ML20215J848

Discusses Review of Licensee Commitments for Participation of Licensed Instructors in Requalification Training Program. Two Items in Sections 4.4 & 4.2 in Noncompliance W/Regulations

ML20215J848
Person / Time
Site:	Catawba
Issue date:	09/10/1986
From:	Russell W Office of Nuclear Reactor Regulation
To:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8610270210
Download: ML20215J848 (2)

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}p NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 g 6 pQ, *.September 10, 1986 MEMORANDUM FOR: Albert F. Gibson, Director Division of Reactor Safety Region II FROM: William T. Russell, Director Division of Human Factors Technology Office of Nuclear Reactor Regulation

SUBJECT:

PARTICIPATION 0F LICENSED INSTRUCTORS IN OPERATOR REQUALIFICATION TRAINING AT CATAWBA As requested in your August 21, 1986, memorandum, we have reviewed the commitments for participation of licensed instructors in the requalification training program at Catawba.

As a result of this review, we have identified two items in Sections 4.2 and 4.4 of the licensee's requalification program description dated November 27, 1984, that do not appear to be in compliance with the regulations. One item deals with participation of licensed individuals in the requalification program. The other item deals with the performance of licensed duties by licensed personnel.

Section 4.2 of the licensee's program description allows licensed training staff to be excused from the segment training portion of the requalification training. However, 10 CFR 55, Appendix A, requires individuals who maintain operator or senior operator licenses to participate in the requalification program except to the extent that their normal duties preclude the need for specific retraining in particular areas. Accordingly, to maintain an operator's license, an instructor must participate in requalification training, including manipulation of the plant controls per 10 CFR 55, Appendix A. While a limited number of instructors may be exempt from portions of the requalification training which they normally teach or evaluate, assignments should be rotated so that the same licensed instructors will not continually be exempt from requalification lectures, on-the-job training and annual evaluations, including examinations. In addition, unless licensed instructors fully participate in requalificat. ion training and occasionally perform the functions of an operator or senior operator,10 CFR 55.31(e) and 10 CFR 55.33(c)(2)(i) requirements may not be satisfied.

l Section 4.4 of the licensee's program description exempts reactor operators  !

in training for a senior operator's license from participation in l requalification training. While this is acceptable for candidates who obtain a senior operator's license, candidates who do not successfully obtain an SR0 license may not meet the requirements of 10 CFR 55.31('e) to return to licensed duties. NRC approval may be required prior to return of such individua].sito~

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licensed duties if they have not been actively performing thE.ftRCti, ~ "~g OFFICIAL i; i y

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^ Albert F. Gibson reactor operator for a period of four months or longer. The staff believes that it 1s necessary for the licensee to certify such an individual's

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qualifications at the reactor operator level for NRC license. renewal by demonstrating that the candidate has successfully completed an appropriate requalification program or equivalent and has been actively performing the functions of an operator.

Duke Power Company has submitted their reactor operator, senior reactor operator, and licensed operator requalification training programs at Oconee, McGuire, and Catawba for review by letter dated August 15, 1986. The staff will address these issues in its safety evaluation report upon completion of the review.

Thank you for bringing these matters to our attention.

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I William T. Russell, Director Division of Human Factors Technology cc: K. Jabbour L \