ML20204C530
| ML20204C530 | |
| Person / Time | |
|---|---|
| Issue date: | 03/31/1999 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| TASK-*****, TASK-RE REGGD-01.008, REGGD-1.008, NUDOCS 9903230135 | |
| Download: ML20204C530 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION March 1999 i
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OFFICE OF NUCLEAR REGULATORY RESEARCH Division 1 5
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Draft DG-1084 DRAFT REGULATORY GUIDE v
Contact:
- 1. Schoenfeld (301)415-6778 DRAFT REGULATORY GUIDE DG-1084 (SeCond Proposed Revision 3 of Regulatory Guide 1.8)
(Previous Draft was DG-1012)
QUALIFICATION AND TRAINING OF PERSONNEL
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FOR NUCLEAR POWER PLANTS
%g4 A. INTRODUCTION h
in 10 CFR Part 50, " Domestic Licensing of Production andhtill tion Facilities," Section 50.120, " Training and Qualification of Nuclear Power Plati$Per$$ondi," requires that each nuclear power plant licensee or applicant for an operating license MhiemeIlt training and qualification programs that are derived from a systems approach idraining7 Paragraph 50.34(b)(6)(i) requires that an application for a license to operate a nuclear p'$wd?hIant include information concerning organizational structure, personnel qualificationshinId reiMed matters. Subpart D, " Applications," of Q] information concerning an individual's edpcidorNrkt experience and other r
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10 CFR Part 55, " Operators' Licenses," requNes that'$perator license applications include regulatory guide endorses ANSI /ANS-3f1-1993$" Selection, Qualification, and Training of Personnel for Nuclear Power Plants,"' with cert $1n cladfications, additions, and exceptions. Personnel cf test, training, research, and mobile reactorsMe,n8t covered by this regulatory guide.
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Regulatory guides are is$ed to describe and make aveilable to the public such information as f
methods acceptable to the NRC $tSfffor implementing specific parts of the NRC's regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and guidance to applicants. Regulaihry guides are not substitutes for regulations, and compliance with regulatory guides is not requifedgRegulatory guides are issued in draft form for public comment to involve the public in the early st' ages of developing the regulatory positions. Draft regulatory guides have not received co@Idiet'slstaff' review and do not represent official NRC staff positions.
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ies may be obtained from the American Nuclear Society,555 North Kensington Ave., La Grange Park, IL 9
60525, telephone (708)352-6611.
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N a (,o lt has not received coniplete staf. Jpproval and does not represent 80 official NRC staff position.This regulatory g
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-t Public comments are being solicited on the draf t guide (including any implementation schedule) and its associated regulatory analysis or valuehmpact statement. Comments should as accompanied by appropriate supporting data. Written comments may be submitted to the Rules and Directives Branch, office of Administration, u.S. Nuclear Regulatory Commissiun, Washington, DC 20555. Copies of comments received s
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may be examined at the NRC Public Document Room,2120 L Street NW., Washington, DC. Comments will be most helpful if received by
(,) May 20,1999.
Requests for single copies of draf t or active regulatory guides (which may be repro uced) or for placement on an automatic distribution list for single copies of future draft guides in specific divisions should be made in writing to the u.S. Nuclear Regulatory Commission, Washington, DC 20555. Attention:
Reproduction end Distribution Services Section, or by f ax to (301)415-2289, or by email to < DISTRIBUTION @NRC. gov >.
9903230135 990331 FDR REGOD 01.008 R PDR
The information collections contained in this regulatory guide are covered by the j
requirements of 10 CFR Parts 50 and 55, which were approved by the Office of Management and Budget, approval numbers 3150-0011 and 3150-0018. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information uniess it displays a currently valid OMB control number.
B. DISCUSSION This regulatory guide endorses ANSl/ANS-3.1-1993, " Selection, Qualification, and Training of Personnel for Nuclear Power Plants," with certain additions and exceptions that are listed in the Regulatory Position of this guide. Some of the exceptions are endorsements of certain sections of two other standards, ANSI N18.7-1976 (ANS-3.2), " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants,"' and ANSI /ASME NOA-1-1983, " Quality Assurance Program Requirements for Nuclear Power Plants."'
