ML20212G537
| ML20212G537 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1986 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| Shared Package | |
| ML20212G533 | List: |
| References | |
| REGGD-01.114, REGGD-1.114, NUDOCS 8701210024 | |
| Download: ML20212G537 (6) | |
Text
_ _ _ _ _ _ _ _ _ _
i f~'X DRAFT VALUE/ IMPACT STATEMENT
\\
l s
1.
PROPOSED ACTION 1.1 Description The licensed operator staffing rule amends paragraph 50.54(m) of 10 CFR Part 50 to require licensees of nuclear power units to provide a minimum number
, of licensed operators and senior operators on shift at all times to respond to normal, abnormal, and emergency conditions.
Guidance is needed on the require-ments of paragraph 50.54(m)(2)(iii), which prescribes that all licensees of nuclear power units provide a licensed senior operator in the control room when-ever the unit is in an operational mode other than cold shutdown or refueling ds defined by the unit's technical specifications.
1.2 Need for Proposed Action Revision 1 of Regulatory Guide 1.114, " Guidance on Being Operator at the i
Controls of a Nuclear Power Plant," is not in conformance with the operator staffing amendments to 10 CFR Part 50.
The guide should be revised in accor-dance with the changes to paragraph 50.54(m) to include additional guidance on l
being a senior operator in the control room of an operating nuclear power unit.
In particular, the new guidance should reflect the staffing rule requirements that, when a nuclear power unit is in an operational mode other than cold shut-down or refueling as defined by the unit's technical specifications, each licensee must have in the control room at all times an individual holding a senior operator's license for the nuclear power unit.
This guidance is needed to clarify the NRC's requirement that the senior operator in the control room is expected to spend most of the time in that portion of the control room where there is direct and prompt access to information on current plant conditions and where the operator at the controls can be supervised.
In some unit technical specifications, the control room is defined so that a senior operator can be within the confines of the control roc but not have direct and prompt access to information on unit current conditions.
Guidance is needed ta clarify areas p
in the control room that meet the requirements of the rule.
\\
l v
l 8701010024 061231 7
The licensed operator staffing rule indicates that, as duties necessitate, the senior operator should have the flexibility to periodically move to other parts of the control room.
This means that the senior operator must be within I
the vital security area of the control room and must be either (1) in sight of or in the audible range of the reactor operators at the controls or (2) in the j
audible range of the control room annunciators.
The objective is to ensure that the senior operator will be immediately available in the control room to use his or her training and knowledge to mitigate the consequences of accidents and to increase the probaLility of detecting abnormal events and human error early enough to prevent an accident.
2.
VALUE/ IMPACT OF PROPOSED ACTION i
2.1 NRC The value of the proposed action for the NRC will be (1) to restore i
Regulatory Guide 1.114 to fully usable status (the current version has been rendered partially obsolete by the licensed operator staffing rule), (2) to enable Standard Review Plan 13.1.2 to be amended to make it fully consistent with this rule and Regulatory Guide 1.114, and (3) to reduce ambiguities in what constitutes compliance with the rule.
The lack of a regulatory guide and standard review plan section that conform with the licensed operator staffing I
rule has proved to be a detriment in licensing and a detriment in identifying appropriate enforcement actions following operating events at nuclear power plants during which licensee compliance with the staffing rule was in question.
The impact of the proposed action on the NRC is limited to the several staff weeks entailed in preparing and processing the revisions to Regulatory Guide 1.114 and Standard Review Plan Section 13.1.2.
2.2 Other Government Agencies The proposed action will not affect other government agencies unless the government agency is a licensee or an applicant, such as TVA, in which case the value to and impact on the government agency would be the same as for industry.
O d
8 J
f j (O) 2.3 Industry v
The value of the proposed action to industry is that it will clarify the requirements of the amended rule.
Clarificaticn of compliance with the rule can reduce industry costs of meeting applicable requirements. To avoid possible violations of ambiguous rules, nuclear plant licensees have in some instances adopted unnecessarily conservative interpretations of the
{
regulations and thereby incurred unnecessary expense.
By following updated guidance, the licensees can minimize the expense of compliance.
In some cases, licensees have overstepped the latitude afforded by the generality of some rules and incurred fines for noncompliance.
Such economic risks can be reduced by providing clear, up-to-date guidance for licensees.
No attempt has been made to measure cost savings to industry associated with revising Regulatory Guide 1.114. The cost savings are not thought to be large.
Nevertheless, clarification of the licensed operator staffing rule is l
expected to be of value to the industry.
The impact of the revision to Regulatory Guide 1.114 is expected to be
(
negligible.
It imposes no requirements not in the licensed operator staffing rule. A value/ impact assessment was part of the rulemaking. Most licensees will need to review their administrative procedures for conformance with the regulatory guide.
A few may need to tighten their administrative procedures, but some may discover that they may relax constraints on the freedom of move-ment of one or more licensed operators.
2.4 Public Revising Regulatory Guide 1.114 is expected to have no effect on the public since it merely clarifies an existing rule and updates the regulatory guidance.
- 2. 5 Workers (Occupational Exposure)
The proposed action would have no effect on the workers' occupational exposure.
O
3.
TECHNICAL APPROACH The technical approach used the guidance provided in the justification for paragraph 50.54(m).
An analysis of current control room boundary definitions was made to derive the basis for determining acceptable control room boundaries in this regulatory guide.
4.
PROCEDURAL APPROACH Regulatory Guide 1.114 should be revised to include guidance for meeting the requirements of paragraph 50.54(m)(2)(iii).
l 5.
STATUTORY CONSIDERATIONS I
5.1 NRC Authority i
NRC authority for the proposed action is derived from the Atomic Energy Act of 1954, as amended, and from the Energy Reorganization Act of 1974, as amended, and implemented through the Commission's regulations.
5.2 Need for NEPA Assessment Issuance or amendment of guides for the implementation of regulations in Title 10, Chapter I, of the Code of Federal Regulations is a categorical exclu -
sion under paragraph 51.22(c)(16) of 10 CFR Part 51.
Thus, an environmental impact statement or assessment is not required for this action.
i l
6.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICY The proposed guide does not conflict with or overlap requirements promul-gated by other agencies.
Implementation of the proposed action is discussed in Section D of the proposed regulatory guide.
7.
SUMMARY
AND CONCLUSIONS Revision 2 to Regulatory Guide 1.114 should be prepared to provide guidance in t.onformance with paragraph 50.54(m) of 10 CFR Part 50.
10
UNITED STATES n neu uut NUCLEAR REGULATORY COMMIS810N Po"^os o rese puo WASHINGTON, D.C. 20666 wIE.7c.
mm.. a.
OFFICIAL BUSINESS PENALTY FOR PRIVATE USE,6300 120555064215 1 1SA1S110P11S US NRC j
IRM-DIV 0F INFO SUP SVCS Ek DOCUMENT CONTROL DESK-RECSB 042 WASHINGTON OC 20555
)
O I
l
(
(
O'
_