ML20197J226
| ML20197J226 | |
| Person / Time | |
|---|---|
| Issue date: | 04/25/1991 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| FRN-57FR537 AD80-1-020, AD80-1-20, SECY-91-108, NUDOCS 9104300399 | |
| Download: ML20197J226 (134) | |
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RULEMAKING ISSUE (Notation Vote)
April 25, 1991 SECY-91-108 For:
The Commissioners From:
James M. Taylor Executive Director for Operations Sub.iect :
PROPOSED RULEMAKING FOR TRAINING AND QUALIFICATION OF fW~ LEAR p0WER 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 training and qualification programs for their personnel.
Backaround:
In Section 306 of the Nuclear Waste Pulicy Act of 1982 (NWpA), Pub. L.97-425, the NRC was " directed to promulgate regulations, or other appropriate Commission regulatory guidance for the training and qualifications of civilian 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."
The staff submitted to the Commission on February 13, 1984, a proposed rulemaking for Training and Qualification of Civilian 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 plants would implement a program for training and qualification that would be essentially equivalent to the type of program NRC rulemaking would have required.
This would be accomplished
Contact:
NOTE:
Mary Louise Roe, RES TO BE MADE PUBLICLY AVAILABLE 301-492-4649 WHEN THE FINAL SRM IS MADE AVAILABLE
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i The Commissioners 2
through the 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 INPO-managed training accreditation program "in that it encompasses tht 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 17, 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 civilian nuclear power plants.
The Court remanded the issue to the NRC for action consistent with the Court's findings.
.S ef,
e Public Citizen v. NRC, 901 F.2d 147 (D.C. Cir.), cert.
denied, 59 U.S.L.W. 3392 (Nov. 26, 1990).
The Commission requested a rehearing of the decision by the full court, which was denied on June 19, 1990.
On November 26, 1990,
%e Supreme Court denied certiorari on petition by the Nuclear Utility Management and Resource Council.
Discussion:
In response to the U.S. Court of Appeals order, the staff has prepared for public comment a proposed rule for 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 training and qualification for specific categories of nuclear power plant personnel which consider all modes and conditions of operation including shutdown, normal, l
l The Commissioners 3
abnormal, emergency, and accident conditions (Enclosure A).
The proposed rule would require that 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 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 recognized the appropriateness of using this approach to training 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 cperator 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) design and implementation of the training program based upon the learning objectives, (4) trainee evaluation, (5) program evaluation, 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 qualification programs.
Within 180 days after the effective date of this rule, each licensee would be required to certify to the Commission on NRC Form 393, " Training and Qualification Program Certification," (Attachment 2 of Enclosure B) that it has implemented personnel 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 l
s-The Commissioners 4
deliberations during development of the proposed rule, indicated the need to provide additional guidance beyond that provided in the Policy Statement.
The proposed additional provisions are provided below:
(1)
Requirements have been included to develop training and qualification programs based on the performance requirements of their jobs 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.
Th e --
staff believes that personnel primarily performing the operational QA function will be most effective in contributing to overall plant performance if they are 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 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. The staff recognizes that information relevant to accident assessment and mitigation will continue to evolve. Applicants and
. licensees would be required to incorporate such information into their training programs as L
appropriate to their plants.
L (2)
Contractor personnel. performing in positions covered L
by the proposed rule would be required to meet L
appropriate-qualification requirements.
Contractor personnel have been-included in the proposed rule i
because all individuals who perform in the job categories covered by the proposed rule-should be qualified to perform their job responsibilities j
i The Commissioners 5
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.
Although only contractor qualification, not training, is covered, it is expected that licensees will assure that contractor personnel will receive appropriate training to meet qualification criteria.
(3)
The proposed rule clarifies that all modes of operation and conditions for a nuclear power plant could range 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.
The staff has also developed conforming amendments to 10 CFR Parts 50, 52, ano 55 to accompany the proposed rule.
The conforming changes to Parts 50 and 55 are considered minor, and have been prepared to provide for consistency among the proposed new regulations and the current regulations.
Licensee compliance with 10 CFR 50.120 and the conforming amendment to 10 CFR 55.59(c) will eliminate the discretion regarding alternative licensed operator training programs currently permitted in 10 CFR 55.59(c).
The changes to Part 52 are more substantive, and have been developed to ensure that applicants for a combined license will establish, implement, and maintain training and qualification programs in accordance with 10 CFR 50.120.
The proposed rule is not intended to preclude vendor training programs developed in conjunction with standardization of design.
Draft Revision 3 to Regulatory Guide 1.8, " Training and Qualification of Nuclear Power Plant Personnel" (Enclosure B), has been prepared for public comment as part of this proposed rulemaking effort. This guide provides criteria and methods acceptable to the staff for meeting the requirements in the rule.
The guide describes an acceptable means for achieving a systems approach to training at nuclear power plants and, with some exceptions, endorses the most recent version of industry standard ANSI /ANS-3.1,
" Selection, Qualification and Training of Personnel for Nuclear Power Plants."
Although the above ANSI /ANS standard includes guidance for selection, as well as for training and qualification,- the proposed rule does not require a selection program.
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The Advisory Committee on Reactor Safeguards (ACRS) has reviewed and commented on the proposed rule.
The Committee's comments were provided to Chairman Carr in a letter dated March 12, 1991.
The staff believes it has been responsive to the ACRS comments.
Coordination:
The Office of the General Counsel has no legal objection.
Recommendation:
That the Commission:
(1)
Acorove publication for comment of the proposed rule as set forth in Enclosure A.
(2)
In order to satisfy tie requirements of the Regulatory Flexibility Act, 5 U.S.C. 605(b), certify that this rule, if promulgated, will not have a significant economic impact on a substantial number of small entities.
This certification is included in the enclosed Federal Reaister Notice.
(3)
Note that:
(a)
The notice of proposed rulemaking (Enclosure A) will be published in the Federal Reaister, allowing 50 days for public comr.ent.
(b)
The staff will also make available for public comment a revision to Regulatory Guide 1.8 (Enclosure B).
(c)
A regulatory analysis will be available in the Public Document Room (Enclosure C).
(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 (Enclosure D).
(e)
A public annour. cement will be issued (Enclosure E).
(f)
The 3cbcommittee on Nuclear Regulation of the Senate Committee on Environment and Public Works, the Subcommittee on Energy and Power of the House Committee on Energy and Commerce, and the Subcoumittee on Energy and the Environment of the House Committee on Interior and Insular Affairs will be informed by letter (Enclosure F).
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The Commissioners 7
(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),
ar.d the Amended Policy Statement on the Training and Qualification of Nuclear Power Plant Personnel (53 FR 46603) are provided as Background (Enclosure G).
(h)
A copy of the ACRS letter to Chairman Carr, dated March 12, 1991, with comments on the proposed rule is provided (Enclosure H).
(i)
This rule will be submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
(j)
Copies of the proposed rule will be dist:ioutea to all affected licensees and other interested persons.
(k)
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.
(1)
Inspection procedures will be revised.
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JaesM.Thlor xecutive Director for Operations Enclosure A - Proposed Federal Reaister Notice Enclosure B - Proposed Revision 3 to Regulatory Guide 1.8, " Training and Qualification of Nuclear Power Plant Personnel" (DG-1012) and NRC form 393, " Training and Qualification Program Certification" Enclosure C - Regulatory Analysis Enclosure D - Environmental Impact Assessment Enclosure E - Draft Public Announcement Enclosure F - Draft Letters to Congress Enclosure G - Background Enclosure H - Letter from ACRS to Chairman Carr dated March 12, 1991 l
e P
8 rummissioners' comments or consent should be provided directly
'o the Cffice of the Secretary by COB Thursday, May 9,
- 1993, Commission Staff Office comments, if any, should be submitted to the Commissioners NT.T Thursday, May 2, 1991, with an infor-
.mation copy to the Office of the Secretary.
If the paper is of auch a nature that it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissionern OGC OIG LSS GPA REGIONAL OFFICES EDO ACRS ASLBP ASLAP E"CY o
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[7590-01)
NUCLEAR REGULATORY COMMISSION 10 CFR Parts 50, 52, and 55 klN 3150 - AD80 Tra'.ning and Qualification of Nuclear Power Plant Personnel AGENCY:
Nuclear Regulatory Commission.
ACTION:
Proposed rule.
SUMMARY
The Nuclear Regulatory Ccmmission is proposing to amend its regulations 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 training and qualification for specific categories of nuclear power plant personnel, that consider all modes and conditions of operation includ ng 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 generally 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 i is practical to do so, but assurance of consideration cannot be given except for comments received on or before this date.
_s-
e ADDRESSES: Mail written comments to: The Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555, ATTN:
Docketing and Service Branch.
Deliver comments to: One White Flint North, 11555 Rockville Pike, Rockville, Maryland, between 7:.'i0 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 Ragulatory Research, U.S. Nuclear Regulatory Commissior,, Washingtoa, DC 20555, telephone: (301) 492-4649.
SU1PLEMENTARY INFORMATION:
Background
Nuclear Waste Policy Act of 1982 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 training and qualifications of civilian nuclear power piant 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 meet this directive, on March 20, 1985; 50 FR 11147, the Commission published a Policy Statement on Training and 2
Qualification of Nuclear Power Plant Personnel.
The Policy Statement endorsed a training accreditation program managed by the Institute of Nuclear Power Operations (INPO) in that it encompassed the following five essential elements of " effective performance-based trainir.g":
(1)
Systematic analyses of the jobs to be performed.
(2)
Learning objectives derived from the analysis that describe desired performance after training.
(3)
Training designed and implemented based upon the learning objectives.
(4)
Evaluation of trainee mastery of the objectives during training.
(5)
Evaluation and revision of the trainina 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 INPO-managed training accreditation program. Training programs accredited through the INP0-managed accreditation program provide the basis to ensure that personnel have qualifications commensurate with the performance requirements of their jobs.
In addition to endorsing the INP0-managed training accreditation program, the 1985 Policy Statement also recognized the INP0-managed accreditation of utility training for the following training programs:
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(1)
Non-licensed operator.
(2)
Control room operator.
(3)
Senior control room operator / shift supervisor.
(4)
(5)
Instrument and control technician.
(6)
Electrical maintenance personnel.
(7)
Mechanical maintenance personnel.
(8)
Radiological protection technicion.
(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.
4
1 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 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.
See, Public Citizen v. NRC, 901 F.2d 147 (D.C. Cir.), cert.
denied, 59 U.S.L.W. 3392 (November 26, 1990).
The Commission requested a rehearing of the decision by the full court, which was denied on June 19, 1990.
On November 26, 1990, the Supreme Court denied certiorari on petition by the Nuclear Utility Management and Resource Council.
Actions Proposed in Response to the Court Decision The NRC is oroposing a rule on 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 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 5
a
a 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 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 accompanied by a regulatory guide that provides to industry an acceptable method for meeting the personnel 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 performante 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 rule.is to specify the essential elements of a process to be implemented by applicants and licensees, by which job performance criteria'and associated personnel training and qualification programs would be derived.
Because under this approach little change would be required to existing industry practice for personnel training 6
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n and qualification, there is little additional cost associated with this approach. This cpproach Llso provides for flexibility and site-specific adaptations in the training and qualification programs.
Approaches to the rulemaking other than that proposed, which establishes requirements consistent with the programs already largely developed and implemented by the industry, were not evaluated in detail.
There is no evidence that any other approach would provide greater protection of the public's health and safety than the site-specific training programs called for in the proposed rule.
At the same time, other approaches may involve greater costs to the industry and the NRC.
Summary of Proposed Rule Each applicant for and each holder of an operating license for a nuclear power plant would be required to --
(1)
Establish 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) Use a systems approach to training in order to ensure personnel are trained -to meet the performance requirements of their jobs; (4) Derive qualifications that are commensurate with job performance requirements; (5) Maintain and keep available for NRC review and inspection the materials related to those personnel training and qualification programs; and 7
e (6)
Certify that they have implemented the required personnel training and qualification programs.
The 1985 Policy Statement, as amended in 1988, serves as the basis for the proposed rule. However, subsequent review and inspections of industry programs by the NRC, and deliberations during development of the proposed rule, indicated the need to provide additional guidance beyond that provided in the Policy Statement.
The proposed additional provisions are provided below:
(1)
Requirements have been included to develop training and qualification programs based on the performance requirements of their jobs for personnel with (a) quality assurance responsibilities and (b) accident assessment and mitigation responsibilities.
Appendix Blof 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 personnel primarily performing the operational QA function will be most effective in contributing to overall-plant performance if they are trained and qualified under the same overall system as the other plant personnel i cluded n
in the proposed rule.
Hence, the proposed rule also applies to QA personnel.
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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 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.
The staff recognizes that information relevant to accident assessment and mitigation will continue to evolve.
Applicants and licensees should incorporate into their training programs information or, accident assessment and mitigation as required in current regulations and licensing conditions or any future revisions of these, and any new information developed through the licensees' evaluation of their plants (e.g., Individual Plant Examination (IPE) submittals).
When new training needs are identified they should be incorporated into the training programs.
(2)
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 who perform in the job categories covered by the proposed rule should be qualified to the same standards regardless of the
-source of their employment.
It is important to note that only contractor qualification, not training, is covered.
Itisexpectedthatjicenseeswill
- SECY-89-012 1. available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street NW. (Lower Level), Washington, DC.
9
assure that contractor personnel will receive appropriate training to meet qualification criteria.
(3) The proposed rule clarifies that all modes of operation and conditions for a nuclear power plant could range from shutdown to accident conditions. These modes and conditions should be addressed by applicants and licensees in developir.g and implementing their initial and contir. Jing training programs.
The Commission has also developed conforming amendments to 10 CFR Parts 50, 52, and 55 to accompany the proposed rule.
The conforming changes to Parts 50 and 55 are considered minor, and have been prepared to provide for consistency among the proposed new regulations and the current regulations.
Licensee compliance with 10 CFR 50.120 and the conforming amendment to 10 CFR 55.59(c) will eliminate the discretion regarding the alternative licensed operator training programs currently permitted in 10 CFR 55.59(c).
The proposed rule does not, however, apply to research and test reactor facilities, nor does the scope of training contained in current requirements change as a result of this proposed rule.
The change to Part 52 is more substantive and has been developed to ensure that applicants for a combined license will establish, implement, and maintain training and qualification programs in accordance with the requirements in 10 CFR 50.120.
The proposed rule is not intended to preclude vendor training programs developed in conjunction with standardization of design.
10
o-Discussion of Proposed Rule A new section, s 50.120, would be added to 10 CFR Part 50, entitled
" 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 training and qualification requirements for all appropriate personnel, (2) develop corrosponding personnel training and qualification programs to ensure that the appropriate qualification requirements are met, and (3) implement and operate these programs effectively on a continuing basis.
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 i 50.120.
t Paragraph (c)(1), General requ'.rements,- would require that each applicant and licensee establish, implement, and maintain programs for training and qualification of nuclear power plant personnel in specific l
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 covered by the requirements.
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O The proposed rule wculd expand the number and type of personnel for whom training is currently expected under NRC's policy guidance and the INP0-managed training accreditation program.
Requirements for 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 proposed rule, applicants and licensees would need to consider personnel performance at the nuclear power plant during all modes and conditions of operation, The proposed rule is not intended to require duplication of training in the event an individual is covered by two categories.
For example, if an operator has accident assessment and mitigation responsibilities in addition to his/her responsibilities as an operator, those responsibilities should also have been included in the task analysis performed to identify that category's job performance requirements.
Or, if a supervisor were to have QA responsibilities in a review capacity, he/she would only be given appropriate QA training needed to perform the review function.
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 personnel primarily performing the operational QA function will be most effective in contributing _to overall plant performance if they are 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.
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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 given a high priority.
Hence, personnel with accident assessment and mitigation responsibilities also have been included in the proposed rule.
The Commission recognizes that information relevant to accident assessment and mitigation will continue to evolve.
Applicants and' licensees should incorporate into their training programs information on accident assessment and mitigation as required in current regulations and licensing conditions or any future revisions of these, and any new information developed through the licensees' evaluation of their plants (e.g., Individual Plant Examination (IPE) submittals).
When new training needs are identified they should be incorporated into the training programs.
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 (t)(2), 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:
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c (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; (3) Trairae success in training can predict satisfactory on-the-job performance; and, (4) Training aad 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; and (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 subjact matter or to specific licensee personnel.
Training programs based on job performance requirements have been successfully used by j
the military for over 20 years, and by the nuclear industry for the past 7 4
14
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 requtiification prescribed in i 55.59(c).
Paragraph (c)(3), Qualification program, would require applicants and licensees to ensure that all affected personnel, including contractor personnel, 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 derign, procedures, and special circumstanc.es 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.
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 training of contractor personnel prior to their employment at the site.
However, continuing training provided to job 15
incumbents covered by the proposed rule should also be provided to contractor personnel.
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 required training programs for the affected personnel.
Similar documentation would also be required for qualification
-requirements, qualification determinations, and certifications for all personnel, including contractors performing in positions covered by this rulemaking.
Paragraph (e), implementation / Certification, would require applicants and licensees to certify to the Commission that they have implemented the required training and qualification programs.
Applicants would be required to submit the certification that they have training and qualification programs 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 per_iod for implementation.
The Commission is providing additional guidance on the proposed new requirements in the form of a proposed Revision 3 to Regulatory Guide 1.8,
" Training-and Qualification of Nuclear Power Plant Personnel." This-regulatory guide provides criteria acceptable to the NRC staff for meeting the 16
requirements in the rule.
It should be noted that applicants and licensees are not precluded from using criteria other than those in the regulatory guide to meet the requirements of the proposed rule.
However, if they do not intend to follow the regulatory guide, they will be requested to inform the Commission as to what approach they will follow.
The Commission believes that providing this option to applicants and licensees, to indicate how they intend to comply with the requirements in the rule, ensures flexibility in meeting the requirements of this rule.
It will also ensure that the Commission has a clear understanding of the applicant's and licensee's commitments.
Applicants and licensees must submit NRC Form 393 in order to both certify compliance with the rule and inform the NRC staff of the means utilized by the applicants or licensees to confotm with the requirements of the rule.
The certification requirement is necessary to provide the NRC staff with a clearly defined licensing basis since the rule only specifies the essential elements of the process by which the appropriate programs would be derived.
Completion of NRC Form 393 will necessitate an evaluation of the applicants' and licensees' current training and qualification commitments against the latest revision of Regulatory Guide 1.8, and will be used to establish a new licensing basis.
This basis should be used to revise existing technical specifications (e.g. perhaps deleting Standard Technical Specification Section 6,4 - Training) and/or previous licensee commitments as appropriate.
Submittal of license amendments should be provided on a schedule consistent with the submittal of NRC Form 393. The above approach will ensure a common understanding of training commitments (between applicants and licensees and the NRC staff) when future inspections are conducted.
The 17
certification is also necessary because the NRC staff does not intend to review or inspect training programs when implementing the rule except in those cases where problems concerning training are identified.
This regulatory approach is similar to that used by the Commission for certification of plant reference simulators, required under 10 CFR 55.45 using form NRC-474, and for certification of the accuracy of revisions to the final safety analysis report required under 10 CFR 50.71.
Impact of the Rule on Existing Industry Training Programs The rule, if adopted, would supersede the Policy Statement on Training and Qualification of Nuclear Power Plant Personnel.
The 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 INP0 guidelines for accreditation, will follow the guidance in Regulatory Guide 1.8, Revision 3, " Training and Qualification of Nuclear Power Plar,t Personnel." 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 guide for the fully imolemented accredited programs.
18
\\
l
O 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 certificction.
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 technicians trained by the vendor to do generic tasks related to the cert _ified 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.
The requirements for personnel training and qualification programs prescribed by i 50.120 do not prevent a vendor from training personnel or from developing a training and qualification process.
It is important to note, however, that the licensee is ultimately responsible for personnel qualification, and that vendors are not included in the rule.
Applicants for a Combined License Part 52 is being amended to require that applicants for combined licenses establish, implement, and maintain training and qualification
-programs in accordance with the requirements in 10 CFR 50.120.