The first proposed Revision 3 of Regulatory Guide 1.8, Draft Regulatory Guide DG-1012, was published for public comment in September 1996. This Draft Regulatory Guide DG-1084 reflects modifications made to DG-1012 following the pubiic comment period.
Some regulatory positions have remained unchanged from DG-1012, socne have been modified, and some were developed following the publication of DG-1012 for public comment. The complete history of the development of this guide is in an appendix to this draft guide.
Certain regulatory positions in this Draft Regulatory Guide DG-1084 reflect th previous endorsement of ANSl/ANS-3.1-1981 by Revision 2 of Regulatory Guide 1.8 (April 1987). In addition, certain regulatory positions regarding quality control, quality assurance, and independent review are consistent with Regulatory Position = in Revision 3 of Regulatory Guide 1.28, " Quality Assurance Program Requirements (Design and Construction)" (August 1985), and Revision 2 of Regulatory Guide 1.33, "Outfity Assurance Program Requirements (Operation)" (February 1978).
C. REGULATORY POSITION ANSI /ANS-3.1-1993, " Selection, Qualification, and Training of Personnel for Nuclear Power Plants,"' provides criteria for the selection, qualification, and training of personnel for nuc! ear power plants. These criteria, with the following additions, exceptions, and clarifications, are acceptable to the NRC staff for comolying with the qualifications and training requirements of 10 CFR Parts 50 and 55 and with the guidance regarding the STA function provided in the Commission's " Policy Statement on Engineering Expertise on Shif t. " *
' Copies are available from Global Engineering Documents,7730 Caronde!et kan m Luite 407, Clayton, MO 63105, telephone (800)854-7179.
' Copies are available for inspection or copying for a fee frem the NRC Public Document Room at 2120 L Street NW., Washington, DC: the POR's mailing address is Mail Stop LL-6, Washington, DC 20555; telephone (202)S34 3273; fax t202)634 3343.
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SECTION 2, DErudlTIONS t
1.1 The definition of "related experience" should be replaced by " Experience in performing job duties in the discipline for which the individual seeks qualification and wh ch may or may not be at a nuclear power plant."
e 1.2 Add a dcfinition for " designated nuclear control room operator": "Those individuals assigned to licensed control room operator positions ideritified in either Technical Specification Table 6.2.1 or the table " Minimum Requirements Per Shift for On Site Staffing of Nuclear Power Units by Operators and Senior Operators Licensed Under 10 CFR Part 55" in 10 CFR 50.54(m)(2)(i)."
1.3 Add a definition for " responsible nuclear power plant experience": " Responsible nuclear power plant experience for a Senior Operator (SO) is having actively performed as a designated nuclear control room operator or as a power plant staff engineer involved in the day-to-day activities of the facility."
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QUAllFICATION CRITERIA The qualification criteria described in Section 4 of ANSI /ANS-3.1-1993 are acceptable to the N3C staff with the following exceptions.
2.1 Sections 4.1.1.1 Alternatives to
Dearse Reouirements:
4.1.1.2. Experience p
Substitution for Education: 4.1.2.1. Alternatives to Exoerience U
The equivalents in these sections do not apply to individuals assigned to positions in Quality Assurance (Section 4.3.7), Quality Control (Section 4.5.5), and Quality Assurance (Section 4.5.6). The following equivalents for education anc8 experience apply.
2.1.1 Section 4.3.7. Quality Assurance Individuals who do not possess the formal educational and experience requirements specified in this section for this position will not be eliminated automatically when other
'We provide s"fficient dembastration of their abilities. These other factors are to be a sted on a W by-case basis and approved and documented by the plant manager.
- ,,osever, the individual assigned to this position is to meet the Special Requirements in Section 4.3.7.
2.1.2 Section 4.5.5 Quality Con _trgi This regulatory guide endorses ANSI /ASME NOA-1-1983, " Quality Assurance Program Requirements for Nuclear Power Plants," for the equivalents for education and experience for individuals assigned to this position (see Regulatory Position 2.12 of this guide.
