ML20237K940
| ML20237K940 | |
| Person / Time | |
|---|---|
| Issue date: | 04/09/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| FRN-49FR4628, RULE-PR-50, RULE-PR-55 NUDOCS 8708200009 | |
| Download: ML20237K940 (250) | |
Text
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... UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
NRR - MEETING , FINAL RULEMAKING FOR % .. . OPERATORS' LICENSES . __s. l l LOCATION: ATLANTA, GEORGIA PAGES: 1- 261 DATE: THURSDAY, APRIL 9, 1987 AG-FEDERAL REPORTERS, INC. i OffalReportes 444 North CapitolStreet Waslungton, D.C. 20001
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1 y 1 1 3 4 6 PUBLIC HEARING 7' 10 CFR 55 AND CONFORMING AMENDMENTS 8 IMPLEMENTATION OF THE REQUIREMENTS OF THE RULE 9 10 , i 11 12 Thursday April 9, 1987
; 13 8:00 a.m.
14 j 15 Location Strom Auditorium 16 Richard B. Russell Federal Building ] 17 I 75 Spring Street Atlanta, Georgia 18 1 19 20 21 , 4 esemane ACE-FEDERAL REPORTS, INC. l 23 444 North Capital Street L ( 4. 24 Washington, D. C. 20001 25 (202) 347-3700 t
1 meeting. And it will be distributed such that you will I I _ ? have the questions and answers in hand prior to the 3 effective date of the Rule. , 4 So, unless, there are any other logistical i 5 questions at this point, I would l'ike to go ahead and 6 start-in the presentation. Dr. Shankman? l 7 DR. SHANKMAN: Good morning. I can tell by 8 the fact that some of you have your coats off, that you i 9 realize we have a really lengthy task. We're going tc l 10 go through the Rule, Section by Section by Section. At 11 the end of this morning, you should know both the 12 process by which we got here, which I think many of you 13 already know, and the major changes between how we de 14 business now, and how we will be doing business. 15 Could I have a quick show of hands of how many 16 of you received the Generic Letter, and have read cover 17 to cover, the Rule? Too many hands, put them down. 18 okay -- Al l righ t , what I would like to do, since so 19 many of you are f amiliar with the rule, is to go through 20 it, and point out the major changes, and where we have 21 made a change in wording. It is really important to 22 understand that this is a complete re-write of the Ru3e. 23 This is no longer Part 55, as it stands. And, so, even 24 where there are similar words, there may be subtle 25 changes.
In addition, we've renumbered everything. We 1'
, i have revised everything. It's gone through a technical L 2 i 3 editor. It's gone through a Rules editor, it's gone 4 through the Federal Register editor. It's gone through 5
substantive editing, it's gone through internal review, 6 and so that there are some changes where it 3coks 7 totally dif f erent, and the substance is basically the 8 same, And others, where it looks the same, but the 9 substance is different. And that is the point of this 10 morning for me, and I hope for you, is to come away 11 knowing where those subtle changes are. Where there has 12 been an addition of a few works that might make a
; 13 difference in practice.
14 So, if you wi 31 f ollow a 3 ong, it wil 3 take a 15 little time. It's a lot of pages, and a lot of words, 16 but we' 3 J go through it slowly. First, let's talk a 17 3 i t t l e bit about how we got here. If you look at the 18 beginning date, and the ending date, you will realize 19 that this has become my lif e 's work. In January of 20 1983, in fact, I' joined Operator Licensing. In 21 February, we had the famous " Snow Mee t ing ." I knew it i 22 was not a good beginning, but there I was. How many of q l 23 you were at the " Snow Meeting?" j , 24 Okay, as you may know, the Section 306 to the
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L 25 Nuc lear Was t e Act , said you have to take a good look, )
Page 6 1 NRC, at your training and operator licensing j i !
.. 2 regulations. And we formed a task force. In February 3 of.'84, we sent to the Commission a training Rule, and 4 revisions to Part SS, as a complete package. The ;
5 Commission looked at the package, and based on some 6 discussions with NUMARC and INPO, and review by training ] 7 staf f, they decided to split the two parts of that Rule 8 package. 9 The training part went forward as a Policy 10 Statement, that was issued in March of '85. And the 11 Operator Licensing part went through as a proposed Rule, 12 that was issued in November of '84. We solicited, as 13 you a3 ways do with proposed Rules, public comments. And 14 the attorneys at NRC te)3 me that the average comments 15 one gets on a Ru 3 e promu 3 ga t ed by the Agency as a 16 proposed Rule range from five to ten to twenty letters, i 17 and anywhere from a hundred to two hundred comments. 18 So, we got seventeen hundred comments -on this l 19 Ru3e, and I'm sure many of you are responsible for that. 20 (Laughter.) i 1 l 21 I forgive you. Anyway, we got seventeen ) i 22 hundred comments, and those comments varied from
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I 1 23 have to te 3 3 you, we sent it out to all licensed ) 1 1 24 operators -- solicited their comments. Many of them j 25 responded, as did the facilities, as d$d interested
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parties outside of the industry. And the comments 1
~) What do you ranged from, who do'you think you are?
i 2 think you are doing? To some very detailed comments, 3 4 you didn't dot t he l' on page 6-11, and that was the 5 range. 6 We cata'loged them, and as a Resolution to 7 Public Comments Reports, which is available in the PDR, 8 and you can'get a single copy by calling John Hannon's 9 secretary, that takes each of those comments and traces So, if you did 10 them to a reso3ution in the final Rule. 11 Wri te a l et ter, and you want to see how we handled your 12 separate comments, you can trace that out.
+ 13 Okay, it took us a year to do that, because 14 there were so many; because some of them were very And, so, 15 serious, and needed a great deal of attention.
16 we drafted a proposed final -- that sounds like an oxymoron, but it was, a proposed final Rule. And we 17 18 sent it through our internal review process, and it arrived at the Commission in April of '86. Now, that 19 20 was record time, I am also told, for a Rule, considering 21 that Section 306 said we would do it in twelv e months. 22 But, Government time. Anyway, in April of '86, we sent a package to 23 24- the Commission. They reviewed the proposed final Rule. Based on their comments, in November -- or in October, 25 l 4 I (
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Page 8 1 really, we sent back another' version of it in November.
, I. j i 2 Then we got additional comments from the Commission, and.
3 when we responded to those comments, we published a ! 4 final, fina3 Ruje in the Federal Register. It was 5 approved by the Commission in February. It wac 6 published March 25th, and the-effective date is May 7 26th. you get an extra day, because of the Memorial Day i 8 Holiday. It's sixty days after the publishing in the 9 Register, plus one, i. 10 Okay, if anybody is interested in the i 11 citation, I don't know if you've seen it in the Federal 12 ' Register. I say that you need to see it in the Federal 13 Register, only because that is the legal copy. Whatever 14 other copy you have is a reference document, yes, but 15 not something that you can quote. So, the cite.is 52 16 CFR 9453, and you might want to get an official copy. 17 The package sent out with Generic Letter 87-07 18 is the same as the copies that were in front, being 19 given out by the Regional staff, And that is the copy 20 as we sent it to the Federal Register. To give you an 21 example why it is different, there is one word where we 22 said heat, and the Federal Register says head. We are 23 going to change that. It makes a big difference in 24 terms. It's one of the list s of what is on the 25 operating test.
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Page 9 1 Anyway, okay, as Bill and Dr. Grace' mentioned, I _ .2 there will be a NUREG 1262, questions and answers 3 raised at these meetings, and it is going to be 4 distributed t o al l facility licensees. But if you want 5 to make sure you get a_ copy, sign up when you leave the 6 meeting. The Examiner's Standards to implement this 7 Rule, we are going to discuss this afternoon. 8 So, those -- that's the basic background. 9 That's how we got here, It's been a long process, I t 's i 10 been'a process with lots of input from, I'm sure, almost 11 a ll of you. There has been a great deal of exchange 12 between INPO, NUMARC, the Commission, facility 13 Ideensees, and the Regions. The internal review, 14 itself, for the final Rule, took over a year. So, this 15 has gone through many eyes. 16 I say that, because when you look at it, 17 sometimes you wonder where different parts came from. 18 And it's important for you to know that there are 19 several reviewers in there. There is a list, also, in 20 your handout, of documents that are related to the 21 revisions of Part 55. Without having all of those i 22 documents in hand, I think it's difficult to understand ' 23 the complete implementation of the Rule. Do you have 24 that 31st? I don't want to bore you and go through it, 25 but it refers to the Reg Guides. It refers to their i l l l i
i Page 10 1 supporting ANSI Standards. It refers to all of the new l { _, 2 Reg documents, one of whom you got this morning for the 3 first. time, which has to do with the review of.the 4 simulation facility. 5 The Examiner's Standards will be out in April. 6 The new Reg that is being developed today, with this 7 public meeting, will be out in May. And, of course, the ! 8 Commission Policy Statements that relate to training 9 qualifications and engineering expertise on' shift. So, 10 you really need all of those in order to implement the , i 11 Rule. 12 So, this morning, then, we are going to talk l 13 about the major changes. And I. hope to highlight them i' 14 in such a way that there will be no doubt what we have 15 changed, and what we haven't changed. It's also, I 16 think, many of you have been involved with our Rule 17 process, but I just want to point out that the Statement 18 of Considerations, and particularly with this Rule, II, 19 without that, you cannot understand the Rule, q 20 When Part 55 is incorporated into the update l 21 of Title 10, that Statement of Considerations will not 4 22 be included. But that is used to interpret the Rule. ] 23 So, they go hand and hand. And what we have said in the 24 Statement of Considerations bears directly on how we are s 25 going to implement the Rule. And as we go through, I l I
Page 11 1 will call attention to those things that' we have l i-
- 1. 2 clarified. Our support of INPO is one. The approval of
{ 3 training. programs is another.