This would include the requirement that such applicants submit the required certification to the Commission (on NRC Form 393) 18 months prior to fuel load.
19
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\\
Invitation to Comment Comments concerning the level of detail specified and the implementation of the proposed amendments are encouraged.
Comments are especially solicited 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 mitigation, (5) the absence of initial and continuing training requirements for contractor personnel, (6) the various time periods chosen for implementation of the requirements, and (7) difficulties that may be encountered in retalning the required documentation and records.
Sugged ions for alternatives to those rulemaking methods described in this notice s estimates of costs for implementation are encouraged.
Regulatory Guide in addition to the proposed rule, a draft Revision 3 to Regulatory Guide 1.8, " Training and Qualification of Nuclear Power Plant Personnel" is also available for public comment.
This revised guide has been developed to provide guidance on an acceptable method of implementing the proposed amendments to the regulations.
Comments concerning this regulatory guide are encouraged.
The guide is 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 20 i
Services.
The comments on the guide 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 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 environmental 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 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 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 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),
L L
Washington, DC.
Single copies of the environmental assessment and finding of l
no significant impact are available from Mary Louise Roe, Office of Nuclear 21
.~
s l
Regulatory Research, U.S. iNclear Regulatory Commission, Washington, DC 20555, telephone:
(301) 492-4649.
Paperwork Reduction Act Statement This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
This rule has been submitted to the Office of Management and Budget for review and 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 training and 22
i qualification.
The draft analysis is available for inspection in t' 9C Public Document Room, 2120 L Street, NW. (Lower Level), Washington, Single copies of the analysis may be obtained from Mary Louise Roe (see t
ADDRESSES heading).
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 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 23
s.
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.ould be modified to take into account the differing needs of small entities should specifically discuss the following items:
(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.
lhe comments should be sent to the Secretary of the Commission, U.S. Nuclear p
Regulatory Commission, Washington, DC 20555, Attn: Docketing and Serv'ce l
Branch.
l 1
24
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 Section 306 of the Nuclear Waste Policy Act of 1982, 42 U.S.C. Section 10226.
Therefore, a backfit analysis is not required for this proposed rule.
List of Subjects in 10 CFR Part 50 Antitrust, Classified information, Criminal penalties, Fire protection, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Radiation protection, Reactor siting criteria, Reporting and recordkeeping requirements.
List of Subjects in 10 CFR Part 52 Administrative practice-and procedure, Antitrust, Backfitting, Combined license, Early site permit, Emergency planning, Fees, inspection, limited work authorization, Nuclear power plants and reactors, Probabilistic risk assessment, prototype, Reactor siting criteria, Redress of site, Reporting and recordkeeping requirements, Standard design, St ndard design certification.
List of Subjects in 10 CFR Part 55 Criminal penalty, Manpower training programs, Nuclear power plants and reactors, Reporting and recordkeeping requirements.
25
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 fluclear Waste Policy Act of 1982, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Parts 50, 52 and 55 as follows:
PART 50 - DOMESTIC LICENSING OF 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 arended, 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.
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 issued 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 26 l
. 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 - 50.81 also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234).
Section 50.120 is also issued under Section 306 of the NWPA of 1982, 42 U.S.C. i 10226. Appendix F also issued under sec. 187, 68 Stat.
955 (42 U.S.C. 2237).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273);
is50.46(a) and (b), 50.54(c) and 50.120 are issued under sec. 161b, 161i and 1610, 68 Stat. 948, as amended (42 U.S.C. 2201(b); sis 0.7(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. 161i, 68 Stat.
949, as amended (42 U.S.C. 2201(i)); and 5550.49(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)).
2.
In i 50.8, paragraph (b) is revised to read as follows:
5 50.8 Information collection reouirements: OMB aooroval.
27
(b) The approved information collection requirements contained in this part appear in in 50.30 E0.33, 50.33a, 50.34, 50.34a, 50.35, 50.36, 50.36a, 50.48, 50.49, 50.54, 50.55, 50.55a, 50.59, 50.60, 50.61, 50.63, 50.64, 50.71, 50.72, 50.80, 50.82, 50.90, 50.91, 50.120, and Appendixes A, B, E, G, H. I, J, K, M, N, 0, Q, and R.
3.
In 6 $0.34, paragraph (b)(8) is revised to read as follows:
4 50.34 Contents of annlications: technical information.
I
+
(b) * * *
(8) A description and plans for i.aplementation of an operator requalification program.
The operator requalification program must as a minimum me*; the requirements for those programs contained in i 50.120 and i 55.59 of this chapter.
4.
In 5 50.54, paragraph (i)(1-1) is revised to read as follows:
i 50.54 Conditions of licenses, 28
-w.
,,y-.,
vr.......,-~,-+--e-4---.,,,,y v.v-.-.--,--.
,mm-,-,--..w,.,,,m.
r,-...
4-,--.....~~-w,-.o.,-,.
..u-.
(i) * * *
(i-1) Within three months after issuance of an operating license, the licensee shall have in effe:t an operator requalification program which must as a minimum, meet the requirements of i 50.120 and i 55.59(c) of this chapter.
Notwithstanding the provisions of i 50.59, the licensee may not, except as specifically authorized by the Commission decrease the scope of an approved operator requalification program, i
5.
Section 50.120 is added to read as follows:
i 50.120 Traininn and cualification of nuclear newer niant personnel.
(a) Applicability.
The requirements of this section apply to each applicant for (applicant) and each holder of an operating license (licensee) for a nuclear power plant of the type specified in i 50.2)(b) or i 50.22.
(b) Definitions.
As used in this section:
Lpyrnina objective means an instructional goal that is expressed in terms of measurabie performance. A learning objective:
(1)
Indicates the conditions under which the performance must occur; (2) Delineates the standards a.id evaluation criteria that must be met for mastery of the performance; and (3) Describes expected performance after training.
29
l s
Qualification pronram means the planned, organized, and managed sequence of interactions between individuals and evaluators designed to demonstrate and document successful c quisition by personnel in the covered catectries of skills, knowledge, and abilities required for job performance.
Trainina proaram means the planned, organized, and managed sequence of interactions between individuals and instructional resources and processes designed to establish and maintain skills, knowledge, and abilities required for 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 ioad, whichever is later, and each licenset, by (180 days af ter the effective date of the rule),
shall establish, implement, and maintain 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.
30
(ix)
(x) personnel with other plant specific titles who perform functions similar to those in the above categories.
(xi)
Plant managerial, supervisory, and engineering support personnel.
(xii)
Personnel performing quality assurance functions as described in 10 CFR Part 50, Appendix B, Criterion 1.
(xiii)
Personnel responsible for accident assessment and mitigation.
(2)
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:
(A) Analysis.
Perform a systematic analysis appropriate to the job to determine performance requirements and training needs.
(B) Derivation of learning objectives. Where the analysis indicates the need for training, derive from the analysis a set of learning objectives
-- in terms of conditior.s, actions, and standards -- that describe the desired job performance after training.
31
s (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 i
trainees rneet the learning objective:..
(E). Program evaluation.
Develup 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 the training program for each category of plant personnel 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)(2)(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 programs.
Program revisions must be completed within 12 calendar months of completion of the program evaluation performed in accordance with paragraph (c)(2)(ii)(E) of this section.
(3) 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 32
commensurate with the performance requirements of the jobs to which they are assigned.
The applicant or licensee shall establish and identify qualification requirements for its personnel.
(d)
Records.
In accordance with i 50./l(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 training programs must be retained for at least five years.
Documentation demonstrating the qualification of personnel covered by paragraph (t)(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 on NRC Form 393, " Training and Qualification Program Certification," by a duly authorized officer of the applicant or licensee that personnel training and qualification programs meeting the requirements of this section have been implemented.
PART 52 - EARLY SITE PERMITS; STANDARD DESIGN CERTIFICATIONS; At:0 COMBINED LICENSES FOR NUCLEAR POWER PLANTS 6.
The authority citation for 10 CFR Part 52 continues to read as follows:
33
e Authority:
Secs. 103, 104, 161, 182, 183, 186, 189, 68 Stat, 936, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244, as amended (42 U.S.C.
2133, 2201, 2232, 2233, 2236, 2239, 22d2); secs. 201, 202, 206, 88 Stat. 1242, 1244, 1246, as amended (42 U.S.C. 5841, 5842, 5846).
7.
Section 52.78 is added to read as follows:
i 52.78 Contents of nonlications: trainina and avalification of nuclear nower plant nersonnel.
(a) Applicability.
The requirements of this section apply only to the personnel associated with the operating phase of the combined licenses.
(b)- The application must demonstrate compliance with the requirements for training and qualification programs established in i 50.120 of this chapter.
PART 55 - OPERATOR'S LICENSES 8.
The authority citation for 10 CFR Part 55 continues to read as follows:
Authority:
Secs. 107, 161, 182, 68 Stat. 93S, 948, 953, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2137, 2201, 2232,_2282); secs. 201, as amended, 202, 88 Stat. 1242, is amended, 1244 (42 U.S.C. 5841, 5842).
34
Sections 55.41, 55.43, 55.45, and 55.59 also issued under sec. 306, pub.
L.97-425, 96 Stat. 2262 (42 U.S.C. 10226).
Section 55.61 also issued under secs. 186, 187, 68 S'at. 955 (42 U.S.C. 2236, 2237).
For the purposes o' ses 3, 68 Stat. 958, as amended (42 U.S.C. 2273);
i s 55.3, 55.21, 55.49, and 55.'
are issued under sec. 1611, 66 Stat. 949, as amended (42 U.S.C. 2201(i)); and ni 55.9, 55.23, 55.25, and 55.53(f) are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)).
9.
In 6 55.4, the definition of " Systems approach to training is revised to read as follows:
6 55.4 Definitiqni.
Systems approach to trainina means a training program that includes the following six elements:
(1)
Systematic analysis of the jobs to be performed.
(2)
Learning objectives derived from the analysis which describe desired performance after training.
(3) Training design and implementation based on the learning objectives.
(4)
Evaluation of trainee mastery of the objectives during training.
(5)
Evaluation of the training program based on the performance of trained personnel in the job setting.
35 l
l
[
(6)
Periodic revision of the training program based upon trainee and program evaluations.
10.
In i 55.31, paragraph (a)(4) is revised to read as follows:
i 55.31 How t o app 1v.
(a) * * *
(4)
Provide evidence that the applicant has successfully completed the facility licensee's requirements to be licensed as an operator or senior operator and of the facility licensee's need for an operator or a senior operator to perform assigned duties.
An authorized representative of the facility licensee shall certify this evidence on form NRC-398.
This certification must include details of the applicant's qualifications, and details on courses of instruction administered by the facility licensee, and describe the nature of the training received at the facility, and the startup and shutdown experience received.
These details are not required for an applicant that has certified compliance with section 50.120 and that uses a simulation facility acceptable to the Commission under s 65.45(b) of this part; l
36
e 11.
In 5 55.59, paragraph (c) is revised as follows:
5 55.59 Peoualification.
(c)
Requalification program requirements.
A facility licensee shall have a requalification program which meets the requirements of i 50.120 of this chapter, and paragraphs (c)(1), (5), and (6) of this section.
Paragraphs (c)(1)-(7) of this section are applicable to research and test reactor facilities.
Research and test reactor facilities shall have a requalification program reviewed and approved by the Commission.
Dated at Rockville, MC, this day of 1991.
For the Nuclear Regulatory Commission.
Samuel J. Chilk, Secretary of the Commission.
37
6 I
ENCLOSVRE B ATTACHMENT 1.
Draft Revision 3 to Regulatory Guide 1.8, " Training and Qualification of Nuclear Power Plant Personnel" ATTACHMENT 2.
NRC Form 393, " Training and Qualification Program Certification"
Revision 3 Date REGULATORY GUIDE office of Nuclear Regulatory Research Draft Regulatory Guide 1.8 (DG-1012)
(Task
)
TIUsI!JI!!G A!;D QUALIFICATION OF IJUCLEAR POWER PLA!JT PERSO!;!!EL A.
INTRODUCTION Section 50.120, " Training and Qualification of liuclear Power Plant Personnel," of 3v CFR Part 50, " Domestic Licensing of Production and Utilization Facilities," requires that each nuclear power plant licensee or applicant for an operating license establish, implement, and maintain training and qualification programs for specific categories of nuclear power plant personnel, that consider all modes and conaitions of operation including shutdown, normal, abnormal, energency, and accident conditions.
The categories of personnel were intended to identify personnel whose job activities may have an impact on the health and safety of the public.
Section 52.78, " Contents of applications; training and qualification of nuclear power plant personnel,"
of 10 CFR Part 52, "Early Site Permits; Standard Design Certifications; and Combined Licenses f or 11uclear Power 1
Plants," also requires that applicants for a combined license establish,-implement, and maintain training and qualification programs in accordance with S 50.120.
Paragraph 50. 34 (b) (6) (i) of 10 CFR Part 50, requires that an application for a license to operate a nuclear power plant include information concerning organizational structure, allocations or responsibilities and authorities, and personnel qualifications requirements.
Subpart D, " Applications," of 10 CFR Part 55, " Operators' Licenses,"
requires that operator license applications include information concerning an individual's education, training, and experience and related matters.
This regulatory guide describes a method acceptable to the NRC staff for complying with the trainina and qualification requirements of 10 CFR Part 50, SS 50.120, 50.34, and 50.54, and 10 CFR Part 52, 5 52.78, and 10 CFR Part 55.
Applicants and licensees are required to certify in writing on NRC Form 393 that they have implemented training and qualification programs at their facility by either endorsing this regulatory guide or proposing an acceptable alternative.
This regulatory guide also endorses ANSI /ANS-3.1-1987 with certain clarifications, additions, and exceptions.
Personnel of test, training, research, and mobile reactors are not covered by this regulatory guide.
Program documentation and program conduct will be inspected by-the NRC periodically throughout the life of the facility.
NRC inspection reports will be issued following these inspections t
l l
~~
~
~~'
.. _ _ _ _ _ _ _. _. ~. _ _ _ _. _ _ _ _ _ _ _
providing comments and identifying conditions needing corrective actions, as appropriate.
Any information collection activities mentioned in this regulatory guide are contained as requirements in 10 CFR Parts 50, 52 and 55, which provide the regulatory basis for this guide.
The information collection requirements in 10 CFR Part 50 have been approved under OMB Clearance No. 3150-011, those in 10 CFR Part 52 under OMB Clearance No.
and those in 10 CFR Part
{
i 55, under OMB Clearance No. 3150-0018.
B.
DISCUSSION Subcommittee ANS-3, Reactor Operations, American Nuclear Society Standards Committee, developed a standard containing criteria for the training and qualification of nuclear power plant personnel.
This standard was approved by the American National Standards Institute (ANSI) Committee NIB, Design Criteria for Nuclear Power Plants, and designated ANSI N18.1-1971, " Selection and Training of Nuclear Power Plsnt Personnel."
" Personnel Selection and Training,"
endorsing ANSI N18.1-1971, was issued in March 1971, and Revision 1 was issued in September 1975.
A revision of ANSI N18.1-1971 was subsequently approved by the ANSI Board of Standards Review and designated ANSI /ANS-3.1-1978, " Selection and Training of Nuclear Power Plant Personnel."
During 1981, ANSI /ANS-3.1 was updated to factor in lessons learned from the TMI-2 accident and changing regulatory 3
.._._._m__.____
requirements.
The standard was approved by the American Nuc1 car
{
Society's Nuclear Power Plant Standards Committee (NUPPSCO) and I
the ANSI Boats of Standards Review, and was reissued as ANS1/ANS-l 3.1-1981, " Selection, Qualification and Training of Personnel for Nuclear Power Plants. "'
Revision 2 of Regulatory Guide 1.8 was issued in April 1987 endorsing Sections 4.3.1.1,
" Shift Supervisor," 4.3.1.2,
" Senior Operator," 4.5.1.2, " Licensed operators,"
4.4.8, " Shift Technical Advisor," and 4.4.4,
" Radiation Protection," of ANSI /ANS-3.1-1981.
Endorsement for all other positions remained with ANSI N18.1-1971.
A revision of ANSI /ANS-3.1-1981 was issued on May 19, 1987 and designated ANSI /ANS-3.1-1987.
The 1987 standard contained major revisions in content and format from the 1981 standard.
These revisions reculted from actions taken by the NRC and industry since the 1981 standard in selection and training practices as described
'below.
The Commission's " Policy Statement on Engineering Expertise on Shift" incued on October 28, 1985 (50 FR 43621) provided two options for meeting nuclear power plant staffing requirements (paragraph 50. 54 (m) (2) (1) of 10 CTR Part 50) and the requirement to have a shift technical advisor (STA) available to the shift (NUREG-0737, I.A.i.1).
One option in the Policy Statement on Engineering Expertise on Shift, which'is preferred by the Commission,--allows combining the functions of the STA with-one of
' Copies may be obtained from the American Nuclear Society, 555 North Kensington Avenue, LaGrange Park, IL 60525.
4
~ _ -,. _ _,. _ _ _. _... _ _ _.._.. _ _ _,. _ _ _, -,._.._-._. _,.-_ _ _ _
0 the required senior operators as long as specific training and
{
l education requirements are met.
The other option allows for continuation of an approved independent STA program.
Regulatory Position C.2.f. reflects the guidance provided in this Policy Statement.
In response to a Congressional mandate, the NRC issued a
" Commission policy Stateuent on Training and Qualification of Nuclear Power Plant Personnel," on March 20, 1985 (50 FR 11147).
The policy statement provided regulatory guidance for the training and qualification of civilian nuclear power plant operators, supervisors, technicians, and other appropriate operating personnel.
The policy statement also endorsed "the INPO-managed Training Accreditation Program in that it encompasses the elements of performance-based training and will provide the basis to ensure that personnel have qualifications commensurate with the performance requirements of their job."
Following a two-year period of monitoring and evaluating the industry initiative, the NRC issued an " Amended Policy Statement I
on Training and Qualification of Nuclear Power Plant Personnel,"
on November 18, 1988 (53 FR 46603), reaffirming the efficacy of the-industry training programs.
l
-on April 17, 1990, the U.S. Court of Appeals for the I
District of Columbia Circuit concluded that the Commission's Policy Statement does not satisfy the Congressional intent.
Therefore,-the NRC has developed.a rule addressing requirements for the training and qualification of nuclear power plant 5
l
personnel (10 CTR 50.120). The rule requires that each licensee or applicant provide training to personnel listed in 10 CFR 50.12 0 ( c ) ( 1 ) using a performance-based systems approach to training (SAT).
The rule also requires each licensee or applicant to have a qualification program to ensure that personnel listed in 10 CTR 50.120(c) (1), including contractor personnel, have qualifications commensurate with the perfarnance requirements of the jobs to which they are assigned.
This rule supersedes the above mentioned Policy Statement on Training and Qualification.
The SAT ir the deliberate, orderly process of analysin, design, and development of training programs and their systenatic cperation, evaluation and maintenance to ensure continued effectiveness and job relevance.
The approach is iterative; ence initiated, activities are performed continually throughout the life-cycle of the program, and training programs are modified and refined as necessary to meet changing requirements.
This is designed to ensure that personnel are equipped with the skills and knowledge essential for adequate job performance.
It is based on extensive research and practical application by both the U.S. military and industry since World War II.
Experience of the NRC staff over the past several years has led them to conclude that Inspection Procedure (IP) 41500, " Training and Qualification Effectiveness," of the NRC Inspection Manual, which references NUREG-1220, " Training Review Criteria and Procedures," provides a suitable basis for developing guidance regarding implementation 6
i
of a SAT.
1herefore, the guidance provided in Section C.
Regulatory Positica, is based on the inspection procedures of IP 41500 and NUREG-1220.
C.
REGULATORY POSITIOh The criteria contained in ANSI /ANS-3.1-1987, " Selection, Qualification and Training of Personnel for Nuclear Power Plants," provide an approach acceptabic to the NRC staff for complying with the training and qualification requirerents of 10 CFR Parts 50, 52 and 55 and the guidance regarding the STA function provided in the Commission's " Policy Statement on Engineering Expertise on Shift." The NRC does not endorse Section 5 of ANSI /ANS-3.1-1987 because selection of personnel in not required by 10 CTR 50.120.
