and (y), 50.55(f), 50.55a(a), (c)-(e),. (g), and (h),
50.59(c), 50.60(a), 50.62(c), 50.64(b), and 50.80(a) and (b) are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and sis 0.49(d),,(h'),
and (j), 50.54 (w), (z), (bb), (cc), and (dd), 50.55(e), 50.59(b), 50.61(b),
50.62(b), 50.70(a), 50.71(a)-(c) and (e), 50.72(a), 50.73(a) and (b), 50.74, 50.78, and 50.90 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
I 24 .
o l
- 2. Section 50.120 is added to read as follows:
l s'50.120 Selection, training, and qualification of nuclear power plant i personnel.
(a) Applicability. The requirements of this section apply to each applicant for (applicant) and each holder of an operating license (licensee) i for a nuclear power plant of the type specified in i 50.21(b) or i 50.22. l
'1 u
(b) Definitions. As used in this section:
learnina ob.iective means an instructional goal that is expressed in terms of measurable performance. A learning objective:
(1) Describes er implid the conditions under which the performance
must occur; (2) Delineates the standards and evaluation criteria that must be met for mastery of the performance; and (3) Describes expected performance after training.
Qualification crocram means the planned, organized, and managed sequence of interactions between individuals and evaluators designed to demonstrate and document successful acquisition by the trainee of the proficiency of skills, knowledge, and abilities required for, job performance.
d 25 .
i j ..
e.
Selection crocram meAns those activitips related to choosing nuclear y ey cisds% s Co b es.c7ee per~s onne/ y /
V .
power plant personnel based on training program And job performance A
requirementsgne!"dhg job , qui. ;d physic 9 char.actaristict F h19na $ '
Trainino crocram means the planned, organized, and cor,tra' equence /
of interactions between individuals and instructional resources and processes designed to establish and maintain skills, knowledge, and abilities required for wccc :fs JobY performance. l V
(c) Requirements.
(1) General requirements. Each applicant, by (180 days'after the effective date of the rule) or 18 months prior to ruel load, whichever is later, and each licensee, by (180 days af ter the effective date of the rule),
shall establish, implement, and maintain a selection program, a training program, and a qualification program considering all modes and conditions of operation including shutdown, normal, abnormal, emergency, and accident conditions, for nuclear power plant personnel in' the following categories:
(i) Operators as defined in 10 CFR 55.4. i l
(ii) Senior operators as defined in 10 CFR 55.4 (iii) Non-licensed operators.
(iv) Mechanical maintenance.
(v) Electrical maintenance. H (vi) Instrument and control.
(vii) Health physics and radiation protection.
'(viii) Chemistry and radio-chemistry.
26 1
(ix) Shift technical advisors.
(x) Personnel with other plant specific titles who perform functions sfmilar to those in the above categories.
(xi) On-site managerial, supervisory, and engineering support personnel.
(xii) Personnel performing quality assurance functions as described in 10 CFR Part 50, Appendix B.
(xiii) Personnel responsible for accident assessment and mitigation.
(2) Selection program. Under its selection program each applicant and each licensee shall select personnel who either -- ,
idebthied (i) Have those job-required skills, knowledge, and abilities which are v based on the systematic analysis performed under paragraph (c)(3)(ii)(A) of.
this section; or e n h>7 eve) .
(ii) Have3skills, knowledge, and abilities sufficient to satisfactorily ./
complete the applicable training and qualification programs.
(3) Training program.
(i) Under its training program, each applicant and each licensee shall establish, implement, and maintain initial and continuing training programs for personnel listed in' paragraph (c)(1) of this section. These programs must be derived from a systems approach to training as described in paragraph-(c)(3)(ii) of this section.
(ii) The systems approach to training must contain, as a minimum, the following essential steps:
27
I o
1 (A) Analysis. Perform.a systematic analysis appropriate to the job to determine performance requirements and training needs of job incumbents.
(B) Derivation of learning objectives. Where the analysis has indicated the need for training, derive from the analysis a set of learning objectives that describe the standard of desired job performance after training.
(C) Design and implementation. Design training programs based on learning objectives selected for training, and implement the program to achieve those learning objectives.
(D) Trainee evaluation. Develop tests and testing procedures that are in accord with the job performance requirements and the learning objectives derived from the analysis. Administer the tests to demonstrate that the trainees meet the learning objectives.
(E) Program evaluation. Develop and implement a plan for periodic evaluation of the effectiveness of the personnel training program as indicated 44e t/s by persongel performance in the job settir)gs. An evaluation of M}ectin fn
.fo e esc.h Cc.ft3 0,.7 o f pla n F pao.s.,e f
- ogramp must be compTetdd at idast once every 24 calendar months.
/\ V (F) Program revision. Develop and implement a plan for using the information from paragraphs (c)(3)(ii)(D) and (E) of this section, and other pertinent information (e.g., operating experience, and changes to equipment / systems, regulations, and procedures), to revise the training 28
b programs. Program revisions must be completed within 12 calendar months of completion of the program evaluation performed in accordance with paragraph-(c)(3)(ii)(E) of this section.
(4) Qualification program. Under its qualification program, each applicant and each licensee shall ensure that personnel listed in paragraph (c)(1) of this section, including contractor personnel, have. qualifications commensurate with the performance requirements of the jobs to which they are assigned. The applicant or licensee shall establish- the position selection criteria, specify the appropriate training, and identify post-training qualification requirements for its personnel.
(d) Records. In accordance with i 50.71(d)(1), each applicant and each-licensee shall maintain and keep available for NRC inspection, materials
. sufficient to document that the requirements of paragraph (c) of this section have been met. Documents related to the establishment, implement'ation, and maintenance of the selection and training programs must be retained for at least five years. Documentation demonstrating the qualification of personnel covered by paragraph (c)(1) of this section, including contractor personnel, must be retained for each individual for the. duration of employment.
(e) Implementation / Certification. Each applicant, by (180 days after the effective date of the rule) or 18 months prior to fuel load, whichever is later, and each licensee, by (180 days after the effective date of the rule).
O h NR c Fo~ 391 shall submit to the Commission a certification by a duly authorized of'icer of
/\
the applicant or licensee that personnel selection, training, and 29
L ,
- e qualification programs meeting the requirements of this section have been implemented.
N
( '
Dated at Rockville, MD, this _ th day of 1991, for the Nuclear Regulatory Commission.
Samuel J. Chilk, Secretary of the Commission.
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- Enclosure 4 to the Minutes of CRGR Meeting No. 201 Draft Generic Letter on Chances in Technical Specification Surveillance Interval (_and Exceptions to 10 CFR_50.
Appendix J) to Accommodate a 24 Month Fuel Cycle February 26. 1991 TOPIC E. Rossi and T. Dunning of NRR presented the subject letter for CRGR review, improved fuels would allow licensees to extend refueling intervals from 18 month to 24 months (nominal) and there would be substantial economic incentives for do so. In order to fully accommodate 24 months refueling cycles, licensees would need to request technical specification changes to extend certain surveillance intervals to 24 months nominal (30 months maximum). They would also need to request exceptions to 10 CFR 50, Appendi/ J, to obtain similar extensions on the intervals for local leak rate testing.
BACKGROUND The review package was forwarded by a memorandum dated February 11,1991, for E. Jordan from F. Miraglia. The package included:
- 2. Draf t generic letter.
Copies of two revisions to the draft letter, provided by the staff at the meeting, are provided as an attachment to this enclosure.
CONCLUSIONS / RECOMMENDATIONS The CRGR recommended in favor of the draft letter, subject to several revisions to be coordinated with the CRGR staff.
The action was not considered to be a backfit because it involved prospective, voluntary actions by licensees (requesting relaxation of surveillance intervals). For the same reasons, safety goal considerations were not considered material. (In addition, the staff pointed out that there would be no appreciable affect on safety and thus no change in plants' relationship with the safety goals.)
Specific revisions, comments and agreements were as follows:
- 1. CRGR noted that, in the CRGR review package, there was little justification for the change [ items v and vii(c)]. This could be corrected by making reference to the model SER, which contained such justification.
It was agreed that this would be documented in the CRGR meeting minutes rather than by changing the CRGR review package.
- 2. CRGR did not believe it would be appropriate to call the change in surveillance intervals small, as was done in the CRGR review package (e.g., item ix) and the generic letter (e.g., page 2). It was agreed to .
document this point in the CRGR meeting minutes rather than by changing I
O' 3
the CRGR review package. In addition, appropriate changes would be made in the generic letter.
3.
The CRGR recommended that the staff reexamine the radiation dose conclusion, presented in the CRGR review package, in view'of the radiation dose estimates associated with the staff's recent proposal to issue a final amendment to 10 CFR 50, Appendix J. The staff agreed to do this and address the subject in the memorandum that would respond to
, CRGR comments.
4.
The staff agreed to explain more fully, in the generic letter, that 10 CFR 50, Appendix J may change and, if so, licensees may be automatically given an interval of 24 months nominal (30 months maximum) between containment local leak rate tests.
5.
The CRGR recommended that the staff consider the advisability of changing the title of Enclosure 2 to " Factors to take into account ...."
6.
The statement at the end of Enclosure 2 to the effect that exemptions would last until Appendix J is revised should be removed.
7.
The conclusion on page 2 of the generic letter indicating the acceptability of all other changes to 18 months surveillance intervals should be removed.
8.
Conforming changes to the above points should be made, as appropriate, in other parts of the enclosures, including the model SER.
a s'
would be appropriate based upon prior inspection results. Finally, an exten-sion of the inspection interval would not be appropriate if the results of the prior inspections fell in worst category with respect to steam generator tube integrity.
Instrument drift is another important consideration that licensees must address when proposing an increase in the surveillance interval for calibrating instru-ments that perform safety functions including the capability for safe shutdown.
Because instrument errors due to drift are included as considerations for the determination of safety system setpoints and are one of the initial condition considerations of safety analyses, the effects of an increased calibration interval on instrument errors need to be addressed. Information is required as outlined in Enclosure 3 to address the safety impact of an increased calibration interval on instrument drift.
For all other 18-month surveillances, experience has shown that the effect on cycle isofsmall.
safety a small change in test intervals to accommodate a 24-month fuel However, licensees should confirm that plant historical maintenance and surveillance data do not invalidate such conclusions.Also, Ticensees should confirm that the performance of any surveillance at the bound-ing surveillance interval limit provided to accomodate a 24-month fuel cycle would not invalidate any assumption in the plant licensing basis. With these 4 contirmations, licensees do not need to quantity the effects of the change in l surveillance intervals on the availability of _ individual systems or components.
Licensees that plan to adopt a 24-month fuel cycle are encouraged to propose TS changes and a request for an exemption to Appendix J requirements that are consistent with the enclosed guidance. Proposed amendments that deviate from the guidance provided will lengthen the time required to complete the review.
Please contact the have questions NRC on this Project Manager or the contact indicated below if you matter.
Any response to the NRC suggestion for TS changes is voluntary. Therefore, any action taken in response to the guidance provided in this generic letter is not a backfit under 10 CFR 50.109. Likewise, Office of Management and Budget clearance is not required.
