ML20206E889

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EDO Control of Rulemaking Package Re 10CFR55 & 50, Ol. Continuation of Rulemaking Approved
ML20206E889
Person / Time
Issue date: 08/20/1985
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8606240030
Download: ML20206E889 (26)


Text

T AUG 2 01985 MEMORANDUM FOR:

Harold R. Denton, Director Office of Nuclear Reactor Regulation

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i FROM:

William J. Dircks Executive Director for Operations

SUBJECT:

CONTROL OF NRC RULEMAKING By memorandum of February 13, 1984, " Control of NRC Rulemaking by Offices Reporting to the EDO," Offices were directed that effective April 1, 1984, (1) all offices under EDO purview must obtain my approval to begin and/or continue a specific rulemaking, (2) resources were not to be expended on rule-makings that have not been approved, and (3) RES would independently review rulemaking proposals forwarded for my approval and make recomendations to me concerning whether or not and how to proceed with the rulemakings.

In accordance with my directive, the followi.g proposal concerning rulemaking has been forwarded for my approval:

Proposed amendments to 10 CFR Parts 55 and 50 - Operator's Licenses (sponsored by NRR - memorandum, R. B. Minogue to EDO dated August 12,1985).

I approve continuation of this rulemaking. The NRC Regulatory Agenda (NUREG-0936) should be modified to reflect the status of this rulemaking.

(Signed) William L Dircks William J. Dircks Executive Director for Operations cc:

V. Stello Distribution:

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  1. SNNWO MEMORANDUM FOR:

William J. Dircks Executive Director for Operations FROM:

Robert B. Minogue, Director Office of Nuclear Regulatory Research

SUBJECT:

CONTROL 0F NRC RULEMAKING: RES INDEPENDENT REVIEW 0F ONG0ING RULEMAKING Based on our independent review of proposed amendments to 10 CFR Parts 55 and 50--Operators' Licenses, RES recommends that this rulemaking effort should continue. The basis for the RES recommendation is summarized below.

Section 306 of the Nuclear Waste Policy Act assigned the NRC responsibility for developing regulations and/or guidance on nuclear power plant personnel training, qualifications and licensing. The proposed rulemaking to revise 10 CFR 55, Operators' Licenses, is intended to respond to the licensing part of this responsibility. A Commission policy statement responding to nuclear power plant personnel training and qualification was published effective on March 20, 1985. The proposed rule would codify current activities which have strengthened the operator licensing process since TMI-2.

In addition, the proposed rule would take advantage of and facilitate industry efforts toward self improvement (e.g., INPO accreditation). Furthermore, the proposed rule would bring needed emphasis on the validation of simulators and their use in operator training and examinations. Finally, the proposed rule would provide a structural cleanup of existing regulations, for exam)le, the operator requalification requirements would be integrated wit1 the text of the rule as opposed to an appendix as currently set forth.

In terms of the regulatory analysis, it is our judgment that the value of this )roposed rulemaking should generally outweigh the impacts. However, it should )e noted that the proposed requirements related to a simulation facility and associated commission approvals requires careful analyses to better determine actual value and impacts.

There are some limitations and concerns which we have identified related to the proposed rulemaking:

1)

The effectiveness of this proposed rulemaking is dependent upon a successful industry training accreditation program and NRC access to the documentation. This may prove to be a problem given the industry's concern regarding the potential use of accreditation documents in licensing and enforcement actions by the NRC.

m t-e William J. Dircks 2

1 2)

Validation of simulation facilities is an enterprise that we support fully. However, we are concerned that certain opportunities will be missed if NRC limits its concern with simulator validation to that of operator licensing alone. We propose that the data resulting from simulator validation programs (utilizing detailed thennal hydraulic research results) would be useful in identifying " interactions" between plant systems (e.g., safety and control systems) that could lead to improvements in system safety.

3)

The requirements for the use of simulation facilities should emphasize its potential for operator training, which we view as the more crucial application of simulators. The operator licensing examination is intended, after all, to verify that operators are properly trained and qualified. Therefore, some provision needs to be made for NRC recognition of the importance of simulators to operator training.