However, the NRC believes it is appropriate for applicantc and licensees to have a selection program.
Clarifications, additions, and exceptions to ANSI /ANS-3.1-1987 are provided in the following paragraphs:
1.
Definitions -
The following definitions are additions to the definitions listed in Section 2 of ANSI /ANS-3.1-1987:
Continuing Training - Training provided to incumbent personnel to ensure that they maintain proficiency in performance of job-related functions.
7
o Enabling Learning objective - A learning objective keyed to supporting mastery of an associated terminal learning objective.
Initial Training - Training provided to candidates for specific nuclear power plant positions which enables them to adequately perform job-related functions.
Initiating cue - The prompt, signal, or stimulus that causes an individual to perform a specific task.
Instructior.a1 Designer - Person who designs and develops a program or course of instruction based on a systematic analysis.
Instructional Media - The means for presenting subject matter to trainees for purposes of instruction, e.g., books, audio-tapec, films, video-tape, and control room simulator.
Instructional Method - The method by which a trainee is provided with the means and the opportunity for achieving Icarning objectives, e.g., lecture, on-the-job training, self-study, simulation.
Job - All the duties and associated tasks performed by a single worker.
8
- - ~ - - - -
- ~ - ~ ~ ~ - ~ ~ ~ ~ ~ ~ ' - ~
.=-
Job / Task Analyst - An individual whose thorough familiarity with and experience in the application of established job and tast analysis techniques qualifies him/her to assist in the analysis of jobs and determination of performance requirements to support training program development.
Knowledge - Understanding of facts, principles, or concepts including cognitive (mental) processes necessary to develop the skill (s) required in the effective performance of a task.
Learning objective - An instructional goal that is expressed in terms of measurable performance.
A learning objective (1) indicates the conditions under which the performance must occur, (2) delineates the standards and evaluation criteria that r:ust be met for mastery of the performance, a.1d (3) describes expected performance after training.
Lesson Plan - A standard outline that ensures consistency in instructor presentation and evaluation of trainee performance by including the learning objectives and the methods and media by which the objectives are to be achieved.
Onsite Experience
- Experience gained at the plant for which an individual seeks the position and should not include time in training.
l 9
i i
. ~.,.. _, - _ _ _. _ _ -
O
+
Performance Feedback - Information provided to the trainee to reinforce performance mastery or to provide explanation of mistakes and corrective guidance.
Qualification Program - The planned, organized, and managed sequence of interactions between individuals and evaluators designed to demo.istrate and document successful acquisition by the trainee of the proficiency of knowledge, skills and abilities required for job performance.
sequencing - The order in which instruction is provided to allow the learner to make the transition from one skill or body of knowledge to another, and to assure that supporting skills and knowledge are acquired before dependent performances are introduced.
l Simulators - Devices or processes designed to provide training which will have high positive transfer to the actual equipment or situation.
l i
skill - The ability to perform a job-related activity which contributes to effective task performance.
t Subject Matter Expert - An individual whose thorough technical knowledge of and experience in performing a job qualifies him/her l
to assist in the training development process.
10 l
O Systems Approach to Training - The orderly, iterative process of systematic analysis, design, development, implementation, evaluation and revision of training programs to ensure that j
trainees acquire the knowledge, skills, and abilities essential for adequate job performance.
Training approaches such as performance-based training or criterion referenced instruction are all derived from the principles and procedures underlying a systems approach to training.
Task Condition - On-the-job circumstances that significantly influence performance of a task.
Task Element - The smallest step into which it is practical to subdivide any work activity for purposes of instructional development.
Task Inventory - List-that itemizes all of the tasks that make up a selected job.
Task Standard - A measurable st-atement of how well a task must be performed.
Terminating Cue'-
The prompt, signal, or stimulus that indicates task completion.
11 l
l l
Terminal Learning Objective - A learning objective expressed ir terms of and keyed to a specific job task which should be achieved at the end of an instructional sequence.
Test - Any method used to measure trainee performance with respect to a specific task or subject matter as reflected in the associated terminal and enabling learning objectives.
Training Plan - A plan that describes the management, scheduling, instruction and evaluation of trainees toward the goal of course completion.
Training Program - A planned, organized, and managed sequence of interactions between individuals and instructional resources and processes designed to establish and maintain knowledge, skills and abilities required for job performance.
Training Program Evaluation - The continual assessment of training program effectiveness in terms of (1) student performance of stated learning objectives, (2) graduate on-the-job performance with respect to the job performance requirements or trainee success in subsequent training programs, and (3) external changes affecting the training subject matter.
Training Specialist - An individual whose knowledge of the 12
O learning process and whose thorough familiarity with and experience in the application of systematic training program development methods quelify him/her to apply any or all of these methods in the training program design and development process.
2.
Qualification - 10 CFR 50.120(c) (3) requires that each applicant and each licensee shall establish a qualification program based on an analysis of the job tasks and functions to be performed to ensure that affected personnel have qualifications commensurate with the performance requirements of the jobs to which they are assigned.
The applicant / licensee may elect to commit to the qualifications criteria described in Section 4 of ANSI /ANS-3.1-1987 with the following exceptions:
a.
An applicant for a senior operator (SO) license should have 4 years of responsible power plant experience.
Responsible power plant experience for an 50 is defined as having actively performed as a designated control room operator (fossil or nuclear) or as a power plant staff engineer involved in the day-to-day activities of the facility during or after the final year of construction.
A maximum of.2 years of responsible power plant experience may be fulfilled by academic or related technical training on a two-for-one time basis.
Two years should be nuclear power plant experience and should not include experience gained in licensed operator classroom training on the plant.
At least 13
. _~.
Q 6 months of the nuclear power plant experience should be at the plant for which an applicant seeks a license.
In addition, applicants for an S0 position not holding a bachelor's degree in engineering or equivalent should have held an operator's license and should have been actively involved in the performance of licensed duties for at least 1 year.
b.
In meeting the experience qualifications criteria for
!!RC licensed personnel in Sections 4.4.2 and 4.5.1, the following exceptions are made to Table 1:
for a structured simulator program conducted on a o
reference plant simulator, the weighting factor should be 3.0 for 6 months maximum credit.
For a structured simulator program conducted on a o
similar plant simulator, the weighting factor should be 1.0 for 6 months maximum credit.
Licensed operator classroom training on the plant o
may not substitute for experience.
The 6 months of "on site" experience required in Section c.
4.5.1, should be as a non-licensed operator at the plant for which an applicant seeks a license, d.
In addition to the requirements in Sections 4.4:2 and 4.5.1, each applicant for an operator or senior operator 14
,. ~ -...-
license should serve 3 months as an extra person on shift in training for that position.
These 3 months as an extra person on shaft in training should include all phases of day-to-day operations under the supervision of licensed personnel and should not count toward experience qualification.
Control room operating experience for licensed operator e.
applicants, described in Section 4.5.1 of the standard, should include manipulation of controls of the facility during a minimum of five reactivity changes.
Every effort should be made to have a diversity of reactivity changes for each applicant.
Startups, shutdowns, large load changes, and changes in rod programming are some examples and could be accomplished by manually using such systems as rod control, chemical shim control, or recirculation flow.
/
f.
In addition to the responsibilities described in Section 4.6.4 of the standard, the STA should assume an active role in shift activities and reflect the guidance provided in the policy Statement on Engineering Expertise on Shift.
" Assume an active role in shift activities" means performing on at least three shifts per quarter as the STA.
If an STA has not assumed an active role in shift activities, the STA should receive training sufficient to ensure that the STA is 15
cognizant of facility and procedure changes that occurred while not in an active role, g.
The radiation protection manager should have the 1
qualifications described in Section 4.3.3 of ANSI /ANS-3.1-1987 with the clarification that all 3 years of experience in applied radiation protection at a nuclear power plant should be professional-level experience. In addition, the minimum radiological protection experience criteria for both Radiation Protection Supervisors (Section 4.4.5) and Technicians (Section 4.5.3.2) should be "related Radiological Protection" experience.
Furthermore, in Section 4.4.5, during the two years of nuclear power plant experience, the individuals should have participated in varied activities of the radiological protection organization.
3.
Selection of Personni i 10 CFR 50.120 does not require a selection program, therefore, this regulatory guide does not endorse Section 5 of ANSI /ANS-3.1-1987.
4.
Training-Process -
10 CFR 50.120 (c) (2) requires that each applicant and licensee shall establish, implement, and maintain initial and continuing training programs, for the positions / functions listed in 10 CFR 50.120(c) (1), based on a systems approach to training (SAT). The following paragraphs are 16 o
provided in lieu of Section 6.2 of ANSI /ANS-3.1-1987 to describe an acceptable SAT process for those positions listed in 10 CFR 50.120.
Using qualified personnel (i.e.,
subject matter experts, job / task analysts, training specialists) licensees and applicants should implement the SAT using the following process steps:
(1)
Analysis A systematic analysis appropriate to the job / hot:1d be performed to determine performance reg'tirements of j ceb incumbents and t131ning needs of perst.inel selseted for these jobs.
The following steps should be performed when doing the analysis:
(a)
Identify and analyze all job performance areas.
(b)
State job performance requirements in terms of tasks.
Describe each task in terms of a distinct unit of work performed.
(c)
Collect information required to identify the requisite tasks and to support subsequent training program development, such as:
safety considerations and consequences of o
inadequate task performance; o
Frequency of task performance; and 17
4 Difficulty of task performance.
o (d)
Determine any prerequisite knowledge and skill qualifications for all requisite tasks.
(e)
Determine the training needs of job incumbento and initial trainees, Identify tasks for which adequate performance o
cannot be ensured by methods other than training (e.g., by job performance aids).
Estimete the job skills, knowledge, previous o
training and experience possessed by initial trainees meeting the facility's minimcm job selection criteria and identify associated-tasks for which training is not required.
(f) systematically select tasks for initial and cont,-
ing training, o
Base the principal selection criteria on factors such as the consequences of inadequate performance, Base secondary selection criteria on factors o
such as probability of error, existing performance deficiency, frequency ol' L
18 l
l 1:
1 performance, difficulty of performance and team coordination.
(g)
Determine the task elements, skills and knowledge, and other information supporting adequate task performance by analyzing the tasks selected for training.
o Determins necessary steps (task elements), and their logical sequence, required for the successful performance of each task, Identify the conditions under which the task o
(task element) is performed.
Identify the initiating and terminating cues o
for task (task element) performance, o
Specify the standards to which the task (task element) must be performed.
o Identify the skill (s) required in the performance of each task and ta<.k element.
Identify the knowledge necessary to support o
each identified skill.
continue the task analysis to the level at o
which the identified skills and knowledge match the skills and knowledge assumed for 19
trainees meeting the licensee's minimum selection criteria.
Where the above information has previously been identified through procedures, or other mechanisms, it does not have to be redeveloped.
(h)
Verify analysis data.
o Collect verification data in accordance with established techniques, Collect verification data from a sufficient o
number of knowledgeable subject matter experts to ensure that the data are accurate and complete.
(2)
Learning Objectives Where the analysis indicates a training need, the applicant or licensee should derive from the analysis, learning objectives that describe desired trainee performance after training in terms of conditions, actions, and standards.
The following steps should be perfcrmed when. deriving learning objectives:
20
s (a)
Develop terminal learning objectives for each task which describe what the trainee will be able to do at the conclusion of training in terms of measurable performance by:
Specifically stating the observable action or o
behavior trainees are to exhibit at the conclusion of training, Specifically stating the conditions under o
which the action should occur, and o
Specifically stating the standards and criteria which must be met for adequate 1
performance.
(b)
Translate task elements, skills, knowledge, and related information associated with each terminal learning objective into enabling learning objectives by:
Specifically stating behavior, conditions, o
and standards as described in (a) above, Directly relating each enabling learning o
objective to a specific terminal learning objective.
21
(3)~
Design and Implementation The applicant or licensee should design training programs based on the Icarning objectives selected ior training, and implement the training programs to ensure that those learning objectives are achieved.
Learning objectives should be the basis for all decisions regarding instructional methods, tests, and media, training program development and instructor personnel qualifications, and training program management.
The following steps should be performed when designing and implementing a training program.
(a)
Establish qualification requirements for training program personnel including analysis, design and development personnel and instructors.
The requirements should include technical expertine, analysis / instructional development expertise, and instructional delivery expertise sufficient to ensure satisfactory analysis, design and development as well as the delivery of effective training with respect to:
Initial and continuing training, o
Individual.and team training, o
22
o Each instructional method (e.g.,
- lecture, simulation),
o The effective employment of instructional media (e.g.,
simulators), and o
The provision of effective trainee performance feedback during training.
(b)
Sequence the learning objectives.
Identify those learning objectives which must o
be mastered before certain other learning objectives can be reasonably achieved.
o Use these relationship: to organize the learning objectives in a sequence in which they should be mastered.
(c) systematically select the instructional and testing method (s) and media to be used in the training programs.
Select the instructional method (s)
(e.g.,
o lecture, on-the-job training, simulation, self-study, team training) and testing methods (e.g., written, oral, performance) based on learning objective performance requirements, instructional requirements 23
(e.g.,
initial training, contiiuing training), and requirements for trainee / instructor interaction.
o Select instructional media based on:
The type of performance specified by the learning objectives (e.g.,
use of rule, verbal communication);
The type of learning required (e.g.,
mental skill, physical skill); and Instructional media characteristics required to support the type of performance and the type of learning (e.g.,
initiating cues associated with a specific learning objective may require dynamic visual presentation for effective mastery learning).
(d) organize the instructional content.
Organize training, according to the proper o
sequence of learning objectives.
Provide for sufficient practice of and o
performance feedback for previously mastered A
learning objectives as new instructional o
24
O content is introduced to ensure retention and integration of the associated skills, Select instructional content for continuing o
training based on the tasks identified for continuing training as well as other needs (e.g., plant modifications, procedure changes, industry lessons learned).
(e)
Prepare training program instructional media, Prepare lesson plans and supporting o
instructional information to include:
The instructor's role and actions, Instructor / trainee references, Instructional methods and media to be used, and Learning objectives.
Evaluate the capability of existing o
instructional media (e.g.,
lesson plans, trainee text, visuals) to support the achievement of identified learning objectives; modify and incorporate as required by the training program design.
25
Develop new instructional media as required o
to support the training program design using established methods.
(f)
Prepare and implement a training plan which provides for organizing, controlling and evaluating the delivery of training.
ClearJy delineate the assignment and o
definition of training program management, administration, instructor, and support i
responsibilities.
Establish policy or procedure as required (e.g.,
- training, contracting) to ensure the availability of personnel with these qualifications to participate in training program design, development, and conduct.
Delineate the trainee management strategy, o
-including program entry and completion criteria, and procedures for identifying / controlling marginal trainees, specify instructional tacilities (e.g.,
o building, classroom, laboratory, equipment) and instructional media requirements, Specify-the training schedule for both o
initial and continuing training.
26
Delineate trainee record requirements and o
management.
Specify the training program evaluation plan.
o Provide for the delivery of systematic o
performance feedback to the trainee throughout the training program.
(g)
Conduct training in accordance with the training plan.
(4)
Trainee Evaluation The applicant or licensee should develop testo for jearning objectives appropriate to the performance standards and evaluation criteria delineated.
Tests should require appropriate demonstration of knowledge and skills outlined in the learning objectives.
Necessary procedures and guidelines should be established for administering tests to ensure consistency and job relevance.
The following steps should be performed when evaluating trainees:
(a)
Develop tests for terminal and enabling learning objectives.
27
o Develop each test to require the demonstration of knowledge and skill (s) directly related to the associated learning objectives and underlying tasks.
o Develop the performance standard and criterion for each test to clearly distinguish between adequate and inadequate learning objective mastery, Provide a scoring key and directions o
specifying the necessary procedures and esources for administering each test.
(b)
Give tests in accordance with the training plan.
(c)
Systematically analyze test results and provide effective performance feedback to trainees.
(5)
Program Evaluation The applicant or licensee should develop and implement a plan for systematic and regularly scheduled evaluation of the effectiveness of the training program as indicated by performance of trainees in the training program and graduates in the job setting.
The following steps should be performed when evaluating the program:
28
0 l
l (a)
Continually monitor and evaluate the conduct of the training program (e.g.,
instructor performance, program administration, instructor feedback).
(b)
Systematically analyze test results obtained during trainee evaluation to identify training program deficiencies.
(c)
Collect on-the-job performance data for graduates of the training program and evaluate it with respect to task performance requirements.
(d)
Continually monitor external factors affecting performance requirements (e.g.,
operating experience, and changes to equipment / systems, rules / regulations, or procedures).
(e)
Evaluate deficiencies identified in the conduct of the training program, in graduate trainee performance, or as a result of changes in external factors, for their impact on both the subject matter and conduct of the training program.
29
(6)
Program Revision The applicant or licensee should develop and implement a plan for systematic and regularly scheduled revision of the training program.
Revision and upgrading of the training program should be based on both the trainee and training program evaluation described in paragraphs (4) and (5) above.
- 5. Records - 10 CFR 50.120(d) requires each applicant and licensee to maintain and keep available for NRC inspection, materials sufficient to document that the requirements of 5 50.130(c) have been met.
These records should document the process used to such an extent that a determination can be made, by individuals not. associated with the training and qualifications programs, that these programs adequately address the requirements.
Specifically, the applicant or licensee should maintain and keep available the following materials and records used to establish, implement, and maintain the training and qualification programs.
Training Records (Retain for at least 5 years)
The analyses for all personnel categories covered by o-paragraph 50.120 (c) (1) ;
30
o The learning objectivos that can be traced to the analyses; o
Documentation related to the selection of instructional settings, methods, and media; modes of implementation; and training program materials, media, and tests; Trainee tests and performance evaluations including on-o the-job training records; o
Records of the evaluations conducted to determine program effectiveness; and o
Records of the program revisions.
Qualification Records (Retain for each individual for duration of employment)
Qualification documentation for individuals perforning o
in the personnel categories covered by paragraph 50.120(c)(1);
o Documentation of the qualifications for contractor workers performing in the personnel categories covered by paragraph 50.120 (c) (1).
The documentation should provide evidence how each contract worker, within the categories listed in paragraph 50.120(c)(1),
was determined to be qualified to the standards established by the applicant and licensee for the job tasks to which the contract worker is assigned.
31
s D.
IMPLEMENTATION The purpose of this section is to provide information to applicants und licensees regarding-the NRC staff's plans for using this regulatory guide.
This proposed revision has been released to encourage public participation in its development.
Except in those cases in which an applicant proposes an acceptable alternative method for complying with specified portions of the Commission's regulations, specified in Section A, the guidance to be provided in Section C in the active guide will be used in the evaluation of the training and qualifications requirements for nuclear power plant personnel.
Paragraph 50.120(e) requires applicant and licensee certification of compliance with the requirenents of 10 CFR 50.120 by a duly authorized officer using NRC Form 393.
One MRC Form 393 can be submitted by the licensee or applicant for all nuclear power plant personnel categories subject to 10 CFR 50.320, or a separate NRC Form 393 can be submitted for each category of personnel.
l l
E.
RELATED DOCUMENTS The following documents are sdditions to the documents listed in Section 7 of ANSI /ANS-3.1-1987:
A Systems Anoroach to Training 2 Dept. of the Army, Training and Doctrine Command, TRADOC Rey. 550-7, Ft. Monroe, VA 23651.
32
.. _ ~
e
- Blank, W., Handbook for the Develooment of Competency-Based Trainino Proaram.
Englewood Cliffs, NJ:
Prentice-Hall, Inc.
1982.
- Branson, R.,
- Rayner, G.,
- Cox, J.,
- Furman, J.,
- King, F.,
- Harnum, W.,
Interservice Procedures for Instructional Systems Develonment NAVEDTRA 106A, Vols. I - V.