2.1 M Section 4.5.6. Quality Assurance A
/E Individuals who do not possess the formal education and experience specified in this section 'or this position will not be eliminated automatically when other factors provide 3
sufficient demonstration of their abilities. These other factors are to be evaluated on a case-by-case basis and approved and documented by the plant manager.
l 2.2 Section 4.1.2.4, Related Experience l
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l The educational alternative to experience should apply only to those position qualifications in Sections 4.2 through 4.6 that specifically include a related experience clause.
2.3 Section 4.1.4. Trainina For positions not identified in this section, the training development process identified in Section 6.2.2 is acceptable to the NRC staff except for quality control personnel (as defined in Section 4.5.5) and quality assurance personnel (as defined in Section 4.5.6). For ihc training for quality control and quality assurance personnel, this regulatory guide endorses ANSI /ASME NOA-1-1983 (see Sections 2.12 and 2.13 below).
2.4 Section 4.1.4, Trainin.g The managers of all training programs listed in Section 4.1.4 should have education, experience, or training in educational methods and should have knowledge consistent with the technical content and requirements of the initial and continuing training programs for which they are responsible.
2.5 Section 4.2.2 Ooerations Manaaer Under " Spacial Requirements, Subsection (1)(d) "Have plant operational knowledge consistent with the requirements of the Operations Manager's job," is not an acceptable alternative.
2.6 Section 4.3, Middle Manaaer Level The NRC staff considers the following statement unacceptable: "An individual may be accepted for a specific position even if the person does not meet the requirements for that position if the individualis provided a staff of individual (s) whose qualifications meet the selected middle manager qualification." Individuals in middle manager positions described in Section 4.3 should meet the qualification requirements described for their positions.
2.7 Section 4J.1. Trainina e
The required Baccalaureate education should include courses in education and technical subjects. If educational techniques are not covered in the Baccalaureate course material, training should be provided in educational techniques.
2.8 Section 4.3.3, Radiation Protection For the Radiation Protection Manager, the three years of nuclear power plant experience should be at a level requiring policy planning and decision making related to the programmatic aspects of the radiation protection program as a whole.
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2.9 Section 4.4.1, Operations Shift Supervisor, and Section 4.4.2. Senior Operator
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An applicant for a senior operator (SO) license should have three years of responsible nuclear power plant experience. A maximum of one year of responsible nuclear power plant experience may be fulfilled by academic or related technical training on a one-for-one basis.
At least six months of the responsible nuclear power plant experience should be at the plant for which an applicant seeks a license and should not include any of the time spent in the control room as an extra person on shift. In addition, applicants for an SO position who do not hold 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 one year.
2.10 Section 4.4.6. Radiation Protection The two years of nuclear power plant experience should include varied activities in the radiological protection area.
2.11 Section 4.5.1 ReaAtor Operator An applicant for a reactor operator (RO) license should have three years of power plant experience. At least one year of this experience should have been at the plant for which an applicant seeks a license and should not include any of the time spent in the control room as an extra person on shift. Six months of the time on-site should have been spent performing plant operational duties as a nonlicensed operator.
O 2.12 Section 4.5.5. Quality Control The qualifications criteria in ANSI /ASME NOA-1-1989 are not acceptable to the NRC staff. The qualifications criteria in Supplement 2S-1, " Supplementary Requirements for the Qualification of Inspection and Test Personnel," to ANSI /ASME NOA-1-1983 are endorsed by this regulatory guide. The provisions of Appendix 2A 1, "Nonmandatory Guidance on the Qualification of Inspection and Test Personnel," to ANSI /ASME NOA-1-1983 should be met as part of Supplement 2S-1, 2
2.13 Section 4.5.6. Quality Assurance The qualifications criteria in ANSI /ASME NOA-1-1989 are not acceptable to the NRC staff. Instead, Supplement 2S 3, " Supplementary Requirements for the Qualification of Quality Assurance Program Audit Personnel," to ANSI /ASME NOA-1-1983 is endorsed by this regulatory guide for "Special Requirements" for individuals assigned to this position.
