ML20236U562
| ML20236U562 | |
| Person / Time | |
|---|---|
| Issue date: | 07/23/1998 |
| From: | Munro J NRC (Affiliation Not Assigned) |
| To: | Gallo R NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9807300287 | |
| Download: ML20236U562 (3) | |
Text
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July 23, 1998 MEMORANDUM TO: Robert M. Gallo, Chief
- Operator Licensing and Human l Performance Branch l Division of Reactor Controls
- and Human Factors Office of Nuclear Reactor Regulation FROM
- John Munro Operator Licensing and Human Performance Branch Ortginal signed by:
SUBJECT:
LETTER TO ROBERT N. MEYER REGARDING SIGNIFICANT CONTROL MANIPULATIONS On July 9,1998, the attached letter was transmitted to Mr. Robert N. Meyer regarding the requirement of Title 10, Part 55, of the Code of FederalRegulations (10 CFR 55) for licensed 1
operator applicants to complete five significant control manipulations which affect reactivity or power level. This was in response to Mr. Meyer's e-mail message inquiry dated June 24,1998, regarding the same subject. Although the response referenced Mr. Meyer's incoming message, it was not included as an attachment to the letter. A copy of the incoming e-mail message is also attached. /
Attachments: As stated cg)7, DISTRIBUTION:
PUBLIC HOHB RF 1 l
DOCUMENT NAME: G:\MUNRO\PROES
- See previous concurrence To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with' cttachment/ enclosure "N" = No copy OFFICE HOHB:DRCH lE l l l NAME JMunro [/71 l DATE 7@98 "
OFFICIAL RECORD COPY l
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MEMORANDUM TO: Robert M. Gallo, Chief Operator Licensing and Human Performance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation FROM: John Munro Operator Licensing and Human Performance Branch Original signed by:
SUBJECT:
LETTER TO ROBERT N. MEYER REGARDING SIGNIFICANT CONTROL MANIPULATIONS On July 9,1998, the attached letter was transmitted to Mr. Robert N. Meyer regarding the requirement of Title 10, Part 55, of the Code of Federal Regulations (10 CFR 55) for licensed operator applicants to complete five significant control manipulations which affect reactivity or power level. This was in response to Mr. Meyer's e-mail message inquiry dated June 24,1998, regarding the same subject. Although the response referenced Mr. Meyer's incoming message, ,
it was not included as an attachment to the letter. A copy of the incoming e-mail message is also attached.
Attachments: As stated i
DISTRIBUTION:
PUBLIC HOHB RF DOCUMENT NAME: G:\MUNRO\PROES
- S:;o previous concurrence To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with ettachment/ enclosure "N" = No copy OFFICE HOHB:DRCH lE l l l l NAME JMunro [fl i DATE 'iW98 "
OFFICIAL RECORD COPY i
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' MEMORANDUM TO: Robert M. Gallo, Chief Operator Licensing and Human Performance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation FROM: John Munro Operator Licensing and Huma
, A ,,,,, 23 gg Performance Branch
SUBJECT:
LETTER TO ROBERT N. MEYER REGARDING SIGNIFICANT CONTROL MANIPULATIONS On July 9,1998, the attached letter was transmitted to Mr. Robert N. Meyer regarding the requirement of Title 10, Part 55, of the Code of FederalRegulations (10 CFR 55) for licensed operator applicants to complete five significant control manipulations which affect reactivity or power level. This was in response to Mr. Meyer's e-mail message inquiry dated June 24,1998, regarding the same subject. Although the response referenced Mr. Meyer's incoming message, it was not included as an attachment to the letter. A copy of the incoming e-mail message is also attached.
Attachments: As stated l
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- UNITED STATES i
NUCLEAR REGULATORY COMMISS!ON
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\...../ July 9, 1998 l
f Robert N. Meyer P.O. Box 1074 Byron,IL 61010
Dear Mr. Meyer:
In response to your e-mail message of June 24,1998, regarding the requirement of Title 10, Part 55, of the Code of Feders/ Regulations (10 CFR 55) for licensed operator applicants to complete five significant control manipulations which affect reactivity or power level, the !
following information and discussion is provided. '
Operator license applicants are required by 10 CFR 55.31(a)(5), as part of a Commission- I approved training program, to perform at least five significant control manipulations that affect
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reactivity or power level on the facility for which the license is sought. (License applicants at j multi-unit sites, provided the units are manufactured by the same vendor and are of similar design, are required only to perform the minimum number of five control manipulations on one or more of the units but not multiples of this minimum number based on the number of units at the site.) For a facility that is in an extended shutdown which precludes manipulation of the controls of the facility, the Commission may process the application and may administer the required written examination and operating test, but may not issue the license until the required evidence of control manipulations is supplied.