Sincerely, James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
As stated ,
g7 g
Contact:
Tom Dunning, OTSB/NRR E A/CMStME V (301) 492-1189 gpg X J.O/
s
Generic Letter 91-Enclosure 1 GUIDANCE ON PREPARATION OF A LICENSE AMENOMENT REQUEST FOR CHANGES IN SURVEILLANCE INTERVALS TO ACCOMMODATE A 24-MO DISCUSSION Licensees are planning to use improved reactor fuels because of the significant economic benefits associated with a longer fuel cycle. A longer fuel cycle increases the time interval between refuelin the associated technical specification (TS) g surveillance outages and requirements.
the performance of This guidance is provided to address TS changes for those surveillances that are per-aformed on an 24-month 18-month fuel cycle. or other refueling outage interval basis to accomodate The NRC staff has reviewed a number of one-time requests to extend 18-month surveillances to the end of a fuel cycle and a few requests for changes in sur-veillance intervals to accomodate a 24-month fuel cycle. Based on these reviews, the staff concludes that an increase in 18-month surveillance inter-vals to accomodate a 24-month fuel cycle does not have a significant effect on safety since any associated decrease in system availability is small. This is because of the redundancy that exists in both electrical and mechanical com-ponents used in safety systems and the assurance provided by other surveil-lances performed during plant operation that confirm the capability of these system components to perform their safety functions. However, licensees should confirm that plant historical maintenance and surveillance data do not invali-date such conclusions. Also, licensees shouid confirm that the performance of surveillance at the bounding surveillance interval limit to accomodate a 24-month fuelbasis.
licensing cycle would not invalida~te any assumption addressed in the plant TECHNICAL SPECIFICATION CHANGES Changes to accomodate a 24-month fuel cycle should be proposed by modifying 18-month surveillances to indicate that they are to be performed ". . . at least once each REFUELING INTERVAL." In addition, the surveillance interval notation in Table 1.1 in the Definitions Section of the TS should be modified to include the term " REFUELING INTERVAL" along with the letter "R" notation to definerefueling each the. frequency interval.for surveillances that are specified to be performed once (Capitalization of the term " refueling interval" is used in the TS to designate a defined term.) The frequency for this notation should be changed from "At least once per 18 months" to "At least once per 24 months" to define the nominal frequency for surveillances that are specified to be performed each refueling interval or with the letter "R" notation. The bounding time interval for these surveillances would then be 30 months under the25 by provision percentofofSpecification the specified4.0.2 that allows a surveillance to be extended interval.
Where the TS specify that an 18-month surveillance is to be performed "during shutdown," this qualification may be omitted when specifying the surveillance interval as ". . . at least once per REFUELING INTERVAL."
Because TS have defined " Hot" and " Cold Shutdown" as operating modes or conditions, the added restriction to perform certain surveillances during shutdown is subject to misinterpretation.
The intent of this rest;iction is to ensure that a surveil-lance would only be performed when it is consistent with safe plant operation.
However, this is also a valid consideration for other surveillances that are l performed during power operation, plant startup, or shutdown, but one that is not addressed by placing a restriction on conducting these surveillances. .'
3 n es:g'o UNITED STATES 8 o NUCLEAR REGULATORY COMMISSION 4 wAsmNoToN. o. c. rosse -; o /
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's l MEMORANDUM FOR: !EdwardL. Jordan, Chairman,CommitteetoReviewGeneric Requirements i David A. Ward, Chairman, Advisory Committee on Reactor Safeguards FROM: C. J. Heltemes, Jr., Deputy nirector for Generic Issues and Rulema, og, Office of Nuclear Regulatory Research
SUBJECT:
PROPOSED RULEMAKUG ON SELECTION, TRAINING, AND QUALIFICATION 1 0F NUCLEAR POWER vlANT PERSONNEL l
Enclosed for review by CRGR and ACRS is a proposed rulemaking package to amend l
Part 50 to require selection, training, and qualification programs for nuclear power plant personnel. This proposed rule is being initiated in order to respond to the April 27, 1990, decision by the U.S. Court of- Appeals for the District of Columbia Circuit that the NRC implement Section 306 of the Nuclear Waste Policy Act of 1982. The Act required NRC to promulgate regulations or other )
/ appropriate regulatory guidance establishing instructional requirements for civilian nuclear power plant personnel.
The draft Regulatory Analysis to support this rulemaking and the two regulatory guides, referred to in the package, are under preparation. They will be j
forwarded to you at a later date.
Please note that, because of the accelerated schedule for this rulemaking, we I are forwarding this rulemaking package for your review before all offices have concurred in the package. When we meet with you to discuss the package, we expect to have received concurrence from the cognizant offices. Questions regarding this rulemaking should be addressed to Mary Louise Roe at x24649.
I e tenies, C.
D pu1 y Director, neric Issues and i kriemaking Office of Nuclear Regulatory Research
Enclosure:
As stated
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- ~ - - . ~ . . - - - . - . . . - . . - - - -- .- - - .. -
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?
.t For: The Commissioners
-t From: James M. Taylor .
- Executive Director for Operations e
Sub.iecti: PROPOSED RULEMAKING FOR SELECTION, TRAINING, AND.
QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL
Purpose:
To obtain Commission approval to publish a' proposed rule that would revise 10 CFR'Part 50 to require nuclear power ' '
plant applicants.and licensees -to establish- selection, training, and qualification programs for their personnel. :
Backaround: ' In Section 306 of the Nuclear Waste. Policy Act of'1982 (NWPA), Pub. L.97-425, the NRC was " directed to promulgate regulations, or other appropriate Commission regulatory ,
guidance for the trt ning and qualifications of civilian i
nuclear power plant operators, supervisors, technicians and -
other operating' personnel. Such regulations 'or guidance -
shall establish... instructional .. requirements for. civilian ,
nuclear power plant licensee personnel training programs."
In order to comply with this directive,- the staff submitted - '
to the Commission on February 13,21984, a' proposed.
rulemaking for- Training and Qualification of Civilian 1 Nuclear- Power Plant Personnel (SECY-84'-76).. -However, on -
October 23,.1984, the Commission decided'to defer rulemaking -
for.a minimum'of two years. That decision was to allow the '
Nuclear Management. and Resources Council: (NUMARC), formerly the Nuclear Utility Management and Human Resources.
Committee, 'to' fulfill. its ~ commitment to ensure that all ~
licensees of commercial nuclear power plant's would implement .
a program for training and qualification that would be: . H essentially. equivalent to the type of program NRC rulemaking would have required. This would be accomplished through the y
Contact:
Mary Louise Roe, RES 301-492-3745 .
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P t %
y of e- -in- --* p
l I
The Commissioners 2 l
Institute of Nuclear Power Operations (INPO)-managed training accreditation program.
On March 20, 1985, the Commission published a Policy Statement on Training and Qualification of Nuclear Power Plant Personnel (50 FR 11147). The Policy Statement endorsed the INP0-managed training accreditation program "in that it encompasses the elements of effective performance-based training" that the NRC considered essential to acceptable training programs.
Following a two-year period of monitoring and evaluating the industry initiative by the NRC staff, the Commission published an Amended Policy Statement on Training and-Qualification of Nuclear Power Plant Personnel on November 18,1988 (53 FR 46603) reaffirming the efficacy of.
the industry training programs. This Amended Policy Statement was developed in order to (1) provide additional information regarding NRC's experience with industry accreditation (2) change the policy regarding enforcement to normalize NRC inspection and enforcement in the areas covered by the policy statement, and (3) reflect current Commission and industry guidance.
On April 27, 1990, the U.S. Court of Appeals for the District of Columbia Circuit concluded that the Commission's Policy Statement did not meet the intent of the Congressional directive to create mandatory requirements for the training and qualification of personnel at civtlian nuclear power plants. The Court remanded the-issue back to the NRC for action consistent with the Court's findings.
The Office of the General Counsel, at the direction of the Commission, requested a rehearing of the decision by the full court, which was denied on June 19, 1990.
Discussion: In response to the U.S. Court of Appeals order, the staff has prepared for public comment a proposed rule for selection, training, and qualification of nuclear power plant personnel. The rule is being proposed to meet the directives of the NWPA as interpreted by the. U.S. Court of Appeals for the District of Columbia Circuit.
The proposed rule would require that each applicant for and each holder of an operating license for a nuclear power plant establish, implement,.'and maintain programs for the selection, training, and qualification for specific categories of nuclear power plant personnel and for all modes and conditions of operation (including shutdown, normal, abnormal, emergency, and accident conditions)
(Enclosure A). The proposed rule would require that
.~.
x f4 '
The Commissioners 3 applicants and licensees develop these programs with an approach based on job performance requirements.
The proposed rule is based upon the current industry practice for personnel selection, training, and qualification in that it would require these programs to be derived from a systematic analysis-of job performance requirements. From the staff's monitoring of industry training programs since the Policy Statement went into-effect, the staff has concluded that these programs have been generally effective in ensuring that personnel have qualifications commensurate with the performance -
requirements of their jobs. Training programs based on job performance requirements have been successfully used by the military for over 20 years, and by the nuclear industry for the past 7 years. Furthermore, the Commission has recogn, zed the appropriateness of using this approach to d
trairing in its requirements, referred to as the systems approach to training (SAT), for operator licensing prescribed in 10 CFR 55.31(a)(4), and for operator requalification prescribed in 10 CFR 55.59(c) .
For the training program, the proposed rule would require the SAT. Consistent with this process, the proposed rule.
would require each applicant and licensee to include the-following key elements in the development of its training program: (1) analysis of job performance requirements and training needs, (2) derivation of learning objectives based upon the preceding analysis, (3) aesign and implementation of the training program based upon t' learning objectives, (4) trainee evaluation, (5) program e, ration, and (6) program revision based upon the preceding evaluations. In addition, the proposed rule would also require nuclear power plant applicants' and licensees to use findings' from the analysis performed in element #1 above to develop the appropriate programs for personnel selection and qualification.
Within 180 days after the effective date of this rule, each licensee would be required to certify to the Commission that it has-implemented personnel selection, training, and.
qualification programs required by the rule. Applicants would be required to make the certification'either 18 months prior to fuel load or 180 days after the effective date of this rule, whichever comes later.
Although the'1985. Policy Statement, as amended in 1988, serves as the basis for the proposed rule, subsequent review.
- and inspections of industry programs by the NRC staff,'and
. deliberations during development of the proposed rule,.
indicated the need to modify certain aspects of the. guidance i
i
g s
The Commissioners 4 from that provided in the Policy' Statement. These proposed changes from the policy guidance are provided below:
(1) In order to emphasize the need to develop and implement a plan that ensures the content of training programs is revised as needed, the two aspects of element #5 of the training approach described in the Policy Statement (evaluation'and revision) have been split into two new elements, " Program evaluatien" and
" Program revision." Inspection experience at over 15 sites indicates that, while training programs are being evaluated, the results of the evaluations have not been used consistently to revise the programs.
(2) The proposed rule would require a personnel selection program for nuclear power plant personnel entering the training and qualification programs. This prograr, has been included because the development of selectica criteria is seen as a necessary element linked to the success of subsequent training and qualification activities.
(3) Requirements have been included to develop selection, ,
training, a :d qualification programs for personnel with (a) quality assurance responsibilities and (b) accident assessment and mitigation responsibilities.
Appendix B of 10 CFR Part 50 requires that the licensee's quality assurance (QA) program provide for training of personnel performing activities-affecting quality as necessary to ensure that suitable proficiency is achieved and maintained. QA is related to virtually every. element 'of assuring safe plant operation, and every aspect of job performance. The staff believes that QA personnel will be most effective in contributing to overall plant performance if they are selected, trained, and qualified under the same overall system as the other plant personnel included in the proposed rule. Hence, the proposed rule also applies to QA personnel.
In 1987, the Commission was informed that the industry was planning to voluntarily provide training on accident assessment and mitigation procedures. The need for specific training in. accident assessment and mitigation has been emphasized by both the NRC, in its-Accident Management Program (see SECY-89-012), and by the indudry, as evidenced by the development of a NUMARC working group to address the matter of severe accidents with accident management being given a high priority. Hence, personnel with accident assessment-
4 The Commissioners 5 and mitigation responsibilities also have been
' included in the proposed rule.
(4) Contractor personnel performing in positions covered by the proposed rule would be required to meet appropriate qualification requirements. Contractor personnel have been included in the proposed rule because all individuals working at nuclear power plants who perform in equivalent positions should be qualified to perform their job responsibilities regardless of the source of their employment. It would be the responsibility of the applicant or licensee to ensure that contractor personnel are properly qualified to perform those tasks for which they are put under contract. Therefore, only contractor qualifications, not selection and training, l are covered.
(5) The proposed rule would apply to nuclear power plants in all modes of operation and conditions ranging from shutdown to accident conditions. These modes and conditions should be addressed by applicants and licensees in developing and implementing their initial and continuing training programs.
A draft regulatory guide, " Application of a Systems Approach to Training at Nuclear Power Plants" (Enclosure B), has been prepared for public comment as part of this proposed rulemaking effort. This guide describes an acceptable means for providing SAT training programs at nuclear power plants.
A proposed revision to-Regulatory Guide 1.8, " Personnel Qualifications and Training for Nuclear Power Plants" (Enclosure C), also has been prepared to provide guidance on developing selection, training, and qualification requirements. With some minor exceptions, the guide will endorse the most recent version of industry standard ANSI /ANS-3.1, " Selection, Qualification and Training of.