2.14 Section 4.6.2 Shift Technical Advisor (STA)
In addition to the qualifications described in the standard, the STA should assume an active role in shift activities and should reflect the guidance provided in the " Policy Statement on Engineering Expertise on Shift" (see 50 FR 43621, October 28,1985).8
" Assume an active role in shift activities" means performing at least three shifts per quarter O/
as the STA. If an STA has not assumed an active role in shift activities, the STA should 5
receive training sufficient to ensure that the STA is cognizant of changes to the facility and procedures that occurred during the absence.
2.15 Section 4.7.1. Suoervisor or Chairman of Standina Committee Responsible for Independent Review.
The minimum experience for this position, " Combined managerial and technical support -- 6 yrs." is that the individual should have the necessary overall nuclear background in the plant at..s identified in Section 4.3 of ANSI N18.7-1976 (ANS3.2), " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," and in all phases of the plant as discussed in Section 4.3.4 of ANSI N18.7-1976(ANS3.2), to determine when to call consultants and contractors for dealing with complex problems beyond the expertise of the owner organization.
2.16 Section 4.7.2. Independent Review Oraanization Members Members of the independent Review Organization should have a minimum of five years of experience in their own area of responsibility, i.e., in one of the twelve areas listed in Section 4.7.
D. IMPLEMENTATION The purpose of this section is to provide information to applicants and licensees regarding the NRC staff's plans for using this regulatory guide. No backfitting is intended or approved in connection with the issuance of this guide.
This draft guide has been released to encourage public participation in its development. Except in those cases in which an applicant or licensee pro.coses an acceptable alternative method for complying with specified portions of the NRC's regulations, the methods to be described in the final guide reflecting public comments will be used in the evaluation of submittals in connection with applications for construction permits, standard design certifications and design approvals, and combined operating licenses.
The final guide will also be used to evaluate submittals voluntarily initiated by operating tr' actor licensees who propose modifications that go beyond the current licensing basis if there is a clear connection between the proposed modifications and this guidance.
l This regulatory guide will be used by the NRC staff in conjunction with the Standard Review Plan for reactors, NUREG-0800.
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1 APPENDIX
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HISTORY OF REGULATORY GUIDE 1.8,
" Qualification and Training of Personnel for Nuclear Power Plants" The following is a chronology of industry and NRC actions regarding the qualification and training of personnel for nuclear power plants:
Subcommittee ANS-3, Reactor Operations, American Nuclear Society Standards e
Committee, developed a standard containing criteria for the qualifications and training of nuclear power plant personnel. This standard was approved by the American National Standards institute (ANSI) Committee N18, Design Criteria for Nuclear Power Plants, and designated ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."'
Regulatory Guide 1.8, " Personnel Selection and Training," endorsing ANSI N18.1-e 1971, was issued in March 1971, and Revision 1 was issued in September 1975.'
o A revision of ANSI N18.1-1971 was approved by the ANSI Board of Standards Review and issued as ANSI /ANS-3.1-1978, " Selection and Training of Nuclear Power Plant Personnel."'
During 1981, ANSI /ANS 3J-1978 was updated to factor in lessons learned from the TMI-2 accident and changii.g regulatory requirements; it was reissued as ANSI /ANS-O 3.1-1981, " Selection, Oualification and Training of Personnel for Nuclear Power O
Plants."'
Revision 2 of Regulatory Guide 1.8, " Qualification and Training of Personnel for e
Nuclear Power Plants," issued in April 1987, endorsed Sections 4.3.1.1, " Shift Supervisor," 4.3.1.2, " Senior Operator," 4.5.1.2, " Licensed Operators," 4.4.8, "Shif t Technical Advisor," and 4.4.4, " Radiation Protection," of ANSI /ANS-3.1-1981.
Endorsement for all othu positions remained with ANSI N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel."
e A revision of ANSI /ANS-3.1-1981 was issued on May 19,1987, and designated ANSl/ANS-3.1-1987, " Selection, Qualification and Training of Personnel for Nuclear Power Plants." The 1987 standard contained major revisions in content and format from the 1981 standard. These revisions resulted from actions taken by the NRC and industry since the 1981 standard in selection and training practices, including the fcilowing.