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t 4 Okay, j f you would take out the Rule, and turn ) 1 5 to the table of contents. Some of you have it on page l l 6 twenty-five. There are about three versions that you 7 may have; the Federal Register version, the generic ] 8 letter version, and the version-that I have up here, 1 9 with me. Okay, the easy stuff first. We renumbered all % i 10 of the Sections. That.was just to confuse you. No,
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11 there is a reason. We did try to make this Rule conform 12 with the style of the Rules as they are coming out now. 13 Since it was a complete rewrite, it gave us an 14 opportunity to bring this Rule into conformance with the , 15 rest of the NRC Rules, as they are written. 16 So, you will notice that everything has an odd l l 17 number, or uneven, I guess I should say. I don't want l 18 to characterize it as being odd. And some of them have 19- been retitled. As I said before, it has been completely 3 I 20 reorganized, and the entire document has been edited by l
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21 many hands. 22 Let's turn to Subpart A. We haven't made j 23 many changes, here. We have clarified the purpose of 24 the Rule. We have made it, now, that it is not onl y -- 25 the purpose is, also, to modify licenses, and to provide
Page 22 1 the terms and conditions to maintain and renew these I _ 2 licenses. A little minor change. Where we have added 3 some things, is in the definition Section, under 55.4. 4 We're going to discuss each of.the new definitions in 5 context, except the ones that were made just for i 6 clarification. So, if you are marking your copy, the 7 new definitions are actively performing the functions of 8 an operator, or a senior operator. We'll discuss that I 9 in context. 10 Contro3s, that was a change for clarification. 11 Facility, we have made it, I hope, clearer, that if you
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12 are licensed for more than one f acility -- mul tiple 13 3 A cense, when we use the word f acility in the Rule, we 14 mean both, or three facilities. Facility licensee is t 15 put in to make it crystal clear that in this part of the 16 Ru3e, unlike Part 50, and other parts of the Rul e,- the 17 licensee is the operator, and the facility licensee is 18 the uti]$ty, or the unit that's docketed with the 19 license. 20 We have changed operator, we've made that 21 clear, or clearer, l e t 's say. Performance testing, 22 Jerry Wachte3 wi33 talk about when he talks about the 23 simulator. Physician, we changed that from medical 24 practitioner, because we use physician in another part 25 of the Rule, and we made it conform. Plant-referenced
lw Page. 13 1 1 simulator, Jerry will talk about referenced plant:_ Jerry [ 2 will talk about senior operator, is also f or l l 3 clarification. 4 Simula, tion facility, Jerry will talk about. l 5 And systems approach to training has been changed, and 6 it is exactly the same words as in the Policy Statement. 7 I should say systems approach to training has been 8 added. We left the United States alone, so it's still 9 the same fifty states that it was when you walked'in. 10 55.5 is the Section that we changed for 11 clarification, the substance is the same. If you have a 12 plant in Region Two, you apply to Region Two. The only i- 13 difference is, any communications about the simulation 14 facility, and that includes the certification, goes 15 Headquarters, and not to the Region. The only other 16 change in this Section is, we revised our OMB-clearance, 17 to make sure that we got clearance f or all of the 18 information requests in here, and that includes the new a 19 Form 474, and the new, revised Form 396. 20 Okay, l e t 's go to Subpart B. I Subpart B is the 4 i 1 21- exemptions to the Rule. And under the general 4 22 exemptions, we have maintained the exemption for people 23 who are in, of course, research or training reactor 24 people. And have also maintained the general exemption 1 25 for trainees. But we have clarified it, so that now it
w _ _ _ _ _ _ _ _ _ _ _
.1 osyn that an individual is exempt from nasding to have a I.
_ 2 license'to manipulate the controls, if they are in a 3 facility licensee's training program, as approved by the 4 . Commission, to qualify for an Operator License under 5 this Part. In other words, if you are on the books of 6 the training department, as being a trainee, in an 7 operator licensing program, you are exempt. 8 The second thing we have done, is we have 9 said, under the direction, and in the presence of a 10 licensed senior operator. And, of course,.that could be 11 an SRO that's limited to f uel handling, but as long as 12 they hold an SRO, you are exempt f rom needing a license 13 ff you manipulate the controls of a facility to load, 14 unload the fuel into, out of, or within the reactor 15 vessel, so, that should clarif y the issue of fuel 16 handlers, which has, I think, been -- yeah. 17 MR. RUSSELL: Before we go on, on the training 18 issue, I want to make sure tha t ' i t 's understood, the l 19 full implications of being in the training program. { 20 Because we have had some cases in the past where shif t l 21 supervisors have made the determination on their-own, to 22 put an individual on the controls of the reactor, to get 23 a practical factor of opportunity that he would have to 24 perform later in his training program. This is prior to 25 the individual actually having been trained on that l l l l
1-evolution,'or having the classroom training, or t'he a I r i . 2 other. aspects of the training sequence. 3 We have actually had events which have 4 involved improper manipulations of the controls. This 5 aspect of the Rule would require that the, individual be
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6 enrolled in the training program. .Within INFO i 7 accreditation, it is necessary that the individual have [n 8 completed the necessary prerequisite training before 9' being involved in the evolution. This is an important 10 aspect of the Rule, and it means that you do not put 11 people on the controls unless they have been N Y 12 appropriately trained for the tasks that they are. going 1 13 to perform. 14 That's a significant difference from practice, 15 the way .it was in the past , of allowing people to be 16 instantly in training because he was under the direction 17 of a 3icensed operator. He-is now required to be under 18 the direction of that operator, but he also must be in 19 training at that time. 20 DR. SHANKMAN: The medical requirements in 21 Subpart C, and we have moved those, and they have their 22 own part are, again, an area where we have changed the 23 process significantly, but not the substance. Those who i 24 are applying for the first time, and those who are going ) to renew, are required to have a medical exam, and to l 25 1 1
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( ' j i.' I [ Pego 16
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1 maintain your license, you are required to maintain that i i s i 2 medical examination on a biennial basis. Just like now, 3 you need an exam every two years. i >
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4 We have also endorsed, in Reg Guide 1.134, the j i , - 1 5 ANSI Standard 3.4-1983, without exception. So, the ) 1 i ( ! 6 medical standard is simply that you meet the ANSI v 7 Standard. What we have done, is changed the way in 8 which we know that that is true. We have revised the
. ;0 NRC Form 396, which I think you have in your package,
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10 behind the s33 des on the Reg Guide, and what it says on 11 t hat Form, now, is that if you are at a test and , 12 research reactor, you mean the ANSI 15.4 Standard, and 13 if you are at a power reactor, you meet the ANSI 3.4 14 Standard, 1983. And that the position examined the 15 candidate, or the licensee on a certain date, and that 16 they have to3 d the f acility that that is true, and the s 17 facility -- an authorized representative of the facility 18 is willing to certify to us that that, in fact, is true. 19 That requires you, then, to make sure that the 20 position, and by that, we also mean any 3deensed medical c 21 practitioner. There are a few states where someone 22 other than a physician can examine somebody, has the 23 ANSI Standard before the, and knows to what standard
; 24 they are examining the candidate, or the'3deensee. We i
25 have, then, I hope, simplified the process, and cut down
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Pcge 17 s t- ,3 1 on the loop some' of us have got ten into, in terms of
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2 licensing people, with the medical paperwork. And, so, s 3 on the revised form, if there are no restrictions, and h 4 an, authorized representative of the facility can certify ' .e + 5 th'at they meet the ANSI Standard, that is sufficient. . T'S \s
, 6, We wil1 not, then, review that, except in an c.s .
7 inspection, or audit mode. If, though, there is a minor s 3 8 restriction that needs to go'on the license, having to 1 I 9 do with corrective lenses, or hearing aids, that can
,, 10 a 3 so just be checked of f, and that will probably not.be 11 reviewed by any medical person prior to issuing the 12 licence.
; 1J We have a fourth condition, or a fourth case, 3 14 where you would want to have the license issued, even i:
I 15 though the person has, based on the ANSI Standard, a 16 disqualifying condition. And have now allowed you to 17 propose that restriction, and support it with medical , 1 18- data. That medica; data will still be reviewed by an 19 NRC medical examiner. So, it's our intent for the 20 average, normal person noe to have one of these medical 21 review loops that, I think, occasionally have occurred. 22 But it is also our intention not to issue a license to 23 someone who doesn't meet that standard without a medical 24 review by NRC medical examiners. I 25 Where it says proposed wording of the 1 i
Pcge 18 1 restriction, I think..most of your.are familiar.with.the
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'.. 2 wording. It fits in our old system, and it's short and
'3 brief. And we have some standard wording. We don't, 4- really, invite creative proposed wording f or additional 5 1 $ censes, because it is still going.to have to be 6 ; printed out by the old system.
7 'I think there was a question about who the 8 f acility authorized representative would be on this 9 form, and'we intend for it to be the same person that i
' 10 signs the 398. N o w ', .the 396 you have, do not use,
?1 because i t's not: an' official form, yet. It's
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12 - impri.nting; it will be available prior to your needing ( 13 to use .it on May 26th. It had a little minor
'14 '
. correction, you might --
it's an eye test for some of 15- you to find it', and.then it's going to be fixed.
- 16 Okay, the other part of this Section that has 17 been changed is the retention of medical records, and l- 18 that is, we are. requiring you to keep those records for 19 the current Ideensing period, and provide documentation 20 to the Commission upon request. So, we will check some j' 21 of those medical records, and if we have no problems, 22 we'13 continue to use this, taking your certification 23 without a prob 3em.
24 We have al so changed -- 55.25 is a change, l 25 incapacitation because of disability or illness. In the 3 1 i
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r- ' 1 l' f Page 29 h 1 past, that's been fifteen days. We have now changed it s1 i i 2 to thirty, that's the Agency standard of asking for ! 3 notifications within thirty days. So, we have changed 4 that to thirty days. Ant) we also -- there is a phrase 5 in there I want to call your attention to, that says, 6 "Of learning of the diagnosis." So, the facility 7 licensee is on the hook to let us know about a condition 8 thirty days after Jeaning of the diagnosis. Obviously, 9 Af you don't know about it, you can't let us know about ID At. 11 There has also been some questions about what 12 kind of a condition we are ta3 king about. The only -- I
, 13 was trying to think of an example. If somebody is 1 14 Jicensed, and has two arms, they meet the ANSI Standard 15 for being able to manipulate contro3s, no question. Now 16 they break their arm, but they are expected to f ully 17 recover, and come back. And when they come back in the 18 control room, they wi3] again have two, usable, working 19 arms. So, they have not changed their medical 20 condition. They will not be in the control room in a 21 disabled condition, or incapacitated, okay?