Personnel for Nuclear. Power Plants." Draft Regulatory Guide 1.8 will also be issued for public comment as part of this-proposed rulemaking effort. Together, these regulatory guides provide criteria and methods acceptable to the staff for meeting the' requirements in-the rule.
Recommendation: That the Commission:
(1) Acorove publication for comment of the proposed rule as set forth in Enclosure A.
(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
.s; The Commissioners 6 economic impact on a substantial number of small entities. This certification is included in the enclosed Federal Reaister Notice.
I (3) Note that:
(a) The notice of proposed rulemaking (Enclosure A) will be published in-the Federal Reaister, allowing 60 days for public comment.
(b) The staff will also make available for public comment a new regulatory guide, " Application of a Systems Approach to Training at Nuclear Power Plants" (Enclosure B), and a revision to Regulatory Guide 1.8 (Enclosure C).
(c) A regulatory analysis will be available in the Public Document Room (Enclosure D).
(d) In accordance with 10 CFR Part 51, the staff has prepared an environmental assessment and finding of no significant impact to support the determination that this action does not affect the quality of the human environment.
(e) A public announcement will be issued (Enclosure E).
(f) The Subcommittee on Nuclear Regulation of the Senate Committee on Environment and Public Works and the Subcommittee on Energy and Power.of the House Committee on Energy and Commerce and the House Committee on. Interior and Insular Affairs will be informed by letter (Enclosure F).
(g) Copies of Section 306 of the NWPA of 1982, the Policy Statement on Training and Qualification.
of Nuclear Power Plant Personnel (50 FR 11147),
and the Amended Policy Statement on the Training and Qualification of Nuclear Power Plant Personnel (53 FR 46603) are provided as :
Background (Enclosure G).
(h) This rule will be submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
(i) Copies of the proposed rule will be distributed to all affected licensees and other interested persons.
I ,
The Commissioners 7 (j) The Chief Counsel for Advocacy of the Small Business Administration will be informed of the certification and the reasons for it as required by the Regulatory Flexibility Act.
(k) Inspection procedures will be revised.
Schedulina: Recommend affirmation at an open meeting.
Coordination: The Office of the General Counsel has no legal objection. ;
James M. Taylor Executive Director for Operations Enclosure A - Proposed Federal Reaister Notice Enclosure B - Draft Regulatory Guide, " Application of a Systems Approach to Training at Nuclear Power Plants" (DG-10ll)
Enclosure C - Proposed Revision to Regulatory Guide 1.8, " Personnel '
Qualifications and Training for Nuclear Power Plants" (DG-1012)
Enclosure 0 - Regulatory Analysis Enclosure E - Draft Public Announcement Enclosure F - Draft Letters to Congress Enclosure G - Background j
J
- - )
4 '
4
[7590-01]
NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 RIN 3150 - AD80 Selection, Training, and Qualification of Nuclear Power Plant Personnel AGENCY: Nuclear Regulatory Commission.
ACTION: Proposed rule.
SUMMARY
- The Nuclear Regulatory Commission is proposing to amend its regulations in 10 CFR Part 50 to require each applicant for and each holder of .
a license to operate a nuclear power plant to establish, implement, and ;
maintain programs for the selection, training, and qualification for specific categories of nuclear power plant personnel, that consider all modes and conditions of operation (including shutdown, normal, abnormal, emergency, and '
accident conditions). The rule is being proposed to meet the directives of Section 306 of the Nuclear Waste Policy Act of 1982. The proposed. rule reflects current industry practice.
DATES: The comment period expires (60 days following publication in 'the Federal Register). Comments received after this date will be' considered if it is practical to do so, but assurance of consideration cannot be given'except for comments received on or before this date.
, }
ADDRESSES: Mail written comments to: The Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555, ATTN: Docketing and Service Branch.
l Deliver comments to: One White Flint North, 11555 Rockville Pike, Rockville, Maryland, between 7:30 am and 4:15 pm on weekdays. Copies of the draft regulatory analysis, as well as copies of the comments received on the proposed rule, may be examined at the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.
FOR FURTHER INFORMATION CONTACT: Mary Louise Roe, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone: (301) 492-3745.
SUPPLEMENTARY INFORMATION:
Background
Nuclear Waste Policy Act of 1982 Section 306 of the Nuclear Waste Policy Act of 1982 (NWPA),
Pub. L.97-425, directed the NRC to promulgate regulations, or other appropriate regulatory guidance, for the training and qualifications of nuclear power plant personnel. Such regulations, or guidance, were to establish " instructional requirements for civilian nuclear power plant
- licensee personnel training programs." In order to meet this directive, on March 20,1985; 50 FR 11147, the Commission published a Policy Statement on '
- l Training and Qualification of Nuclear Power Plant Personnel. The Policy l 2
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Statement endorsed a training accreditation program managed by the Institute of Nuclear Power Operations (INP0) in that it encompassed the following five essential elements of " effective performance-based training":
(1) Systematic analyses of the jobs to be performed.
(2) Liarning objectives derived from the analysis that describe desired perforrrance after training.
(3) Training designed and implemented based upon the lear ing ,
objectives.
(4) Evaluation of trainee mastery of the objectives during training.
(5) Evaluation and revision of the training based on the performance of trained personnel in the job setting.
The Commission decided to defer rulemaking in this area for a minimum of two years in order to allow the industry to continue its initiatives to upgrade training programs through the INP0-managed training accreditation program. Training programs accredited through the INPO-managed-accreditation program provide the basis to ensure that personnel have qualifications i l
commensurate with the performance requirements of their jobs, i i
l In addition to endorsing the INP0-managed training accreditation-program, the 1985 Policy Statement also recognized the INPO-managed ]1 accreditation of utility training for the following training programs: I I
(1) Non-licensed operator.
I (2) Control room operator.
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(3) Senior control room operator / shift supervisor.
(4) Shift technical advisor.
(5) Instrument and control technician.
(6) Electrical maintenance personnel.
(7) Mechanical maintenance personnel.
(8) Radiological protection technician.
(9) Chemistry technicians.
(10) On-site technical staff and managers.
Following issuance of the policy statement, the NRC evaluated the effectiveness of the INPO-managed training accreditation program over a two-year period and concluded that it was an effective program for ensuring that nuclear power plant personnel have qualifications commensurate with the performance requirements of their jobs. On November 18, 1988,- the NRC published an amended policy statement in order to (1) provide additional information regarding the NRC's experience with industry accreditation, (2)-
change the policy regarding enforcement to normalize NRC inspection and enforcement in the areas covered by the 1985 Policy Statement, and (3) reflect current Commission and industry guidance. The NRC staff continues to perform training inspections at different utilities with accredited training programs to ensure that these programs remain effective.
U.S. Court of Appeals Decision On April 27, 1990, the U.S. Court of Appeals for the District of Columbia Circuit concluded that the Commission's Policy Statement 'did not meet 4
the intent of the Congressional directive to create mandatory requirements for the training and qualification of personnel at civilian nuclear power plants.
The Court remanded the issue back to the NRC for action consistent with the Court's findings. The Office of the General Counsel, at the direction of the Commission, requested a rehearing of the decision by the full court, which was denied on June 19, 1990.
- Actions Proposed in Response to the Court Decision The NRC is proposing a rule on selection, training, and qualification of nuclear power plant personnel. The rule is being proposed to meet the directives contained in Section 306 of the Nuclear Waste Policy Act of 1982 (NWPA), Pub. L.97-425, as interpreted by the U.S. Court of Appeals for the District of Columbia Circuit.
The proposed rule is based upon the current industry practice for personnel selection, training, and qualification in that it requires these programs to be derived from a systematic analysis of job performance requirements. From the NRC's monitoring of industry training programs since the 1985 policy statement went into effect, the NRC has concluded that these programs have been generally effective in ensuring that personnel have qualifications commensurate with the performance requirements of their jobs.
The proposed rule would amend 10 CFR Part 50 to require each applicant for and each holder of a license to operate a nuclear power plant to establish, implement, and maintain programs for the selection,' training, and 5
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qualification for specific categories of nuclear power plant personnel, that consider all modes and conditions of operation (including shutdown, normal, abnormal, emergency, and accident conditions).
The Commission has also developed two regulatory guides that provide to industry an acceptable method for meeting the personnel selection, training, and qualification requirements contained in the proposed rule.
Discussion The safety of nuclear power plant operations and the assurance of general public health and safety depend on personnel performing at adequate performance levels. The systematic determination of qualifications and the provision of effective initial training and periodic retraining will enhance confidence that workers can perform at adequate performance levels. The approach the Commission has taken in this proposed ruel is to specify the essential elements of a process to be implemented by applicants and licensees, t
by which job performance criteria and associated personnel selection, training, and qualification programs would be derived. Because under.this approach little change would be required to existing industry practice for personnel selection, training, and qualification, there is little additional cost associated with this approach. This approach also provides for flexibility and site-specific adaptations in _the selection, training, and qualification programs.
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. I Summary of Proposed Rule _ 1 Each applicant for and each holder of an operating _ license for_ a nuclear power plant would be required to --
(1) Establish selection, training, and qualification ;
programs for nuclear power plant personnel in specific categories; (2) Consider all modes of operation and conditions ranging from shutdown to accident conditions in developing these programs; (3) Select personnel with qualifications either commensurate with job performance requirements or sufficient to satisfactorily ,
1 complete applicable training and qualification programs; (4) Use a systems approach to training in developing training programs in order to ensure personnel are trained to meet the performance requirements of their jobs; ]
i (5) Derive qualifications that are commensurate with job ;
performance requirements; ,
1 (6) Maintain and keep available for NRC review and 1 inspection the materials related to those personnel' selection, training, and-1 qualification programs; and (7) Certify that they have implemented the required 1
selection, training, and qualification programs for personnel. -l l
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'I The 1985 Policy Statement, as amen'ded in 1988, serves as the basis for-the proposed rule, However, subsequent review and inspections of industry 1
programs by the NRC, and deliberations during development of the proposed rule, indicated the need to modify certain aspects of the guidance provided in 4 7 'l
4 the Policy Statement. These proposed changes-from the policy guidance are ,
provided below:
(1) .In order to emphasize the need to develop and implement a plan that ensures the content of training programs is revised as needed, the two aspects of element #5 of the performance-based training approach described in the Policy Statement (evaluation and revision) have been split into two new elements, " Program evaluation" and " Program revision." Inspection experience at over 15 sites indicates that, while training programs are being' evaluated, the results of the evaluations have not been used consistently to revise the programs.
(2) The proposed rule would require a personnel selection program for nuclear power plant personnel entering the training and qualification programs. This program has been included because the development of' selection criteria is seen as a necessary element linked to-the success of subsequent -
training and qualification activities.
(3) Requirements have been included to develop selection, training, and.
qualification programs for personnel with (a) quality assurance responsibilities and (b) accident assessment and mitigation responsibilities. .-
Appendix B of 10 CFR Part 50 requires that the licensee's quality assurance (QA) program provide for training of personnel performing activities affecting quality as necessary to ensure that suitable proficiency is achieved-and maintained. QA is related to virtually every element of assuring safe plant operation, and every aspect of job performance. The Commission believes that QA personnel will be most effective in contributing to overall plant performance if they are selected, trained, and qualified under the same B
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9 overall system as the other plant personnel included- in. the proposed rule.
Hence, the proposed rule also applies to QA personnel.
4 In 1987, the Commission was informed that the industry was planning to voluntarily provide training on accident assessment and mitigation procedures.
The need for specific training in accident assessment and mitigation has been emphasized by both the NRC, in its Accident Management Program (see SECY-89-012)2, and by the industry, as evidenced by the development of a NUMARC working group to address the matter of severe accidents with accident management being given a high priority. Hence, personnel with accident assessment and mitigation responsibilities also have been included in the proposed rule.
(4) ' Contractor personnel performing in positions covered by the proposed rule would be required to meet appropriate qualification requirements. Contractor personnel have been included in the proposed rule because all individuals working at nuclear power plants who perform in ,
equivalent positions should be qualified to perform their job ~ responsibilities regardless of the source of their employment. It is important to note that only contractor qualifications, not selection and training, are covered.
(5) The proposed rule applies to nuclear power plants in all modes of operation and conditions ranging from shutdown to accident conditions. These modes and conditions should be addressed by applicants and licensees in developing and implementing their initial and continuing training programs.