Pensacola, FL:
Navy Education and Training Command, 1975.*
Institute of Nuclear Power Operations, Trainino System Develonment Manual.
- Mager, R.
& Pipe P. Criterion-Referenced Instruction Analysin, Desian and InnlenentatioD.
Los Altos Hills, CA:
Mager Associates, Inc., 1979.
Requirements for Training System Development (Military
. Specification MIL-STD-29053B(TD)).
(To include associated Unique Data Item Descriptions.)*
U.S. Nuclear Regulatory Commission, " Clarification of TMI Action Plan Requirements," NUREG-0737.
Copies may be obtained from the National Technical Information Service, Springfield, VA 22161.
33
o U.S. Nuclear Regulatory Commission, " Guidance on Being an Operator at the Controls of a Nuclear Power Plant," Regulatory Guide 1.114.
U.S.
Nuclear Regulatory Commission, " Medical Evaluation of Nuclear Power Plant Personnel Requiring Operator Licenses," Regulatory Guide 1.134.
U.S. Nuclear Regulatory Commission, "NRC Action Plan Developed as a Result of the TMI-2 Accident," NUREG-0660.
U.S. Nuclear Regulatory Commission, " Nuclear Power Plant Simulators for Use in Operator Training," Regulatory Guide 1.149.
U.S. Nuclear Regulatory Commission, " Training and Qualification Effectiveness," Inspection Procedure 41500, 34
4 1
VALUE/ IMPACT ANALYSIS A seperate value/ impact analysis nas not been prepared for this regulatory guide.
A value/ impact analysis was included in the regulatory analysis for the amendments to 10 CFR part 50 published on This analysis is also appropriate to Revision 3 of Regulatory Guide 1.8.
A copy of the regulatory analysis is available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street, NW.,
Washington, D C.
35 l
.~
g g
NRC FORM 303 U.S. NUCLEAR REGULATOR ( COMht3S80N I
s 1O R M 120 tstuAtto suaotN era mesest to couaty wrtw t.<s woauAtoN cou.rctics neoutst Mas roRwAno couweNTs arsAnoeN3 TRAINING AND QUAUFICATION aumcN es=Are to t"e wc=mN e accoms wavem PROGRAM CERTIFICATION aRANcM rWNSB 77Hi. us NUcLEAA REGULATORY CoMMiSSich wasmaroN. oc ass Ano to tae
- Area voax aroucroN eaoacci otso
), omet or uANAarwENT Ano suoctT, WASP 4NGYoN. DC a*n INSTRUCmONS: File this form for inital certfication of training and qualification programs pursuant to 10 CFR 50.120. Provide the f informatan and check the appropriate boxes.
FACILITY DOCKET NUMBER 50-APPLICANT /UCENSEE DATE This is to comfy that the above named facilrty applicant / licensee has implemented training and qualification programs tha of 10 CFR 50.120.
For your informaton, the above named applicant s/ licensee's training and qualification programs have been implemented as in TRAINING PROGRAM For the checked program (s), we conform to the guidance contained iri the latest revision to Regulatory Guide 1.B.
QUAUFlCATION PROGRAM TRAINtNG PROGRAM For the checked program (s), we conform to the guidance contained in the latest revision to Pegulatory Guide 1.8 with exceptions as described below.
QUALIFICATION PROGRAM i
TRAINING PROGRAM For the caecked program (s), we have implemented the program with the method opcibe below.
OUALIFICATION PROGRAM DESCRIPTION OF EXCEPTIONS AND/OR METHODS TO BE USED FOR IMPLEMENTATION @ttach additional pag Aoy falso statement of omission in this document, including attachments, may be subject to civil and criminal sancti pertury that the information in this document and attachtr.ent is true and correct.
SIGNATURE. AUTHORIZED REPRESENTATIVE TITLE DATE.
In accordance with 10 CFR 50.120. Training and qualification of nuclear power plant personnel, submit this form to the NRC as follows:
BY MAIL ADDRESSED TO:
BY DELNERY IN PERSON TO THE NRC OFFICE AT:
Director, Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 11555 Rockville Pike Washington, DC 20555 Rockville, Marytand
d a
I -'
l-l L
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Regulatory Analysis 1
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4 REGULATORY ANALYSIS Proposed Regulations to Require Training and Qualifications Programs for Nuclear Power Plant Personnel
t TABLE OF CONTENTS EXECUTIVE
SUMMARY
l 1.
STATEMENT OF THE PROBLEM 2
2.
OBJECTIVES 4
3.
ALTERNATIVES 5
3.1 The Proposed Action:
Issue Regulations that Establish Requirements for Training and Qualification Programs for Nuclear Power Plant Personnel 5
4.
CONSEQUENCES 8
4.1 Benefits and Costs 8
4.1.1 Benefits 8
4.1.1.1 Reduction in Public Health Risk 9
4.1.1.2 Reduction in Occupational Risk - Accidents 11 4.1.1.3 Reduction in Occupational Risk - Normal Operations 12 4.1.1.4 Summary of Health Risk Averted 13 4.1.1.5 Summary of Benefits 14 4.1.2 Costs 14 4.1.2.1 Industry Costs 14 4.1.2.1.1 Program Development and Implementation 14 4.1.2.1.2 Program Maintenance and Revision 15 4.1.2.1.3 Property Losses Averted 15 4.1.2.1.4 Summary of Industry Costs 17 4.1.2.2 NRC Costs 17 4.1.2.3 Summary of Costs 18 4.2 Impact on Other Requirements 19 4.3 Constraints 19 5.
DECISION RATIONALE 20 6.
IMPLEMENTATION 21 REFERENCES 22 i
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EXECUTIVE
SUMMARY
Consistent with the Court's decision in Public Citizen v. NRC, the NRC is proceeding with a rulemaking to establish training and qualification require-ments for personnel at civilian nuclear power plants.
The proposed rule specifies the elements essential to an effective training program and defines the personnel to~ be trained and the modes of operation for which they must be qualified.
The proposed rule is compatible with the industry's existing training programs, which have proven generally effective in ensuring that nuclear power plant personnel have qualifications commensurate with the per-formance requirements of their jobs.
The alternatives evaluated in this re Court's decision in Public Citizen v.gulatory analysis are limited by the NRC.
The alternatives of taking no action, continuing to rely on the existing Policy Statement, or only issuing regulatory guidance are rejected without analysis as they would not meet the dictate of the Court.
Furthermore, given the NRC's previous findings that training programs developed using a systems approach provide high assurance that personnel will have the qualifications needed to perform their duties, and its findings that the training programs implemented by the industry during the 1980s have proven effective, alternative regulatory approaches, although identified, are not evalusted in detail.
The value impact analysis of the proposed rule indicates that it will provide additional protection of the public health and safety.
The benefit derives from the estimated reductions in human errors which, in turn, reduces the probability of large accidents.
Training is also estimated to significantly reduce occupational exposures for routine operations.
The evaluation of impacts (costs) indicates that the proposed rule is cost effective for both industry and the NRC.
Costs to the industry are minimized by the fact that training and qualifications programs that are largely con-sistent with the requirements of the proposed rule have already been developed and implemented.
Similarly, the NRC has already largely developed the regula-tory guidance and inspection and enforcement procedures necessary to assure the full implementation and effectiveness of such programs.
I
1.
STATEMENT OF THE PROBLEM The major incidents a't Brown's Ferry and Three Mile Island made it clear that training and qualification of personnel at civilian nuclear power plants was not receiving the same scrutiny and careful decisionmaking that was devoted by the NRC and the industry to structures, systems, and components in.portant to safety. A study performed after the accident at Three Mile Island found that during the period of 1969-1979, 38 percent of precursors to potentially severe core damage accidents involved human error (NRC82). Moreover, the human errors were not confined to licensed operators; they were made by licensed and non-licensed operators, instrument technicians, mechanical and electrical maintenance personnel, and engineering and plant testing personnel.
In the aftermath of the accidents at Brown's Ferry and Three Mile Island, both the NRC and the industry focused increased attention to the factors that contribute to human errors.
Significant among the factors identified was the failure to ensure that personnel assigned to tasks that affect the safe opera-tion of the plant were qualified to perform their duties.
The training pro-grams in place at that time were found to be of poor design, insufficient in their scope, and incompletely implemented.
In light of these findings, the NRC continually emphasized the need to upgrade training and qualifications programs.
In the NRC Action Plan Developed as a Result of the 7N1-2 Accident (NRC80), the NRC cited its ongoing study of accreditation of training programs as a possible means of upgrading the quali-fications of industry personnel.
Such an accreditation program was envisioned to assure that industry programs were addressing job requirements impu tant to safety, that the training provided to personnel performing such jobs was appropriate to their responsibilities, and that the training was effective.
Subsequently, the Institute of Nuclear Power Operations (INPO) and the Nuclear Management and Resources Council (NUMARC) initiated efforts to improve train-ing at nuclear power plants and began to develop an accreditation plan for training programs.
The industry indicated strong voluntary support for the INPO training iritiative.
The Congress also expressed its concern over the role of human errors in the safety of plant operations.
Section 306 of the Nuclear Waste Policy Act of 1982 (Public Law 97-425) directed the Nuclear Regulatory Commission (NRC) to promulgate regulations or Other regulatory guidance establishing instructional requirements for civilian nuclear power plant operators, supervisors, techni-cians, and other appropriate operating personnel, in 1985, the Commission determined that a Policy Statement would provide licensees with the appropri-ate regulatory guidance (50 FR 11147).
The decision to rely on guidance rather than regulations was made after a careful review of the INP0-managed program and in recognition of the progress that industry was making in improv-ing the training and qualifications of personnel.
The Policy Statement pro-vided for the NRC to closely monitor, over a two-year period, the industry's progress in implementing effective, accredited training programs.
In 1988, the NRC found that the INPO managed training accreditation program was generally effective in ensuring that personnel have qualifications commen-surate with the requirements of their jobs, and that industry was making satisfactory progress in achieving accreditation for their training programs.
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Based on these findings, the Commission concluded that its Policy Statement provided sufficient guidance to industry and that industry has amassed suffi-cient familiarity with the process to warrant changes in the enforcement policy to normalize the NRC's inspection and enforcement in areas covered by the Policy Statement.
Accordingly, amendments to the Policy Statement were published in the Tedera? Register on November 18, 1988 (53 FR 46603).
The legality of the NRC's decision to rely on guidance in lieu of promulgating regulations was challenged by Public Citizen. On April 17, 1990, the U.S.
Court of Appeals for the District of Columbia Circuit concluded that the Congressional intent was for the NRC to promulgate regulations and that the NRC's reliance on its Policy Statement did not satisfy the statutory require-Therefore, the. Court found for the plaintiff and remanded the issue to ment.
the NRC for further action consistent with the Court's decision.
In response, the NRC is proceeding with rulemaking.
The NRC is proposing a regulation that incorporates the principals and proce-dures underlying the systems approach to training originally incorporated in the Policy Statement.
The inclusion of a systems approach to training (SAT) in the Policy Statement was based on the success of such programs in other environments (e.g., military weapons systems and space programs) involving highly complex man-machine interfaces.
The regulation specifies the process by which appl (ants and licensees are to determine the job functions important to safety, and how the appropriate training and qualification programs are to be derived and implemented.
The primary advantages of this approach include:
high assurance that personnel performing functions important to o
safety have the skills, knowledge, and abilities required to perform their duties; flexibility for licensees to determine plant-specific training o
requirements based on the needs of their personnel and plant configuration; and prompt remediation of deficiencies through the provision of o
mechanisms to identify and incorporate plant-specific operating experience into the programs.
-Since the proposed rule is based on current industry practice and is generally compatible with the industry's existing programs, it will also:
minimize the NRC resources committed to the rulemaking; and o
minimize the additional industry resources that will need to be o
expended for program development and implementation.
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2.
OBJECTIVES The objectives of the proposed rulemaking are to comply with the order of the Court and to assure that the industry's training and qualification programs continue to enhance plant safety through the improved performance of all individuals who perform tasks important to safety.
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.3.
ALTERNATIVES As noted in Section 1, the rulemaking is being conducted pursuant to the Court's o.<ier that the NRC establish training and qualification requirements
_ by rulemaking as' called for by Section 306 of the Nuclear Waste Policy Act (Public Law 97-425).
Therefore, the alternatives of taking no action, reaf-firming the existing policy statement, and/or issuing regulatory guidance are not viable and are not considered further in this regulatory analysis.
Approaches to the rulemaking other than that proposed, which establishes re-quirements consistent with the programs already largely developed and imple-mented by the industry, are not evaluated in detail.
There is no evidence that any other approach would provide greater protection of the public's health and safety than the site-specific training programs called for in the proposed rule. At_the same time, other approaches may involve greater costs to the industry and the NRC.
3.1 The ProDosed Action:
1ssue Reculations that Establish Recuirements for Trainino and Qualification Procrams for Nuclear Power Plant Personnel In its earlier considerations of the need ta promulgate regulations specifying training and-qualifications requirement, the NRC found that programs based on a systems approach to training (SAT) offer high assurance that the personnel performing tasks important to safety would possess and maintain the aptitudes and skills.needed to perform their jobs.
The proposed action requires each applicant and licensee for a nuclear power plant to establish, implement and maintain a personnel training and qualifica-tion program for each of the following categories:
a.
operators as defined in 10 CFR 55.4; b.
senior operators as defined in 10 CFR 55.4; c.
non-licensed operators; d.
mechanical maintenance; e.
electrical maintenance; f.
instrument and control;
.g.
health physics and radiation protection; h.
chemistry and radio-chemistry; i.
- j. personnel with other plant specific titles who perform func-tions similar to those in the above categories; k.
plant managerial, supervisory, and engineering support personnel; 5
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personnel performing quality assurance functions as described in 10 CFR Part 50, Appendix B; and personnel responsible for accident assessment and mitigation.
m.
The training and qualification programs are required to consider all modes and conditions of plant operation, including:
a.
shutdown; b.
normal;
- c. -abnormal; d.
emergency; and e.
accident conditions.
The systems approach to_ training specified in the-proposed rule is required to contain (at a minimum) the following steps for each program developed for the classes of personnel identified above:
b_NALYSIS.
Perform a systematic analysis appropriate to the job to determine perform;nce requirements and training needs.
DERIVATION OF LEARNING-0BJECTIVES.
Where the analysis indicates a need-for_ training, derive from the analysis a set of learning objectives that describe the standard of desired job performance after training.
DESIGN AND IMPLEMENTATION.- Design training programs based on the learning objectives selected for training, and implement the programs to achieve those_ learning objectives.
TRAINEE EVALUATION.
Develop tests and testing procedures that are in accord with the job performance requirements and the learning i
objectives derived from the analysis. Administer the tests to demonstrate that the trainees meet the learning objectives.
PROGRAM EVALUATION. Develop and implement a plan for periodically evaluating the effectiveness. of the training requirements based on the performance of the staff. The effectiveness evaluation must be systematic, and completed at least once every two years.
PROGRAM REVISION. Develop and implement a plan for revising the training program on'a periodic basis. The plan must provide.for
-the revision of the training. requirements, course contents, and/or presentation to reflect-feed-back obtained from trainee evalua-tions, program evaluations, and/or internal and external program audits. Where program evaluation indicates the need for revi-sions, such-revisions must'be~ completed within one year.
Implementation of the systems' approach to training described above assures that the affected personnel will have and maintain the skills, knowledge, and l
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abilities necessary to perforn their duties.
Furthermore, since the analysis of qualification requirements and training needs is performed on a site spe-cific basis, the cost effcctiveness of the programs is optimized.
This approach, building as it does on existing programs, minimizes the imple-mentation period and the costs to both the NRC and the industry.
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4.
CONSEQUENCES The benefits and costs associated with the imposition of SAT based training and qualification requirements on the industry were developed in 1983 to support the Cnmmission in its 9 ermination of the most cost-effective manner of attaining a high level of unnel competency (NRC83a).
The basic data developed in NRC83a have been reviewed, updated as appropriate, and used to determine the benefits and costs of the proposed action.
4.1 Benefits and Costs.
The benefits that are anticipated to accrue due to the imposition of the proposed rule are reductions in radiation exposure to both occupational work-ers and the public.
The magnitude of these potential benefits are estimated based on the expected reduction in human errors attributable to training.
The costs for the proposed rule are the development, implementation, and operating costs that will be incurred by the NRC and the industry.
(Note:
industry's costs are subject to a cost off set due to averted on-site costs.)
It should be noted that since the accident at ihree Mile Island Unit 2 (THI-2), ths industry has developed, updated, and won accreditation for training programs that embrace the fundamental elements of the systems approach to training and cover most of the personnel and the modes of operation specified in the proposed rule.
Thus, the benefits, in terms of averted dose, discussed in the following subsections are essentially already being accrued due to the industry's initiatives. However, it is the staff's position that these bene-fits are.he result of voluntary programs and without the proposed rule the industry could disband its training initiative and the benefits would dissi-pate.
It is in this context that sizable benefits are attributed to this rulemaking. The imposition of the proposed rule will assure that the industry continues to maintain and update its personnel training programs and that it uses these programs as an integral part of its evaluation of the appropriate-ness of the qualifications of the personnel whose performances affect the safe operation of the plant.
With regard to the impacts, the costs of development and implementation of training and qualification programs based on the systems approach have already been largely expended by the NRC and the industry.
These costs, which for the industry were estimated in NRC83a to total $63.3 million (1983 dollars) for program development alone, are sunk costs and are not included as incremental costs of the rulemaking. However, the future costs of maintaining and operat-ing these training programs over the remaining lifetimes of the plants is included in this analysis.
4.1.1 Benefits The reduction in risk that is potentially achievable by the proposed training and qualification requirements is dire.tly related to the reduction in human errors that is achieved. All probabilistic risk assessments indicate that human error is a major contributor to the potential risks from nuclear power plan +s.
This fact is supported by the industry's performance prior to the voluntary improvement of training programs.
Analysis of operating experience from that era indicates that human error was involved in 38 percent of the events that were precursors of severe core damage accidents (NRC82).
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Rigorous studies quantifying the reduction in human error rates that the current voluntary programs have achieved are not available.
However, the efficacy of such programs is suggested by the continual decline in the number of scrams experienced at operating reactors and in the improvements that have been achieved in unit capacity factors.
In the 1983 evaluation of training and qu.lification programs, expected error rate reductions were estimated based on performance ratings of individual plants. A composite estimate, combining the ratings made by an expert panel established by Pacific No:thwest Laboratory (PNL) the opinions of NRC region-al inspectors, and the results of SALP (Systematic Assessment of Licensee Performance) inspections, rited the performance of 19 percent of operating plants above average, 48 percent as average, and 33 percent below average.
Error rate reductions were then estimated for each class of plants as follows:
Ratino Classification Ranae of Expected Reduction Point Estimate Above Average 0 - 10 percent 5 percent Average 10 30 percent 15 percent Below Average 20 - 50 percent 30 percent Based on the percentage of plants ranked in each classification a weighted average error reduction of 18 percent was calcu;.ted.
Based on consideration:,
of non quantifiable factors, the 1983 analysis used 20 percent as the point estimate of human error reduction with lower and upper bounds of 10 and 50 percent, respectively.
These estimates were based on training programs oe-veloped and iriplemented using a systems approach to training.
The proposed rule also includes requirements for training ano qualifying personnel involved with Quality Assurance and Accident Assessment and Mitiga-tion, and extends the scope of the required programs to include all modes and conditiens of operation.
Experience.wer the past seven years has shown that these additional requiremants wir mprove the safe operations of nuclear power plants.
While, the additio.al benefit attributable to training of these personnel and for all operating modes has not been quantified, it is extremely unlikely that the magnitude of the benefit would fall outside of the 10 - 50 percent human error reductions previously determined.
Therefore, 20 percent is retained in this analysis as the point estimate of the reduction in human error rates, within a range of 10 - 50 percent.
4.1.1.1 Reduction in Public Health Risk The expected reduction in public health risk is estimated using a methodology similar to that used in the 1983 analysis.
The methodology and analysis are as follows.
1.