22 We don't need to know about that. Now, they 23 may loose their active status. They may need to go 24 through some other change in order to maintain, but as i 25 3ong a they are enro3 3 ed in requa3, and continuing to do
Page 20 1 that, we don't need to know that. They are not going to I _ 2 be in the contro3 room in an incapacitated status. If, 3 for some. reason, their arm is amputated, that's a' 4 condition we nee,d to know about, because, obviously, 5 they are not going to return to active functioning, or 6 active duty with the same two arms that they were 7 licensed With. 8 And if you look in the ANSI Standard, I think 9 they make it clear, the difference between temporary, 10 transitory, co3ds, f3u, things, like that, and 11 permanent, disabling, disqualifying condition. So, if 12 their medical condition changes during the license 13 period, we expect to know about that. I think we 14 already ta3ked about this Form, Kurt, so l e t 's go on to 15 Subpart D. Yeah, go on, unless you love to look at NRC 16 forms. I have 3 earned to live without them. 17 Okay, here is another case where we made a big i 10 change in the Rule, but no change in practice. You are 19 1.ow required to do Form 3 9 8, which I think we have all 20 be using for quite a whi3e. If you look at number four, 21 this is where I think we have made the first major 22 change, that is a change both in practice, and in 23 substance, and in the Rule. If you look at number four, 24 this has to do with e31gib5 31ty -- qualifications and 25 eligibi3dty. And we are still asking that on the 398,
Page 21 1 1 you supply to us inf ormation about the nature of the I
- i i 2 training,~and the start up, shut down experience, and 3 the' courses of. instruction, and the applicant's j 4 quali fica t ions. , That's, basically, the eligibility
.I 5 process the way we have it now, and Reg Guide 1.8 6 explains what we want to hear in regard to that 7 particular Section, s The difference is, that in lieu of those !
i 9 details, we have now said that you' can successf ully
'10 complete an NRC approved training program, and you have 11 to be in a program that uses a simulation f acility 12 acceptable to us.under 5 5.4 5 ( b) . If that's true, then, 13 on the 398, you can just let us know the date you were 14 certified --
I mean, the date you were accredited by 15 INPO. That. wil l automatically mean that you are NRC 16 approved while the Policy Statement is in effect. And 17 te]3 us when the certification was signed and sent to 18 the NRC regarding the simulation facility. 19 Now, there is also a third case. You could 20 have one that 's acceptable to us through an approval i 21 process. But when Jerry describes that, any simulation 22 f acility that's acceptable to us meets -- fulfills the 23 requirements of this Section. But the typical case will 24 be one that certified to us. If you are like me, and 25 you want to make sure that what I said about
Page 22 1 accreditation is true, if you will look in Section l- _ 2 (2)(c) of the Statement of Considerations, you will see 3 that we say, a program is approved by being accredited 4 by the National Accreditation Board. 5 Okay, that's one major change.. Another major 6 change, five significant control manipulations must be 7 performed to be licensed. And on the 398, we expect you 8 to provide evidence of what those were, and when they 9 happened. 10 We've said -- I assume most of you have read 11 Section 5, but I just want to summarize it for you. For 12 a hot plant, you provide evidence of five significant
', 13 control manipulations. For a cold plant, you provide 14 evidence of completing the training program approved in 15 the FSAR. For a plant in extended shut-down, we may 16 std 31 come and give the operating test and the written 17 examination. But you will not have a full license until 18 after you have an opportunity to do the five control I 19 manipulations, i
20 Another part of this, not related to the 21 condition of the plant, but related to the condition of l 22 the operator, is that if it's an SRO upgrade, we don't 1 23 need to have those five control manipulations evidence
< 24 provided again. If you provided them in your j t j 25 application -- in the application for an RO, then they I l
I Page 23 1 are still all right f or the upgrade. And I think those
,i 1 2 are the two major changes, and they will make a 3 difference in the way we do business.
4 In the next Section, in (b), we have added the 5 words, "under oath or af firmation." Not a major change, 6 but I promised to tell you where we added words. In 7 55.33, we still have our health standard which, as I 8 say, we've defined as being -- in the Reg Guide, as 9 being the ANSI Standard, but it will not adversely 10 affect the performance of assigned operator job duties. 11 We've also said, for a conditional license, we ask for 12 medical support. In reapplication, in 55.35, we say, 13 on the 398, we want to know the extent of the 14 app l i can t 's additional training since the denial, when 15 there is a dendal, and there is a reapplication. And, 16 again, we bless the 398 form. 17 Okay. We have received several questions 18 about the operating test, and the written examination, 19 and how it's changed, and how it hasn't changed. This 20 is an area where I would invite you to take the old 21 Rule, and the new Rule, and put them side by side, and 22 you will come up with something like this, where there 23 are changes. Most of the changes in the items are for 24 clarification. The majer change is in the Section 25 labe3 led content. And in there, for both the RO and the h
Pcge 24 1 SRO writton examination, and for the operating test,-wo 2 have'put the ~ same statement. If it isn't exactly the 3 same , i t 's because somehow it was set wrong in the 4 Federa3 Register. 5 It's meant to be exactly the same, which is to 6 say that the content of that examination, or operating 7 test, wi33 contain a representative selection of 8 questions on the knowledge, skills, and abilities needed 9 to perform licensed operator duties, or licensed senior ; 10 operator duties. And that this will be identified, in i 11 part from learning objectives derived from a systematic i 12 analysis of'the training program. And that we also will 4( 13 take some of the content from the FSAR System 14 Description Manuals, and operating. procedures; facility 15 31 cense, and license amendments, LER's, and other 16 materia) that is requested in the ninety day letter. 17 Now, we intend, ultimately, and if you look in 18 the Statement of Considerations, II(d)(1), you wilI see 19 that our goa 3 is to get to the point where the learning ; 20 objectives derived through the INPO accreditation 21 process will provide the major part of our examination 22 content. I'm sure most of you know the catalogues we 23 have out, and I am sure you are aware of other ways that 24 we use your training materials. 25 Right now, for many facilities, the 3 earning
Page 25 7 i ob'jectives do not work well in terms of translating them-f I L 2 Anto testing objectives. I'm sure you also know- that in j 3 evaluation, the learning objective is not sufficient, it 4 has to be-massaged into a testing objective if you are 5 going to be able to judge the quality of your questions. I 6 We intend to use the learning objectives as they get to 1 7 the point where they all have a condition of 8 performance, and a standard of performance, and are 9 clear. In many cases, in many facilities, that's 10 already true, in many of the training areas. ! l 11 But that is not true in all f acilities, and j 1 12 that's why it says, in part. It's also our intent that i 13 although the learning objectives will supply the major 14 content, we also reserve the right, as things change, to 15 use LER's, and other changing conditions at the plant, j 16 which may not be reflected in the training program until 1 17 a little time goes.by. Because with the SAT, you have a ] 18- loop that will filter those back into the training 19 program. But there are instances where the event may be 20 such that would expect them to be cognizant of what l 21 happened, even though it is not in the learning 22 objective process. 23 In the sampling list , let me just point out , 24 quickly, some of the changes. I don't think they are 25 ma jor, but as I said, I w i l .1 teII you what changes there l
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1
r Vaga 26 1 are. In Item one, we have added reactivity coefficients I i 2 and poluon effects. In Item three, we have modified, it 3 says mechan:1 cal components. In four, we have added 4 secondary coolant. In five, we have added facility 5 operating characteristics during steady state and 6 transient conditions. Including cool and chemistry. In 7 seven, we have added failure modes. Eight is modified 8 slightly. Thirteen and fourteen come out of the Denton
- 9. let ter, and we have now-put them in the Rule; procedures 10 and equipment available f or handling and disposal of 11 radioactive materials and ef fluents, and principles of 12 heat transfer, thermodynamics, and fluid mechandes.
13 The same statement about content is in the SRO 14 written exam. In the Items, in number two, we have 15 added facility operating limitations in the Tech Specs, 16 and their bases. In four, we have added radiation 17 hazards that may arise during normal, and abnormal l 18 situations. Five has been rewritten, but I think it's i 19 an item you are familiar with. We have added normal, 20 abnormal, and emergency situations. In the operating 21 test, we have also made a small change to Item five, 22 observe and safely control. In eight, we have added i l 23 emergency systems, and the release of radioactive l 24 materials to the environment. And we have added a new 25 number thirteen, which has been significantly revised,
Page 27 i 1 based on public comment, from the proposed Rule. f _ 2 You may have seen it in the proposed Rule as l 3 team dependent, time critical. Maybe we changed it 4 because I cou l dn' t say that. No. But, anyway, it's 5 demonstrate the applicant's ability to function within 6 the control room team, as appropriate to the position, 7 and maintaining the Tech Specs, and other operating 8 conditions. 9 The rest of 55.4 5, all of B, will be covered 10 by Jerry Wachtel . It has to do with the approval and 11 acceptance of the NRC of simulation facilities for the 12 conduct of operating exams. At the end of Subpart E, we 13 have added the integrity of examinations and tests. j 14 That was in the proposed Rule, but in the final Rule, we i 15 have changed the wording, so that applicants, licensees, I l 16 and facility licensees, are all included in not engaging 17 in any activity that compromises the integrity of an 18 application, test, or examination. I think the j 19 substance of that is here. 20 I think we will handle one more dif ficul t 21 item, and then we will take a break for coffee. If you i 22 will look under Subpart F -- we have changed E, and this 23 is where the definition of actively performing the 24 function of an operator or senior operator applies. We 25 have now, in effect, made two kinds of licenses, an
Page 28 1 active and an inactive license. As you know, it has not
, I
_ 2 a 3 ways been clear what active 3 y and extensive 3 y engaged I 3 meant in the renewal process. l f 4 So, we have deleted that requirement in the 'l 5 renewal. Instead, what we have said is that, in order ! 6 to have an active license, everyone who holds a license, 7 and wants to maintain active status, must be on shift, 8 meeting the definition of actively performing, for a 9 minimum of seven eight hour, or five twelve hour shif ts. 10 Now, we have modified it for test and research reactors, b' 11 so that they only have to do it fm four hours. 12 Obviously, their conditions are different. 13 But an active license is someone who is on 14 shift these number of hours, these number of shifts, 15 meeting the Tech Specs requirements for the position for 16 which they ho3d a license. I want.to make that point, 17 because it does not include people who are in the 18 contro3 room. It also says that they have to do that, 19 according to -- well, according to E, every calendar 20 quarter. S c. . 936 you do it in January, and again in 21 June? Yeah. It's not every three months, it's every 22 calendar quarter. 23 In order to maintain an active 31 cense, you 24 have to be enro3 3 ed, and successfully complete a 25 continuous requalification program, and meet these on
tr y ae i i shift standards; and maintain your medical i ' i 2 qua l .i f i ca t i ons. An inactive license is someone who 3 doesn't meet these on shift qualifications, may not meet 4 the medical, but stays enrolled continuously in the 5 requalification program. 6 Okay,'so, you don't meet the shift 7 requirements, and you have stay in requal, and you have 8 an inactive license, and you want to go back on shift. 9 No problem, the fix is in F. If your qualifications and 10 your status are current and valid, meaning your medica] 11 status is current and valid, and your requalification is 12 current and va3Ad, but you haven't maintained this on 13 shift requirement, then you need to a fortij hour 14 para 33e3 shift. And, again, we have modified it for 15 test and research reactors, they have to do a six hour 16 para)3e1 shift. And f uel handlers, or any license 17 Jimited to f uel handling would have to do one shift, 18 because we recognize that those licenses limited to fuel 19 handling may not maintain their active status. So, you 20 wou3 d have to have someone with an active SRO 21 supervising them for one shift. And, then, that would 22 reactivate that license. 23 Who signs the certification? The same guy 24 what signed the 398 and the 396. And where does it go? 25 In a file that we can review if we are on site. Okay,
Page 30 1 it has to be available to us.