SECY-89-012 is available at the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.
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E Discussion of Proposed Rule 1 A new section, s 50.120, would be added to 10 CFR Part 50, entitled
" Selection, training, and qualification of nuclear power plant personnel."
The proposed rule would establish the requirements for and the essential elements of the process to be used by applicants and licensees to: .(1) determine selection, training, and qualification requirements for all l 1
appropriate personnel, (2) develop corresponding personnel selection, )
l 1 training, and qualification programs to ensure that the appropriate ]
1 qualification requirements are met, and (3) implement and operate these !
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programs effectively on a continuing basis. {
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Paragraph (a), Applicability, indicates that the proposed rule would apply to each applicant for and each holder of an operating license for a nuclear power plant.
Paragraph (b), Definitions, defines terms used in s 50.120.
Paragraph (c)(1), General requirements, would require that each applicant and licensee establish, implement, and maintain programs for the selection, training, and qualification of nuclear power plant personnel in specific categories that consider all modes and conditions of operation (including shutdown, normal, abnormal, emergency, and accident conditions).
The paragraph also lists those specific categories of personnel that would be 3 covered by the requirements.
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The_ proposed rule would expand the number and type of personnel for whom training is currently expected under NRC's policy guidance and the INPO-managed training accreditation program. Requirements for selection, training, and qualification programs for quality assurance personnel and personnel responsible for accident assessment and mitigation have been included in the proposed rule. In developing their training programs in accordance with the 1
proposed rule, applicants and licensees would need to consider personnel performance at the nuclear power plant during all modes and conditions of operation.
Appendix B of 10 CFR Part 50 requires that the licensee's quality assurance (QA) program provide for training of personnel performing activities affecting quality as necessary to ensure that suitable proficiency is achieved.
and maintained. QA is related to virtually every element of assuring safe plant operation, and every aspect of job performance. The staff believes that QA personnel will be most effective in contributing to overall plant performance if they are selected, trained, and qualified under the same overall system as the other plant personnel included in the proposed rule.
Hence, the proposed rule also applies to QA personnel.
In 1987, the Commission was informed that the industry was planning to voluntarily provide training on accident assessment and mitigation procedures. ,
The need for specific training in accident assessment and mitigation has been emphasized by.both the NRC, in its Accident Management Program (see SECY 012), and by the industry, as evidenced by the development of'a NUMARC working group to address the matter of severe accidents with accident management being 11
i given a hgh i priority. Hence,: personnel with accident assessment ~and mitigation responsibilities also have been included in the proposed rule, e
The category pertaining to personnel with other plant specific titles has been included in the proposed rule to ensure that the job categories listed in the proposed rule are covered regardless of job titles used by individual licensees.
Paragraph (c)(2), Selection program, would require that applicants and licensees select personnel who either have qualifications commensurate with job performance requirements or who have entry level-qualifications sufficient to satisfactorily complete appropriate training and qualification programs.
These requirements are contained in the proposed rule because the. Commission believes that development of a selection program is a necessary element to be included with the training and qualification programs. The selection criteria should be specifically linked .to the success of. subsequent training and qualification activities.
Paragraph (c)(3), Training program, would require applicants.and
. licensees to establish, implement, and maintain training programs that are derived from a systems approach to training (SAT). The systems approach to training was' selected because it has the following characteristics:
(1) Training content and design are derived from job performance requirements; (2) Training is evaluated and revised in terms of the job performance ,
requirements and observed _results on the job; 12 y
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(3) Trainee success in training can predict satisfactory on-the-job performance; and, (4) Training and associated programs can be readily audited because they involve clearly delineated process steps and documentation.
The proposed SAT process contains six major elements and is intended to require a training system that will ensure successful performance on the job by trained individuals. The elements are:
(1) Analysis of job performance requirements and training needs.
(2) Derivation of learning objectives. ,
(3) Design and implementation of the training programs.
(4) Trainee evaluation.
(5) Program evaluation.
(6) Program revision.
The SAT process also provides a sequential method of generating the type of documentation needed for training review. Use of SAT will obviate the need for additional documentation for NRC review.
The SAT process is a generic process, and its application is not limited to a certain subject matter or to specific licensee personnel. Training programs based on job performance requirements have been successfully used by the military for over 20 years, and by the nuclear industry for the past 7 years. Furthermore, the Commission has recognized the appropriateness of using this approach to training in its requirements for operator licensing prescribed in i 55.31(a)(4), and for operator requalification prescribed in i 55.59(c).
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Paragraph (c)(4), Qualification program, would require applicants and j licensees _to ensure that all affected personnel, including contractor ~
pdrsonnel, have qualifications appropriate for the levels and types of .
responsibilities assigned to them. Qualification determinations would be derived from the analysis of the job tasks and functions to be performed. It would be necessary for applicants and licensees to identify affected personnel; ,
based on a systematic analysis of the facility's design, procedures, and special circumstances and needs. It is important to note that the proposed rule also applies to the qualification of personnel who are either employed by or are under contract to the applicant or licensee to perform the covered jobs in each facility. Thus, it will be the responsibility of the facility ,
applicant or licensee to ensure that contractor personnel are also properly qualified to perform those tasks for which they are put under contract. The proposed rule would require that applicants and licensees keep on file documentation certifying the appropriateness of the qualifications of. ,
contractor personnel hired to perform any of the covered job positions, or any particular tasks with specific relevance to public health and safety. The applicants and licensees will be responsible for the correctness of these records. It is important to note that the rule refers only to contractor qualifications and does not refer to the selection and training of contractor personnel prior to their employment at the site.
Paragraph (d), Records, would require that each applicant and licensee maintain and keep available for NRC review and inspection the materials used to establish and implement both selection requirements for the affected a
personnel and their required training programs. Similar documentation would'
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F c also be required for qualification requirements, qualification determinations, and certifications for all personnel, including contractors performing in po'sitions covered by this rulemaking.
Paragraph (e), Implementation / Certification, would require applicants and licensees to certify to the Commission that they have implemented the required personnel selection, training, and qualification programs.
Applicants would be required to submit the certification that they have personnel selection, training, and qualification proccams implemented either 180 days after the effective date of this rule, or by 18 months prior to fuel load, whichever is later. Licensees would be required to submit their certifications by 180 days after the effective date of this rule. The 180-day period was selected because the Commission believes that licensees _have already implemented most of the required programs and, therefore, do not require a longer period for implementation.
The Commission is providing additional guidance on the proposed new requirements in the form of a iraft regulatory guide, " Application of a Systems Approach to Training at Nuclear Power Plants," and a proposed Revision 3 to Regulatory Guide 1.8, " Personnel Qualifications and Training for Nuclear Power Plants." Together, these regulatory guides provide criteria and methods acceptable to the Commission for meeting the requirements in the rule. It should be noted that applicants and licensees are not precluded from using criteria and methods other than those in the regulatory guides to meet the requirements of the proposed rule. However, if they do not intend to follow the regulatory guides, they will be requested to inform the Commission.as to 15
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_. o what approach they will follow. The Commission believes that requesting i' applicants and licensees to indicate how they intend to comply with the rdquirements in the rule would provide flexibility in meeting this proposed rule. It will also ensure that the Commission has a common understanding of the applicant's and licensee's programs.
Impact of the Rule on Existing Industry Training Programs
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The proposed rule, if adopted, would supersede the Policy Statement on Training and Qualification of Nuclear Power Plant Personnel. The proposed rule should not result in replacement of accredited training programs since those programs were developed using an approach to training based on job performance requirements. Inspections by the Commission have also found the programs to be generally acceptable. The Commission expects that those programs, developed in accordance with INPO guidelines for accreditation, will follow the guidance in the draft Regulatory Guide, " Application of a Systems Approach to Training at Nuclear Power Plants." Applicants and licensees must still conduct independent assessments of their training programs for purposes-of certification under i 50.120(e). When completing the certification, the Commission expects that the applicants or licensees could indicate full ,
compliance with the guidance contained in the above regulatory guiae for the fully implemented accredited programs.
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Vendor-Developed Programs
' In 10 CFR Part 52, the Commission articulated the goal of safety through standardization of design. The Commission believes that the benefits of standardization may also be realized through the standardization of some types of training associated with the 10 CFR Part 52 design certification.
Therefore, nothing in the proposed rule is intended to preclude standard training programs being developed or implemented by a vendor. For example, the initial and basic training for instrument and control technicians related to a particular standard design may be conducted by a vendor. Then the pool of trained technicians, qualified by the vendor to do generic tasks related to the certified design, can be hired at a nuclear power plant site. These personnel can then complete site-specific training related to the administrative and operating philosophy of the site. Thus the requirements for personnel selection, training, and qualification programs. prescribed by i 50.120 do not prevent a vendor-developed personnel selection, training, and qualification process.
Invitation to Comment Comments concerning the level of detail specified and the implementation Comments are especially solicited R of the proposed amendments are encouraged.
on (1) the categories of personnel to be covered, (2) the impact of the-proposed amendments on industry training programs, (3) the relationship of the industry's accreditation process to the proposed rule, (4) the anticipated process to be used to identify persons responsible for accident assessment and 17 1
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mitigatio'n,.(5) the various time periods chosen for implementation of the <
requirements, and (6) difficulties'that may be encountered in retaining tha rsquired documentation and-records. Suggestions for alternatives to those rulemaking methods described in this notice and estimates of costs for q implementation are encouraged.
Regulatory Guides l
In addition to the proposed rule, two draft regulatory guides are. also available for public comment. A new regulatory guide, " Application of a Systems Approach to Training at Nuclear Power Plants," has been developed to provide guidance on an acceptable method of implementing the proposed amendments to the regulations, as has a proposed Revision 3 to Regulatory Guide 1.8, " Personnel Qualification and Training for Nuclear Power Plants."
Comments concerning these regulatory guides are encouraged. The guides are available for inspection at the NRC Public Document Room, 2120 L Street, NW (Lower level), Washington, DC. Single copies of-the draft regulatory guides may be obtained from the U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Director of Information Support Services. The comments on the guides will be most helpful if received by (60 days following publication in the Federal Register).
Finding of No Significant Environmental Impact: Availability The Commission has determined under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in subpart A of 10 18 1
4 CFR Part 51, that this rule, if adopted, would not be a major Federal action significantly affecting the quality of the human environment and therefore an e'nvironmental impact statement is not required. Numerous studies have shown that in complex man-machine systems, human error has often been the overriding contributor to actual or potential system failures that may be precursors to-accidents. With this rulemaking, the NRC is emphasizing the need to ensure that industry personnel selection, training, and qualification programs are based upon job performance requirements, and that nuclear power plant :
personnel have qualifications commensurate with the performance requirements of their jobs. Personnel who are subjected to selection, training, and qualification programs based on job performance requirements should be'able to perform their jobs more effectively, and with fewer errors. Therefore, the environmental effect of implementing this rule would, if anything, be positive ,
i because of the reduction in human error. The environmental assessment and finding of no significant impact on which this determination.is based are available for inspection at the NRC Public Document Room, 2120 L Street, NW.
(Lower Level), Washington, DC. Singie copies of the environmental assessment and finding of no significant impact are available from Mary Louise Roe, ,
Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, H I
Washington, DC 20555, telephone: (301) 492-3745.
Paperwork Reduction Act Statement 1
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.1 This proposed rule amends information collection requirements that are 'l
-1 subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.). This H 19 l
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.i rule has been submitted to the Office of Management and Budget for review and 4 approval-of the paperwork requirements.
Public reporting burden for this collection of information is estimated to average hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Send comments regarding this burden estimate 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; and to the Desk Officer, Office of Information and Regulatory Affairs, NE08-3019, (3150-0011), Office of Management and Budget, Washington, DC 20503.
Regulatory Analysis The Commission has prepared a draft regulatory analysis on this proposed -
regulation. The analysis examines the values (benefits) and impacts (costs) of implementing the proposed regulation for personnel selection, training, and qualification. The draft 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 Mary Louise Roe (see.
ADDRESSES heading). .
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c The Commission requests public comment on the draft regulatory analysis.
Comments on the analysis may be submitted to the NRC as indicated under the ADDRESSES heading.