The rulemaking package is currently undergoing resolution of public coments for the proposed rule.

The Director, NRR, has recommended continuation of rulemaking to assess public coments in a memorandum to the ED0 dated March 28, 1965. The complete RES independent review package has been sent to OED0 (Attention: DEDROGR)andtotheDirector,NRR.

t 6. I Robert B. Minogue, Director Office of Nuclear Regulatory Research

Enclosures:

1. Sponsoring Office Rulemaking Package
2. Other Supporting Documents Used in the Independent Review
3. RES Task Leader Recommendations
4. Three-Part RES Staff feview

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William J. Dircks Executive Director for Operations FROM:

Robert B. Minogue, Director Office of Nuclear Regulatory Research

SUBJECT:

CONTROL OF NRC RULEMAKING:

RES INDEPENDENT REVIEW 0F ONG0ING RULEMAKING Based on our independent review of proposed amendments to 10 CFR Parts 55 and 50--Operators' Licenses, RES recommends that this rulemaking effort should continue. The basis for the RES recomendation is sumarized below.

Section 306 of the Nuclear Waste Policy Act assigi ed the NRC responsibility for developing regulations and/or guidance on nuclear power plant personnel training, qualifications and licensing. The proposed rulemaking to revise 10 CFR 55, Operators' Licenses, is intended to respond to the licensing part of this responsibility. A Comission policy statement responding to nuclear power plant personnel training and qualification was published effective on March 20, 1985. The proposed rule would codify current activities which have strengthened the operator licensing process since TMI-2.

In addition, the proposed rule would take advantage of and facilitate industry efforts toward self improvement (e.g., INP0 accreditation).

Furthermore, the proposed rule would bring needed emphasis on the validation of simulators and their use in operator training and examinations. Finally, the proposed rule would provide a structural cleanup of existing regulations, for example, the operator requalification requirements would be integrated with the text of the rule as opposed to an appendix as currently set forth.

In terms of the regulatory analysis, it is our judgment that the value of this proposed rulemaking should generally outweigh tha impacts. However, it should be noted that the proposed requirements related to a simulation facility and associated comission approvals requires careful analyses to better determine actual value and impacts.

There are some limitations and concerns which we have identified related to the propose.1 rulemrking:

1)

The ettectiveness of this proposed rulemaking is dependent upon a successful industry training accreditation program and NRC access to the documentation. This may prove to be a problem given the industry's concern regarding the potential use of accreditation documents in licensing and enforcement actions by the NRC.

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L. lid: tion of sir.ulttien ficilities is an enterprise that w: support fully. However, we are ccncerned that certain opportunities will be missed if NRC limits its concern with simulator validation to that of operator licensing alone. We propose that the data resulting from simulator validation programs (utilizing detailed themal hydraulic

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research results) would be useful in identifying " interactions" between plant systems (e.g., safety and control systems) that could lead to improvements in system safety.

3)

The requirements for the use of simulation facilities should emphasize its potential for operator training, which we view as the more crucial application of simulators. The operator licensing examination is l

intended, after all, to verify that operators are properly trained and qualified. Therefore, some provision needs to be made for NRC recognition of the importance of simulators to operator training, j

The rulemaking package is currently undergoing resolution of public coments for the proposed rule. The Director, NRR, has recomended continuation of rulemaking to assess public coments in a memorandum to the EDO dated March 28, 1905. The complete RES independent review package has been sent to OEDO (Attention: DEDROGR)andtotheDirector,NRR.

s h by:

ROBERT B. Mrggg Robert B. Minogue, Director Office of Nuclear Regulatory Research

Enclosures:

1. Sponsoring Office Rulemaking Package
2. Other Supporting Documents Used in the Independent Review
3. RES Task Leader Recomendations i
4. Three-Part RES Staff Review DISTRIBUTION:

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We are at step III.C.2, RIRB deliberations " of the RES independent review procedures for the attached specific onDoing rulemaking sponsored by #Rt(

Please evaluate the. attached dra'ft independent review package and provide RAllRB with your voting sheet indicating your position on the rulemaking.

l Y 2 8 1985 Your response by c.o.b.

will assist in RES' makinD independent recomendations to the EDO in a timely manner.

