ML20151G083
| ML20151G083 | |
| Person / Time | |
|---|---|
| Issue date: | 04/11/1988 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Raby T NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY (FORMERL |
| Shared Package | |
| ML20151G085 | List: |
| References | |
| NUDOCS 8804190213 | |
| Download: ML20151G083 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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APR 11 1988 Mr. Tawfik M. Raby, Chairman Test, Research, and Training Reactors Building 235 National Bureau of Standards Gaithersburg, Maryland 20899
Dear Mr. Raby:
SUBJECT:
IMPACT OF RECENT REVISIONS TO 10 CFR 55 ON TEST AND RESEARCH REACTORS Thank you for your letter of October 12, 1987 in which you raised the concerns of the test, research, and training reactor (TRTR) community about the effect of recent changes to 10 CFR 55 on that community. Although we intended to provide clear guidance about the impact of the regulation upon test and research reactors in the preamble accompanying the regulation, we agree that the regulation itself was not sufficiently clear on this matter.
Accordingly, we have reviewed the major areas of concern expressed in your letter and have prepared a reply that we believe is respor.sive to those concerns. That reply is enclosed.
The enclosure also explains the options available in the area of TRTR requalification pregrams and re-examination of licensed personnel as a condition of the 6-year license. To allow the TRTR community to pursue these options, the regional operator licensing sections have been directed to delay implementation of 10 CFR 55.57 examinations at TRTR facilities until early 1991.
It should be noted that, to ensure the conti.ued safe operation of TRTR facilities, it was and is our intent that long-term licensed personnel at such facilities participate in requalificatior programs and pass NRC-administered comprehensive requalification examinations in accordance with the requirements of 10 CFR Part 55.
We appreciate the concerns of the TRTR group and those other facilities that utilize 10 CFR Part 55 in the training, certification, and retraining of operators at nuclear facilities. We encourage continuing dialecue with the TRTR group on any issues of concern.
Please address any correspondence to Mr. John N. Hannon, Chief, Operator Licensing Branch, Division of Licensee Performance and Quality Evaluation, Office of Nuclear Reactor Regulation.
Sincerely,
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orM.d cirned tr yict u "t tlk Victor Stello, Jr.
I' Executive Director for Operations
//
Enclosure:
Response to Letter Dated 10/12/87 cc: Dr. A. Johnson Oregon State University 8804190213 080411 PDR ORG NE E
RESPONSE TO CONCERNS RAISED BY TEST, RESEARCH.
AND TRAINING REACTORS ON THE EFFECT OF 10 CFR 55 CHANGES (1) Background When Appendix A to 10 CFR 55 was implemented in 1973-74, all test,'research, and training reactor (TRTR) programs were expected to meet the Appendix A requirements and to be submitted for approval by the Atomic Energy Commission / Nuclear Regulatory Commission. When ANSI /ANS-15.4-1977, "Selection and Training of Personnel for Research Reactors," was issued, no supporting regulatory guidance had been published; however, some TRTR licensees may have used ANSI /ANS-15.4 as guidance to modify their reoualification programs.
In Generic Letter 83-12A, dated July 13, 1983, the staff advised non-power reactor licensees that the use of ANSI /ANS-15.4-1977 criteria was acceptable for establishing requalification programs.
Between 1983 and 1986, the staff used the criteria in both Appendix A to 10 CFR 55 and ANSI /ANS-15.4-1977 in its review of TRTR requalification programs.
The staff is aware that seme consideration was given to issuing a regulatory guide (RG) to endorse ANSI /ANS-15.4-1977; however, no RG was published since Generic Letter 83-12A already endorsed the standard for regulatory use.
(2)
Intended Applicability of Revised 10 CFR 55 to Test and Research Reactors Since the publication in the Federal Register (52 FR 9453) of revisions to 10 CFR 55 on March 25, 1987, the staff has become aEare that the applicability of the regulation to test and research reactors may not have been clear. Although the "Supplementary Information," published as a preamble to the regulation, sought to describe its applicability to TRTRs in several areas, the regulation itself may have been subject to interpretation, specifically in the areas of recualification programs and NRC-administered reocalification examinations.