Regulatory Flexibility Certification As required by the Regulatory Flexibility Act of 1989, 5 U.S.C. 605(b),
the Commission certifies that this rule, if adopted, will not have a significant economic impact.upon a substantial number of small entities. This proposed rule primarily affects the companies that own and operate light-water nuclear power reactors and the vendors of those reactors. The companies that own and operate these reactors do not fall within the scope of the definition i
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 Part 121. Since these companies are dominant in their service areas, this proposed rule does not fall within the purview of the Act.
However, because there may be now or in the future small entities that will provide personnel to nuclear power plants on a contractual basis, the NRC is specifically seeking comment as to how the regulation will affect them and how the regulation may be tiered or otherwise modified to impose less stringent requirements on them while still adequately protecting the public health and safety. Those small entities who offer comments on how the regulation could be modified to take into account the differing needs of small entities should specifically discuss the following items:
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.(a) The size of their business and how the proposed regulation would result in a significant economic burden upon them as compared to
' larger organizations in the same business community.
(b) How the proposed regulation could be modified to take into account -
their differing needs or capabilities.
(c) The benefits that would accrue, or the detriments that would be avoided, if the proposed regulation was modified as suggested by the commenter.
(d) How the proposed regulation, as modified, would more closely equalize the impact of NRC regulations or create more equal access to the benefits of Federal programs as opposed to providing special advantages to any individuals or groups.
(e) How the proposed regulation, as modified, would still. adequately protect the public health and safety.
The comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attn: Docketing and Service Branch.
Backfit Analysis The Commission has determined that the backfit rule, 10 CFR 50.109, does not apply to this proposed rule because these amendments are mandated by 1
Section 306 of the Nuclear Waste Policy Act of 1982, 42 U.S.C. Section 10226. ';-
-l Therefore, a backfit analysis is not required 'for this proposed rule.
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O-E' List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Criminal penalties, Fire prevention, Incorporation by reference, Intergovernmental relations, Manpower training-programs, Nuclear power plants and reactors, Occupational safety and health',
Radiation protection, Reactor siting criteria, Reporting and recordkeeping requirements.
b 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, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Part 50 as follows:
PART 50 - DOMESTIC LICENSING 0F PRODUCTION AND UTILIZATION FACILITIES
- 1. The authority citation for 10 CFR Part 50 is revised to read as follows:
Authority: Secs. 102, 103, 104, 105, 161, 182, 183, 186, 189, 68 Stat, 936, 937, 938, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244, as amended (42 U.S.C. 2132, 2133, 2134, 2135, 2201, 2232, 2233, 2236, 2239, 2282); secs, 201, as amended, 202, 206,.88 Stat. 1242, as amended, 1244, 1246, (42 U.S.C. 5841, 5842, 5846).
Section 50.7 also issued under Pub. L.95-601, sec.-10, 92. Stat. 2951 (42 U.S.C. 5851). Section 50.10 also issued under secs. 101, 185, 68 Stat.
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5 936, 955, as_ amended (42 U.S.C. 2131, 2235); sec. 102, Pub. L.91-190, 83 Stat. 853 (42-U.S.C. 4332). Sections 50.13, 50.54(dd), and 50.103 also issuej under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138). Sections 50.23, 50.35, 50.55, and 50.56 also issued under sec.185, 68 Stat. 955 (42 U.S.C.
2235). Sections 50.33a, 50.55a, and Appendix Q also issued under sec. 102,_
Pub. L.91-190, 83 Stat 853 (42 U.S.C.-4332). Sections 50.34 and 50.54 also:
issued under sec. 204, 88 Stat. 1245 (42 U.S.C. 5844). Sections 50.58, 50.91, and 50.92 also issued under Pub. L.97-415, 96 Stat. 2073 (42 U.S.C. 2239).
Section 50.78 also issued under sec. 122, 68 Stat. 939 (4? U.S.C. 2152). i Sections 50.80 through 50.81 also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.L. 2234). Appendix F also issued under sec. 187, 68 Stat. 955-(42 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, 4s amended (42 U.S.C._2273);
siSO.46(a) and (b), and 50.54(c) are issued under sec. 161b, 1611 and 161o. 68.
Stat. 948, 949, and 950 as amended (42 U.S.C. 2201(b), 2201(i), and 2201(o));
siSO.7(a), 50.10(a)-(c), 50.34(a) and (e), 50.44(a)-(c), 50.46(a) and (b), '
50.47(b), 50.48(a), (c), (d), and (e), 50.49(a), 50.54(a), (i), (i) (1), (1)-
(n), (p), (q), (t), (v), and (y), 50.55(f), 50.55a(a), (c)-(e), (g), and (h),
50.59(c), 50.60(a), 50.62(c), 50.64(b), and 50.80(a) and (b) are issued under f
sec. 161i, 68 Stat. 949, as amended (42 U.S.C. 2201(i)); and sl50.49(d),-(h),
and (j), 50.54 (w), (z), (bb), (cc), and.(dd), 50.55(e), 50.59(b), 50.61(b),
50.62(b), 50.70(a), 50.71(a)-(c) and (e), 50.72(a), 50.73(a) and (b), 50.74,.
I 50.78 and 50.90 are issued under.sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)). ,
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9 a.
- 2. Section 50.120 is added to read as follows:
s*50.120 Selection, training, and qualification of nuclear power _ plant personnel.
(a) Applicability. The requirements of this section apply to each applicant for (applicant) and each holder of an operating license (licenste)
- for a nuclear power plant of the type specified in s 50.21(b) or i 50.22.
(b) Definitions. As used in this section:
Learnino ob.iective means an instructional goal that is expressed in terms of measurable performance. A learning objective:
(1) Describes or implies the conditions under which the performance must occur; (2) Delineates the standards and evaluation criteria that must be met for mastery of the performance; and (3) Describes expected performance after training.
Qualification oroaram means the planned, organized, and managed sequence ,
of interactions between individuals and evaluators designed to demonstrate and document successful acquisition by the trainee of the proficiency of skills, ,
knowledge, and abilities required for job performance.
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Selection oroaram means those activities related to choosing. nuclear power plant personnel based on training program and job performance rdquirements, including job required physical characteristics.
Trainina proaram means the planned, organized, and controlled sequence of interactions between individuals and instructional resources and processes designed to establish and maintain skills, knowledge, and abilities required for successful job performance.
(c) Requirements.
(1) General requirements. Each applicant, by (180 days after the effective date of the rule) or 18 months prior to fuel load,'whichever is later, and each licensee, by (180 days after the effective date of the rule),
shall establish, implement, and maintain a selection program, a training program, and a qualification program considering all modes and conditions of operation including shutdown, normal, abnormal, emergency, and accident conditions, for nuclear power plant personnel in the following categories:
(i) Operators as defined in 10 CFR 55.4.
(ii) Senior operators as defined in 10 CFR 55.4.
(iii) Non-licensed operators.
(iv) Mechanical maintenance.
(v) Electrical maintenance.
(vi) Instrument and control.
(vii) Health physics and radiation protection.
(viii) Chemistry and radio-chemistry.
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(ix) Shift technical advisors.
(x) Personnel with other plant specific titles who perform functions
-similar to those in the above categories.
(xi) .0n-site managerial, supervisott, , and engineering support personnel. .
(xii) Personnel performing quality assurance functions as described in' 10 CFR Part 50, Appendix B.
(xiii) Personnel responsible for accident' assessment and mitigation'.
(2) Selection program. Under its selection program each applicant and each licensee shall select personnel who either --
(i) Have those job-required skills, knowledge, and abilities which are based on the systematic analysis performed under paragraph (c)(3)(ii)(A) of this section; or (ii) Have skills, knowledge, and abilities sufficient to satisfactorily complete the applicable training and qualification programs.
(3) Training program.
(i) Under its training program, each applicant and each licensee shall establish, implement, and maintain initial and-continuing training programs for personnel listed in paragraph (c)(1) of this section. These. programs must be derived from'a systems approach to training as described'in paragraphi (c)(3)(ii) of this section.
(ii) The systems approach to. training must contain,.as a minimum,:the-following essential steps:
I 27 4
.-a (A) Analysis. Perform a systematic analysis appropriate to the job to determine performance requirements and training needs of job incumbents.
I i
(B) Derivation of learning objectives. Where the analysis has indicated the need for training, derive from the analysis a set of learning objectives that describe the standard of desired job' performance after.
training.
(C) Design and implamentation. Design training programs based on learning objectives selected for training, and implement the program to achieve those-learning objectives.
(D) Trainee evaluation. Develop tests and testing procedures that are in accord with the job performance requirements and the learning objectives derived from the analysis. Administer the tests to demonstrate that the trainees meet the learning objectives.
(E) Program evaluation. Develop and implement a plan for periodic evaluation of the effectiveness of the personnel training program as indicated by personnel performance in the job settings. An evaluation of each program must be completed at least once every 24 calendar months.
= ,
(F) Program revision. Develop and implement a plan for using the ')
information from paragraphs (c)(3)(ii)(D) and (E) of this section, and other f l
. pertinent information (e.g., operating experience, and changes to ]
equipment / systems, regulations, and procedures), to revise the training 28 ;
1
/*'
programs. Program revisions must be completed within 12 calendar months of completion of the program evaluation performed in accordance with paragraph (c)(3)(ii)(E) of this section.
(4) Qualification program. Under its qualification program, each applicant and each licensee shall ensure that personnel listed in paragraph (c)(1) of this section, including contractor personnel, have qualifications commensurate with the performance requirements of the jobs to which they are assigned. The applicant or licensee shall establish the position selection criteria, specify the appropriate training, and identify post-training qualification requirements for its personnel. -
(d) Records. In accordance with i 50.71(d)(1), each applicant and each licensee shall maintain and keep available for NRC inspection, materials sufficient to document that the requirements of paragraph (c) of this section have been met. Documents related to the establishment, implementation, and maintenance of the selection and training programs must be retained for at least five years. Documentation demonstrating the qualification of personnel covered by paragraph .(c)(1) of this section, including contractor personnel, must be retained for each individual for the duration of employment.
(e) Implementation / Certification. Each applicant, by (180 days after-the effective date of the rule) or 18 months prior to fuel load,'whichever is:
later, and each licensee, by (180 days after the effective .date of the rule). -
shall submit to the Commission a certification by a duly authorized officer of 3 the applicant or licensee that personnel selection, training, and.
29 ,
c
.V 1
qualification programs meeting.the requirements of this section have been implemented.
Dated at Rockville, MD, this th day of 1991. .-
For the Nuclear Regulatory Commission.
Samuel J. Chilk, Secretary of the Commission.
30
s February 11, 1991 MEMORANDUM FOR: Edward L. Jordan, Chairman Committee to Review Generic Requirements FROM: Frank J. Miraglia, Douty Director Office of Nuclear Reactor Regulation
SUBJECT:
LINE-ITEM TECHNICAL SPECIFICATION IMPROVEMENT 5 - CHANGES IN SURVEILLANCE INTERVALS TO ACCOMMODATE A 24-MONTH FUEL CYCLE Licensees have proposed changes to Technical Specifications (TS) on a plant-specific basis to extend surveillance intervals to accommodate a longer fuel cycle. Increasing the length of the fuel cycle is a significant economic benefit. Therefore, the nuclear industry has expressed an interest in NRC guidance on information needed to support TS changes to extend all 18-month surveillances to accommodate a 24-month fuel cycle. The staff has prepared the enclosed CRGR review package for a proposed generic letter to provide guidance for extending surveillance intervals. The staff requests CRGR approval for this action.
The Commission's Interim Policy Statement on Technical Specification Improve-ments recognized the advantages of improved (TS) and endorsed the recommendations of the nuclear industry and the NRC staff for a program to develop TS improvements.
An important part of that program is the implementation of line-item TS improve-ments. The proposed action is to provide guidance for TS changes to accommodate an increase in the length of fuel cycles and is responsive to industry's interest in obtaining guidance on this subject.
ThestaffhaspreparedagenericlettertoprovideguidancetoallholdeFs$f operating licenses and construction permits for nuclear power reactors to facilitate the efficient implementation of this line-item TS improvement.
A draft of the generic letter is included in the CRGR package ~. This package has been reviewed by the OGC staff and they have no legal-objection to the proposed action. Please schedule a meeting at the earliest opportunity for CRGR review of this proposal. The generic letter is sponsored by Charles E. Rossi, Director, Division of Operational Events Assessment.