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G. A. Arlotto, Member, RIRB

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TITLE OF LEMAKING:

Operators' Licenses - Parts 50 and 55 AGREE WITH DRAFT RES REQUEST RIRB V

INDEPENDENT RECOMMENDATIONS MEETING.

IN DRAFT INDEPENDENT REVIEW PACKAGE.

MODIFY DRAFT RES NOT PARTICIPATING.

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COMENTS AND SUGGESTIONS:

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F. P. GILLESPIE, CHAIRMAN, RIRB FROM:

K. R. Goller, Member, RIRB TITLE OF RULEMAKING:

Operators' Licenses - Parts 50 ar.d 55 y

AGREE WITH DRAFT RES REQUEST RIRB v

INDEPENDENT RECOMMENDATIONS MEETING.

IN DRAFT INDEPENDENT REVIEW PACKAGE.

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RES INDEPENDENT REVIEW BOARD VOTING SHEET TO:

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W. M. Morrison, Member, RIRB TITLE OF RULEMAKING:

Operators' Licenses - Parts 50 and 55 AGREE WITH DRAFT RES REQUEST RIRB INDEPENDENT RECOMMENDATIONS MEETING.

IN DRAFT INDEPENDENT REVIEW PACKAGE.

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MODIFY DRAFT RES NOT PARTICIPATING.

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Task leader Recomendations concerning NRR Submitted Proposed Rule - Proposed Amendment of 10 CFR Parts 55 and 50 - Operators' Licenses.

Based upon the RES independent review as sumarized below, it is recomended by this office that the subject ongoing rulemaking be continued through resolution of public coments on the proposed rulemaking.

It is further recomended that this rulemaking be reviewed again following the resolution of public comments to ascertain the need for certain parts of the rulemaking based upon consideration of public coments. This recomendation is based on a three part RES staff review (enclosed as attachment 4) which is sumarized below.

1.

Section 306 of the Nuclear Waste Policy Act assigned the NRC responsibility for developing regulations and/or guidance on nuclear power plant personnel training, qualifications and licensing. The proposed rulemaking to revise 10 CFR 55, Operators' Licenses is intended to respond in part to this responsibility, improve the safety in operations at nuclear power plants and to upgrade regulations to improve NRCs' regulatory basis in these areas. The comission policy statement on training and qualification of nuclear power plant personnel which covers all non-licensed positions was published effective on March 20, 1985. The proposed rule would upgrade NRC regulatory requirements for the operator licensing process. The regulatory analysis for the proposed rule was tnat which was prepared for the proposed Training and Qualifications Rule and Operator Licensing Examination Changes. This regulatory analysis does not separate out the value and impacts or alternatives for the subject proposed rule on Operator Licenses. Therefore, specific alternatives that might have been considered for the proposed rule cannot be addressed. There is a need for rulemaking in this area for the following reasons:

a) the need to respond to Section 306 of the Nuclear Waste Policy Act of 1982, Public Law 97-425, b) the need to upgrade the regulatory basis for the operator licensing process including the operator license examination, and c) to achieve real gains in the assurance of qualified operators obtaining licenses.

Promulgation of this rule will significantly upgrade the NRC's regulatory basis for <>dministering the operator licensing process by codifying accepted practice in conducting licensing activities that have been implemented since TMI-2, and l

clarify h g requirements for obtaining and applying for operators licenses.

2. The RES independent review also identified potential disadvantages associated with some of the operating test requirements contained in the rulemaking.

It is recommended that consideration be given to alternatives to specific rulemaking in the area of simulation facilities.

Reasons for this recommendation are sumarized below.