A " Policy Statement on Engineering Expertise on Shift,"2 issued on October 28, 1985 (50 FR 43621), provided two options for meeting the requirements in 10 CFR 9
'ANs standards may be obtained from the American Nuclear society. 555 North Kensington Avenue, La Grange Park. IL 60525; telephone (708)352-6611.
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' Copies are available for inspection or copying for a fee from the NRC Public oocument Room at 2120 L Street NW..
g Washington. DC; the PoR's mailing address is Mail stop LL-6, Washington, DC 20555; telephone (202)634-3273; fax b
(202)R34-3343.
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50.54(m)(2)(i) for nuclear power plant staffing and the requirernent to have a shift technical advisor (STA) available to the shift (see Section I.A.1.1 of NUREG-0737,
" Clarification of TMI Action Plan Requirements,"' November 1980). One option in the Policy Statement, which is preferred by the NRC staff, allows combining the functions of the STA with one of the required senior operators as long as specific training and education requirements are met. The other option allows for continuation of an approveu independent STA program. K99ulatory Position 2.11 of this guide reflects the guidance provided in this Policy Statement.
On March 20,1985, the NRC issued a " Commission Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel"* (50 FR 11147). The policy statement provided guidance on qualification programs and on a systems approach to training at commercial nuclear power plants. The policy statement also " endorses the INPO-managed Training Accreditation Program in that it encompasses the elements of performance-based training and will provide the basis to ensure that perscnnel have qualifications commensurate with the performance requirements of their jobs."
Based on an April 17,1990, decision of the U.S. Court of Appeals for the District of Columbia Circuit, the NRC developed a rule addressing requirements for the training and qualification of nuclear power plant personnel (10 CFR 50.120). Each licensee or applicant for a license must ensure that personnellisted in 10 CFR 50.120(b),
regardless of whether they are employees or contractor personnel, have qualifications commensurate with the performance requirements of the jobs to which they are assigned. The rule requires that each licensee or applicant provide training to personnel using a systems approach to training (SAT). This rule superseded the above mentioned Policy Statement on training and qualifications.
On April 23,1993, ANSl/ANS-3.1-1993 was issued. This standard reflects more recent actions of the NRC and industry since 1987, including the requirement to use the systematic approach to training (SAT) process to establish and maintain training programs for certain positions. In addition, this standard does not allow credit for simulator and classroom training to substitute for an operator's nuclear power plant experience; a compensating change has been made to the experience requirements.
Draft Regulatory Guide DG-1012, the proposed Revision 3 to Regulatory Guide 1.8, was published for public comment in September 1996. This Draft Regulatory Guide DG-1084 reflects modifications made to DG-1012 following the public comment period. Some regulatory positions have remained unchanged from DG-1012, some have been modified, and some were developed following the publication of DG-1012 for public comment.
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3Copies are availab'e for inspection or copying for a fee from the NRC Public Document Room at 212o L street NW..
Washington, DC: the PDR's mailing address is Mail stop LL6. Washington, DC 20555, telephone (2021634-3273: f ax (202)634-3343 8
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VALUEllMPACT ANALYSIS A separate value/ impact analysis has not been prepared for this regulatory guide. A value/ impact analysis was included in the regulatory analysis (Accession No. 8703120143) for the amendments to 10 CFR Part 55 published on March 25,1987: in the regulatory analysis for the amendments to 10 CFR 50.120 published on July 21,1993 (58 FR 39092);
and in the regulatory analysis in Revision 3 of Regulatory Guide 1.28, " Quality Assurance Program Requirements" (August 1995). These analyses are also appropriate for Revision 3 of Regulatory Guide 1.8. Copies of these regulatory analyses are available for inspection and copying for a fee at the NRC Public Document Room,2120 L Street, NW., Washington, DC. The Public Document Room's mailing address is Mail Stop LL-6, Washington, DC 20555; telephone (2021634-3273, fax (202)634-3343.
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