Original signed by Frank J. Miraglia Frank J. Miraglia, Deputy Director Office of Nuclear Reactor Regulation
Enclosure:
As stated DISTRIBUTION: See Attached Document Nome: 18M MEM0 This package was reviewed by J. Main, Technical Editor, on 08/06/90.
- Please see previous concurrence.
OTSB:00EA OTSB:D0EA C:0TSB:00EA C:GCB:00EA D:D0EA:NRR C:SM& DST
- TGDunning:tgd *RMLobel *JACalvo *CHBerlinger *CERossi SN@erry 08/08/90 08/09/90 08/27/ 0 08/30/90 ,08/31/S 01/d/ 1 D:DREP:NRR D:DET D4M OGC 4DT:NRR DD
- FJCongel *JERichardse .,T hada ni *SATreby (YMRussell FJ lia 09/20/90 12/09/90 OJ/q /9 ).09/10/90 0ll/ V^ 91 OQ/ /91
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Edward L. Jordan February 11, 1991
' DISTRIBUTION:
0158 R/F 00EA R/F Central Files TEHurley FJMiraglia WTRussell JGPartlow FPGillespie ,
-SAVarga DMCrutchfield CERossi ACThadani JERichardson FJCongel JWRoe BKGrimes JLieberman JHConran + 20 Copies- 44)86 Md/
CIGrimes SATreby SHLewis SNewberry JACalvo CHBerlinger AEChaffee RMLobel TGDunning LEKokajko OTSB Members i
4
. Enclosure CRGR REVIEW PACKAGE PROPOSED ACTION: Issue a generic letter to provide guidance on a license amendment request for changes in surveillance requirements that will f acilitate a 24-month fuel cycle.
CATEGORY: 2 RESPONSE TO REQUIREMENTS FOR CONTENT OF PACKAGE SUBMITTED FOR CRGR REVIEW (i) The proposed generic requirement or staff position as it is proposed to be sent out to licensees.
Enclosure A is a proposed generic letter to be sent to all holders of operating licenses or construction permits for nuclear power reactors.
It provides guidance for requesting a license amendment to implement changes in surveillance requirements that are compatible with the use of improved reactor fuels to obtain a 24-month fuel cycle.
(ii) Draft staff papers or other underlying staff documents supporting the requirements or staff position.
52 FR 3788, INTERIM COMMISSION POLICY STATEMENT ON TECHNICAL SPECIFICATION IMPROVEMENT This Policy Statement acknowledges the recommendations of the nuclear industry and the NRC staff, the studies of TS problems, and the role of short-term (line-item) improvements in the overall program to imple-ment improvements in TS.
(iii) Each proposed requirement or staff position shall contain the sponsor-ing office's position as to whether the proposal would increase requirements or staff positions, implement existing requirements or staff positions, or would relax or reduce existing requirements or staff positions.
The guidance related to 24-month fuel cycles results in an increase in the surveillance interval for those 18-month surveillances that are generally performed at each refueling outage. This increased interval is a relaxation of the existing bounding time limits for these surveil-lance intervals from 22.5 months (18 months + the 25-percent extension allowance) to 30 months (24 months + the 25-percent allowance).
(iv) The proposed method of implementation along with the concurrence (and any comments) of the Office of General Counsel (0GC) on the method proposed.
Changes in surveillance intervals for a 24-month fuel cycle are volun-tary and plant-specific based on the use of improved reactor fuel that permits plants to operate for a longer time between refueling outages.
Licensees would propose TS changes in accordance with the regulatory !
requirements for license amendments. 0GC has no legal objection to this proposal. )
1 (v) Regulatory analysis generally conforming to the directives and guidance of NUREG/BR-0058 and NUREG/CR-3568.
A formal regulatory analysis is not applicable because the relaxation of these requirements is voluntary.
(vi) Identification of the category of reactor plants to which the generic requirement, or staff position, is to apply.
This guidance is applicable to all power reactors. Any proposed TS change to accommodate a 24-month fuel cycle is voluntary.
(vii) For each category of reactor plants, the evaluation should be priori-tized and scheduled in light of other ongoing regulatory activities.
The evaluation is to consider information available concernfng any of the following factors as may be deemed appropriate and any other in-formation relevant and material to the proposed action.
(a) Statement of the specific objectives that the proposed action is designed to achieve.
Surveillance requirements that are specified with an 18-month interval are not compatible with the use of improved reactor fuels that would allow operation over a 24-month fuel cycle. Because small changes in surveillance intervals do not significantly affect risk from a system or component _ availability standpoint, the staff has not required extensive quantitative risk analysis to support license amendment requests to change TS surveillance requirements that would permit a 24-month fuel cycle. The only safety issues that the staff has identified, and that needs to be addressed on a plant-specific basis, is the possible effect on instrument errors due to instrument drift that could increase with the increase in instrumentation calibration interval. Errors caused by instrument drift are considerations that are included in safety analysis assumptions and the determination of trip system setpoints. The guidance provided in the proposed generic letter addresses information required to justify that the effect of instrument drift on safety is acceptable with an increase in instrument calibration intervals.
(b) General description of the activity that would be required by licensees in order to complete the action.
Licensees would propose a license amendment to change the existing TS consistent with the guidance provided.
(c) Potential change in risk to the public from the accidental offsite release of radioactive material.
No significant impact.
l (d) Potential impact on radiological exposure of facility employees and other onsite workers. !
No significant impact.
(e) Installation and continuing costs associated with the actbn, including the cost of facility downtime or construction delay.
This guidance will not increase costs for licensees because it merely clarifies information needed by the staff to review a request for a license amendment to change surveillance intervals to be compatible with an increesed fuel cycle interval. The cost associated with monitoring instrument drift to confirm that such drift does not affect safety is small in comparison to the economic benefits of an increase in the length of fuel cycles.
(f) The potential safety impact of changes in plant or operational complexity, including the relationship to proposed and existing regulatory requirements and staff positions.
This guidance will not increase plant or operational complexity.
Over the life of a plant, an increase in the length of the fuel cycle will reduce the number of refueling outages.
(g) The estimated resource burden on the NRC associated with the proposed action and the availability of such resources.
The burden on NRC resources should be minimal for all technical areas of the review with the exception of the Instrumentation and Controls Systems Branch (SICB) review of the justification that the licensee has accounted for instrument drift in an acceptable manner. With a thorough justification of the proposed TS changes, the effort for the SICB review should not exceed 0.1 staff-year per amendment request. It is not possible to forecast the number of licensees that will respond to this action. The project manager will be able to process the amendment without input from ;
other technical specialists, and the staff resource burden should be much less than that currently required for plant-specific reviews of such changes for submittals that are not based upon generic guidance. Therefore, there should be a net reduction in the NRC resource burden associated with the review of TS changes addressed by this action. ,
(h) The potential impact of differences in facility type, design or-age on the relevancy and practicality of the proposed action.
Facilities licensed before 1974 will generally have TS with custom formats. Although the guidance for this change follows the STS format, it would be adaptable to custom format TS with a minimum of effort. Differences in facility type and design would have minimal effect on the proposed action.
9 (1) Whether the proposed action is interim or final, and if interim, the justification for imposing the proposed action on an interim basis.
This action is considered final in that the staff anticipates no further changes to extend fuel cycles.
(viii) for each evaluation conducted pursuant to 10 CFR 50.109, the proposing office director's determination, together with the rationale for the determination based on the considerations of paragraphs (1) through (vii)above,that (a) there is a substantial increase in the overall protection of public health and safety or the common defense and security to be derived from the proposal; and (b) the direct and indirect costs of implementation, for the facilities affected, are just'fied in view of this increased protection.
Because this initiative is voluntary, backfit considerations are not applicable.
(ix) For each evaluation conducted for proposed relaxations or decreases in current requirements or staff positions, the proposing office direc-tor's determinction, together with the rationale for the determination '
based on the considerations of paragraphs (i) through (vii) above, that (a) the public health and safety and the common defense and security would be adequatc'y protected if the proposed reduction in re-quirements or positions were implemented, and (b) the cost savings attributed to the action would be substantial enough to justify taking the action.
The small change in the time interval for performing surveillances that would be allowed to accommodate a 24-month fuel cycle would have a negligible effect on safety. The cost benefits of an in-creases in the length of a fuel cycle are a major economic consid-eration for operating nuclear power plants. However, the major savings attributed to this guidance are a reduction in costs for ;
preparing license amendment requests for the licensees and a l reduction in costs for staff reviews of those proposals.
I i
0%g f UNITED STATES
,Q/. tg Enclosure A
.y} NUCLEAR REGULATORY COMMISSION
- j cil WASHINGTON, D. C. 20%5 o, + ;IN.pj (draft) l T0
- ALL HOLDERS OF OPERATING LICENSES OR CONSTRUCTION PERMITS FOR NUCLEAR POWER REACTORS
SUBJECT:
CHANGES IN TECHNICAL SPECIFICATION SURVEILLANCE INTERVALS TO ACCOMMODATE A 24-MONTH FUEL CYCLE (Generic Letter 91- )
Improved reactor fuels allow licensees to consider an increase in the duration-of the fuel cycle for their facilities. On a plant-specific basis, the staff has reviewed requests to modify the 18-month or other refueling outage related surveillance intervals to be compatible with a 24-month fuel cycle. In response to industry interest, guidance for a license amendment request to extend surveillance intervals to accommodate a 24-month fuel cycle is provided in Enclosure 1.
Technical Specifications (TS) that specify an 18-month surveillance interval would be changed to state that these surveillances are to be performed once per refueling interval. The notation for surveillance intervals would be changed to include the definition of a " Refueling Interval" with the existir.g letter "R" notation for surveillances that are generally performed during a refueling outage. The frequency for this notation would be changed from 18 months to "At least once every 24 months." With the provision to extend surveillances by 25 percent of the specified interval, the time limit for completing these surveillances would increase from the existing bounding limit of 22.5 n:onths to a maximum 30 months.
This change does not, however, alter the required 24-month testing interval for performing Type B and C tests under the leakage testing requirements of Appendix J to Title 10 of the Code of Federal Regulations (10 CFR) Part 50.
It is anticipated that an extension of the testing interval will be required to actually accommodate a 24-month fuel cycle. This increase in the testing interval for Type B and C tests will require a request for an exemption from Appendix J requirements. The specific time interval is considered a plant-specific issue, however a minimum of 27 months appears to be prudent in view of historical variations in the actual time of any given fuel cycle. Licensees desiring an exemption from the 24-month testing interval should provide supporting leak testing data to demonstrate that the requested test interval would not provide unacceptable results. Guidance for perparing this exemption request is included in Enclosure 2.
The interval for conducting steam generator inservice inspections is worthy of special consideration for extending surveillance intervals to be compatible with a 24-month fuel cycle. This is an important consideration' based on oper-ating experience and the frequency of steam generator tube ruptures, as well' as the possible effect on safety. Therefore, an alternative for extending the existing 24-month interval for steam generator ISI requirements is provided based on a conservative approach that includes an increase in the sample size of the number of tubes for an inspection based upon the TS category of the prior inspection results. In some cases, an analysis of steam generator tube integrity and a lower TS limit on primary-to-secondary coolant system leakage
, l l
)
would be appropriate based upon prior inspection results. Finally, an exten- l sion of the inspection interval would not be appropriate if the results of the i prior. inspections fell in worst category with respect to steam generator tube j integrity.
Instrument drift is another important consideration that licensees must address when proposing an increase in the surveillance interval for calibrating instru-ments that perform safety functions including the capability for safe shutdown.
Because instrument errors due to drift are included as considerations for the determination of safety system setpoints and are one of the initial condition considerations of safety analyses, the effects of an increased calibration l interval on instrument errors need to be addressed. Information is required as outlined in Enclosure 3 to address the safety impact of an increased calibration interval on instrument drift. ,
for all other 18-month surveillances, experience has shown that the effect on safety of a small change in test intervals to accommodate a 24-month fuel cycle is small. Therefore, licensees do not need to address the effect of changes in surveillance interval on the availability of systems or components on an individual TS basis.
Licensees that plan to adopt a 24-month fuel cycle are encouraged to propose TS changes and a request for an exemption to Appendix J requirements that are consistent with the enclosed guidance. Proposed amendments that deviate from the guidance provided will lengthen the time required to complete the review.