. I 2 HEARING ATTENDEE: (Dr. Johnson) Wait a 3 minute, I missed that last bit, we have to sign 4 something. I missed that last one.
5 DN. SHANKMAN: According to F, you have to 6 have an authorized representative of the facility 7 licensee certify that one, they are current, and two, E that they completed a f orty hour para 3 lel shif t. And 9 t ha t has to be on file at the f acility f or us to review, l 10 on site. 11 HEARING ATTENDEE: (Dr. Johnson) No new NRC 12 forms, then? 13 DR. SHANKMAN: No. Dr. Johnson, would you 14 31ke a new NRC form? 15 HEARING ATTENDEE: (Dr. Johnson) I don't 16 think so. 17 DR. SHANKMAN: No? We have form makers. 18 Right, they are in the umpire league -- referee league, 19 right? 20 (Laughter.) 21 Okay, but, of course, obviously, we would need 1 22 to verify the qualifications that it's current. We l 23 cou3d review the requalification records, the medical 24 records, anything that supports that certification. 25 Okay, this one (indicating), conviction of a fe3ony.
1 There has been a little discusofon of that. I don't how
- f. 2 many of you are familiar, there is a particular incident 3 that brought that about.
4 But the point is, that the licensee, the 5 operator himself, or herself, is required to let us know 6 Af they are in jail. They get one phone call, they 7 should call us. No. 8 (Laughter). 9 It's our intent that if you are convicted of a 10 felony -- of a serious offense, that we need to know 11 about it, and tha t 's why tha t 's in there. Okay , thi s 12 part also continues -- it just reiterates the fact that 13 you have t o compl ete a requalification program. You 14 have to maintain a biennial medical examination. 15 Let me just say a word about expiration, .i t 's 16 now a six year license. We have also added that filing i 17 by mail or telegram will be deemed complete. Some 18 people have wanted to let us know by electronic mail for 19 a renewal, and we are not quite there. Our Office of ; l 20 the General Counsel is working on how we would receive f l 21 things electronically. So, in the meantime, it still 22 has to be by telegram, or by mail. -l 23 You may look in expiration, we have changed 24 the way in which a license can expire. Not only does it 25 expire based on a six year cl ock, but it also can expire
Page 32 1 when the facility determines that the operator is no (-1 1 2' longer needed in the 13 censed position. And it also can 3 expire if someone'is fired from a facility. Obviously, 4 they would no longer need them, so that's to clarif y 5 whether you continue to hold your license after you 6 leave a facility. 7 Okay, I wou.1d like to take a break f or cof f ee 8 before we go into requalification. The cafeteria is 9 right out here. How about if we take about fifteen 10 minutes? Okay. 11 (Whereupon there was a pause in the proceedings.) 12 DR. SHANKMAN: Let's get started again,. 13 p3 ease. I had some questions during the break, which I i 14 want to clarif y. They may not have been clear in the
- 1 15 presentation. One is that, if you have someone at your 16 plant, according to your Tech Specs, who must maintain a 17 3dcense; an inactive 33 cense is a license. The second 18 question I had was about the forty hours, does that have j i
19 to be a continuous forty hours? And the answer is no, 20 it just has to be continuous shifts -- not continuous -- 21 it has t o be shi f t s, but it could be several shif ts, not 22 one right after the other, in a full week. 23 Another question that I got during the break 24 was, if you are at a plant that has eight hour shifts, 25 can you do the shifts four hours and four hours? And
Page 33 1 the Regulation is very clear, you are to do shif ts -- ( l 1, 2 seven eight hour shifts. Not four hours and four hours.
.3 The intent is that you will do all of the things that 4 are necessary, shift turnover, log keeping, whatever is 5 involved in an entire shif t. Except if your plant has 6 twelve hour shifts, you can do twelve five hours shif ts.
7 But they also don't have to be one right after another, 8 Another question that someone asked me, was do 9 the -- does the Plant Manager, to maintain an active 10 license, have to be on shift, and the answer is yes. 11 Not in and out of the control room is not sufficient. I 12 There were a few other questions, but I think I told
. 13 people to ask them at the panel. I didn't want to 14 answer them until we could all answer them together, 15 about medical qualifications.
16 MR. RUSSELL: Susan, let me clarify one issue. ; 17 P" SHANKMAN: Yeah. 18 MR. RUSSELL: She has indicated that for a ! l 19 Plant Manager, or for anyone, in fact, to maintain an 20 active license, they must stand watch on shift, in the i' 21 control room, as one of the two senior operators in a 22 control room, or one of the two reactor operators. The 23 corollary to that, you need not have an active license 1 24 to satisfy the requirements of the Tech Specs. So, if 25 the Operations Manager is required by technical
Page 34 1 specification to be licensed, he must participate in i _ 2 requalification. And he must have a license which is 3 current. 4 He need not stand function on watch in a 5 . control inom. So, the issue of actively and extensively 6 engaged, >rhere we previously gave credit for certain 7 functions meeting the definition of actively engaged, 8 that has gone away. And the issue we are addressing 9 with 53(e) is actively performing the function on shift. 10 This is i n+, e n d e d to insure proficiency at control 11 manipulations, and directing the activities of 12 operators. 13 And the parallel forty hour requirement, -i s to 14 get proficiency, again, before the individual resumes 15 those duties. It does not address other positions, 16 which are required to hold a license. An inactive n 17 license is satisfactory in that case. ! 18 DR. SHANKMAN: Okay. So, you have a six year - 19 license. How do you get a six year license, you renew I 20 your license after May 26th, 1987, whenever it comes up 21 for renewal. Your renewal will be for seven years, or 22 your are issued -- any license that we issue after that ]
)
23 date will be f or six year. If you have a two year 24 license now, you have a two year license. Why do I 25 maxe 31 clear, who has a s3x year license, and who 1 l l C- j
1 Page 35 i I 1 doesn't?- /'
- , 2 Because if you have a six year license, you i
3 need to be examined by the NRC, both written and f 4 operating, durin,g the term of your six year license. 5 So, if you just renewed your license, you have a lit t l e i 6 breathing period in terms of that particular 7 requirement. It doesn't mean we may not examine you, j 8 but it just means that you are not hooked by that 9 requirement. 10 Everyone holding a six year 31 cense wil 3 be 11 examined by the NRC, both a comprehensive, written, l I 12 requalification examination that covers a representative l
- 13 sample of those items listed under the written 14 exami na t i on f or RO's and SRO's , - 55.41, and 5 5.4 3 ; and an 15 operating test. Again, a sample of Items (2) through i
16 (13), from 5 5.4 5 ( a ) . Tha t 's wha t we mean. 17 In order to renew your license, you must have 18 passed a comprehensive requalification writtt" 19 examination and operating test adminisit 4 of the ; l 20 Commission during the term of the six year license. And 21 we say, in the Statement of Considerations, that we l 22 intend to examine everyone at least every six years on a l l 23 random sample basis, ] l 24 MR. RUSSELL: We'll cover that in the 5 1 25 questions and answers this afternoon. It wilI be j
._ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ..__J
.y Page 36 1 random.
i 2 DR. SHANKMAN: Yeah. So, a license will be 3 renewed if the medical condition, and the general health 4 of.the , licensee continues to be such as not to cause 5 operational errors that endanger public health and 6 safety. The license will be renewed if the licensee is 7 capable of continuing to competently and safely assume 8 licensed duties. That's stjl1 the same. Has 9 successf ully completed a requalification program that 10 has been approved by the Commission; and has passed the 11 requalification examinations, and annual operating tests 12 given under the approved program, and has passed a 13 comprehensive written exam, and operating test 14 administered by the Commission. That's what you need to i 15 renew a 31 cense, 16 The continued need stays the same. If the 1 17 f acility believes they need you, we believe they need 18 you. We have also added that the past performance of 19 the l'icensee has been satisfactory to the Commission. 20 And to make that clear, we have added the phrase that q l 21 we're -- we're talking about formal notices of 22 vio3ation, or letters of reprimand in the licensee's 1 l J 23 docket. And as you might know, we have a policy on how j l i how they get reviewed. l 24 they get their -- ) i 25 Just because there is a notice of violation, 1 l l _ .. _
1 or a letter of reprimand, does not mean that we won't 1-L 2_ ' renew .the license, it's just that we are, now, going to 3 be taking notice and consideration of things that really 4 happened in the past, but are now in the Regulation. 5 Requalification -- oh, wait a second. Let's 6 go back a second. I'm sorry, I wanted to go back. When. 7 we talked a little bit about the expiration of the
.8 33 cense, I wanted to make c3 ear that we have modified 9 Part 50, and it's on the last page of your document. '
10 There wi31 be something -- it says number five, a new 11 50.74, which is a modification to Part 50, that says, 12 " Notification of change in operator or senior operator 13 's t a t u s." That is the facility licensee, Part 50. is'now 14 ob3dgated to let us know of a permanent reassignment 15 from the position for which the licensee has certified a 16 need. Do you remember that on the initial application? ; 17 And also on renew, where you certify a continued need. i 18 Another obligation, is to let us know of the 19 termination of any operator, or senior operator. I 20 think we mean termination of erap l oymen t , not termination 21 of the operator. Okay, and disability or illness, 22 harking back to the thirty days af ter learning of the 1 23 diagnosis. So, once you let us know, that will cause 24 the license to expires. Okay, go ahead. 25 Requalification. here we made changes in
Page. 38 1 substance and in practice and in the-Regulation, so.this r i _ 2 is a Section we have,to deal with caref ully. First, you 3 must successf ully. complete a requalification program 4 developed by the facility licensee.that has been ! 5 approved by the Commission. How do you get it approved 6 by the Commission? All you have -- all facility 7 Ilcensees have requalification programs that have been 8 approved. 9 'We'11 talk a little about it when we get to 10 Reg Guide 1.8 in the -- maybe we'll talk about it, now. ; l 11 I think, looking at your faces. There is a slide that 12 says training approval. Is there a slide that says 13 train $ng approval'3n there? Anyway, in the process by 14 wh3 ch you submi t to us a let ter that tells us when you 15 were accredited, you also need to tell us whether your 16 requa13 fication program was developed under the SAT k 17 based process. ! I 18 If it was not, it's still an approved program, 19 but we have some concerns about how it's developed, and i 20 how it's used. What we expect, and encourage, is that ! 21 the requalification program, once you are accredited, l 22 would be developed along the same lines as the SAT i 23 process used for your initial program. And the 24- guidelines that INPO has just released under 86-025, are l s t 25 the guidelines that tell you how to do an S AT based l
)
l 1
! I l Page 39 1 1 requalification program,-as opposed to one that mirrors
, l i 2 Appendix A. The old INPO guidelines really were a I
3 modification of. Appendix A. 4 So, it's our intent that the programs -- the 5 requalification programs will not move to SAT based, in 6 the same way as your initial programs have been 7 accredited as SAT based. And you will see that we have 8 changed the Regulations to allow that. In the past, the 9 reason that the -- well, in our discussion,s with INPO, 10 the reason that they weren't converted, was that we were 11 all locked into Appendix A. That is no longer the case. 12 Wha t you woul d do, is i f you have an SAT based' ( 13 requalification training program, in order to modify the 14 FS AR,' or modif y your approval, you would let us know the 15 date that it was accredited. Tell us that it's SAT 16 based, or tell us that you used 86-02 5 in developing it. 17 If you are accredited, we assume you know how to do SAT 18 based. And, then, when you do the 50.71(e) update of 19 the FSAR, you would delete the current training program 20 requirements that are on file with us. We can talk 21 about that a little bit later, but that's the idea; to 22 encourage everyone to move towards SAT based 23 requalification, as well as initial training programs. 24 All right, you must have a program approved by 25 the Commission. And that is either your currently i
Page 40 1 approved program, or moving to the SAT based program, I
;_ 2- whj ch you have been accredit ed, and you have used the l
3 new INPO_ guideline. That program, we have allowed more 4 flexibility than the current Appendix A. That program 5 could be, on a continuous basie, not to exceed twenty-6 four months, as opposed to an annual program. 7 Obviously, if you have a program, that's an 8 annual program, and it's been approved as an annual 9 program, you have to do the appropriate thing, to move 10 to the twenty-four month based continuous program. If 11 SAT -- weII, I don't think SAT should be strange words, 12 but if you want to know exactly what we, the Commission, 13 mean by that, that's why the SAT definition is under 14 55.4. And that's the same as the policy statement that 15 endorses INPO's process. 16 You must pass a comprehensive requallfication 17 written examination, and an annual operating test. The 18 operating test is annual, the comprehensive written l 19 examination could be every two years, because if your j i 20 program can be every two years, your written exam could 21 be every two years. If you have obligated, in your 22 approval of your program, to an annual written exam, you 23 have to maintain that until you do the appropriate 24 things to shift to the twenty-four months, 1 25 What do we mean by comprehensive written
I 1
- 1. examination? In (2)(i), we say, that is one that 1
(' 1, 2. sampies from 55.41 and 55.43. It says, "Any 3 Ami tation 3 of the license." Obviously, a fuel handler doesn't need 4 to be tested on everything in the requalification. .I f 1 5 their license is limited to fuel handling, their l 6 requalification program would be limited to f uel 7 handling, too. 8 The. operating test, again, we've spelled out 9 that we mean t hose i tems in 5 5.4 5(a), (2) through (13). 10 And we've all owed tha t in lieu of our accepting a
.11 certification from the facility licensee, we, the NRC, 12 can come in and give those examinations. We have also, i 13 obviously, in the other Section, said that not only can 14 we, but we will come in at least once every six years, 15 for an individual.