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2 Sections (b) (1), (2), and (3) of proposed 55.45, Operating Tests would require licensees to:

a) acquire and maintain a simulation facility (defined as either:

the plant, a plant referenced simulator, or other simulation device) for use in conducting simulator examinations, b) submit an application for NRC review and approval of their simulation facility, c) conduct comprehensive performance tests on the simulation facility (100% over a four year period - 25% per year), and d) submit reports on results of performance tests each year.

The justification for this requirement rests on the assumption that valid operating tests (non-walk through part) can be conducted only on simulation facilities which undergo recurrent and comprehensive performcnce tests to verify their fidelity to the reference plant (except in the case of the plant itself being the simulation facility).

It is the reviewer's judgment that this proposed requirement for a simulation facility will lead to the procurement by industry of plant referenced simulators alone for the following reasons. The plant is an unacceptable response to this proposed requirement because of the obvious danger in conducting operating tests on abnormal and emergency conditions in the plant.

In addition, even without these attendant difficulties, it would be too costly to tie up the plant with non-power generating activities (such as operating tests). The use of another simulation device (i.e., non-plant referenced simulators) would constitute another unlikely option.

Industry would not generally take the risk of trying new simulator technology because they would have no guarantee of its approval by the NRC.

This is especially noteworthy since the NRC staff cannot now specify what alternatives to a plant referenced simulator would meet this requirement. As one might expect this would lead industry to one of two options: procure a plant referenced simulator or apply to the NRC for an exemption to the requirement.

There are four problems with this justification:

a)

The relationship of simulator fidelity to examination validity is unknown. There is presently no data to support a requirement for a plant referenced simulator.

b)

Simulator fidelity is only one of numerous issues which may have an impact on examination validity.

c)

There are no fundamental differences between simulator requirements for licensing purposes and for training purposes.

d)

Personnel who conduct simulator fidelity evaluations have highly specialized skills and are expensive to obtain. They are in high demand and few in number.

NRC may not be able to attract qualified software engineers and industry may have trouble obtaining them in sufficient numbers. The need to use support contractors is likely and would increase costs.

3 Based on these considerations, it is recommended that the requirements contained in the proposed rule dealing with simulation facility evaluations, review and approval be carefully assessed. A possible alternative may be to incorporate the intent of this requirement within the policy statement on INP0 accreditation.

INP0 accreditation may provide a more appropriate vehicle for specifying simulation needs since simulators will be an integral part of a licensee's systems approach to training and are needed to obtain accreditation for their training programs. This would also have the added benefit of supporting the current industry trend towards procurement of plant referenced simulators (108 of 128 have or will have voluntarily obtained them).

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Results of Indepeitdent Review of NRR Submitted Proposed Rule - Proposed Amendment of 10 CFR Parts 55 and 50 - Operators' Licenses.

Based upon the RES independent review as detailed below, it is recomended by this office that the subject ongoing rulemaking be continued through resolution of public coments on the proposed rulemaking.

It is further recomended that this rulemaking be reviewed again following the resolution of public coments to ascertain the need for certain parts of the rulemaking.

The following criteria were considered.

Part I.

Quality Control Evaluation.

Staff compliance with NRC procedures and guidelines.

A final rulemaking package is under development pending outcome of the resolution of public coments. The proposed rule package complies with applicable NRC procedures and guidelines.

Part II. Review of Rulemaking.

1.

The issue to be addressed.

Section 306 of the Nuclear Waste Policy Act assigned the NRC responsibility for developing regulations and/or guidance on nuclear power plant personnel training, qualifications and licensing. The proposed rulemaking to revise 10 CFR 55, Operators' Licenses is intended to respond in part to this responsibility, improve the safety in operations at nuclear power plants and to upgrade regulations to improve NRC's regulatory basis in these areas. The comission policy statement on training and qualification of nuclear power plant personnel which covers all non-licensed positions was published effective on March 20, 1985.

2.

Necessity and Urgency.

The proposed rule will upgrade NRC regulatory requirements for operator licensing, training and qualifications. The public coment period for the proposed rulemaking has been completed and resolution of public comments is l

currently underway.

3.