The following information is intended to clar'fy the staff's position on these issues.
(3) Reoualification Programs for Test and Research Reactors The Statement of Considerations indicates that no changes are required to the content of test reactor training programs that were acceptable under the old rule. However, there may be some changes required to the procedural aspects of the program (e.g., a comprehensive examination once every 2 years, an operating test every year). A facility licensee may make these revisions without prior notification provided that no decrease in program scope is involved. A facility licensee may also decide to continue with the annual comprehensive examinations if they were previously approved; i.e.,
they would not have to make certain procedural changes unless they wanted to.
Facility licensees must follow their internal review processes to determine whether the pregram scope has decreased and therefore requires Commission approval.
With regcrd to the use of ANSI /ANS-15.4-1977, the staff continues to support Generic Letter 83-12A. However, in light of the revised 10 CFR 55, the staff is willing to work with the TRTR comunity to revise the standard if appropriate.
(4) Comprehensive Recualification Examinations for Test and Research Reactors A.
Administration of Comprehensive Requalification Examinations '
In the revised regulation, all licensed personnel are required to pass an NRC-administered comprehensive written examination and operating test during the term of the six-year license. Although the 10 CFR 55 revisions are geared toward nuclear power plants, 10 CFR 55.57(b)(2)(iv) makes no distinction between power reactors and test and research reactors.
- Indeed, to renew their six-year licenses)g-term licensed personnel (those who intend it was and is our intent that lon at test and research reactors be subject to the same requirements for an NRC-administered requalification examination as licensed personnel at power reactors.
For example, this means that a student holding a license while in the process of acquiring a degree who does not intend to renew the license due to its transitory status, would not be administered an NRC requalification exam during the term of the 6 year license.
If, on the other har ', the same student decided to extend his tenure and acquire an advanced degree that would necessitate renewing the license, that individual would be required to pass an NRC-administered requalification exam before the license could be renewed.
Thus, without any action on the part of the TRTR, comprehensive requalification examinations will be administered to licensed personnel by NRC starting in 1991. Long-term licensed personnel who expect to retain their licenses will likely be in the initial group of renewal candidates.
B.
Revisions to 10 CFR 55.57(b)(2)(iv)
A TRTR may advance the argument that a requalification program for non-power reactors need only naintain initial knowledge and skills of licensed personnel since the reactor and systems are simple and pose little threat to public health ano safety. Following this premise, a TRTR could petition the Comission to revise 10 CFR 55.57 accordingly.
C.
Exemptions Under 10 CFR 55.11 Under 10 CFR 55.11, the Commission may grant exemptions from the requirements in the regulations upon application by an individual or upon its own initiative. The Commission must make an evaluation before granting any exemption. Therefore, an exemption application should have supporting information in order for the NRC to make this evaluation. Past facility operating experience and the performance of licensed individuals may be considered in the evaluation.
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EDO PRINCIPAL CORRESPONDENCF CONTROL FROM:
DUE: 11/18/87 EDO CONTROL: OO3P75 D'.iC DT 10/12/87 TAWFIK M.
RABY FINAL REPl.Y:
NBS TO:
STELLO FOR SIGNATURE OF:
OREEN SECY NO:
EXECUTIVE DIRECTOR DESC:
ROUTING:
IMPACT OF RECENT REVISIONS TO 10 CFR.55 ON TEST STELLO AND RESEARCH REACTORS TAYLOR REHM DATE: 11/03/87 BECK. LORD ASSIGNED TO: NRR CONTACT: MURLEY THOMPSON MURRAY SPECIAL INSTPUCTIONS OR REMARKS:
NRR RECEIVED: IOVEMBER 4, 1987 ACTION:
DLPQ: ROE NRR ROUTING:
MURLEYlSNIEZEK MIRAGLIA STAROSTECxt ACTION GILLESPIE "jsis DUE TO NRR DIRECTOR'S OFFICE FDSSBURG BY 9/ h 11 19T7 J
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