Please contact the NRC Project Manager or the contact indicated below if you have questions on this matter.
Any response to the NRC suggestion for TS changes is voluntary. Therefore, any action taken in response to the guidance provided in this generic letter is not a backfit under 10 CFR 50.109. Likewise, Office of Management and Budget clearance is not required.
Sincerely, James G. Partlow Associate Director for Projects Office of Nuclear Reactor Regulation
Enclosures:
As stated
Contact:
Tom Dunning, OTSB/NRR (301)492-1189
Generic Letter 91- Enclosure 1 GUIDANCE ON PREPARATION OF A LICENSE AMENDMENT REQUEST FOR CHANGES IN SURVEILLANCE INTERVALS TO ACCOMMODATE A 24-MONTH FUEL CYCLE DISCUSSION Licensees are planning to use improved reactor fuels because of the significant !
economic benefits associated with a longer fuel cycle. A longer fuel cycle increases the time interval between refuelin the associated technical specification (TS) gsurveillance outages and the performance requirements. This of guidance is provided to address TS changes for those surveillances that are per-formed on an 18-month or other refueling outage interval basis to accommodate a 24-month fuel cycle.
The NRC staff has reviewed a number of one-time requests to extend 18-month surveillances to the end of a fuel cycle and a few requests for changes in sur-veillance intervals to accommodate a 24-month fuel cycle. Based on these reviews, the staff concludes that an increase in 18-month surveillance inter-vals to accommodate a 24-month fuel cycle does not have a significant effect on safety since any associated decrease in system availability is small. This is because of the redundancy that exists in both electrical and mechanical com-ponents used in safety systems and the assurance provided by other surveil-lances performed during plant operation that confirm the capability of these system components to perform their safety functions.
TECHNICAL SPECIFICATION CHANGES Changes to accommodate a 24-month fuel cycle should be proposed by modifying 18-month surveillances to indicate that they are to be performed ". . . at least once each REFUELING INTERVAL." In addition, the surveillance interval notation in Table 1.1 in the Definitions Section of the TS should be modified to include the term " REFUELING INTERVAL" along with the letter "R" notation to define the frequency for surveillances that are specified to be performed once each refueling interval. (Capitalization of the term " refueling interval" is used in the TS to designate a defined term.) The frequency for this notation .
should be changed from "At least once per 18 months" to "At least once per 1 24 months" to define the nominal frequency for surveillances that are specified to be perforned each refueling interval or with the letter "R" notation. The bounding time interval for these surveillances would then be 30 months under the provision of Specification 4.0.2 that allows a surveillance to be extended by 25 percent of the specified interval.
Where the TS specify that an 18-month surveillance is to be performed "during shutdown," this qualification may be omitted when specifying the surveillance interval as ". . . at least once per REFUELING INTERVAL." Because TS have defined " Hot" and " Cold Shutdown" as operating modes or conditions, the added restriction to perform certain surveillances during shutdown is subject to misinterpretation. The intent of this restriction is to ensure that a surveil-lance would only be performed when it is consistent with safe plant operation.
However, this is also a valid consideration for other surveillances that are performed during power operation, plant startup, or shutdown, but one that is not addressed by placing a restriction on conducting these surveillances.
The staff concludes that the TS need not restrict surveillances as only being performed during shutdown. Nevertheless, it would be contrary to safety if refueling interval surveillances were performed during power operation without
+ -
+.
Generic Letter 91- Enclosure 1 proper regard for their effect on safe plant operation. If.the performance of a refueling interval surveillance during plant operation would adversely affect safety, the surveillance should be postponed until the unit is shutdown for.
refueling or is in a condition or mode that is consistent with the safe. conduct of that surveillance.
Because' the TS changes to accommodate a longer fuel cycle alter the basis for Specification 4.0.2 that was updated by Generic Letter 87-09 and subsequently modified by Generic Letter 89-14, the Bases Section of Specification 4.0.2 should also be changed to-be consistent with these TS changes and particularly with respect to the safe conduct of refueling interval surveillances. The-underlined changes to the asseciated paragraph of the previous guidance on the Bases Section of Specification 4.0.2 is as follows:
It also provides flexibility to accomodate the length of a fuel cycle for surveillances that are specified to be performed at least once each REFUELING INTERVAL. It is not intended that this provision be used repeatedly as a convenience to extend surveil-lance intervals beyond that specified for surveillances that are not performed once each REFUELING INTERVAL. Likewise, it is not the intent that REFUELING INTERVAL surveillances be performed during power operation unless it is consistent with safe plant operation. The. limitation of Specification:4.0.2.is . . .
Licensees should incorporate these changes to the Bases..Section of Specifi-cation 4.0.2 where-they have been modified as identified in Generic Letters 87-09 and 89-14. Otherwise, the Bases Section should be updated.to reflect the intent of this guidance. The proposed amendment request should include a copy of the updated Bases Section for Specification 4.0.2.
The surveillance interval for performing.the second inservice inspection of steam generators is currently specified with a bounding time limit of 24 calen- -
dar months after the previous inspection. .The. interval for subsequent inspec-tions may be extended to a maximum of 40 months if the results from two consec-utive inspections, excluding the preservice inspection', fa11'within-the C-1
- Category results or if two consecuti.ve inspections demonstrate that previously-observed degradation has not continued.and no additional degradation has occur-red. However, for plants having steam generator inspection results.in the C-2 Category during either of .the two' previous inspections, the bounding time-interval for the next inspection would be 24 months from the last inspection. ,
A 24-month inspection interval may not coincide with the next refueling outage when operating on a 24-mounth fuel' cycle, particularly ..if any outage time is - ,
accumulated over the duration of the fuel cycle or there 'is any significant delay from the completion of the previous inspection and startup for the next ;
fuel cycle. Therefore, to overcome the potential that the interval for steam '
generator inspections could fall near the end of a 24-month fuel cycle but -- :
prior to the refueling outage, the staff developed an alternative based on the -
l following considerations; (1) an increase in the sample size of tubes examined-during the previous inspection, (2)'a suitable analysis of' steam generator tube integrity if the results of either of the two previous inspections fell within C-2 Category results, and (3) a more restrictive primary-to-secondary coolant-system leakage limit for operation beyond 24 months of the previous inspection.-
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o Generic Letter 91- Enclosure 1 These considerations would provide an acceptable basis to permit the next ir.spection interval to be compatible with the 30-month bounding limit for refueling interval surveillances so long as the results of either of the two previous inspections did not fall within the C-3 Category results.
The current TS requirements permit inspections to be conducted at a 40-month interval if the results of two previous inspections fell within the C-1 Cate-gory results. However, this may not provide a practical alternative for facilities that would operate on a 24-month fuel cycle. The inspection results would fall into the C-2 Category if only one defective tube were found during either of the two previous inspections and this would preclude the use of the provision for extending the inspection interval to 40 months.
The alternatives for the TS section on steam generator inspection frequencies are shown underlined based on the current STS requirements.
4.4.5.3 Inspection Frequencies - The above required inservice inspections of steam generator tubes shall be performed at the following frequencies:
- a. The first inservice inspection shall be performed after 6 Effective Full Power Months but within 24 calendar months of initial criticality. Subsequent inservice inspections shall be performed at intervals of not less than 12 nor more than 24 calendar months after the previous inspection. If 20% of the tubes were inspected and the results found to fall within C-1 Category results or if 40% of the tubes were inspected and fell within C-2 Category results during the previous inspection, the next inspection may be extended up to a maximum of 30 months in order to correspond with the next refueling outage provided the results of the two 3revious inspections did not fall within the C-3 Category results. iowever, when the results of either of the previous two inspections tall within C-2 Category results, an engineering assessment shall be performed prior to operation beyond 24 months and shall provide assurance that all tubes will retain adequate structural margins against burst for the spectrum of normal operating, transient, and accident conditions until the end of the fuel cycle or 30 months, which ever occurs first.
If two consecutive inspections, not including the preservice inspec-tion, result in all inspection results falling within the C-1 Cate-gory or if two consecutive inspections demonstrate that previously observed degradation has not continued or no additional degradation has occurred, the inspection interval may be extended to a maximum of once per 40 months;
- b. If the results of the inservice inspection of a steam generator conducted in accordance with Table 4.4.2 at 40-month intervals fall into Category C-3, the inspection frequency shall be increased to at least once per 20 months. The increase in inspection frequency shall apply until the subsequent inspections satisfy the criteria of Specification 4.4.5.3a.; the interval may then be extended to a maximum of once per 30 or 40 months, as applicable;
- c. (no change to unscheduled inservice inspection requirements.); and
l o ;
4 Generic Letter 91- Enclosure 1
- d. The provisions of Specification 4.0.2 do not apply for extending the l frequency for performing inservice inspections as specified in ;
Specifications 4.4.5.3a. and b.
Specification 4.4.5.3d. has been added to clarify the staff's position that the provision of Specification 4.0.2 is not applicable for extending inspection intervals since Specification 4.4.5.3a. addresses those conditions under which the 24-month surveillance interval for steam generator tube inspections may be extended and Specification 4.4.5.3b. address conditions under which the surveillance interval for inspections shall be reduced to at least once per 20 months.
The Bases Section of Specification 3/4.5.4 should be updated to clarify the intent of the engineering assessment of steam generator tube integrity addressed in the above addition to Specification 4.4.5.3a. by including the following:
The purpose of an engineering assessment of steam generator tube integrity is to confirm that no undue risk is associated with plant operation beyond 24 months of the previous steam generator tube inspection. This purpose is met by an assess-ment which demonstrates that all tubes will retain adequate structural margins against burst for the spectrum of normal operating, transient, and accident conditions until the end of the fuel cycle. This evaluation would include the following elements:
- 1. An assessment of the maximum flaw sizes (i.e., flaw depth and length) found during the previous inspection.
- 2. An assessment of the maximum flaw size which can be expect-ed prior to the end of the current fuel cycle or 30 months, which ever comes first, and the corresponding structural margins relative to the criteria of Regulatory Guide 1.121.
- 3. An update of the assessment model, as appropriate,-based on comparison of steam generator tube integrity assessment predictions with actual inspection results from prior inspections.
With the above alternative for inspection intervals, the following addition to the TS section on reactor coolant system operational leakage is required and 1 shown underlined for the current STS requirements.
3.4.6.2 Reactor Coolant System leakage shall be limited to:
- a. & b. (No change.)
- c. 1 GPM total reactor-to-secondary leakage through all steam generators not isolated from the Reactor Coolant System and [500] gallons per day through any one steam generator not isolated from.the Reactor Coolant System. For plant operation beyond 24 months of the previous steam generator tube inspection when the results of either of the two
a
- Generic Letter 93- Enclosure 1 arevious inspections fall within the C-2 Category results as defined
>y Specification 4.4.5.2, the leakage through any one steam gene ator not isolated from the Reactor Coolant System shall not exceed 100 '
gallons per day,
- d. & e. (No change.)
o Generic. Letter 90- Enclosure 2 l l
GUIDANCE ON PREPARATION OF AN EXEMPTION TO APPENDIX J OF 10 CFR PART 50 TO ACCOMM0DATE A 24-MONTH FUEL CYCLE DISCUSSION The NRC staff has been working on changes to Appendix J to 10 CFR Part 50 to address the resolution of a number of problems that have been' encountered with this regulation. Among the changes currently being considered are changes to the surveillance interval for performing Type B and C leak testing that would accommodate a longer fuel cycle. However, until such changes are incorporated in the regulation, the current 24 month surveillance interval for Type B and C tests would likely require a plant shutdown to perform Appendix J leak testing before the completion of a 24-month fuel cycle. Therefore, the practical solution to this limitation is a plant-specific exemption to the requirements of Appendix J until such time as the regulation is revised in a manner such that an exemption to its requirements would no longer be needed to accomodate a 24-month fuel cycle.
The bounding time limit for surveillance intervals specified in TS is being revised to 30 months to accommodate a 24-month fuel cycle. Thus, a 25 percent increase in the 24-month surveillance interval for Type B and C leak tests as specified by Appendix J would be required to be compatible with the change in the TS surveillance interval limit to accommodate a 24-month fuel cycle. The NRC staff concludes that two considerations should be addressed to justify an exemption to the Appendix J to permit the surveillance of Type B and C tests to be extended up to 30 months.