The performance of five control manipulations on the plant was made a license eligibility requirement in May 1987 when 10 CFR 55 was revised. The new rule precluded an applicant from a facility which has completed preoperational testing from qualifying for a license examination with only simulator trainirig. During rulemaking, the nuclear industry requested clarification of the phrase "leamed to operate" (Federal Register Vol. 52, No. 57 Wednesday, March 25,1987, page 9456). As a result, the NRC added 10 CFR 55.31(a)(5) to specify the minimum number of control manipulations that the applicant had to conduct on the facility. In addition, the Commission directed that the rule clearly state that hot license applicants (defined as an applicant at a unit which has operated at power levels with major systems in automatic control) have some minimum leve! of actual on-the-job training manipulating the controls under instruction in the control room.
While acknowledging that 10 CFR 55 does not define the term "significant," Regulatory Guide (RG) 1.8, Revision 2. " Qualification and Training of Personnel for Nuclear Power Plants,"
published concurrent with the rule, provided in Regulatory Position C.1.h an acceptable method for implementing this revision to the regulation by providing examples. RG 1.8 states in part that: " Control room operating experience for hot license applicants ... should include manipulations 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, j shutdowns, large load changes, and changes in rod programming are some examples and could be accomplished by manually using systems such as rod control, chemical shim control, or recirculation flow." Additional clarification and examples regarding the requirement for egc7/"CQ75 tfp
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performance of significant control manipulations by license applicants was provided in NUREG-1262,' Answers to Questions at Public Meetings Regarding implementation of Title 10. Code of Federal Regulations, Part 55 on Operators' Licenses," question numbers 60 through 65,73. 74 and 76. The additional examples referenced include, but are not limited to, items A-F of 10 CFR 55.59(c)(3) (on-the-job training for requahfication). However, while this section of the regulatioa deals with requalification requirements and allows for performance of the manipulations on the plant or a simulator, the manipulations to meet the requirement of 10 CFR 55.31(a)(5) can only be performed on the facility for which the license is sought and not j the simulator. Furthermore, NUREG-1262 recognizes the control manipulation examples in i
RG 1.8 and items A-F of 10 CFR 55.59(c)(3) are not an allinclusive list and indicates that the !
acceptability of any alternatives proposed by the facility licensee will be determined on a case-by-case basis. For example, operator-controlled power changes of approximately 4% to 5% i have been accepted as meeting the rule on a case-by-case basis. Information Notice 97-67, l
" Failure to Satisfy Requirements for Significant Manipulations of the Controls for Reactor Operator Licensing," published on August 21,1997, reiterated the discussion above and a!erted I
facilities regarding the proper interpretation of this section of the rule.
Before the 1987 rule change, NRC regulations required evidence that a license applicant had learned to operate the controls of the facility (i.e., change power or reactivity). The regulation at that time did not specify a minimum number of control manipulations; however, staff practice had been to waive a reactor startup as part of the NRC licensing examination if evidence existed that an applicant had performed five such control manipulations on the facility. This practice was first established by the Atomic Energy Commission (AEC)in 1974 and allowed license applicants to sit for examinations without requiring a reactor startup providinq the applicants had met certain eligibility pre-requisites. Those pre-requisites included five reactivity changes on the reactor facility for which the license was sought in addition to participation in a training program at a nuclear power plant simulator.
in conclusion, the discussion above summarizes the basis for the requirement that license operator applicants perform five significant control manipulations on the facility for which a license is sought. The discussion also includes references to clarifying guidance on acceptable methods for meeting that requirement. If you have any questions or comments please contact me at (301) 415-1031.
Sincerely, rt M. Gallo, Chief perr 'r Licensing and Human Performance Branch Division of Reactor Controls and Human Factors Office of Nuclear Reactor Regulation f