Alternatives to rulemaking.

The regulatory analysis for the proposed rule was that which was prepared for the proposed Training and qualifications Rule and Operator Licensing Examination Changes. This regulatory analysis does not separate out the value and impact or alternatives for the subject proposed rule on Operator Licenses. Therefore, specific alternatives that might have been considered for the proposed rule cannot be addressed.

It is the opinier, of this reviewer, that rulemaking as defined in the proposed rule is appropriate as formulated with one exception. Sections (b) (1), (2), and (3) of proposed 55.45, Operating Tests would require licensees to:

2 a) acquire and maintain a simulation facility (defined as either:

the plant, a plant referenced simulator, or other simulation l

device) for use in conducting operating tests, b) submit an application for NRC review and approval of their simulation facility, c) conduct comprehensive performance tests on the simulation facility (100% over a four year period 25% per year), and d) submit reports on results of performance tests each year.

The justification for this requirement is that valid operating tests (the non-walk through part) can be conducted only on simulation facilities which undergo recurrent and comprehensive performance tests to verify their fidelity to the reference plant (except in the case of the plant itself being the simulation facility).

It is the reviewer's judgment that this proposed requirement for a simulation facility will lead to the procurement by industry of plant referenced simulators alone. The plant is an unacceptable response to this proposed requirement because of the obvious danger in conducting operating tests on abnormal and emergency conditions in the plant.

In addition, even without these attendant difficulties, it would be too costly to tie up the plant with non-power generating activities (such as operating tests). The use of another simulation device (i.e., non-plant referenced simulators) would constitute another unlikely cption.

Industry would not generally take the risk of developing new simulator technology because they would have no guarantee of its approval by the NRC. This is especially noteworthy since the NRC staff cannot now specify what alternatives to a plant referenced simulator would meet this requirement. As one might expect this would lead industry to one of two options: procure a plant referenced simulator or apply to the NRC for an exemption to the requirement.

There are four problems with this justification:

a)

The relationship of simulator fidelity to examination validity is unknown. There is presently no data to support a requirement for a plant referenced simulator.

l b)

Simulator fidelity is only one of numerous issues which may have an impact on examination validity. Others include:

1) examiner qualifications, 2) examiner familiarity with the reference plant, and 3) content, format and structure of the simulator examination.

Each issue can be expected to have an impact on examination validity.

a.

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3 c)

There are no fundamental differences between simulator requirements for licensing purposes and for training purposes. The need for a simulator, its operating characteristics and configuration are ideally specified as part of a systems approach to training program. This ensures that the designers of the simulator take the job performance requirements of operators into account during simulator development or improvement. This provides industry with assurance that they buy only what they.need to train and qualify operators, and ensures that simulator fidelity is not a cause of invalid simulator examinations.

d)

Personnel who conduct simulator fidelity evaluations have highly specialized skills and are expensive to obtain..They are in high demand and few in number. NRC may not be able to attract qualified software engineers and industry may have trouble obtaining them in sufficient numbers. The need to use support contractors is likely and would increase costs.

Based on these considerations, it is recommended that the requirements contained in the proposed rule dealing with simulation facility evaluations, review and approval be carefully a:,sessed.' An alternative may be to incorporate this requirement within the policy statement on INP0 accreditation.

INPO accreditation could provide a vehicle for specifying simulator needs since simulators will be an integral part of a licensee's systems approach to training and are needed to obtain accreditation for their training programs.

4.

How the issue will be addressed through rulemaking, Revisions to 10 CFR 55 and 50.74 (and associated regulatory guides 1.134, i

1.149, and 1.8) will address this issue.

5.

a)

How public will be affected?

The regulatory analysis for the proposed rule was that which was prepared for the proposed Training and Qualifications Rule and Operator Licensing Examination Changes. This regulatory analysis does not separate out the value and impacts or alternatives for the subject proposed rule on Operator Licenses. Therefore, specific alternatives that might have been considered for the proposed rule cannot be addressed.