Determine the person-rem exposure resulting from a severe core melt accidert at a typical pressurized water reactor (PWR).and boiling water reac-tor (BWR).
Based on the probabilistic risk assessments for Oconee and Calvert Cliffs,theexposureresulting{romaseverecoremeltaccidentatatypical PWR is estimated to be 3.2 x 10 person-rem.
Based on the probabilistic risk 9
assessment for Grand Gulf, the exposure resulting frog a severe core melt accident at a typical BWR is estimated to be 6.8 x 10 person rem.
2.
Determine the average probability of a severe core melt accident per reactor year of operation for a typical PWR and BWR prior to the establishment oftrainiggprograms.
Based on the same three pla per reactor year for PWRs and 3.7 x 10 " pts, these probabilities are 1.8 x 10' per reactor year for BWRs.
3.
Det>rmine the baseline risk (person-rem / reactor year) for a typical PWR and BWR prior to the establishment of training programs.
For PWRs this is:
3.2 x 106 person rem x 1.8 x 10-4 severe core melt 576 person-rem severe core melt reactor year reactor year for BWRs this is:
6.8 x 106 person-rem x 3.7 x 10-5 severe core melt = 250 person-rem severe core melt reactor year reactor year 4.
Determine the change in severe core melt probabilities per reactor year based on reductions in human errors of 10, 20, and 50 percent.
Based on relationships developed by PNL (NRCP3b, PNL83), these changes are given as:
Type of Decrease in Decrease in Core Revised Core Melt Plant Error Rate Melt Probability Probability (percent)
(percent)
(events /ry)
PWR 10 5.7 1.7 x 10'4 PWR 20 14.8 1.5 x 10'4 PWR 50 34.5 1.2 x 10-4 BWR 10 27.1 2.7 x 10-5 BWR 20 45.8 2.0 x 10 5 BWR 50 87.8 4.5 x 10-6 5.
Determine the range of potential risk reduction (person-rem / reactor year) for a typical PWR and BWR.
This is simply the percent reduction in core melt probability from Step 4 times the person rem / reactor year calculated for PWRs and BWRs in Step 3.
For PWRs, the rcCuction in risk ranges from 33 to 199 person-rem / reactor year, with a point estimate (20 percent human error reduction) of 85 person-rem / reactor year.
For BWRs, the point estimate of the reduction in risk is 115 person-rem / reactor year, within a range of 68 to 220 person-rem / reactor year.
6.
Based on the number of reactors of each type, a".o the.
average reat-tor lifetime remaining after implementation of the proposei rule, calculate the potential benefit (person-rem avoided) over the entire,iost-implementation period.
As of September 30, 1990, the number of PWRs operating or under construction was 82 and the number of BWRs was 40 (NRC90). Based on the calculations in NRC83b, in 1990, the average PWR has 22.5 years of service remaining, while the average BWR has 21 years.
These life expectancies ignore the possibility of license renewal.
If such renewals occur, the benefits would be greater than estimated 10 er v
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Since the industry has already implemented training programs based on the principals of the systems approach called for by the proposed action, there is
.o need to calculate the period of time needed for implementation.
Therefore, the potential person-rem avoided (point estimate) is:
85 verson-rem x 22.5 reactor years x 82 PWRS - 157,000 person rem at PWRs reactor year plus 115 oerson-rem x 21 reactor years x 40 BWRS 97,000 person-rem at BWRs reactor year 254,000 person-rem TOTAL The lower-bound estimate is 118,000 person rem and the upper bound estimate is 552,000 person-rem.
As noted above, these calculations assume that if the ruie were not implement-ed, industry abandons its voluntary training programs.
They further assume that the reductions in human errors achieved by these programs over the past seven years are immediately lost.
While the first assumption ic tenable (i.e., absent a rule industry could opt to abandon its training initiative),
the second is not.
The trained work force's error rate would not immediately revert to pre training levels However, without refresher courses and given turnover and attrition in the work force, the error rate would be expected to increase to pre training levels over time.
Assuming that the increase in error rate occurs at a rate of 10 percent per year until pre-training error rates are reached, the benefits attributable to the proposed action would be approximately 25 percent smaller than indicated by the above calculations.
Table 4.1 summarizes the adjusted (-25%) estimates of the public health risk averted by the imposition of the training and qualifications requirements.
Table 4.1:
Estimated Public Risk Reduction Totai Risk Reduction (person-rem)
Lower Bound Point Estimate Upper Bound 89,000 191,000 414,000 4.1.1.2 Reduction in Occuoational Risk - Accidents A methodology for calculating avoided occupational exposure from accidents was developed by PNL for the NRC (NRC83c).
This methodology estimates the avoided occupational exposure from accidents as the product of the change in core melt probability and the occupational exposure likely to occur in the event of a major accident.
From the data presented in Subsectirn 4.1.1.1, the changes in core melt frequencies at PWRs and BWRs are calculated as:
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PWRs BWRs Lower Bound Point Estimate Upper Bound Lower Bound Point Estimate Upper Bound 1.0 x 10 5 2.7 x 10-5 6.2 x 10-5 1.0 x 10 5 1.7 x 10-5 3.2 x 10-5 In the event of an accident, increases in cccupational exposure may be expect-l i
ed to be incurred both at the time of the accident and at the time that the facility is ultimately decommissioned.
Based on the accident at THI 2, as discussed in NRC83c, a collective occupational dose of 1,000 person-rem could i
be attributed to the emergency management of the incident.
The value of 1,000 person-rem is used here as the point estimate of the immediate occupational dose.
The upper bound is estimated by assuming that the average worker re-ceives a dose equal to that of the maximum individual dose of 4.2 rem received by a worker at THI-2.
Assuming 1.000 workers, this yields an estimate of 4,200 person rem. A lower bound of zero is used to indicate that there could be instances where no increase over normal occupational dose results from the accident.
The estimate of long term occupational dose is also taken from NRC83c.
For a reference light water reactor that experiences a major loss of coolant acci-dent (LOCA) with delayed startup of the emergency core cooling system (ECCS),
PNL estimates the'occu be 20,000 person-rem. pational radiation exposure from cleanup and recovery to The lower-and upper bound estimates are 10,000 and 30,000 person-rem, respectively.
The expected reduction in occupational risk from accidents is calculated as:
DT0A " NPWR TPWR AFPWR (DIO + OLT0)
- NBWR TBWR SIBWR (DIO + DLT0) where:
DT0A = Number of PWRs; Total occupational dose averted (person rem);
N PWR -
TPWR = Average PWR lifetime after implementation; AF gg = Change in core melt frequency at PWRs; 10 = 1mmediate occupational dose (person-ren, LTO - Long-term occupational dose (person-rem ;
D
);
NBWR = Numoer of BWRs; TBWP = Average BWR lifetime after implementation; and AFBWR = Change in core melt frequency at BWRs.
The number of PWRs and BWRs is given as 82 and 40, and T is 22.5 years for PWRs and 21 years for BWRs.
Table 4.2 presents tne estimates of the occupa-tional health risk from accidents averted by the imposition of the proposed training and qualifications requirements.
As above, an adjustment factor of
-25 percent is i.pplied to these estimates to reflect the gradual loss of skill in the already trained work force.
4.1.1.3 Reduction in Occupational Risk - Normal Operationt Since the proposed action involves improved training programs, no increase in occupational exposure will result from implementation. However, the potential exists to reduce occupational exposure during annual operation and maintenance 12
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Table 4.2:
Estimated Occupational Risk Reduction - Accidents Total Risk Reduction f
(person-rem)
Lower Bound Point Estimate Upper Sound 200 1,000 3,600 4
as a result of the improved performance of personnel.
PNL estimated the potential reduction in occupational exposure during normal operations to be 60 person rem per reactor year (NRC83b). The lower and upper bounds are given as 0 and 90 person rem per reactor year, respectively.
For the proposed action, given that the weighted average lifetime remaining for PWRs and BWRs is 22 years, the point estimate of normal occupational exposure averted is 161,000 person-rem.
The lower limit is O person-rem, and the upper limit is 242,000 perton rem.
Table 4.3 presents the estimates of routine occupational exposure averted during normal operations by the imposition of the proposed rule.
These estimates are also adjusted downward by 25 percent. to reflect the fact tt.at the current work force has received training over the past seven years.
Table 4.3:
Estimated Occupational Risk Reduction - Normal Operations Total Risk Reduction (person-rem)
Lower Bound Point Estimate Upper Bound 0
120,800 181,500 4.1.1.4_.ipmmary of Hulth Risk Averted The risks averted by-the imposition of. training and qualifications programs on the industry have been estimated for the public= and occupational workers.
Table 4.4' summarizes the estimated risk reductions achieved by the proposed action.
Table 4.4:
Summary of Estimated Risk Reductions Total Risk Reduction (person-rem)
Lower Point Upper Bound Estimate Bound Public Exposure -
89,000 191,000 414,000
' Accidents Occupational Exposure -
200 1,000 3,600 Accidents Occupational Exposure -
0 120,800 181,500 Normal Operations TOTAL REDUCTION 89,200 312,800 599,100 l
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0 4.1.1.5 Sumary of Benefits The benefits that are attributable to the imposition of requirements for
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training and qualification are due to the safer operations achieved by reduc-tions in human errors.
For regulatory analysis purposes, the estimates of
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person-rem averted may be converted to monetary terms by assuming $1,000 per The staff views $1,000 per person-rem as sufficiently large to person-rem.
encompass an allowance for health, life-shortening, and all off-site property losses associated with the radiological releases that would cause doses of the magnitudes estimated.
The point estimate (20 percent human error reduction) indicates that $312.8 million of benefits accrue to the proposed action, w'th a lower bound of $89.2 million and an upper bouna of $599.1 million.
4.1.2 Costs The costs of the proposed rule are addressed in terus uf the costs to industry and the costs to the NRC.
The costs to industry include development and implementation of the training and qualification programs and the annual costs of program maintenance and revision.
These costs are offset by the averted on-site property losses.
The costs to the NRL include the costs of developing the regulation and the annual costs of program evaluation.
4.1.2.1 Industry Costs 4.1.2.1.1 Program Development and implementation As noted above, the industry has largely developed and implemented the SAT-based training programs required by the proposed action.
The INP0 managed national accreditation programs include explicit training modules for all of the job categories specified in the rule except QA and accident assessment and mitigation.
These training programs also cover the skills needed for all modes of operation except shut-down and accident conditions. As a result, the development and implementation costs for the proposed rule are limited to broadening the existing programs to cover these additional requirements, in 1983, the costs to the industry for developing and implementing training programs based on the systems approach to training was estimated to be $63.3 million (NRC83a),
Using a price deflator of 1.31 (NRC89), the estimated cost of developing and implementing SAT-based training programs would be $82.9 million in 1990 dollars.
The estimate of $82.9 million needs to be adjusted to reflect dollars that the industry has already expended, i.e., the sunk costs.
It also needs to be adjusted to reflect the additional costs associat-ed with broadening the programs to cover additional personnel and modes of operation.
The 1983 analysis from which the cost estimate was derived was based on a task analysis of the tasks important to safety at PWRs and BWRs.
Since the task evaluations included virtually all of the job classifications covered by the proposed action, we can derive an estimate of the fraction of the total costs attributable to development of training modules for QA personnel and for l
personnel responsible for accident assessment and mitigation. Of the 1,357 tasks identified as important for safety at PWRs, 60 (4.4 percent) are per-formed by QA and other technical personnel.
Similarly, at BWRs, the percent-age is 4.7 (60 of 1,269 tasks).
Since it is unclear to what extent the 1983 I
14
O analysis included personnel respor.sible for accident assessment and mitigation among other technical staff, a value of 5 percent is assumed in this analysis to estimate the additional costs associated with expanding the existing pro-grams to cover QA personnel and personnel responsible for accident assessment and mitigation.
The impact of the requirement that the training programs cover all modes of operation is more difficult to quantify.
However, based on discussions with cognizant NRC and industry personnel, it is assumed that this requirement will result in broadening the training programs by 10 percent.
Given these assumptions, the industry's incremental implementation and devel-opment costs for the proposed rule are estimated to be $12.4 million $82.9 million x (5% for additional personnel + 10% for additional modes)). (Since implementation can be accomplished within one year, there is no need to calcu-late the present value of these costs.
The uncertainty in this estimate is assumed to be + 50 percent, so the lower-bound estimate would be $6.2 million, while the upper-bound estimate would be $18.6 million.
4.1.2.1.2 Program Maintenance and Revision The annual costs of maintaining and revising training programs ranges from 10 to 20 percent of the programs' development and implementation cost (NRC83a).
Given the relatively stable configuration of nuclear power plants, the lower end of the range, i.e., 10 percent, is used to estimate the costs associated with program maintenance and revisicn.
The total program development and implementation costs, including sunk costs, for the proposed action are esti-mated to be $91.2 million* in 1990 dollars.
Thus, annual program maintenance and revision costs are 59.1 million per year.
Since these annual costs will be incurred over the remaining lifetimes of the reactors, they need be ex-pressed in terms of their present worth.
The weighted average lifetime re-maining at the 82 PWRs and 40 BWRs is 22 years.
At a 10-percent discount rate, the uniform series present worth factor is 8.77, which yields a present worth value of $80 million.
At 5-percent, the present worth would be $120 million.
Since the annual program maintenance and revision cost is based on the total program implementation cost, the same 50-percent uncertainty applies to the estimate.
Thus, at a 10 percent discount rate the point estimate is $80 mil-lion within the range of $40 million to $120 million.
For a 5-percent dis-count rate, the point estimate is $120 million within the range of $60 million to $180 million.
4.1.2.1.3 Property 1.osses Averted The reduction in the probability of a severe core melt through improvement in worker job performance also results in reduced risk of monetary and property losses associated with an accident.
Simply stated, reducing the risk of severe accidents reduces the risk of damaging both off-site and on-site property.
As discussed in Subsection 4.1.1.5, the value of the off site property losses averted is encompassed in the value of $1,000 per person-rem
- $91.2 milTTon
$78.6 million in sunk implementation costs ($82.9 million x 55% implementation completed) + $12.4 million in incremental implementation costs.($82.9 million x (5% additional personnel + 10% for additional modes)).
15
1 used to assign a monetary value to *he averted doses.
The value of the on-site property losses averted can be calculated as:
VFP " NPWR AIPWR DPWR + NBWR AFBWR DBWR where:
Vpp Number of PWRs (82)Present value of avoided property damage NPWR -
AFPWR = Estimated change in core melt frequency at PWRs D
Present value of estimated property loss per accident at PWRs PWR Number of BWRs (40)
N BWR = Estimated change in core melt frequency at BWRs AF BWR = Present value of estimated property loss per accident at BWRs DBWR -
in NRC83a, a point estimate of on-site property losses, based on the experi-ence at TMl-2, is given as $1.2 billion per accident.
Using a price deflator of 1.31, this is equivalent to 51.6 billion in 1990 dollars.
The present value of these on-site property losses is calculated using the uniform series present value factor:
(1 + i)" - 1 1(1 + i)"
where:
i - Interest (discount) Rate; and n - Number of Periods (average lifetime remaining).
The average lifetime remaining for PWRs and BWRs is 22.5 and 21 years, respec-tively. Assuming a 10-percent discount rate, the present value factor is 8.83 for PWRs and 8.65 for BWRs. At a 5-percent discount rate the present value factor is 13.33 for PWRs and 12.82 for BWRs.
Table 4.5 presents the point estimate and the lower and upper bounds of the on-site property losses averted by the proposed rule.
The point estimate it calculated using the point estimates of the changes in core melt frequencies presented in Subsection 4.1.1.2.
The lower bound uses the lower-bound esti-mate, and the upper bound uses the upper-bound estimate.
The 25 percent adjustment factor, to account for the fact that the current work force has received training over the past seven years, was the1 applied to each esti-mate.
Table 4.5:
Estimated On-Site Property Losses Averted (5 million) 10% Discount 5% Discount Point Estimate 30.52 47.52 Lower Bound 12.84 19.27 Upper Bound 67.16 100.98 16 L_______
l 4.1.2.1.4 Summary of Industry Costs The present worth value oof the estimated costs to industry for the proposed action are summarized in Table 4.6.
Since the costs of on-site property damage are averted costs (i.e., cost savings) to the industry, they are shown as negative costs in the table.
Table 4.6 Summary of Industry Costs
($ million, 10-percent discount rate)
Lower Point Upper Bound Estimate Bound
)
Program Development &
6.2 12.4 18.6 Implementation Program Maintenance &
40 80 120 Revision On Site Property (12.8)
(30.5)
(67.2)
Loss Averted
. TOTALS - 10%
33.4 61.9 71.4 (5 million, 5-percent discount rate)
Lower Point Upper Bound Estimate Bound Program Development &
6.2 12.4 18.6 Implementation Program liaintenance &
60 120 180 Revision On-Site Property (19.3)
(47.5)
(101)
Loss-Averted TOTALS - 5%
46.9 84.9 97.6 4.1.2.2 NRC Costs The proposed actionLinvolves the promulgation of a rule that specifies the process to be used to determine-the training and qualification requirements
~-
=for the personnel and modes.of operation specified in the rule.
L The develop-ment costs to the NRC include the costs of developing the rule and the associ-ated regulatory guidance, and the inspection modules necessary to assess i
L applicant's and licensee's compliance with the requirements.
i Since the proposed action is generally compatible with the existing progratos voluntarily established by the industry, the costs to the NRC of developing i
17
_ - _ _ - - =. -
and implementing the rule have already been largely expended, i.e., they are sunk costs.
Based on estimates obtained from cognizant NRC personnel, the preparation of the rule and the revision of the associated regulatory guide and inspection modules is estimated to require less than $0.5 million.
The annual inspection and auditing costs to the NRC for the proposed action woLid be essentially the same as for the industry's current voluntary pro-grams.
Based on discussions with cognizant NRC personnel, the annual costs to the NRC are approximately $0.15 million.
As these inspection costs will be recurrent costs over the remaining lifetimes of the reactors, the present value is $1.3 million at a 10-percent discount rate or $2 million at a 5-percent discount rate.
4.1.2.3 Summarv of Costs Table 4.7 summariies the present value of the costs estimated for the industry and the NRC for the proposed action.
The point estimate (10-percent discount rate) indicates a total cost of $63.7 million.
Table 4.7: Summary of Costs
($ million, 10-percent discount rate)
Lower Point Upper Bound Estimate Bound Program Development &
6.2 12.4 18.6 Implementation Industry Program Development &
<0.5 Implementation - NRC Program Maintenance &
40 80 120 Revision - In.'ustry Program Maint wance &
l.3 Revision - NRC On-Site Property losses (12.8)
(30.5)
(67.2)
Averted - Industry TOTALS - 10%
33.4 63.7 71.4
($ million, 5-percent discount rate)
Lower Point Upper Bound Estimate Bound Program Development &
6.2 12.4 18.6 Implementation - Industry Program Development &
<0.5 Implementation - NRC Program Maintenance &
60 120 180 Revision - Industry Program Maintenance &
2 Revision - NRC On-Site Property losses (19.3)
(47.5)
(101)
Averted - Industry TOTALS - 5%
46.9 87.4 97.6 18
I 4.2 Impact on Other Reauirements i
The action will have~only minor impacts on other requirements.
10 CFR Part i
50, sections 50.8(b), 50.34(b)(8) and 50.54(i)(1-1), and Part 55, sections 55.31(a)(4) and 55.59(c) will require minor conforming amendments. The deft-nition of Sys; ems Approach to Training will need to be revised in section 55.4.
In addition, 10 CFR Part 52, section 52.78 will be amended to require applicants for combined licenses to develop training and qualifications pro-grams in accordance with section 50.120 of 10 CFR Part 50.
4.3 Constraints lhere are no known constraints on the industry or NRC for the proposed action.
19
5.
DECISION RATIONALE Given the Court's decision and the NRC's previous oversight of the development and implementation of the industry's existing programs, the decision to pro-pose regulations consistent with the existing programs is obvious.
Further-i more, all of the quantitative decision factors determined in this analysis support such a decision.