16 The other Sections have been modified, and 17 additional training has been added. It's still the same 18 requirement, to successf ully complete the training 19 before returning to licensed duties. We have modified 20 Section (C), it now says that the requalification 1 21 program requirements have -- if you look at this 22 Section, it will seem very familiar, because it is t 23 Appendix A moved into the body of the Regulation. 24 So, 5 5. 5 9 ( C ) is Appendix A, wit h a f ew L 25 modi fica tions I will point out. But if you look at the L.r. .
Pege 42 1 1 last sentence, that is how you are permitted to move to I; . I L 2 a systems approach to training. It says, "In lieu of 3 parag raph (C)( 2 ), (3), and (4) of the Section, the 4 Commission may approve a program developed by.using a ; systems approach to training. And as I said, it's our l 5 , 6 intent to -- and the Generic Letter, I believe, one of l 7 the paragraphs told you, it's our intent-to accept those 8 SAT based requalification training programs that have 9 been accredited, and that will gain NRC approval. 10 We have modified this a .little bit, it's not 11 exactly Appendix A, because we have f olded in all of the 12 requirements from the Denton letter, and NUREG.0737, 13 Again, when we did this, it's a complete rewrite, and 14 it's our intent that this document, and the other 15 documents that I listed on that list, will supersede 16 all of the previous documents we have been using for l 17 operator licensing. And if you have all of those. 18 documents on your desk, you have no room to work. But 19 other than that, you will be able to implement this 20 rule. 21 MR. RUSSELL: Susan? 22 DR. SHANKMAN: Yes. 23 MR. RUSSELL: Let me give an example, so that 24 you understand what we mean by the process, as it is 2 25 described in the Generic Letter. You have a situation,
1 whero if a f eci 31ty was accreditod prior to the time in l L
-L 2 which INPO issued its guidelines for continuing training l
3 for licensed operators. And the training program that 4- was put up with the accreditation program was, in fact, 6 the requal program previously approved by the NRC, 5 3 h\ 6 through some t y p'e o f a report, or other mechanism. We y 7 have said, that based upon the f act that the f acility 8 was accredited, we be31 eve that the facility 9 understands, using INPO's terminology, the TSD process [ 10 training development system, or SAT, which we have i A( 11 endorsed through the Policy Statement by the Commission. 12 If you take and app 3 y the guidelines that are 13 contained in the INPO continual training document to I s 14 your continuing training program, you may substitute 15 that for your previous 3y approved NRC program, that . 16 speci fied you had to have so many hours in lecturea'.of 17 certain types. You had to have certain on-the-job 18 training requirements, and you had to do certain 19 evaluations. That's what this rule says at this point -
,t 20 in time. It says, you may substitute a program which is ]
21 systems approach to training based, for lectures, on-l 1 22 the-job training, and examining. 23 That a 3 so means that if INPO has accredited a 3 I t ) 24 segmented examination, you may continue to use a j 1 25 segment ed eva 3 uation f or your eva3 uation, in . lieu of ! l 1
c, .. Page 44 1
,. 1 a comprehensive written examination, which the NRC would l 2 perform. .So, we'are not requiring, through this a<
s F 3 process, that you change your examination process, as q., s p;' 4 has been accredited. That's a part of training. But we 5 will come in, and still do a comprehensive written. 6 So, that you have to do, is certify to us that
.s 7 one, you have.been accredited, and two, that you program 8 has been done in accordance with a systems approach to 9 trainj$g. We will not review it any further, but we 4 to be]ieve to do that, you have to have a continuing 11 training program that means the guidelines and the 12 intent described in the INPO continuing guideline, that
", 13 was, just published in final form in October of '86.
14 So, even though you were accredited before 15 that came out, you can do a sel f-evaluation, yourself: 16 modify your program, and you may certify. That way, you 17 control the.achedule. If you do that, you need not 18 amend your o3d program with the NRC, to go to a two year 19 program. 20 DR. SH ANKM AN: Okay, the rest of 55.59(c) is, 21 as I said, Appendix A with the Denton letter f olded in 22 from 0737. I am not going to go through all of the 23 contro] manipulations, unless someons is dying to hear 24 t hem out loud. I would like f or you to look at Section 4, 25 (3)(v), just to see that for the purposes of your
Page 45 1 requalification program, we have . allowed that you are
. I' ; 2 using a simulator, as you have been encouraged to do in 3 the past. We expect you to continue to use that 4 simulator, until such time as you certify a simulation Once 'you do that, then you would move back-I 5 faci 11ty.
6 into your requalification training ~ program. as well. 7 The evaluation, we have modified, again. 'We 8 expect a comprehensive written examination, and an 9' annua 1' operating test, that includes emergency to procedures. And, again, we also expect you to make use 11 of the simulator, until such time as your simulation . 12 facility is acceptable t o us , either through the 13 certification process, or the approval process. And we 14 expect records to be kept. The record Section is sti21 15 the same, whether you are using a SAT approach, or 16 during.the transition from the old Appendix A. And we i 17 expect to see_ documentation of operating tests, now, as I 18 well as written tests. I 19 Subpart G, for the modification and revocation 20 of licenses has not changed. The enforcement has not 1 21 changed. As you go on to the end of this document, you 22 will find that we made sure that wherever we mentioned
)
L 23 Appendix A, we have now modified it. Or wherever 55 was I 24 referred ~to, those are all called conforming Amendments. 25 They are no substantive changes, we have just made the l l l
Pcge 46
]
1 opproprjate substitution of the right numbers.
; i 1 l 2 You have in your package both the Rule, the l
{ 3 conforming Amendments, and the Regulatory Guides. As we 4 said before, Reg Guide 3.134 is not a major change. In 5 fact, I hope it s,implifies lif e f or all of us, in that _ 6 it endorses an industry standard, without exception. 7 Reg Guide 1.8 is a little more complicated, but, again, 8 this is another place where we have endorsed the INPO 9 process. And if you are accredited, and in compliance 10 wi t h the INPO process, you will be meeting our -- you 11 will have an acceptable way to meet our regulation. 12 3.8 provides that for the positions of shift. 13 supervisor, senior operator, licensed operator, and STA, 14 you w$11 meet the eligibility requirements that you are 15 familiar with. Or, as we said in 5 5.31( 4 ), in lieu of 16 that, you can have an SAT based initial or l 17 requal j fication t raining program -- initial training l l 18 program, and a simulation facility acceptable to us. I 19 And these eligibility requirements, in effect, go away. 20 Because, under the SAT, you will have defined your 1 21 qualification and eligibility through your analysis 22 process. l 23 MR. RUSSELL: Let me clarify that, in that 1 24 they don't really go away. In the industry, through s 25 NUMARC and through INPO, has committed to ANS 3.1-1981,
1 and th'a t's. the same ' commitment that's in the generic l- y. F l 1 2 letter 84-36. .The same eligibility requirements are 3 also contained in each of the INPO training guidelines. 4 So,'in this case, the staff has already reviewed and 5 determined that the INFO guidelines, and criteria for
- 1. .
I- 6 accreditation ar'e equivalent to those'which the staff 7 has been requiring in the past. And, therefore, we need 8 not.have all of this information submitted if you are 9 accredited. . We will leave it up to the facility to make 10 that determination, and to conform to the industry 11 commitments that have been made to the NRC. 12 So,'they are not really going away. 13 DR. SHANKMAN: Okay. Right. 14 MR.' RUSSELL: You need not submit them to us, 15 and fill out _the f orms, and provide all of the 16 documentation. But you have already committed to INPO, 17 to-the accreditation process, that that's what you are 18 doing, and how you are handling it. So, it's not an 19 issue that you can all of the sudden start changing 20 eligibility requirements, and relaxing requirements for 21 what you. area doing now. We expect those still to be 1 22 met, you just don't have to submit them. 23 DR. SH ANKM AN: Thank you. Okay , in 1.8, we 24 have a3so changed the definition of a cold plant to k 25 match.what is now in 55.31(a)(5), under the control
1 Jeft Reg Guide 1.149 for Jerry, also. So, how io it
; - .I 2 different, now. Eligibility -- the detai3s of 3 eligibility are no longer required if you are INPO 4 accredited,,and have a simulation facility acceptable to 5 the NRC.