It is the opinion of this reviewer, that this rulemaking will improve the public health and safety by the increased assurance of qualified nuclear power plant operators as reflected through improvements to the operator licensing process.

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1 b)

How industry will be affected?

The regulatory analysis for the proposed rule was that which was prepared for the proposed Training and Qualifications Rule and Operator Licensing Examination Changes. This regulatory analysis does not separate out the value and impacts or alternatives for the subject proposed rule on Operator Licenses. Therefore, specific alternatives that might have been considered for the proposed rule cannot be addressed.

It is the opinion of this reviewer, that industry will l

generally benefit from the rulemaking. Alternatives to rulemaking on i

the simulation facility requirement, e.g., a policy statement to assign industry this responsibility through INPO accreditation, could increase the efficiency with which these devices are developed and used by industry in training and qualifying operators.

c)

How NRC will be affected?

The regulatory analysis for the proposed rule was that which was prepared for the proposed Training and Qualifications Rule and Operator Licensing Examination Changes. This regulatory analysis.does not separate out the value and impacts or alternatives for the subject proposed rule on Operator Licenses. Therefore, specific alternatives that might have been considered for the proposed rule cannot be addressed.

It is the opinion of this reviewer, that it would be expensive for the NRC to implement the requirement for simulation facility review and approval. However, the rule should be fully implementable within current staff resources without this requirement.

6. NRC resources and schadling need.

i The regulatory analysis for the proposed rule was that which was prepared for the proposed Training and Qualifications Rule and Operator Licensing Examination Changes. This regulatory analysis does I

not separate out the value and impacts or alternatives for the subject i

proposed rule on Operator Licenses. Therefore, specific alternatives that might have been considered for the proposed rule cannot be addressed.

For comment on NRC resources, (see 5.c) above.

Part III. Needs Assessment for Rulemaking 1.

Need for the rulemaking.

I There is a need for rulemaking in this area for the following reasons:

)

a) response to Section 306 of the Nuclear Waste Policy Act of 1982, Public Law 97-425, b) upgrade the regulatory basis for the operator licensing process (including the operator license examination) by codifying accepted practice used since TMI, and

c) achieve real gains in the assurance of qualified operators obtaining licenses.

2.

Consistency of the rulemaking with applicable policies and planning guidance.

The proposed rulemaking is consistent with all applicable policies and planning guidance.

3.

Importance of the rulemaking to accomplish NRC mandate.

Promulgation of this rule will significantly upgrade the NRC's regulatory basis for administering the operator licensing process by:

a) codifying accepted practice in conducting licensing activities that have been implemented since TMI-2, and b) clarifying requirements for obtaining and applying for operators-licenses.

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OFFICE REVIEW PACKAGE RECEIVED FROM NRR

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l MAR 2 81985 4

i MEMORANDUM FOR: William J. Dircks Executive Director for Operations FROM:

Narold R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

CONTROL 0F NRC RULEMAKING In accord with your February 5,1985, memorandum on this subject. NRR staff members have reviewed ongoing rulemakings being handled in NRR. As appropriate, Regulatory Agenda entries have been updated and review packages assembled for forwarding to RES for independent review. These review packages are being sent to RES ar.d to the Cost Analysis Group, ORM, with i

copies of this memorandum. The status of each of the four rolemakings currently underway in NRR is summarized below, including sy recommendation on whether and how to continue with the rulemaking.

1.

The Pressurized Thermal Shock rule was sent to the Commission on February 20,1985 (SECY-85-60) for approval of issuance as a final effective rule. "This action confirms my recommendation for continuation of the rulemaking effort as proposed in SECY-85-60, and no

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further independent review and EDO approval are needed.

l-2.

The Station Blackcut rule was sent to OEDO by NRR memorandum dated February 22, 1985, with my reconnendation for continuation of the rulemaking in the manner proposed in the enclosures. A copy of this memorandum and its relevant enclosures will be furnished tc the RES independent review group and to Cost Analysis Group. ORM.

3.

The Operators' Licenses rule was published for public comment on November 26, 1984, and the assessment of public comments is in process.