The positive decision factors include:
1.
the averted public and occupational doses are large (312,800 person rem), when valued at $1,000 per person rem, the bene-fits are slightly in excess of $300 million; 2.
the costs to industry and the NRC are small ($63.7 million) relative to the projected benefit; 3.
the systems approach to training offers high assurance that workers will have the skills needed to perform their safety-related jcbs; and 4.
although the consequences of other rulemaking approaches have not been quantified, it is the staff's view that none would be as cost-effective as the proposed site-specific programs which build on the industry's existing programs and all would take longer to implement.
Non-quantified factors also support the proposed action.
The most important of these factors is the improved efficiency that is expected by having the responsibility for program development and maintenance reside with the indi-vidual sites.
This approach will make it easier to tailor the training to the specific needs of the plant and its existing work force.
It will also expe-dite identification and remediation of training program deficiencies.
20
6.
IMPLEMENTATION In this regulatory an'alysis, it is assumed that all licensees will be able to certify to the Commission within 180 days after the effective date of the rule that they have implemented the required training and qualification programs; and all applicants will be able to make the certification within either 180 days or 18 months prior to fuel load, whichever is later.
This assumption is based on the fact that the existing programs are largely compatible with the requirements of the proposed rule.
21
O e
l REFERENCES NRC80 U.S. Nuclear Regulatory Commission, NRC Action Plan Developed as a Result of the 7#1-2 Accident, NUREG-0660, Washington, DC, July 1980.
NRC82 U.S. Nuclear Regulatary Commission, Precursors to Potential Severe Core Damage Accidents: 1969-1979; A Status Report, NUREG/CR-2497, prepared by Minarick, J.W., et al., Oak Ridge National Labo.atory for the NRC, Washington, DC, June 1982.
NRC83a U.S. Nuclear Regu1atory Commission, Regulatory Analysis of Training and Qualificatton Rule and Operator Licensing Examinstton Changes, based on a report prepared by Analysis & Technology, Inc., under Contract No. RS NRR 83-107, Washington, DC, November 1983.
NRC836 U.S. Nuciear Regulatcry Commission, Guidelines for Nuclear Power Plant Safety issue Prioritization Information Development, NURLG/CR-2800, prepared by Andrews, W.B., et al., Pacific Northwest Laboratory for the NRC, Washington, DC, February 1983.
NRC83c U.S. Nuclear Regulatory Commission, A Handbook of Value-Impact Assess-ment, NUREG/CR-3568, prepared by Haeberlin, S.W., et al., Pacific Northwest Laboratory for the NRC, Washington, DC, October 1983.
NRC89 U.S. Nuclear Regulatory Commission, Generic Cost Estimates: Abstracts from Generic Studies for Use in Preparing Regulatory impact Analyses, NUREG/CR 4627, Rev.1, February 1989.
NRC90 U.S. Nuclear Regulatory Commission, " Status of Nuclear Power Plant Units - Data as of September 30, 1990," Office of information Re-sources Manageme", Washington, DC, October 1990.
PNL83 Powers, T.B., et al., Estimating the Pub;ic Risk Reduction Affected by Humn T. -tors improvements, Pacific Northwest Labort. tories, Draft Repurt, September 1983.
22
El4 CLOSURE D DRAFT El4VIR0l4 MENTAL IMPACT ASSESSMEN1 e
i L
- ~ ~ -
-~
~
6 DRAFT {NVIRONMENTAL ASSESSMENT AND FINDING OF NO SIGNIFICANT IMPACT i
ON PROPOSED AMENDMENT 1010 CFR PART 50
" TRAINING AND QUAllFICATION OF NUCLEAR POWER PLANT PERSONNEL" Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission March 1991 1.
THE PROPOSED ACTION The proposed action is to 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 training and qualification of specific categories of nuclear power plant personnel, that consider all modes and conditic,s 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 regulation requires applicants and licensees to certify to the Commission on NRC Form 393 that they have implemented the required programs.
Specifically, 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 the applicant or licensee that personnel training and qualification programs meeting the requirements of the
e rule have been implemented. The proposed rule generally reflects current industry practice.
11.
lHE NEED FOR 1HE PROPOSED RU!.EHAKING Atil0N 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 training and qualification of civilian nuclear power plant operators, supervisors, technicians and other operating personnel, in order to meet this directive, on March 20, 1985, the Commission published a Policy Statement on Training and' Qualification of Nuclear Power Plant Personnel.
The Policy Statement endorsed a training accreditation program managed by the Institute of Nuclear Power Operations-(INPO) in that encompassed the essential elements of " effective performance-based training."
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 require:nents of their jobs. On November 18, 1988, the NRC l
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 L
enforcement in the areas covered by the 1985 Policy Statement, and (3) reflect L
i ~
current Commission-and industry guidance.
2 l
L-4 i
\\. a..
.a...--.-
..---,---.---.-------L---------
- - - - - - - - - - - - - - ~ ~ - ~ * ~ ' " ~ ~ '
~ ' ' ' ~ ~ " ' ~
- 4 On April 17, 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 civilian nuclear power plants.
The Court remanded the issue back to the NRC for action consistent with the Court's findings. Egg, Public Citizen v. NRC, 901 F.2d 147 (D.C. Cir.),.c_ert.
denied, 59 U.S.L.W. 3392 Unvember 26, 1990).
The Commission requested a rehearing of the decision by the full court, which was denied on June 19, 1990.
On November 26, 1990 the Supreme Court denied certiorari on petition by ths Nuclear Utility Management and Resource Council.
The proposed rulemaking is being developed to meet the directives of Section 306 of the Nuclear Waste Policy Act of 1982 as interpreted by the Court.
111.
ALTERNATIVES TO THE PROPOSED RULEMAKING ACTION The alternatives to the proposed rulemaking action are to:
take no action; reaffirm the existing policy statement; or issue regulatory guidance.
As noted previously, this rulemaking is being conducted pursuant to the Court's order that the NRC establish training and qualification requirements by rulemaking as called for by Section 306 of the Nuclear Waste Policy Act of
}982 (Pub. L.97-425).
Therefore, the alternatives of taking no action, j
reaffirming the existing Policy Statement, and/or issuing regulatory guidance are not viable, i
l 3
l
9 IV. ENVIRONMENTAL IMPACT Of THE PROPOSED ACTION (RUL(MAKING)
The safety of nuclear power plant operations'and the assurance t
.,ene ra l public health and safety depend on personnel performing at adequate performance levels.
The systematic determination of qualifications and the provision of effectivt nitial training and periodic retraining will enhance confidence that workers can perform at adequate performance levels. 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 training and qualification programs are based upon job performance requirements, and that nuclear power plant personnel have qualifications comensurate with the performance requirements of their jobs.
Personnel who are subjected to training and qualification programs based on job performante 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 because of the reduction in human error.
V.
FINDING OF NO SIGNIFICANT IMPACT The Comission has determined under the National Environmental Policy Act of 1969, as amended, and the Commission's regulations in 10 CFR Part 51, that the proposed amendment to 10 CFR Part 50, specifying training and qualification requirements for nuclear power plant personnel, if adopted, would not have a significant effect on the quality of the human environment and that an 4
environmental impact statement is not required.
This determination is based on the foregoing environmental assessment performed in accordance with the procedures and criteria in Part 51, ' Environmental Protection Regulations for Domestic Licensing and related Regulatory functions."
VI. MAJOR REFERENCE DOCUMENTS 1.
Regulatory Analysis: Amendment to 10 CFR Part 50 to Require Training and Qualification Programs for Nuclear Power Plant Personnel, Draft, prepared for the U.S. Nuclear Regulatory Commission, Office of Nuclear Regulatory Research by SC&A, Inc., McLean, VA, March 1991.
Vll.
PERSONS CONTACTED Not applicable. No other agencies or persons were contacted to determine any potential environmental impact as a result of this proposed rule.
l l
l 5
ENCLOSURE E Draft Public Announcement t
'l i
1 j.
X y._,, __,,.. _, _,, _
NRC PROPOSES NEW REQUIREt4EHis FOR TRAINil4G ANO QUAllflCAT10t1 0F fidCLEAR POWER PLANT PERSONNEL The Nuclear Regulatory Commission is proposing to amend its regulations to include requirements for training and qualification of nuclear power plant personnel.
If implemented, the proposed rule would meet the directives contained in Section 306 of the Nuclear Waste Policy Act (NWPA) of 1982.
Section 306 directed the NRC to promulgate regulations or other appropriate guidance establishing instructional requirements for the training of civilian nuclear power plant personnel.
As proposed, applicants for and holders of a license to operate nuclear power plants would be required to establish and use a systems approach to training (SAT) in developing training programs for specific categories of nuclear power plant personnel, that conside all modes and conditions of operation (including shutdown, normal, abnormal, emergency, and accident conditions).
The systems approach to training has been used successfully by the military and in other technical areas where human performance and safety are primary concerns.
The nuclear industry has also been using the SAT process for the past seven years.
Therefore, the proposed rule would build upon current industry initiatives related to training and qualification.
Under this approach, there would be a systematic analysis of job performance requirements to identify learning cbjectives.
Following the analysis, training programs would be designed and developed to address the identified learning objectives.
After delivery of the training, trainees
would be evaluated on the basis of performance standards outlined in the learning objectives.
Training programs would then consistently be evaluated and revised, as necessary, based on measurement and observation of trainee performance on the job.
Applicants and licensees would also have to assure that all affected personnel have qualifications--education, training, and experience--that are commensurate with the levels and types of responsibilities assigned to them.
Qualification requirements for each affected position would be derived from the analysis phase of the systems approach to training.
Licensees would have no less than 180 days from the effective date of the rule to certify to the Commission that they have implemented the required programs.
Applicants for an operating license would be required to certify to the Commission that they have the required programs in place no later than 18 months prior to fuel load, or 180 days after the effective date of the rule, whichever comes later.
Comments on the proposed amendment to Part 50 should be submitted in writing by (date).
They should be addressed to:
The Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555, Attn:
Docketing and Service Branch.
1
ENCLOSURE F Draft letter to Congress
l l
The Honorable Peter H. Kostmayer, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs United States House of Representatives Washington, DC 20515
Dear Mr. Chairman:
The NRC has sent to the Office of the Federal Register for public comment, proposed additions to 10 CFR Part 50 (Enclosure A).
This rulemaking is being initiated in order to respond to Section 306 of the Nuclear Waste Policy Act of 1982 which required NRC to promulgate regulations or other appropriate regulatoi guidance establishing instructional requirements for civilian nuclear power plan personnel. If implemented, this proposed rule will replace the March 20, 1985, NRC Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, and its subsequent 1988 amendment, which were intended to meet the Congressional mandate. The NRC is undertaking rulemaking at this time in order to comply with a decision made in April 1990 by the U.S. Court of Appeals for the District of Columbia Circuit which concluded the NRC did not meet the intent of Section 306 when the agency published a non-binding policy statement rather than regulations. The NRC staff believes that the propcsed additions to 10 CFR Part 50 are fully responsive to the spirit and intent of Section 306, and offer an integrated approach to the concerns highlighted by Congress.
The proposed rule would require that each applicant for and holder of an operating license for a nuclear power plant establish, implement, and maintain, training and qualification programs for specific categories of nuclear power plant personnel that consider all modes and conditions of operation including shutdown, normal, abnormal, emergency, and accident conditions. i.icensees would have no less than 180 days from the effective date of the rule to certify to the Commission that they have implemented the required programs. Applicants for an operating license would be required to certify to the Commission that they have the required programs in place no later than 18 months prior to fuel load, or 180 days after the effective date of the rule, whichever comes later.
In order to provide an acceptable method by which to implement the proposed rule, the NRC staff prepared a draft regulatory guide which is also available for public comment (Enclosure B). Revision 3 to Regulatory Guide 1.8, " Training and Qualif kation of Nuclear Power Plant Personnel" describes the characteristics of a metned accepable to the NRC staff for the systematic development, implementation, and 0 valuation of training programs addressed by the proposed
The Honorable Peter H. Kostmayer it also endorses, with some exceptions, the latest version of industry standard A!JSl/Afis-3.1, " Selection, Qualification and Training of Personnel for f4uclear Power Plants."
Sincerely, Eric S. Beckjord, Director Office of Nuclear Regulatory Research
Enclosures:
As stated cc:
Rep. John J. Rhodes l
. e I
ENCLOSURE G ATTACHMENT 1.
Section 306 of the Nuclear Waste Policy Act of 1982
.AT1ACHMENT 2.
Policy Statement on Tra; sing and Qualification of Nuclan Power Plant Perza9nel (50 FR 11147)
ATTt.Ls; MENT ?.
Amended Policy Statement on Trai.t ng and i
Qualification of Nuclear Power Plant Personnel (53 FR 46603)
A1 TACH'IENT 4.
Regulatory Guide 1.8, Qualification and 1 raining of Fersonnel for Nuclear f ouer Plants, Revision 2, April 1987 f
- =.
.c PUBLIC LAW 97-425, Nuclear Vaste Policy Act of 1982 Sectt?r. 306 NUCLEAR REGULATORY C0t941SSION TRAINING. AUTHORIZATION SEC. 306.
NUCLEAR REGULATORY C0t911$5 ION TRAINING AUTHORIZATION.-
The Nuclear Regulatory Commission is authorized and directed to promulgate regulations, or other appropriate Commission regulatory guidance, for the
.... trAint - and qualifications of,ctvilian nUcleg power plant operators, super-visors..ech,nicians and.other. appropriate oper.at,ing, persortnel g,,Such,regula-
,y s. 4..r. 7 t. tons or.p:idance shal). astabl.1sh ss.igil yo.r; tr.ai.h.t eg.3r,eq0ifemeht'.( for,, app.1,J..,..,
j
(
cants for civ111an nuclear power plant operator licenses and for operator requalification programs; requirements governing NRC administration of requal-1 ification examinations; rdquirements for. operating. tests at civilian nue: tar power plant simulators, and instructi,onal requirements for.civ.111an nucle.r pc/ 1r plant licenses personnel training programs. Such regulations or sther regulatory guidance shall be promulgated by the Commission within the 12-month period following enactment of'this Act, and the Commission within the 12-month I
period following enactm :nt of this Adt shall submit a report to Congress catting forth the act. ions the Comission has taken with respect to fulfilling its obligations ut. der this section.
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-.- ee rie na C-se bes,,o-and natur a% orrma yde Some se ehminate the dudhne by as end.as -
Commlulen Peney Statement en
"** 'P"*"'8 ell bcenses throich a notice end Trein6ng and Quanftest, ben of touttner m lmanuary sa tent the
,,,,,,,,,g,,,g3,,, g,gg, g,g g, p,,,,pg,,,p,,,,,,,
C'""""""P"P"d ** ""d4 seapanu > UC5 e.NMC ral FJd no meesser. Nuclear Reguletory swebummmmial Wh= ten (DC Or.1es31 and now in progrue et agew===e= =d ts =** ben a r Me paar47 ItM) An uundan Cannuum
"""P
- '""' D'
- C"*'t M CYI'**** L' of b jene atL1st2 deadime, depends st house a Analsoir homed upon tot Men gammary 21. W4e R
{,
n]g egns annwe stateneet u no g, g,,
wt!! espedite the asnchsien of the pohey of Ow NucJeer Regu lary
' 8*""""
- came me.=,
Comminton (NRC) with rupsce to temmes===e e's= ewo e=== ormho 6'**
eryolns relemaking and latends to reach treaning and perooneel quehfaceuen and er o.snm.es.e e ens m ar.e4 e e decteten by Anarust 111884 describes the activttin that the NRC t
t e e rw. e. e.4ma onH un to pecuw Hs ropagitsu ge wweetes ea=mwaymen so.
a tese ederewei = e.
- a=====.e er erw **=== ne c.-====
e
'.# e..ew m m c.. e.a.e ensure the health and sefety of the
===v ** 6.= as seu mm,w a n 3,a, e,er
- e. p s sur e..o s
pubhc. This Pohey $tetemovit r evidu ngulairsty gwdewe called for try the
- =8~8d *=
P5-PR 24 Movember 30,19E8
. -- --.---_.-,.~. ~ - _ _...
. -.. - -__--.-,.~.-,
e, POLICY S1 ATEMENTS Nudeer Wute Pohey Act IPub L tre.
has found to be en ecceptab&r means of
- belvetion of trainee maskry of W 425) which directed the NRC to industry self imprcuement a traming objectivee dunne treinmg promudgese e guletierw or other De NRC hee. therefore. meer NPO
+ Evoluebon and tevu.on of the ngulatory guidence far the treming end quebficate, e of etvihan nuclear power accreditebon the locvs of the pahey set training bened on the performance of forth bere for trotning ellowing h traines personnel en the job eettmg
)
plani opereier, evpervwore technic.ene industry a mirureum of two peere of and other appropnete operebng occreddstion ochv$ty withaus time he NRC recognisce that the INpO.
penennel la recorronon ofindustry -
Invadecbon of new NRC tressag ladudes the following trairung menesed secreditet on of utibty treming
)
i inst atsves underway to aprede tremag ngulatione progrenie.the NRC endones the programe-Institute of Nuclear Power Operehone he followmg statement eete forth the
- Non.hcensed operetor.
(WWe.enaged Training Accreditetion pobey si the NRC with respect to
- Controlroom operetor.
Progree to that it enconnpenes the training and quehficebon and describes
- Senior control toore operetorfehlft elemente of performance-beoed treirunt tN ecbvibo that the NRC wC) use to
- supatear, and will provide the besie to ensure that execuw He responalbihbu to enoun th
- Shift technicaladvisor.
per,onnel be re quehficehone beelth and eefety of the pubbs.