6 Medical examinations, every two years, the 7 same requirement. Renewal, six years, with NRC 8 administered requalification examination,- and operating 9 tests a requirement within the six year period. 10 Expiration, six years, or by the facility, and I think 11 we talked about how the facility could terminate -- 12 cou3d cause a license to expire. Requalification, 13 wrjtten examination up to ever two years, as-opposed to 14 a nnu e 3 .l y . Operating tests is now required annua 13 y, and 15 systematic evaluation is still required, using the INPO 16 guidelines for SAT. 17 Okay, Jerry? 18 MR. RUSSELL: Why don't we take a break, and I 19 then Jerry will come on. 20 DR. SHANKMAN: Okay. Well, you get a bonus, 21 you get an extra break, and Jerry Wachtel is going to 22 start with simulation facilities. We all know how to 23 say that word -- words. Okay. Just ten minutes, take a 24 stretch, and Jerry will be back here. l 26 (Whereupon there was a pause in the proceedings.)
i 1 MR. RUSSELL: We're ready to get eterted 4 1 1 _ 2 again. We are going.to shift gears for a minute, and 3 we're going to talk about hardware aspects, and, in 4 particular, the simulation f acility, plant referenced 5 simulator, and how we are. going to be transitioning into 6 using simulators as a requirement for an operating test. 7 And I would like Jerry Wachtel, f rom the staf f, to 8 present this Section. And, again, I would request that 9 you hold questions until we complete. We are going to 10 try and anticipate some of the questions in a 11 presentation. We will cover as many as we can this 12 afternoon. 13 Also, if you find that a question, toward the 14 end of the day, has not been answered, simply jot it 15 down, drop it in the same cardboard box that you put
~
16 your business cards in, and we Will incorporate 37 responses to those. questions in the new Reg. So, that 18 all questions that we receive, whether oral or written, 19 by close of business today, f rom this Region, will be 20 incorporated into that new Reg. 21 And we will get it distributed to you prior to 22 the effective date of the Rule. Jerry? 23 MR. WACHTEL: Thanks, Bill. Good morning. 24 I'm going to talk to you about simulators, or, as they 25 are now of ficially called, simulation facilities; and
Page 52 1 about their use in the conduct of operating tests. I'll L_ 2 divide my remarks into two phases. First, a discussion 3 of what is contained in the Rule, and in Reg Guide 4 1.249, and in the new NRC form 474. And then I will 5 describe, in some detail, the new program that we have 6 just developed to inspect simulation f acilities that 7 will be certified by you to the NRC, in order to comply 4 8 wi th the new Rul e. And I will talk a li t tle about your 9 opportunity to review and comment on our draft approach 10 to this inspection procedure. l 11 If I can have the first slide, please. If you 12 have been f ollowing along with the slides in your 13 handout, look for one entitled Subpart E, Written Exams 14 and Operating Tests, Continued. And this is the one 15 that deals with the conduct of operating tests. There 16 are three definitions that are of interest, here. The 17 definition of simulation facility, the definition of l 18 plant-referenced simulator, and of reference plant, q l 19 I'11 skip the definitions just for a moment, and I'll 20 tell you that the key element of Section 55.4 5(b), is 21 that for the first time, all utilities will be required 22 to have a simulation facility that is acceptable to the 23 NRC in use f or the conduct of operating tests no later 24 than May 26th, 1992. 25 There are two broad classes of simulation l
i Page 53 1 fac'ilities that may be used to comply with the p.i> i 2 Regu3ation, and all. util d td es w313 fit into one category 3 or the other,.unless they apply for, and are granted, an 4 exemption. The two categories, the first shown as 5 paragraph-(b)(1)(1) of-the Regulation, is a simulation. 6 facility which.the Commission has accepted --'or, 7 rather, has approved for use after application has been 8 made by-the facility licensee. And second, which is 9 shown in paragraph (b)(1)(2) of the Regulation, is a 10 simulation f aci3 3 ty consisting so3 ely of a plant-11 referenced simulator which has been cectified to the 12 Comm3ssion by the facility 31censee, i 7 13 Now, although these two approaches sound 14 similar, in reality, they are not. And we fully expect 15 that the overwhelming majority of utilities will meet the 16 Regu3ation under the second of these two categories. In 17 order to clarify the distinctions a little bit more, 18 3et's turn to the definitions that I mentioned a moment
.19 ago, on the next slide, please. You will find each of 20 these three definitions in Section 55.4 of the 21- Regulations. And, first, we'31 talk about plant-22 referenced simulator.
23 This is a simu3 ator modeling the systems of I 24 the referenced place, with with the operator interfaces ! 25 in the control room, including operat$ng conso3 es, and i i
Page 54 1- which permits the use of the ref erenced plant's
<. i i 2 procedures. A plant-referenced simu3ator demonstrates 3 expected plant response to operator input, and to 4 normal, transient, and accident conditions, to which the 5 simulator has be'en designed to respond.
6 A plant-ref erenced simulator is, basica13y, 7 that animal with which you are all familiar as the full 8 scope, high fide 35ty, site specific simulator. 9 Essentially, it is a simulator designed in accordance 10 with ANSI /ANS 3.5, the latest edition of which is the 11 1985. version, and which is endorsed by our Regulatory 12 Guide 3.149. 13 Our defini tion of plant-ref erenced simuJ a tor 14 is very similar to the definition of full scope 15 simu3ator that's in the ANSI Standard. With essentially 16 the only difference being that our definition includes 17 the statement that the simu3ator must permit the use of ' 18 the ref erenced plant's procedures. If I could have the 19 -next s31de, we ' l l talk about the definition of 20 referenced plant, also in Section 55.4 21 The referenced p3 ant is the specific nuclear l 22 power plant from which a simulation f acility's contro) 23 room configuration system contro) arrangement, and 24 design data are derived. This definition is identical 25 in a33 respects to the definition that is in ANS 3.5.
Page 55 1-And the third definition on this same slide, is that of 2_ simulation facility. This is defined as one or more of 3 the following components, alone or in ' combination, used 4 for the partial conduct of operating tests, for 5 operators, senior operators, and candidates. 6 One, the plant. Two, a plant-referenced 7 simulator. Three, another simulation device. And'this, 8 rea11y, is the key to understanding this Section of the 9 Rule. These definitions provide the understanding of 10 the two major approaches that a utility may use to meet 11 the requirements of the Regulation. If the utility has 12 a simulation facility that is solely a plant-ref erenced 13 simulator, in accordance with the Regulation, all that 14 utility needs to do is certify to us on NRC Form 474, 15 which has just been developed, and I'll talk about that 16 form in just a moment. 17 If the utility chooses not to ut d i j ze a 18 simulation facility that is solely a plant-referenced i 19 simulator, then they are required to f ollow the second 20 path under the Regulation, which is that they will use i 21 the simulation facility which the Commission has i: 22 approved for use, after the utility has submitted an 23 application for its use. And here is where the 24 definition of simulation facility becomes relevant.
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1 25 Reca11 from a moment ago, that the simulation j i t
- _ _ . I
Page 56 1 facility may consist of one or more components, used It
'.k 2 alone, or in combination, to enable the operating exam 3 to be conducted in accordance with the Regulation.
4 Those components, as I said, may include the plant, the 5 plant-referenced simulator, or some other kind of 6 simulation device, or combination of devices. But the ! 7 burden in f ollowing this path is on the utility, to 8 submit .to us a detailed application, telling us just 9 what the simulation facility is, how it will be used, 10 and which of its component parts will be used to perf orm 11 the different component categories of the operating 12 test. 13 If I could have the next slide.
, This slide is 14 sub-titled, Implementation of the Simulation Facility, t
15 and it discusses the schedule that is described in 16 Section 5 5.4 5(b) ( 2 ) . For those utilities who choose to 17 use a simulation facility that is not a certified plant-18 referenced simulator, they must submit a plan to us by 19 May 26th, 1988, one year from the effective date of the 20 Regulation, that explains what they intend to do in 21 order to meet the requirements of the Regulation. I 22 Then, no later than Noveinber 26th, 1990, 23 which, if you are counting, is forty-two months after l 24 the effective date of the Regulation, they must submit 25 an application for NRC approval, in accordance with the , I l c 1
s L Page S7 l l 1 plan which they submitted earlier. For those utilities I [ 2 who do intend to certify a simulation facility that is 3 solely a plant-referenced simulator, they will have 4 until May -- rather, March 26th, 1991, forty-six months L 5 after the effective date of the Regulation, in order to l 6 submit-this certification. l 7 In the case of certification, and the 8 submittal of a Form 474, there is no requirement for the 9 submit tal of a plan, and there is no requirement f or the 10 submittal of an application f or approval. All you need 11 do is submit the certification on Form 474. And keep in 12 mind Susan's discussion of the 398 form under Subpart D i 13 applications. Remember, that in lieu of details about i 14 an applicant's qualifications and training, the NRC will i l 15 accept certification that the applicant has successf ully 16 completed the INPO accredited training program, that uses 17 a simulation fac3lity acceptable to the Commission under 18 5 5.4 5 (b) . We hope that this will provide the incentive 19 for many utilities to certify, or to seek approval of 20 their simulation f acility well before the f our year 21 requirement has been reached. 22 And, again, a simulation facility that is , 23 acceptable to the Commission means either of these two 24 approaches. Either a certified approach, or one that 25 has been approved by the Commission after you submit an
Page 58 1 application. The remainder of Section 5 5.4 5 (b) provides
!2 more deta13 s about the requirements for the submitta) of 3 periodic reports on simulation f acility perf ormance 4 testing, and I won't go into more detail, here. We can i
5 go into much more detail later, if there are specific 6 questions. 7 I do, however, want to highlight a few 8 paragraphs, just to clarify their meaning. First, l 9 Sect.lon 5 5. 4 5 (b) ( 3 ) , talks about the schedu3e for o 10 e,acility applicants. This refers to clients, not to 11 individua3, and it can probably be ignored by most 12 everyone in this room. { 13 HEARING ATTENDEE: (Mr. W1331ams) Where are 14 you, Jerry? 15 MR. WACHTEL: 5 5.4 5 (b) ( 3 ) . There is a whole 16 section there that references the schedule for facility 17 applicants. We are really dealing, here, with facility 18 licensees. The applicants are only those who are not 19 yet considered facility licensees. I just want to make 20 clear that wc're talking about plants, here, and not 21 Individua3s. 22 The second note, paragraph 5 5.4 5 ( b) ( 4 ) (11 ) . 23 This paragraph refers to the process of NRC approval of
, 24 app 3dcations for non-certified simulation faci)dties.