I reconmend continuation of this rulemaking effort to assess the public consents, after which a determination will be made as to how to proceed further. Part of the originally considered aspect of this rulemaking has been supplanted by the Connission Policy Statement on Training and Dualification of Nuclear Power Plant Personnel, issued on March 20, 1985. Copies of the updated Regulatory Agenda entry and related items are being forwarded to RES and ORM.

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The Technical Specifications rule is currently on hold pending results of the review by the Technic 61 Specifications Improvement Project.

Possible actions include revision of the proposed rule to reflect public coments and the TSIP recomendations.

I expect to have a recomendation on whether and how to proceed on this rulemaking by October 1985. A revised Regulatory Agenda sumary has been prepared to reflect this status.

Original signed by Darrell C.Eisenhut d Harold R. Denton, Director Office of Nuclear Reactor Regulation I

bec: RES Mail & Records Section Distribution Att'n: RAMBR for Central File Independent Review i.RSCB Rdf R. Cleveland Cost Analysis Group. ORM Cleveland CHRON Z. Rosztoczy F. Schroeder T. Speis D. Eisenhut H. Denton K. Bowman (NRR 85-031) l H. Thompson R. Bernero J. Knight I

W. Russell D. Beckham A. Rubin R. Woods B. Boger

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O NRC REGULATORY AGENDA ENTRY

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TITLE:

,n operatorW' Licenses t

CFR CITATION:

l 10 CFR 50; 10 CFR 55 i

ABSTRACT:

wo The Nuclear Regulatory Commission 3proposh to amend its 4

regulations to (1) require each holder of and each applicant for a license to operate a commercial nuclear power plant to establish and use a systems approach in developing training programs and establishing qualifications requirements for cavalian nuclear power plant operators, supervi' sors, technicians, and, as appropriate, operating personnel; (2) clarify the regulations for the issuance of licenses to operators and senior operators; (3) revise the requirements and scope of written examinations and operating tests for operators and senior operators; (4) codify procedures for the administration of requalification examinations; and (5) describe the form and content for operator license applications.

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L.' p: ain response to Section 306 of the Nuclear The proposed, 1:

Waste Policy Act of 1982. A regulatory analysis f:: ;d.: =.=./

d.ici ;t::: a public risk reduction of 268,000 person-rem at a cost of $240.4 million dollars resulting in a value/ impact ratio Oct 1,100 persoT}em/ $million. Coordinated industry objections to the rulemaking were the subject of a Commission meeting on April 1,/fF(

Industry's proposrl was for an NRC policy rather than a rule. At aCommissionmeetinggOctober 17, 1984, the Commission directed the staff to publish the portion of this proposed rule revising 10 CFR Part 55, " Operators' Licenses," and to draf t a Policy Statement on programs'for training and qualification of nuclear E "*5,I "".*_ U S*E E *b*_ b ' l N..,.".. 5.." m'

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The Policy Statement.pouttr replacerthe portion of this rule adding requirements to 10 CFR Part 50 on training and qualification of plant personnel. The training programs are to be developed and implemented by industry during a two year period.

The policy statement m.HT* provide guidance regarding NRC's,

r support the industry-managed training accreditataon program and stat NRC's ontunuing responsibility to independently evaluate applican and licengegs' implementation of training as?s.'s.* *t me rey /g a./y s s a.I anessm f i

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.ca NPRM 11/26/84 49 FR 46428 11/26/84[.f/*'.f' NPRM Comment Period Begin

?/0 L";; 3 NPRM Comment Period End Final Action 12/00/85 m--.--..

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PAGE 2

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TITLE:

Operator Licenses LEGAL AUTHORITY:

42 USC 2137; 42 USC 2201; 42 USC 5841; 42 USC 10226 EFFECTS ON SMALL BUSINESS AND OTHER ENTITIES: No AGENCY CONTACT:

-De~ Trr? h=. Tro e e.3oger Office of Nuclear Reactor Regulation Washington, DC 20555 301 492-4868 e

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