- Instnament and control technicien commeneutete with the perfortnence Poucy Statemeal
- Electrical maintenesee personnel nguirements of their tobe it remame the
- h4echanical maintenance personnel conunuma responsibihty of the NRC to De Commission recognases thet th
- Redeologica; protectson techrucies.
independency evaluete erthcent's and indntry,through k kubeDen vf h
- Cheadstry techniciene 1.censees' unplementa tion of Nuclear Uuhty Management med Wiran
- On-site techtticalstaff end tmpavement programs to ensure that Resources Committee (NUbWlCl and managers.
desired resulte are ech esed. Nothing in the Insurute of Nuclear Power All stibtsee beve come ined to this Pobey 5tetement shallIlmit the -
Operabone (INPOk bee made pegne.
achieving ocA 'stic.of each of h authertry or responsibiht to developmg pierrene to taiprove fellow up on operohone!y of the NRC to nudear ubbty treuuas and persesuwl above training progreme it to any hmit on NRC's enfortement quhfacebon. While some of eneee understood bt each hoensee will es*ert evente or place best efforte to beve all such programe authortty when regulatory requirements enorte have only mendy been instietect ne dy for occreditation (t e.. rmet self-are not met However, while evalueimg the Comrai eion mhaes the separtence evolveUon report embmitted to INPO) by the effecbveneu of this guidance to ben of ladvetry's inibeuve and wishes to the end of teet It to else urieretoed of a new treming regulebon the NRC encour&ge further self-taprovement ht opphcente for operetmg bcensee intende to enertnee oorse d3ecnnon in Subktt to the coetmoed seemse of will emert best efforte to ben all such enforcement mettere related to tromms INpo propone and NRC's shihty to pmgrarse ready for scendstetum within and quellficetion of nudeer plan' esonnor their e!!ecbvenest the personnel and tefrom frorn oe" Commuesion will sairam tras erw two years after leeuence of a futhpower opereung Lanee.
rulcmekang in this ane for e pened of et sulemaldng to the men of tremais for e For o tang reactors, eccredstetion least two years from the effective date minim.es pened of two yeare drum the of the a e trei ' progetros of thae Pobcy Stetement e!!ectin date of the Pohey Statement constitutes e aneth acceptable to the smans mars.: Merch XL ual while b Comutinies le deismos NRC for implementing performena-rulemaking m this area to ressesuuon el poo eusmese amonereTion cowTect the todustry effone to date. Gas NRC can beeed treimres The NPCwillconnoue to Wdhem T. Rusee!L Omar of Nuclear review and 6; prove ad opphcent Reacsor Regulehon U.S Nuclear only eserc6se this fler.Mty as leeg es training progresis in accordance with the todtry programa prodene the opphceble regulatione. regulatory Regulatory Comnussion. Weahington.
denntd multe it rename the emetmuing guidance, and the Standard Review Plen DC ank% telepborte fact)esadets responalb'ht of the NRC to aue,urnerwTeert esponiesAveoec independeody evoluete oppbceene' and and to condschnepectione necenery to Bedgrund bcensee(laplementation af eletermine that current regulebone and Lcense traid6ies commitmente are bems The Nuclear Weste Pohey Act(42 knprovement proyees to ensure these, siet Notwithetending thu Pohey USC 10tm et seq L occt co sotL directed results on schieved and to evoleste the guidance. tegulatione in 13 CFA Fort &&
the Nuclear psguletory Comeuwon elble need for further NRC memon regeribng e-d operetors wig (NRC) to prusoulgete regulebone er othe-ed on the succese of ledustry,
regulatory guadence for the tromms and programe efter a two year pened.
emmtinue to be the beste for evolvetion The followins paragraphe present the of apphcations for operatore* bcenses it should be acted that treinmg guebriceuene of cwthen euclear power NRC pohcy with rupect to bcemmen programe for wtuch regulebone are plant operetare, supervwore, technicione and other appropnete operebrig and appbconte' progress Ier personnel personagt The Pohey Statesent is training and quehficatione curwntly in place leg, fue bngede, evnergericy response, security) or wgich
- responsive to the mandete of the The nuclear powerinduey,dwough are act subject to INPO eteeditation Nuclear Wate PoLey Act for reguletory programe being cooribneted by INpO.
guidance on tretrung ernd quehficehone bee mode end to makmg preyges I'd quehty soeurence) are not affected by this Pohey Statement.
for nuclear power plant personnd lowerd isnprovW the treuuss of nuclear To anure that the nuclearindutry's Reguleboos er regulatory guidance in power plant personnel by accredatebon training progrssiimprovemente eve the receuung aren are bems developed of training progreme. The NRC anJorus effective, the NRC will conunue tc esperate4 h INPO-sianaged Trainies closely monHer the procese and ite Followeis the accident et ThC-1 the Accreditebon Program in that h
'Teelte by the following-NRC bee emphasized the need to encompenes the eleenente of effective
- Recommendmg e ember to uru i
opgrade traming and quehficehens of performance beud trainmg vn each Accredihng Bo6td.
nuclear poser plant pemo.giet in the The NRC conaldere the foGowere five
- Heving as NRC staff member ettend ng! Action Plan. NUREG-eastL 19etL eternente se essenuel to ecceptable and observe Accreditmg Board meetmge the NRC cited he ongoma etedy of training prog
- ems.
wh b INPO staff and/or the utdaty a Systemeuc enelysis of the lobe to MpM*enteWem i
eccreditauen of treuung progreeie is the b, pegge,,e,d,
- hnodsceh observing accredstebo:a industry es e pose;ble eieene of espaved ng tretrung $,nce that trme. the
. gjernmg objectives denved frorn team sHe Weite:
Inoutote of Nuclear Power Operetiene h enelysis which describe des,#-d
- Accompeoyms INPO on selected (INPOl hee developed a treuuit p,rformance efter training plant enheetaune occ>ed,teuon program which the rJRC
- Trainmg design and unplementshon
- Mutmg with 1NPO to ehere beeed on the learnma obycuna.
infonnenon on pmwete and eenvibes.
- Reviewing perunent accreditenon PS PR 25 i
November 30,1988
.- - - - - - - --~ - ~' "-- ~ ~ ~
,,. _ _ - - _. ~.
-..m._
e' POLICY ST ATEMENTS decasments viet teone reteled to these prog sms.
e indu&ng a tisinmg summary Provided the violahens, whether or not evolustaan es port of each systematac ident f.ed by NRC are appropnately seAument report of hcer see corrected in a tamely mennet. Hom ever.
performance isA1Ji),
violations which are not corrected in e e Monitorms plast and industry temely menner,wolsbens of any trends and events that involve personnel oppiscable mportmg requirement, and any willful violchee may be subject to errn
- Conducting operetot hcensing enforcement Any reforcement action
- emaans, talen dunne this grace pened will be e Cenducting operefor requehficehen iden only with Comunassion amasma, consletent with Comminion concurrence.In ad& bon to required reports and inspections, informahon
'ntanuing evaluation of
- e requests under 10 01 go.H[f) may be indewywide training qualification made end enforcement meetinge held to program effectiveness, and ensure understan&rg ef cornctive
- Conducting performance oriented octaons Orders may be issued where treining Inspecnons to eseees the level necessary to achieve corrective actions of kriewtedge of plant personnel.
on mattere effectang plant safety. in le oddshon, INPO will:
bnef. the NRCs deca.on to see
- Continue to manage the industry -
discretion in enforweent bs order to accreditetson program..
recognise industry init euvee in no way
- Continue to conduct performance changes the NRCs abibly to tesue enented evolueboas of tramms and orders, call enforcement mechnss or quebrecahoe propems.
- Make genenc sccreditetson suspend bcensee when a safety problem documents (program descr90cn and is found No% in his Pohey arttersa) pubbcly evallable, a:.d Statement shall haut the authonty of the NRC to conduct taspections ee deemed
- Renew and consider NRC.
debons regardmg tramms necusery and to take appropnete Also, e t industry, through NUMARC er enforc. ment octaan when regulatory requirements are not seet.
- M"d'Of**; *nL, J,;p;* a-* a* *> '
.e,rogre ro.i.ius; end
. Prende penodic etstua repprts to For the Nuctor Raguletary Comumn the NRC staff inclu&ng plant lebe C. Heyk scurvetation status. -
Asosiaar Secretary e/4Ar Comauss.on Personnel Qu. Tafkations
. The NRC and industry recognise that the crushrcahona of personnel et ressear power plants should be comumensu. ate wMh the tet.wirva2ents of the >:bs they perform. Since the INPO-
- managed ocdeditetson and evaluetien prorems are performance-based thae polacy staiement assumes that trainisig
- proprems for those positions covend wiD provide appropftetely quehtied perstanael For positions outside the scope of the LNPOwmanaged cccreditahnn program. for hcensed
. operators and senior operetors. and few cD peranael at fecahties applyms for en operatir4 bcense.NRC staff will eestanee to review quel.ficatsons in accordance with apprepnote regulatory pohey guidance.
NRC wiD use the same general snethods described above for training to spionator the industry's progrert in -
istproths the quehfacahans of nuclear
, peery plant personnel Martement poLcy edetwithsten&ng its Edorcement Pohey 6n to CFR Port 2. Appendia C 49 FR asas (March a toast the Comminion will esercise some dacrebon in selecting oppropnete enforcement
$ctism fot enoletions involving training ta h,ht of the NUMARC/INPOinitiatne Isornsees who are making reasonsule cfforte in des elopmg and implemenhng
- the INPO/NLJM 4RC programs desenbed chove wil ser creDy not be coed for l
November 30,1988 PS P R.26 f.w.
.- - - - - - - - - - - - ~ ~ ~ ~ ~ ~ ~~' ~~~~~ ~ ~ ~ "~
46G03 Rules and Regulations r a -.i %,
Vol. 53. No. r.Z3 fnds). Noseckber itL sus This sacson d & FEDLAAL HEGISTER that small businesses will not be unduly for the reasons set forth in the cocarm repuory oacw=u teg or disproport>onately burdened.
preernMe. 7 CFR Part #10 is amended as generat a;Wsary and War e%cs. rest Market.ng orders inued prenant to the follers:
at.ncn are keyed e are cam h the Case of Feda$ W4'aans. N m Agricultural Marketing Agreement Act.
and rules issued thereunder, are anique PART 910-tIMONS GROWN IN
[ m m smant e 4 in that they are brought about throoth CALIFORN'A AND ARIZONA The Code of F,oerar %detions is soM groep action of essentially small entities l
ty the Supennaandert of Doctrnenta acting on their own behalf. Dus, both 1.ne authority citation for 7 CFR Pnces or new to*s are 6ssed m the etstutes have small entify orientabon Part 910 continues to read as follows:
erst FEDERAL REGISTER tsaae of each and compahbuity.
Authairr Sem ias. as Suut. n
- k.
D!s regulation is ined under amded. 7 U.SE. 001-64 Marketing Order No. 710, as arr-nded L Section 910.Ho fs added to read as DEaARTMENT OF AGRfCULTURE (7 CFR Part 210) regulatirts the her.dhng follows:
ofi m b Cahfornia and Ws adon W//M oppeniir &
Agricurturat Marketlog Service tama. The order is effecthe imder the Code ofrederu/ Regulations /
Ag iculttral Mrketing Ag'eement Act 7 CFTl Part 310 (the "Act" 7 U.S.C. 001-4N). as j311HO Lem n Regutation 640.
fL*anca nae naa 6401 amended.His action s based trpon the ne quantity of lemons g own in recommendation and information California and Arir.oca which may be Crpn h Cam aM subentted by the temon Administratrve handled during the pened Nommber 20.
Mason of W Committee (Committee) and upon other 1988. throoF November 28.19R& ts h
avaDable information. lt is found that established a t :tri,875 cartons.
Accecr.Agacuhura! Marketing Servicr.,
this action wiD tend to effectuate tb?
Da ted. November 16,1968 USDA.
dedaredpobeyof the Act.
l acroc Th:a' rule.
This regule+ ion is consrstent with the gow, c g..,y, I
n:arketing poGey for 1908-69. The Deputy Daecer. fruit end veperaMe SWMARr. SP nt)Cm 640 Establishes yms,,n, i
the quantiry of f:esh Cahfornia.Anzona Committee met publidy on November 15.1988, in les Arr eles, Cahfornia to N noc. #
aed
- e <s.m lemona that may be shipped to market at consider the curren;t and prospective i
l
- aL875 cartons du'ing the period i
Nemnber m through November 28.
conditions of supply and demand and Tsaa Such action is needed to balance unanimously recommended a quantity the aupp}y of fresh lemons with market oflemons deemed advisable to be NUCLEAR REGULATORY demand for the period specified. due to handled during tbc specified week.The COWLS?lON the marketmg situation confrontint a Commitee reports that demand for temon industry.
lemons is god 10 CFR Part 55 Pursuant to 5 U.S.C. 553, n is further CATm Regulation 640 (i 910.MO) is found that it is impracticable, Commission PoDey Statement on eEcctive for the period November 20 Training and Qualificat>on of Nuclear through November 2t 1988.
unnecessary, and contrary to the pbbbc interest to give prelimmary notice and Power Plant Personnel coR mamot osomATion cowtAcT:
eogage in farther public procedure with Aoosev:Noclear Regulatory Raymond C. Martm. Section Head, respect to this action and that good Commission.
l Volume Control Programs, Marietmg cause exists for not postponing the Acnosc Amended Policy Statement.
Order Administration Branch. FaV.
effective date of this ac6cn until 30 days AMS USDA. Room 2523, South Building. after pubbcation in the Feders! Reg: ster swatAar. On March 20.1985.
.e P.O. Boa 96454. Washington. DC 20090-because ofinsufficient time between the Nudear Regulatory Commission (NRC) e45& telephone:(202) 447-6697.
date when information became pubbshed a " Commission Pohey sunt.assemTAny tevomAnoec his available upon which this regulation is Statement on Training and final rule has been reviewed under based and the effective date necessary Qualifications of Nuclear Power Plant Executive Order 2:271 and to effectuate the declared purposes of Personne'" (50 FR 11147). The policy Departmental Regulation 1512-1 and has the Act. lr.terested persons were given statement provided guidance for the been determined no be a "non-major" an opportunity to submit information training and quabfication of nudear rule under criteria contained therein.
. and views on the regulation at an open power plant personnel connnunicated Pursuant to requirements set forth in sneeting. It is necessary, in order to that the NRC would refretn from new the Regulatory Mexibihty Act (RFA). the efectuate the declared purposes of the training regulation during an evaluation AAmu trator of the Ag-icultural Act, to make these regulatory provisione period of two years and endorsed the s
l Marketing Semce has determined that effective as spedfied. and handlers have Training Aa:reditaticu Program this action will not have a significant been appnsed of such provisions and managed by the Institute of Nudear economicimpact on a substantial the effectise time.
Power Operations (INPO). %e NRC numberof small entities.
l De purpose of the RFA is to fit List of Subjects in 7 CTR Part 910 monitored industry initiatives to rpgrade training programs through the regulatory action to the scale of Marketing agreements and orders.
1NPO-managed Trai:ang Accreditation i
business aubject to such actions in order Cahfornia. Arizona. Lemons.
Program for a two year period. nc l
t
[
e I
46G04 Tederal Register / Vol. 53. No. ::.3 / Friday. November 18. 1908 / Rules cnd Regulations i
staff's evaluation of this prog.
Upgrade training and qualifications of the " Annual Status Report on indicates that it is generally an effective nudear power plant personnel. In the implernentation of the Commission program for ensuring thet nuclear power "NRC Action Plan Developed as a Policy Statement on Training and plint personnel have qualifications Result of the Bil-2 Accident"(NUREG-Quahfication"(SECY-86-119)
- and ocmmensurate with the performance 0000 July 1980).8 the NRC cited its "De 2 Year Evaluation on requirements of their jobs.%is ongoing study of accreditation of 1mplementation of the Commission statement amends the Commission's training as a possible means of Pohey Statement on Training and policy statement that was pubbsbed on upgradmg traming programs in the Qualification."(SECY-87-121)
- which M rch 20.198$ regardm' g the training h4dustry. Since that time, the Institute of provided the findings frorn the end qualification of nuclear power plant Nudear Power Operations (INPO). with evaluations of the INPO-managed personneh its associated National Academy for Training Accreditation Program over the Il remains the continuing Nudeat Trair Ing (Academy), has two-yeat evaluation period.
eesponsibility of the NRC to developed a trainmg accreditabon Based on the staffs evaluation of the indipendently evaluate applicants' and program which the f *"C has found to be INPO training accredatation program.
Licensees' implementation of at. acceptable means of self-the NRC condudes that the program is improvement programs to ensure that improvement In training. On March 20.
effective in ensuring that personnel have desired moults an schleved. Nothing in 1985, the NRC published the qualifications commensurate with the this policy statement shalllimit the Commission Policy Statement on performance requirements of their jobs.
authority or responsibility of the NRC to Training and Quahfication of Nudear However, the Commisaluu has follow up on operational events or place Power Plant Personnel.8 allowing the determined that the policy statement cny limit on NRC's enforcement ladustry a minimum of two yean of should be amended to re!)ect the minor authority when regulatory requirements accreditation activity without the modifications made by the Nat'onal en not met, introduction of new NRC training Academy for Nudear Training to its he amendm:nts are (1) the addition regulations.De two. year evaluation accreditation program and the NRC staff ofinfermetion regarding the NRC's penod ended March 20,1987, to the methods by which it mon: tors the experienu with industry acenditation,
%e staff evahated the results of the industry trainits program. In addition.
(E) a change in the enforcement section INPO accreditation program between the Commission bas determined that the to normahze inspection and March 1985 and March 1987.%e staffs industry has had auflicient time to enforcement in the areas covered by the evahation consisted of participating as establish the accreditstion program and policy statement, at d (3) minor changes observers when utilities' training it is nu longer necessary to exercise la conform to the cunent statur of programs were under evaluation by an extra discretion in enfortement when Commission and industry guidance.
INPO accreditation team, observin8 regulatory requirements are not met.
Catt he amendments to the pohey accrediting board activities, and site Accordingly, the, policy statement is statement are effective November 18, in8Pections as described in SECY-as-amended to ehminate the extra 1968.
201.s he staH also developed criteria discredon cunently provided in the FOR FUstTHER 18 SPOR 8 SAT 10N COttf aCT: _
and procedures that were used to assess policy statement and to normalize lack W. Roe. Office of Nuclear Reactor whether accredited utility training inspections sad enforcement actions in R egulation. U.S. Nuclear Regulatory programs include five critical elements.
the areas covered by the policy Commission. Washington, DC 20555.
ne renew criteria Lave been published statement.
Telephone:(301) 492-1004.
as %aWng review Crituia and he following sets forth the Procedures"(NUREG-1220).* ne amendments to the policy of the NRC cum.rwortAmy mromuaraoec citeria were appbed by the staHin with respect to training and Beckground auditing training programs at eight qualification of nuclear powerplant The Nudear Waste Policy Act (Pub. i utilities with accredited trainin8 penonnet ti rev ews i uded in Amendments to Policy Statemeut da egula Co s:1 NRC) to promalante regulations or other (1)ne Commission recognizes that regulatory guidance for the training and a Copa M NUREG Ose0 mar be pedumd the Nationt! Academ) for Nuclear qualifications of civilian nuclear power newsh aw UA cowoment rnnuas m br Training has expanded its accreditation plant operators, supervisors. technicians c[edo$$MYo*aoy pr gram by establishing an eleventh and other appropriate cperating wnunetm Dc sms-rosz copi
, ow be Program fu continuma training of personnel (includmg instructional P= dad from th* Nema! Tedudcal hfarmabon bCensed personnel.
requinments, simuletor traintag -
s rvice. UA p. pero t er co-sus pori
-(2) ne NRC etaff will expand the
- requirements, and requirements for
$ $ "th * [p.ct N. N e"op M t. m methods by which it monitors the I
requalification examinations and the NRC Pubbe Document Room. 212D L 5eset NW.
Indus
's training program and its operating tests). On March 20.1985, the wahme1m DC resulta y performmg post. accreditation NRC publisbed a policy statement which
- C***d***
P*l reviewe at ae!.a ted sites.
gyg"Ng'ey sutemet en Trahme andf PL*8'
****l l50 (3) he section of the 1985 policy is responalve to the mandate of the i
Nudear Weste Policy Act for regulatory
- * *
- co,4
.f Numrc tzm srcym statement entitled "Enfornent Policy" guidance on training and quahfications sECv-as-1ss. and seCY-a7-122 may be perds.ed is withdrawn.De NRC wtii conduct 1
cf nuclear power plant personnel onwsb the UA ca rement ertsene h try inspections as deemed necessary and l
R:gulations or regulatory dance in t btLS-take appropriate enforcement action in cow i
a I
the remaining areas have en wnwym oc acess rosz copw.mr aw be acewdance with the Corarnissiods drveloped separately ae a revision io 10
>=rened fran the Neucnal Tedua inta a.non enforcement policy in 10 CFR Part 2.
CFR Part 55-Operators' Ucenses.
5"'we. UA D.paran.nw%nre.u. szsa Port Appendix C, whers regulatory
$ @ i % * [ Z '.2
- g requirements are not met.
Fellowing the accident at nree Mile Isinnd. Unit 2 (TM1-2). the NRC the NRc Pwbtic Do ment Room rim L sunt ww, Dated at Rockville. MD. this 14th day of continually emphasized the need to wuhneta rc November taea
mamm,
n,,,wn 2e l
- %p " * %
U.S. NUCLEAR REGULATORY COMMISSION April 1987 s
W'o.$) REGULATORYGUIDE
..o OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 1.8 (Task OL 403J5)
OUALIFICATION AND TRAINING OF PERSONNEL FOR NUCLEAR POWER PLANTS A. INTRODUCTION training of nu-lear power plant personnel. Ttus standard w as approved by the American National Standards Paragraph 50.34(b)(6)(i) of 10 CFR Part 50, " Domestic Institute (ANSI) Committee N18, Design Cnteria for licensing of Production and Utihzation FactLties," requires Nuclear Pr"ver Plar ts, and designated ANSI N18.1 1971, that an appbcation for a bcense to operate a nuclear "Selectio' d Training of Nuclear Power Plant Person.
power plant include ir formation concerning organizational nel." Ret
,ory Guide 1.8, " Personnel Selection and structure, personnel quahfications, and related matters.