t 25 It says, and I quote, "The Commission w131 approve a
i Page 59 i simulation facility, if it finds that the simulation I _ 2 facility, and it's proposed use, are suitable for the 3 conduct of operating tests for the facility licensee's t 4 referenced plants in accordance with paragraph A of this 5 Section." ; 6 In other words, the Commission will tie its l 7 approval of a non-certified simulation facility to the 8 demonstrated ability of that simu3ation facility to 9 conduct operating tests at the referenced plant, in 10 accordance wi t h 5 5.4 5(a). 11 The third item that I want to ca 3 3 to your 12 attention appears two times in the Regulation, once as 13 paragraph (v), in Section (b)(4), where it applies to
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14 non-certified simulation facilities, and, again, as 15 paragraph (iv), in Section (b)(5), where it applies to I 16 certified simulation facilities. These words say that, 17 if the Commission determines, based on the results of I 18 performance testing, that a simulation facility does not 19 meet the requirements of the Rule, then it may not be l 20 used to conduct operating tests. I l' 21 The bottom 31ne of a3 3 of this, regardless of l 22 which of the two options is chosen by a utility, is 23 shown in paragraph (b)(2)(iv), at the bottom of this 24 line. And it simply says, "The simulation facility 25 portion of the operating test wil3 not be administered I
Pogo 60 1 on other than a certified, or an approved simulatier. 1 _ 2 fac33dty after May 26th, 1991." , l l 3 So, what we are saying, is that four years 4 from the effective date of the Regulation, the operating 5 test wi33 be administered in both a plant walk-through, 6 and in an acceptable. simulation facility. If, after 7 that date, there is no acceptable simulation f acility, i 8 there is no operating test. Now, there may be many 9 unanswered questions about just what a simu3ation 10 facility has to be able to perform. What happens if it 11 is temporarily unavailable f or use, or how we intend to 12 treat those simulation facilities which are used for 13 mu3ti-unit stations, or for multiple plants. 14 Most of these questions have been addressed in 15 the Statement of Considerations that precedes the Rule. 16 Specifica 3 J y, the Section called Definitions, and the 17 Section ca] 3 ed Simulation Facilities. And in Reg Guide 18 1.249, which, of course, has been revised to reflect the 19 changes in the Rule. And we can deal with specific 20 questions this afternoon. 21 If you can give me slide number six. j 22 MR. RUSSELL: Jerry, before you go on, I would 23 31ke to emphasize the last portion, that is, the conduct , l ' 24 of the operating test. If either you have not 25 certified,'or received approval by May 26th, 1991; or, i 1 l l
._ ._ . ]
Wege G1 I 1 as a result of an inspection ofter that date, the .
, I i 2 Commission determines that your simulator is not 3 acceptable for the conduct of an operating test, we 4 would stop giving operating tests, and you would stop 5 giving operating tests as a part of your requalification 6 program. Recognize that the Regulations require that 7 f or an operator's license to remain current, he must 8 have an operating test annual. Which would mean, if the 9 condition persisted, you would find yourself in a 10 situation where you would no longer have licensed I 11 operators, and you would impact the operation of the 12 facility.
13 HEARING ATTENDEE: Jerry, could we address? 14 MR. RUSSELL: We 'l l cover that in much more 15 detai) 3ater, I just want to emphasize that at this 16 point, that we are talking about stopping testing, 17 stopping 33 censing, and not being ab3 e to meet 18 requirements for requalification programs, which are a 1 19 condition of the Part 55 operator's license. 20 MR. WACHTEL: Okay, if I can have slide six, 21 there, Kurt. Your next s31de shows Form 474, I'm going 22 to skip over that for just a minute. We come to the 23 s)$de on Reg Guide 1.149, now titled Nuclear Power Plant 24 Simulation Facilities f or Use in Operator License 25 Examinations. As I mentioned earlier, the Reg Guide l l
r Page 62 1 endorses ANSI /ANS 3.5-1985, with minor exceptions. It _' 2 endorses the specific list of performance tests 3 identified in the Standard, but states that those test 4 should be perf ormed over a four year cycle, twenty-five 5 per cent per. year. 6 It endorses both of the two appendices to the 7 Standard, which deal with performance testing, and 8 operability testing, respectively. And it provides 9 guidance for those utilities who want to use one 10 simu3ation facility, at more than one plant. That's 11 toward the back of that Reg Guide. Now, let me turn to 12 the simulation f acility evaluation procedure, or SFEP, 13 which has just been developed. 14 The Regulation provides that once a facility
-t 15 31censee either submits a certification for a simulation 16 facility, which is solely a plant-ref erenced simulator, 17 and meets ANSI /ANS 3.5-1985; or submits an application 18 for approval of another type of simulation fac133ty, 19 then the NRC may inspect, or audit that simulation 20 facility, or its associated documentation. We 21 anticipate, as I mentioned earlier, that there will be 22 very few utilities who propose to go the non-certified 23 route. And we expect that any simulation facilities 24 that are proposed under this application and approval 25 path will require a case by case approach, f rom the time
Page 63 1 .that they first submit their plan'to us, or even
- l
_ .2 earlier, i 3 However, f or the majority of utilities, those 4 who will submit a certification for a plant-referenced 5 simulator, we haye developed a Form 474 for this 6 purpose. We have also recently completed the ' 7' development of a program to review the certifications,, 8 and the performance test abstracts, and to conduct 9 inspections of simulation facilities which are certified 10 to us on Form 474, and I'll talk about that program in 11 just'a minute. If I can have the slide on Form 474. 12 The certification process begins when the utility 13 submits this Form 474, which has recently received its 14 OMB approva) , and is available through our normal 15 dist ribution channel s, called Simulation Fac131ty 10 Certification. 17 As you can see, the form requires the 18 certification by the f acility's authorized 19 representative, under penalty of perjury, that the 20 simulation facility meets the requirements of 10 CFR 55, 21 as well as the guidance in ANSI /ANS 3.5, as endorsed by l 22 Reg Guide 1.149. If I can -- the signature of the 23 authorized representative is down here (indicating), and
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24 - the certification, which I can't reach, way up there, 25 indicates the certification to meet the rule, and meet 1
Page 64 1 the ANSI Standard, as endorsed by the Reg Guide. I
-"~~l i 2 you are also certifying that documentation in 3 support of the certification is available for NRC 4 review. We have provided the opportunity, on Form 474, 5 to indicate whether there are any exceptions to your 6 meeting ANSI /ANS 3.5-1985, and that's right up here, as 7 well. Because we recognize that at any given point of 8 time, any particular simulation facility is not 9 necessarily going to be in perfect sync with the plant 10 configuration, and that there may be exceptions that you 11 will have to take.
12 The Form also asks you to submit details about 13 performance testing that you have undertaken prior to 14 submittal of the certification, and it asks you to 15 submit details of your schedule of performance testing 16 over the next four year cycle. 17 Now, let me describe very briefly the SFEP, or 18 simulation facility evaluation procedure. The next 19 couple of slides were taken from another presentation l 20 that I made earlier this week, and you are not going to 21 find them in your handout. If I can have the first one. 22 First, what is the purpose of the SFEP. As I just 23 mentioned, it standards for simulation facility 24 evaluation procedure, and its purpose is to insure that 25 certified simulation f acilities comply with the i
Page 65 l I requirements of Part 55.45, and with ANSI /ANS 3.5-1985, i _. 2 as endorsed by' Reg Guide 1.249, 2 As I mentioned, the certification of a 4 simulation f acil,ity gives the NRC the right to inspect I 5 that simulation facility, or its supporting c documentation. The question comes up.as to what might 7 cause the NRC to select your simulation facility for i 8 such a r(view or inspection, after certification has ' 9 been submitted. If I may have the next slide. 10 First, we may simply choose to perform .) 11 inspections of certified simulation fac1]ities on a 12 random basis, depending upon constraints of manpower, 13 and what have you. Second, details that you have 14 submit t ed to us on your Form 4 74 could lead us to 15 conduct a review of your simulation facility. If there l 16 are any possible, or obvious, .or apparent discrepancies 17 in the information submitted on the Form 474. If there 18 are questions that we have about the Form, or about the I 19 data that you have supplied to us in support of the q l 20 form, this could lead us to come out and conduct an 21 audit. 22 And, third, feedback from our License 23 Examiners could lead us to conduct a review. Although, 24 I should stress that Examiners, acting on their own, 25 will not be empowered to conduct such reviews of their
Pcge 66 1 own. You will-hear more about the Examiner % role in I l i 2 provjding feedback to this plan a little later this 3 afternoon. 4 If the NRC determines that a review of your 5 simu3 ation f acility is appropriate, we will first review 6 the data that you have supplied to us in support of your 7 Form 474, and we will request whatever supporting 8 documentation may be necessary to enable us to perform a 9 desk to, or off site review of your documentation. The to resu3ts of that off site review may tell us that 11 everything is wel 3, that our questions have been 12 answered, and that there is no reason for us to go any 13 further, at that point, in the inspection of your 14 simu3ation fac535ty. 15 At that point, we may determine that issues 16 are reso3ved, and there is no need to go beyond it. Or 17 we may determine that certain issues are not resolved, 18 or there may be continuing causes for our question about 19 the fide 35ty of the simulation facility, the results of 20 your performance testing, your adherence to the 21 Regulation, an ANSI /ANS 3.5-3985. If this is the case, 22 then we wil3 schedule an on site inspection of your 23 simu3ation faci 35ty, and we will notify you of such. 24- We have done some pilot testing, and I'11 talk 1 ., ! 25 about t ha t very brief ly in a minut e, tha t te13 s us that l l
i Page 67
,1 this on si t e inspection, should we have a need to
;i.
_. 2. perf orm tha t , wil .1 take us no more than one week, on 3 s' i t e . And at the end of that week, we will have a 4 pretty so31d idea as to whether or not the simulation
-5 facility passes muster. If it does, then all is fine,
.6 and if not, we wou3d intend to work with you, depending 7 upon'the severity of the failures of the discrepancies 8 that we identified, to get'the machine back in shape for 9 the conduct of operating tests.
l 10 If I couJd have the next slide. There are, 11 essentia)Iy, f our levels at which discrepancies night be 12 found as a result of our on-site review of performance
. 13 testing that may have a potential impact, in our 14 judgement, on the ability to use your simulation 15 facility in the conduct of operating tests. For the 16 first 3 eve 3, discrepancies that might have little or no 17 adverse impact on our ability to conduct an exam, then 18 the staff w133 recommend to the facility licensee that 19 those discrepancies be corrected. And I underline the 20 word recommend.