The first is a possible reduction in the combined leakage limit for Type B and C tests based upon an increase in the margin to the acceptable leakage limit which is proportional to the increase in the surveillance interval. The acceptance criterion for Appendix J Type B and C leak tests is a combined leakage rate for all penetrations and valves that are subject to Type B and C tests that shall be less than 0.6 La. This constitutes a margin of 0.4 of the maximum allowable leakage, La. It should be demonstrated, using leak test data, that this margin will be preserved with the proposed increase in the test interval, or an acceptance criterion limit of less than 0.6 La should be considered.
The second consideration is that there should be a reasonable basis to conclude that containment leakage will be maintained within acceptable limits based upon the extrapolation of the results of past Type B and C leak tests to account for an increase in the survaillance interval up to 30 months. The exemption request should provide a summary of the methodology used and results obtained that support this conclusion.
SUMMARY
The granting of an exemption to the requirements of Appendix J that is based upon a request and justification as noted above would be effective until such time that Appendix J is revised and the revised requirements have been implemented.
G Generic Letter 90- Enclosure 3 GUIDANCE FOR ADDRESSING THE EFFECT OF INCREASED SURVEILLANCE INTERVALS ON INSTRUMENT DRIFT AND SAFETY ANALYSIS ASSUMPTIONS Discussion The NRC staff has identified instrumentation errors caused by drift as an issue that licensees need to address to justify an increase in surveillance intervals to accommodate a 24-month fuel cycle. The effects of an increased calibration interval on instrument arrors must be evaluated to confirm that drift will not result in instrument errors that exceed the assumptions of the safety analysis.
Instrument drift affects the capability of a system to perform its safety function and is a consideration for determining safety system setpoints. The amount of instrument drift that occurs over a long interval.between calibration may not be readily available from the instrument vendor. However, operating experience and available vendor data can provide insights on the potential increase in instrument errors that could occur with an increased calibration interval. These insights, with a program to monitor and assess the long-term effects of instrument drif t, can provide the basis for increasing the refueling outage related calibration intervals for instruments that perform safety functions.
Justification for Increased Calibration Intervals Licensees should address a number of considerations to provide an acceptable basis for increasing the calibration interval for instruments that are used to perform safety functions. For each of these considerations, the NRC staff has identified a specific action to be addressed to justify a proposed increase in the calibration interval.
The surveillance and maintenance history for instrument channels should demon-strate that the vast majority of problems affecting instrument operability are 4 found as a result of surveillance tests other than the instrument calibration.
If the calibration data show that instrument drif t is beyond acceptable limits on other than rare occasions, this would preclude consideration of an increase .
in the calibration interval because of a lack of confidence that instrument !
drif t would not pose a safety problem. I
- 1. Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.
The licensee should have a body of as-found and as-left calibration data that permits the determination of the instrument drift. characteristics per unit time ,
over the calibration interval. This data should allow the determination of I instrument drift for those instruments that perform safety functions.
- 2. Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high degree of certainty and confidence. Provide a 1 summary of the methodology and assumptions used to determine the values of instrument drift per unit time based upon historical plant calibration data.
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Generic Letter 90- Enclosure 3 The magnitude of the instrument drift error that occurs over a longer interval is an important consideration to justify an extension of the calibration inter-val for instruments that perform safety functions. The applications where the calibration interval for these instruments is dependent upon the length of the fuel cycle and could be as long as 30 months (the extension limit for this calibrationinterval)needtobeidentified. For each of these applications, the projected value of the instrument drift error that could occur over a 30-month interval should be determined.
- 3. Confirm that the magnitude of instrument drift has been determined with a high degree of certainty and confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications.
An important consideration is whether the projected value of instrument drift for an increased calibration interval is consistent with the values of drif t errors used in the determination of safety system setpoints. Setpoints are established to ensure that the consequences of accidents and anticipated tran-sients are bounded within the assumptions of the safety analysis. If the allowance for instrument drift that was used to establish trip setpoints for safety systems would be exceeded, this will necessitate the determination of new trip setpoints for safety systems. Instrument Society of America Standard, ISA-A67.04-1982, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants," provides a methodology for evaluating instrument drift.
This standard has been endorsed by Regulatory Guide 1.105, " Instrument Set-points." If a new setpoint must be used to ensure that safety actions will be initiated consistent with the assumptions of the safety analysis, this will require a TS revision to reflect a new trip setpoint value. If the combination of instrument drift errors and current trip setpoints are not consistent with existing safety analysis assumptions, a new safety analysis would be required to confirm that safety limits will not be exceeded with the increased drift associated with longer calibration intervals.
- 4. Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, proposed TS changes to update trip setpoints shall be provided. If the drift errors result in a revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.
The determination of the effect of instrument errors on control systems used to effect a safe shutdown is another important consideration. The instrument errors caused by drift must be confirmed to be acceptable with respect to the capability to achieve a plant shutdown.
- 5. Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation.
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4 Generic Letter 90- Enclosure 3 Experience has shown that oversights have been made when translating the assumptions of the safety analysis and the results of the setpoint methodology to acceptance criteria for plant surveillance procedures. Therefore, a review should be made to confirm that instrument drift and other errors and assump-tions of the safety and setpoint analyses are consistent with the acceptance criteria included in plant surveillance procedures. This review should include channel checks, channel functional tests, and the calibration of channels for which surveillance intervals are being increased.
- 6. Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and ,
channel calibrations.
Finally, a program should exist to monitor calibration results and the effect on instrument drift that will accompany the increase in calibration intervals.
The program should ensure that existing procedures provide data for evaluating the longer term effects of increased calibration intervals. The data should confirm that the estimated errors for instrument drift with increased calibra-tion intervals are withir. the limits projected.
- 7. Provide a summary description of the program for monitoring and continuing to assess the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.
In summary, a justification for increased surveillance intervals for -instrument channel calibration may be provided by addressing each of the items noted herein.
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n Enclosure B MODEL SAFETY EVALUATION REPORT Underscored blank spaces are to be filled in with the applicable informa-tion. The information identified in brackets should be used as applicable on a plant-specific basis.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. TO FACILITY OPERATING LICENSE NFP- '~
AND AMENDMENT N0. ~ TU~ FACILITY OPERATING LICENSE NFP- -
[ UTILITY NAME]
DOCKET N05. 50- AND 50-
[ PLANT NAME], UMTTS 1 AND E~
INTRODUCTION By letter of 199 , [ utility name] (the licensee) proposed a changes to the technicaT, specifications (TS) for [ plant name]. The proposed changes modify surveillances that are specified with an 18-month surveillance interval to accommodate a 24-month fuel cycle. Guidance on the proposed TS changes were provided by Generic Letter 91- , of _ , 199 , to all holders of operating licenses or constructi _on permits for nuclea_r power reactors.
EVALUATION To accommodate a 24-month fuel cycle, the licensee has proposed to modify the TS specifying an 18-month surveillance interval to state that they are to be performed ". . . at least once each REFUELING INTERVAL." With this change in surveillance intervals, the TS for some surveillance will no longer state that they are to be performed during shutdown. In addition, changes to Table 1.1 in the Definition Section of the TS were made to define a REFUELING INTERVAL with the existing letter "R" notation for surveillance that are generally performed during a refueling outage. The frequency for this notation was changed from 18 months to a frequency of "At least once every 24 months."
These changes are consistent with the guidance provided in Generic Letter 91 _ and are, therefore, acceptable.
The licensee proposed changes to the Bases Section of Specification 4.0.2 on the allowance for extending surveillance intervals. These changes clarify that refueling interval surveillances should not be performed during power operation unless such action is consistent with safe' plant operation. The ,
removal of the qualification to perform some surveillances during shutdown l and the clarification of the Bases for TS 4.0.2 are consistent with the guidance provided in Generic Letter 91 _ .
The licerisee has proposed changes to the steam generator inservice inspection I frequencies specified in TS 4.4.5.3. These changes allow the 24 month'intervol for tube inspections to be extended up to 30 months to correspond with the next i refueling outage 1f 20 percent of the tubes were inspected during the previous inspection and the results found to fall within the C-1 Category results or if i 40 percent of the tubes were inspected and fell within C-2 Category results. '
This provision is conditionel upon the results of the two previous inspections not being within the C-3 Category results. If the results of both of these
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y 1
J inspections fell within C-2 Category results, an engineering assessment is 1 required prior to operation beyond 24 months and must provide assurance that all tubes will retain adequate structural margins against burst for the spectrum of normal operating, transient, and accident conditions until the end of the fuel cycle or 30 months, which ever occurs first. Finally, an addition was nade to this section to state that the provision of TS 4.0.2, that allows survrillance intervals to be extended, does not apply for extending the i frequency for performing inservice inspections as specified in this section. i An associated change was proposed for the TS on reactor. coolant system leakage that imposes a restriction that applies for plant operation beyond 24 months of the previous steam generator tube-inspection when the results of either of the i two previous inspections fall within the C-2 Category results. This restric-tion limits the leakage through any one steam generator not isolated from the reactor coolant system to not exceed 100 gallons per day. ;
Finally, the Bases Section for TS 4.4.5.3 was updated to clarify the purpose of what constitutes an appropriate engineering assessment of steam generator tube integrity when required to confirm that no undue risk is associated with_ plant operation beyond 24 months. The TS changes and the updated Bases Section on related to steam generator tube inspections are consistent with the guidance provided in Generic Letter 91 _ and is, therefore, acceptable. <
To support the proposed changes to accommodate a 24-month fuel cycle, the licensee examined calibration data from surveillance and maintenance records and confirmed that instrument drift has not, except on rare occasions, exceeded acceptable results. Therefore, historical data do not indicate any problems would preclude an increase in instrument calibration intervals. The licensee has determined the values of drift for each instrument type and application based on historical calibration data. The licensee provided a description ~of the methodology and assumptions used to determine.the values of instrument drift per unit time. Based upon this information, the licensee determined the projected values of instrument drift that could occur with an increased ,
calibration interval up to a bounding limit 30 months.
The projected instrument drift errors were compared to the values of drift used in the analyses to determine acceptable setpoints'for safety systems. The
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licensee has confirmed that safety limits and safety analysis assumptions are i not exceeded with the consideration of the instrument drift errors associated with the increase in instrument calibration intervals. Hence, not changes in were required in safety system.setpoints or. Safety analysis. [ NOTE: If any such changes were required, they are to be discussed.]
The licensee has confirmed that projected instrument errors caused by drift are acceptable for control'of plant parameters to effect a safe shutdown with the associated instrumentation. Also, the _ licensee confirmed that all condi-tions and assumptions of the setpoint and safety analyses have.been checked and are appropriately reflected in the acceptance criteria of plant surveil-lance procedures for channel checks, channel functional tests and channel calibrations. Finally, the licensee provided a description of the program for ,
monitoring and continuing to assess the effects of increased calibration l
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surveillance intervals on instrument drif t and its effect on safety. Based on the review of this information, it is concluded that the licensee has preformed an adequate analysis of the effect of increased calibration intervals on instrument drift and its impact on safety.
ENVIRONMENTAL CONSIDERATION These amendments involve changes to the use of the facility components located within the restricted area as defined in 10 CFR Part 20. The staff has deter-mined that the amendments involve no significant increase in the amounts and no significant changes in the types of any effluents that may be released offsite, and that there is not significant increase in inoividual or cumulative occupa-tional exposure. The staff based this finding on the licensee's analysis of the effect of increased surveillance intervals on instrument drif t and the verification that these etfects are within the initial conditions and assump-tions of the safety analysis that forms the licensing basis. [ NOTE: Address any changes in setpoints or safety analyses that may have been required as a consequence of the effect of instrument drift errors.] The staff has deter-mined that the amendments involve no significant-hazards consideration, and there has been no public coment on this finding, According the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in conjunction with the issuance of these amendments.
CONCLUSION The Comission made proposed determinations that the amendments involve no significant-hazards consideration, which were published in the Federal Register (5 , FR _ _ ) on _ , 199_. The Comission consulted with the State of . No public coments were received, and the State of did not have any coments.
On the basis of the considerations discussed herein, the staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: Thomas G. Dunning, OTSB/D0EA
, SICB/ DST
, PD _fDRP _
Dated: _ , 199 _
(NOTE TO PMs: A copy of this model SER may be obtained from P. Coates, X-21161 by requesting 5520 Document: "18M GL SER")