Training," endorsing ANSI N18.1 1971, was issued in Subpart D, "Appbcations," of 10 CFR Part 55," Operators' March 1971, and Revision I was issued in September Licenses," requires that operator bcense appbcations 1975. A revision of ANSI NIB l 1971 was subsequently include information concerning an individi.ars education a'pproved by the ANSI !)oard of Standards Review and and expenence and related matters. This regulatory guide desarnated ANSI / ANSI 3.1 1978, " Selection and Traming describes a method acceptable to the NRC staff for of Nuclear Power Plant Personnel" complying with those portions of the Commission's regulations s..S regard to the training and quabfications.
A first proposed Revision 2 to Regulatory Guide 1.8 of nuclear power plant personnel, Personnel of test, e ndor,mg ANSI /ANS 3.1 1978 was issued for pubbe trammg, research, and mobile reactors are not covered comment in February 1979. As a result of expenence by this regulatory guide.
. gamed from the accident at Three Mile Island Unit 2 (TM1-2), additional pubhc comments in the area of The Advisory Committee on Reactor Safeguards t.as p;rsonnel quahfications were requested on proposed been consulted concerning this Funde and has concurred
' Revision 2 to Regulatory Guide 1.8 in May 1979. All in the regulatory position.
of the sommen ts from both requests were forwarded ta the ANS 3 Subcommittee for its use durmg the develop-Any information en!lecuan activities mentioned m ment of a revision to ANSI /ANS 3.1-1976. Subsequent-this regulatory guide are contained as requirements in ly, Draf t Standard ANS 3.1, dated December ti,1979, 10 CFR Parts 50 and 55, wtuch provide the regulatory incorporatmg the upgraded rcquirements was issued. In basis for this guide. The it. formation collection require-September 1980, pubhc coniments were requested on a ments in 10 CFR Part 50 have been approved under second proposed Revision 2 to ReFulatory Guide 1.8 OMil Clearance No 3150 011, those in 10 CFR Part that endorsed Draft Standard ANS 3 1.
The pubbc 55, under OMil Clearance No 3150-0018.
comments reccaved were held in abeyance pendmg Commission action on proposed rules on operator
- 11. DISCUSSION quahfications and bcensing in SECY 8184, "Quahfica-tion cf Reactor Operators,"' February 2, 1961, and Subcommittee ANS 3, Reactor Operations, Amencan SECY 81-84 A,
" Discussion of Revisions to Reac,or Operator Quahfications,"8 June 15,1981. The Commis-Nuclear Socacty Standards Committee, developed a standard containing cntena for the quahfication and sion did not approve either of these proposals and directed the staff to continue to study the issue.
The sostantial number or changes in this revisioei has made it I Copies are available for kaspection or c impractu:al to andacate the changes wiA bnes in the margm.
NRC Pubtac Document Room,17 7 H Street bytna Lr a fee in the
., Washington, DC.
USNRC REGULATORY GuiOES The pusoes are issueo en tne tonowing ten broso civisions:
Regulatory Guion are issued to oescrabe and maue avaliable to the puotic metnoas acceptabte to the NRC staff of empiamer.tmo
- 1. Power Reactors
- 6. Picoucts spectrac parts of the commission s regulations, to detmeata tecn-
- 2. Researen ano Test Reactors
- 7. Transoottation moves useo ov the staff an evaluating specific problems or postu-
- s. Fuets ano Materials Facilities
- 8. Occupational Health lated accioents, or to provide guaoance to appiecants. Reguestory 4 Environmental anc Siting 9 Antneust ano Fmancial Revie.
Guioes aav not subststutes for regusations, and compiaance with
- 5. Materiass ano ptant protection 2 0. Generat them is not reovereo. Metnoon ano solutions cif ferent f rom those set out an the guioes will be acceptanee of they provice a basis for tne fir *omes requHne to the issuance or contmuance of a permit or Coo es of issued ev.oes may be purchased from the Government necense by the Commtssion.
Prmi6ng office at tne cureent Guo prwe. Information on current Tnts guide was issued af ter cons 4deration of comments received from Gpo prices may tw octainen by contactmg 'ne Superintencent of Documents. U.S. G over n me n t Printing of fice, Post of fic o con the punt c. Comments ano s.sgeestions for improvemente 6n tnese a ros2. W ashington, DC 2 cola-70s2, teseonone t&O212 75 2060 or guices are encouraged at aH times and guices weit be revtseo, as t202:275 2173.
appropriate, to accommooste comments ano to reflect new enforma-tion or enperience.
Issueo gusoes may also t e purchaseo from the Nai6cnal Technecat i
Written comenents may be submitted to the Rules and Proceoutes in f ormat 6on sse rv 6C e on s t ano mg oroer basas. Detalis on tnes G ra nC h.
D A R.
- ADM, V 5.
NuCitar N egula t or y Commissace, serveCe may be obtained by writang NTib, 52 0 s Port HUyal Road, Wasnmgton, DC 205s 5.
Spemgfeela V A 22 63.
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'e Dunng 1981, Draft Standard ANS 3.1 was updated to 10 CFR Part 50) and the requirement to have a stuft factor in additional lessons searned from the TMI2 techrucal adstsor (STA) available to the shift (NUREG-accident and changing regulatory requirements. The 0737, l. A,1.1 ).
One option an the Pohey Statement, standard was approved by the Amencan Nuclear Society's which is preferred by the Commission, allows combining Nuclear Power Plant Standards Committee (NUPPSCO) the functions of the STA with one of the required senior and the ANSI Doard of 5tandards Review and was operators as long as specific training and education reissued as ANSI /ANS-3.1 ?981, " Selection, Qualihcation requirements are met. The other option allows for con-and Training of Personnel for Nuclear Power Plants."2 A tinuation of an approved u dependent STA program.
third proposed Revision 2 of Regulatory Guide 1.8 was Regulatory Position C.I.i reflects the guidance provided developed to endorse ANSI /ANS 3.1-1981 with certain in this Pobey Statement.
additions and exceptions and was issued for public com-ment in January 1985. As a result of the public com.
C. REGUI.ATORY POSITION ments and Commission actions concerning training and qualihcations, this Revisica 2 of Regulatory Guide 1.8
- 1. Positions in ANSI /ANS 3.11981 that Are Endorsed now endorses Sections 4.11.1, " Shift Supervisor," 4.3.1.2, by this Regulatory Guide
" Senior Operator," 4.5.1.2, "L.icensed Operators," 4 A.8,
" Shift Tec'aical Advisor," and 4 4.4, " Radiation Protec-For the positions hsted in ANSI /ANS-3.1 1981, tion," of ANSI /AN3 3.1 1981. Endorsement for all other
" Selection, Quahfication and Training of Personnel for positions will remain *vith-ANSI N18.1-1971, " Selection Nuclear Power Plants," as shift supervtsor, seruor opera-and Training of Nuclear Power Plant Personnel." The tor, bcensed op rator, and shift technical advisor, the bases for the additions and exceptions to ANSI /ANS 3.1-requirements contained in the standard provide an 1981 are contained in NUREG-0737, " Clarification of approach acceptable to the NRC staff for complying with TMl Action Plan Requirernents,"3 wtuch includes the the quabhcations and tra2ning requirements of 10 CFR March 28,1980 letter to all power reactor applicants Parts 50 and 55 subject to the guidance regardmg the and bcensees regardmg quahhcation of reactor operators, STA function provided in the Commission's "Pobey and NUREG-0094, " Guide for the 1.icensmg of Facihty Statement on Engineenng Expertise on Shift" and the Operators, including Senior Operators,"3 and the Commis-clarifications, additions, and exceptions in paragraphs a sion's "Pobey Statement on Engineering Expertise on through k below. For radiation protection supervisory Shift" (50 FR 43621). The regulatory position related personnel, Section 4.4A of the standard contains an to the radiation protection manager is revised from what approach acceptable for the position of radiation protec-was included in Revision 1 of Regulatory Guide 1.8 (1975) tion manager (RPM) subject to the following:
The industry has adopted the requisite qualifications in ANSI /ANS 3.1-1981, and the current change endorses
- a. In heu of the desenption in Section 5.1 of ANSI /
that mdustry position.
A NS-3.1-1981, cold heense examinations should be defined as those that are administered before the urut has com-On March 20, 1985, the Commission issued a "Pobey pleted preoperational testing and imtial operations as Statement on Tr, rung and Qualification of Nuclear described in its Final Safety Analysis Report as amended Power plant Personnel" (50 FR 11147) that recog-and approved by the Commission. Hot examinations are nizes industry commitment to accredit training pro-those admintstered after this condition is attained.
grams. In the pobey statement, the NRC endorsed the trainmg accreditation program managed by the institute
- b. Hot hcense apphcants must meet the trainmg of Nuclear Power Operations (INPO) because it encom-elements in Sections 4.3.1.1.c, 4.3.1.2.c, and 4.5.1.2.c of passes the elements of performance based training and the standard and the experience elements in Sections will provide the basis to ensure that personnel have 4.3.1.1.b, 4.3.1.2.b, and 4.5.1.2.b of the standard. Cold quahfications ccmmensurate with the performance re-license applicants are subject to the training elements quirements of their jobs. The Commission has decided identified above, but they are exempt from the expe-to withhold action on promulgating new training and rience elements.
quahfaations regulations dunng an evaluation period.
Dunng that period, NRC will continue to evaluate the
- c. Paragraph 2 of Section 4.3.1.1.a o1 ANSI /ANS-3.1-
. results of the accreditation program to determine if the 1981 is not applicable. An individual who meets the voluntary industry efforts ensure qualifications that meet Cornmission's " Policy Statement on Engmeenng Expertise or exceed the minimum standards included in this guide.
on. shift" is required on all shifts to provide engineering expertise (see Regulatory Position C.I.j).
The Commission's " Policy Statement on Engineenng Expertise o. thift" issued on October 28,1985 (50 FR
- d. The minimum educational requirement for s_hifi 43621) ps
- s. two options for meeting nuclear power supervisors, Section 4.3.1.1.a, and for senior operators, plant staffmg requirements (paragraph 50.54(m)(2)(i) of Section 4.3.1.2.a, as a high school diploma or equivalent.
2Copies may be obtained from the American Nuclear Society,
- c. An apphcant for a senior operator (SO) bcense
&sb North Kensangton Avenue, LaGrange Park,It. 6052s.
should have 4 years of responsible power plant exper-3 Post orface Boa 37082, Washington DC 20ul34082.Co ies may be obtained from the Government Printing Office, icnce. Responsible pc wer plant experience for at 50 a defined as having actiwly performed as a cesignated 1.8 2
i control room operator (fossti or nuclear) or as a power STA his not actively performed, the STA should recene plant staff engineer involved in the day-to-day activities trair<mg sufficient to ensure that the STA is copurant of of the facihty during or after the final year of construc-facihty and I rocedure changes that occurred danns the tion. A maxirnum of 2 years of, responsible power plant a bse nce.
expenence may be fulfilled by acadernic or related tech-nical trainmg on a one for one time basis Two years should Combinmg the functions of a scruor operator and the be nuclect power plant expenence. At least 6 months of STA is acceptable if the provisions of the Commission's the nuclear power plant expenence should be at the "Po ey Statement on Ensineenng Expert se on Shif t" plant for Much an aptbcant seeks a beense. In addition, are met. In addition to the requdernents specified in appbcants for an 50 position not holding a bachelor's Section 4.4.5.c of ANSI / ANS 3.1-1981, the STA should depee m engineennt or equivalent should have held an have specific training in the response to and analysb of operator's beense and should have been actively involved plant transients and accidents and training m the rela-in the performance of bcensed duties for at least 1 year.
tionship of accident conditions to offsite consequences and protective action strateraes
- f. In addition to the requirements stated in Section 5.2.1.2.1 of ANS!/ANS-3.1-1981, classroom instruchon
- k. The radtation protection manager should have the for all bcense apphcants should anchade trattung in the quabfications described in Section 4.4.4 of ANSI /ANS-use of instaued plant systems for the control and mitiga-3.11981 with the clarification that 3 of the 4 years of tion of an accident m which the core is severely damaged.
expenence m apphed radiation protection should be professionallevel expenence.
- g. In addition to the requirements in Section 5.2.1.3.1 of ANSl/ANS 3.1 1951, each appbcant for an operator or
- 2. Positions in ANSI /ANS N18.1-1971 that Are Endorsed senior operator heense should serve 3 months as an extra by this Regulatory Guide person on shif t m trainmg for that posit. ion. These 3 months as an extra person on shift in training should For positions hsted in the standard other than those include all phases of day-to-day operations under the under Regul: tory Position 1 above, the requirements con-supervision of bcensed personnel.
tamed m ANSI N18.11971, " Selection and Traming of Nuclear Power Plant Personnel " provide an approach
- h. Control room operatmg expenence for hot bcense acceptable to the NRC staff for complytng with the quah-appbcanta, desenbed in Sect 2on 5.2.1.3.1 of ANSI /ANS-fications and traming requirements of 10 CFR Parts 50 3.1-1951, should include marupulation of controls of the and 55.
facihty dunng a minircum of five reactaity changes. Every effort should be made to hlne a diversity of reactivity D. IMPLEMENTATION changes for each appheant. Startups, shutdowns,large load changes, and changes m rod programmmg are some exam-The purpose of tlus section is to pronde information ples and could be accomphshed by manually using such to apphcants and bcensees regardmg the NRC staffi systems as rod control, chemical sham control, or rectreu-plans for using this regulatory guide.
lation flow.
Apphcants and hcensees may propose means other
- i. All cold beense appbcants should participate in than those specified in Section C of this guide for meet-practical work assignments as described in Section 5.2.1.4 mg appbcable regulations of ANSl/ ANS 31 1961 for a mmimum of 6 months.
- j. In addition to the responsibihties described in Sec-Except in those cases m wiuch the appbcant or bcensee tion 4.4.6 of ANS!/ANS-31 1981, the STA should assume proposes an acceptable alternative means of complying an active role in shif t activities. For example, the STA with the Commission regulations specified in S*ction A, should revie w plant logs, participate in shift turnover, the guidance provided in Section C has been appreed and mamtam awareness of plant configuration and status.
for use by the staff after March 31, 1988, in the evalua.
The edu ational requirements for the STA specified in tion of the quahfications and training requirements for Section 4.4.S.a of ANSI / ANS-3.1-1981 are not apph-(1) nuclear power plant personnel as desenbed in appu-ca ble. An independent STA should have a bachelor's cations for an operating hcense. (2) appbcants for opera-degree or equivalent in a scientific or engineenng disciphne.
tor and senior operator beenses, and (3) replacement personnel in those positions in operatmg nuclear power
" Actively performmg ST A functions" means perform-plants whose training programs have not yet been accred.
ing at least thre,. 's per quarter as the STA if an ited by an accreditation program endorsed by the NRC.
- 0.s. c. F.c.19et 101-662 60057 1.8 3
o e
VALUE/ IMPACT ANALYSIS A separatt valuchtnpact analysa has not been prepared that time. Tius analysis is also appropriate to Revision 2 fos this seculatory runde. A valuchmpact analysis was of Regulatory Guide 1.h. A copy of the regulatory anal-included in the regulatory analysis for the arnendments to ysis is available for inspection and conytng fot a fee at 10 Cl R Part 55 published on March 25,198 7, a copy the NRC Pubhc Document Room,1717 il Stseet NW.,
of wiuch was placed in the Pubhc Document Room at Wastunyton, DC l-l UNITED STATES NUCLEAR REGULATORY COMMISSION mer mis was WASHINGTON, D,C. 20555
'0" "(' *j'c' ' *
wasaoc PttMerhe 047 OFFICIAL BU$iNESS -
PENALTY FOR PRIVATE USE,4300 1.84
ENCLOSURE H ACRS Letter to Chairman Carr dated March 12, 1991 on Proposed Rule on Selection, Training, and Qualification of Nuclear Power Plant Personnel
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UNITED STATES 7g
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[i ADVISORY COMMITTEE ON REACTOR SAFEGUARDS NUCLEAR REGULATORY COMMISSIOtw
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WASWNGTON D. C. 20555
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March 12, 1991 The Honorable Kenneth M. Carr Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Chairman Carr:
SUB.7ECT:
PROPOSED RULE ON SELECTION, TRAINING, AND QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL During the 371st meeting of the Advisory Committee on Reactor Safeguards, March 7-9, 1991, we discussed the Proposed Rule on Selection, Training, and Qualification of Nuclear Power Plant Personnel.
This matter was also discussed during a meeting of our Human Factors Subcommittee on March 6,1991.
During these meetirigs we had the benefit of presentations by and discussions with members of the NRC staff.
We also had the benefit of the documents referenced.
Section 306 of the Nuclear Waste Policy Act of 1982 states that, "The Nuclear Regulatory Commission is authorized and directed to promulgate regulations, or other appropriate Commission regulatory guidance, for the training and-qualifications of civilian nuclear power pinnt operators, supervisors, technicians and other ap-propriate operating-personnel."
The Commission considered rulemaking, but in 1984 decided, as an alternative, to permit-NUMARC and INPO to develop industrywide improvements to personnel training.
INPO developed a comprehensive program to accredit training programs for_ plant personnel established by each plant-licensee.
In 1985 the Commission issued a~ Policy Statement on Training and Qualification of Nuclear ~ Power Plant Personnel that endersed the INPO-managed training accreditation program, with a proviso -that it would be evaluated for eff e::tiveness over an initial two-year period.
After this evaluation, the Commission concluded the INPO-managed program was functioning effectively, and in 1988-issued an amended policy statement endorcing continuation industry program with some minor changes.
However, the of the Commission's decision to forego rulemaking and substitute a policy statement endorsing an industry program was challenged.
In 1990 the U.S. Court of Appeals for the District of Columois Circuit ordered the Commission-to promulgate specific regulatory I? quire-ments for training and qualification of nuclear power plant personnel.
-7 A
s-The Honorable Kenneth M.
Carr 2
March 12, 1991 The staff has developed a proposed r :lemaking package that includes a statement of considerations and proposed additions to 10 CFR Parts 50 and 52.
This proposal expands the scope of the rule beyond what is now covered by the polic managed training accreditation program. y statement and the INPO-It includes:
Quality Assurance personnel.
e Training in accident management.
A requirement that a licensee develop and use a formal procedure for selection of personnel to be trained.
The package, which will eventually include a Regulatory Analysis and a revision to Regulatory Guide 1.8, " Qualification and Training of Personnel for Nuclear Power Plants," neither of which we have seen, is expected to be issued for public comment during April 1991.
Although the rulemaking package is incomplete and may not reflect the final staff position, we offer the following comments:
(1)
We do not agree with the staff's proposal to require licensees to develop formal procedures for the selection of personnel to be trained.
Although selection is clearly important, believe that this function is best lef t to the industry.
we This option is not permitted by the Court in the areas of training and qualification.
(2)
Training and qualification requirements for fire brigade and security personnel at nuclear power plants are given in Appendix R of 10 CFR Part 50 and in 10 CFR Part 73, respec-tively.
Neither rule includes requirements for selection of personnel.
This is consistent with our recommendation for selection of other plant personnel.
(3)
We agree with the staff's proposal to include requirements in the rule for training and qualification of personnel who will be performing quality assurance functions and personnel who will be responsible for accident assessment and mitigation.
With consideration of these comments, we have no objection to issuLnce of the rulemaking package for public comment.
We would like an opportunity to review the package, including any revision to Regulatory Guide 1.8, after the comment period.
Sincerely, David A.
Ward Chairman
.d The Honorable Kenneth M.
Carr 3
March 12, 1991 References' 1.
Draft SECY paper for The Commissioners from James M. Taylor, Bxecutive Director for Operations,
Subject:
Proposed Rulemak-ing for Selection, Training and Qualification of Nuclear Power Plant Personnel (Predecisional).
2.
Section 306 of Public Law 97-425, Nuclear Waste Policy Act of 1982, " Nuclear Regulatory Commission Training Authorization."
3.
Commission Policy Statement on Training and Qualification of
- <uclear Power Plant Personnel, published in the Federa,1 Recister, March 20, 1985.
4.
Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, as amended, November 18, 1988.
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