21 If the discrepancies are determined to have a 22 minor, but definite impact on the ability to conduct an 23 Exam, then the staff wi13 require that those 24 discrepancies be corrected, as part of the u t i l i t y 's 4-25 ongoing simulator upgrade program, in accordance with ,
Page 68 1 the terms of the ANSI Standard, and ir, your
,I
_ 2 configuration management approach.
}
3 If the discrepancies are found to adversely
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4 affect the NRC's, ability to conduct a reliable exam, on 5 a given procedure, system, or event, then the staff wi23 1 6 require that they be fixed on an accelerated schedule. 1 7 And, finally, what I guess I would call our ultimate 8 weapon, which we would hope never to have to use, is 9 that if the simulation facility has such discrepancies i 10 that they great 3y hinder our abd31ty to conduct an exam, i 11 then we will order that the simulation facility not be 12 used unt13 those discrepancies can be corrected, and
. 13 unti3 the facj3ity 3Acensee can recertify it on Form 14 474, to the NRC, 1!> I should say that Form 4 74 is a one time 16 event. Once you submit a Form 474 the first time, 17 t ha t 's a l l you ha ve t o do, un3 ess we find that there are 18 reasons to pull that certification, in which case you 19 w113 have to recerti f y. And there is a b3 ock on Form 20 474, that indicates decertification.
21 In the Statement of Considerations that 22 precedes the Regulation, we said that we would not begin
- 23 to conduct simu3 ation f acility reviews until the 24 guidance to be used in the conduct of those reviews had f 25 been f u13 y developed, and was pub 3 d cly availab3 e f or a l
I
1 period of six months. That guidance now exists. It is [ l < l' l [ 2 ca3 led NUREG 1258, it's in draft form. And, i 3 hopefully, you all picked up a copy of the blue document 4 in the shrink wrapping when you came in this morning. 5 It's this guy. (Indicating). 6 It is' titled " Evaluation Procedure for j 7 Simulation Facilities Certified Under 10 CFR ' 5 5." In 8 addition to the copies we have made available here 9 today, we have mailed copies to. all utilities through 10 our norma 3 distribution channels. In addition to having 11 it available public3y f or six months, which is now 12 underway, bef ore we begin to use it; we will welcome
; 13 your written comments on this draft document for a 14 period of sixty days, to coincide with the sixty day 15 period, until the Rule takes effect.
16 So, until May 26th of this year, we will 17 accept your written comments. And the address of the 18 Chief of the Operator Licensing Branch, to whom they 19 should be sent, is in the document. And we will 20 endeavor to take whatever comments you have into account 21 in the preparing the final issuance of this NUREG. 22 And it is our intention to begin use of this inspection 23 procedure within six months. 24 HEARING ATTENDEE: Sixty days, and we've just 25 got the document in our hands, does not end on May 26th.
Page 70 1 If we can have some latitude, there, to get our comments [l 2 in. I understand you have to have a definite period'of 3 time, This is the first time we've seen the document, 4 s o ,' therefore, we really don't have sixty days to review 5 it, and comment on it. 6 MR. WACHTEL: This is an informal comment 7 period. It's not anything required by th'e Regulation. 8 If they don't go through the normal docketing process, 9 and I guess it's our f eeling that there is plenty'of 10 time to read through it, and get your comments to us. 11 But we will consider them all. 12 MR. RUSSELL: Let me add to the discussion of 13 potential outcomes from an inspection, to make sure the q 14 people understand that. In the first case, a 15 recommendation, you could choose to dispose of that 16 recommendation by simply documenting the discrepancy, 17 and concluding it's acceptable, and choose not to 18 correct it. i 19 In the second case, it would be a discrepancy ] J 2J which the standard would require to be corrected within l 21 the normal two year cycle that's provided f or in the. 22 Standard. And that's what we mean, just fix it on that 23 cycle. In the third case, Jt's a situation where we 24 cannot conduct some portion of an operating test, but we
.t 25 may have flexibility, when you choose to use another
Pcge 71 I scenario, another procedures, and we f eel we still i i i 2 conduct a meaningful test. But we want that to be 3 corrected, such that in the future we could examine on a that particu3ar procedure or component. 5 So, we wou3d require that to be corrected at 6 some time frame less than the two years, but would a 3 J ow 7 us to examine, for instance, on the next cycle in that 8 area. And the latter one, is the one where it fails to 9 meet the standards for conducting an exam. We w133, 10 through the process of the ninety day 3etter, prior to 11 the examination, request the facility identify any known 12 discrepancies with their simulator, which would impact 13 the conduct of the operating test. 14 The purpose for that is so that we don't go 15 generating scenarios, and plan on using portions of a 16 test which cannot be conducted. It's a practical 17 consideration. But that's the mechanism that we intend 18 to use to implement this, and in following the Standard. J i 19 And that we are trying to show that there are a spectrum 1 , 20 of out comes. And we wil 3 talk about it a lit tle more j 1 21 when Jerry talks about the pilot test that was done at 22 North Anna, and used this process on a trial basis, to 23 discuss the significance of the findings at North Anna. , I 24 As I reca 3 3, this was done prior to their having 25 certified. i l
Page 72 1 But we went through a mock evaluation of each
, I' 2 of the deficiencies we identified, and tried to use them 3 in this context. The majority were the type that would 4 have little or no significance on an operating test.
5 MR. WACHTEL: Okay, I wasn't planning to go 6 into detail on the pilot test, because it is all 7 contained in that NUREG in great detail, and I didn't 8 think it would benefit us all to go through every step 9 of the tests we choose, and how the pilot test facility 10 performed. Perhaps it wou3d be best to cover those 11 during the discussion period this afternoon. 12 But, that's really all I've got on this 13 portion, on the 55.4 14 HEARING A*11E NDE E : Cou3d you make copies of 15 those new drafts available to us?
. 16 MR. WACHTEL: Yes.
17 Mr RUSSELL: Yes. What we are going to do, 18 is we're going to change the agenda, slightly. I'31 19 pick up, now, and go into the changes to the appea3 4 1 20 process, and the hearing process that's described in 21 Part 2 of the Regulations. And, then, we'33 cover some ] 1' ! 22 of the issues associated with the Examiner's Standards, 1 ., 23 and we may be ab3 e to cover the p.lanned presentation I
- 24 before we break for lunch. Then, we'll come back after i 25 Junch and take questions.
Page 82 I have done -is significantly simplified the form. And I 2 I'l l show you-the current version of it in a minute. 3 And I'l l trust you would agree, that it is a 4 simplification over what we've been using. 5 We hav,e made a sincere ef f ort to tie the f orm 6~ directly to 30 CFR Part 55.45(a); the thirteen parts of 7 the operating test. And I'll show you how those 8 groupings appear when we look at the~ form, itself. The 9 next slide. We have tried, as I said, to group the 10 topics that are covered in the operating test 11 functionally, and relate them back to the specific point 12 in the Rule,.where they are addressed. 13 We do have provisions in the form for treating 14 a candidate at a f acility that does not have an 15 acceptable simulation facility. You will see that the 16 form is pretty much the same for both cases, either 17 using a simulator, or not using a simulator. So, we are 18 going to be trying to tailor the evaluation of a 19 candidate in a non-simulator environment, to come up I 20 with an equiva. lent judgement. One that, as c.l osel y as 21 we have, approximates the judgement that we would have ! 22 gotten had we had a simulator available. 23 And we have finally decided to either make our i 24 determination that the candidate is either satisfactory, 25 or he is unsatisf actory. We will no longer be using the 1 L
50, ; Page 83 1 marginal marks that we have used in the past. Okay, 4 I ~ b 2 now, let's take a quick look at the form cover page. It 3 has a typo.that says 157, I think it should -- no, that 4 n is' correct, the second page has a typo on it. 5 Notice how it's laid out. It's designed to be 6 used for any type of exam that we would administer, any 7 type o f ' ope ra t ing tes t. I think we have covered all of a the possible combinations, here, including both power 9 and non-power reactors. We think that's a 10 simplification over what we have been using, because of 11 the multiple forms that were used in the past. The next 12 slide. Here is the one with the typo, i t 's 3 7 5, and i t { 13 should be 157. 14 These are the administrative topics that are , 1 i 15 covered on the operating test, and we've, as I ) l 16 mentioned, tried to group them functionally. And in the ! I 17 examiner's standards that will accompany this revised 18 form, the 300 series, we will attempt to, in the 1 19 narrative -- in the description to the Examiners, as to i 20 how these f orms will be used. We will tie back to the 21 Regulation, each one of these functional groups. Okay, 22 the next slide. 23 Okay, in the operating test, it will be 24 necessary to cover a number of systems in the control 25 room, and we have identified them on this slide. Also, i l
Page 84 1 the. facility wolk-through, one. thing I'll point out, is 9 I L- 2 t ha t 'we' are making a change that will have an impact. w 3 And that is that typically, SRO upgrades were generally 4 not given the facility as part of the walk-through in 5- the past. They were given the control room systems 6 portion. And what we are going to be-doing, effective 7- with the new Part 55 operating test administered after 8 May 26th, we will, . on SRO upgrades, be actually 9 conducting plant walk-throughs. Because we feel i t 's 10 important to have these candidates demonstrate their 11 ability to supervise things outside of the control room, 12 for example, a shutdown frcm outside the control room. 13 So, we w133 be including that on the SRO upgrade. 14- The.next slide. Now, the next page in this 15 form, actually, is basically the same page for both a 16 simulation facility, and one that hasn't an acceptable 17 simulation facility. This one, here, would be'used if 18 the simulation f acility is available. You notice some 19 .of the terms up there, are terms you have probably seen 20 before in our 302 forms -- Ex a m i ne r 's Standard 302, t 21 where we look at the eight competencies. We ' l l still be 22 doing that, there hasn't been any change, there. And we 3 have tried to pull a number of dif f erent things in on 24 this one form, for each of Examiner use. 25 So, we have taken a number of f orms in the old L l- _
Page 85 1- 302 Examiner's Standard, and combined it into this one. 1 -1 C 2 Okay, this'one is for, as I mentioned, for the case 3 where the facility has a simulation facility-that is 4 ava33ab3e, and acceptable for use. The next one is in 5 case, notice the resemblance. This one would be used i f' 6 there was no simulation facility available. 7 A3so, the chief Examiner will be given the 8 responsibility to identify candidates in the group that 9 would be audited under Part 2, the start-up ! 10 certification audit. So, genera 3 ly, there w333 be one 11 or two f olks that wi) 3 be 3 ooked at in that area, in 12 each. examination group. That particular item is not 13 app]icable in requal exams. Is that the last slide? 14 One more. Okay, one more slide. l 15 And this is the f orm that we wi 3 3 be prov j ding 16 for the Examiner to document, and expand upon any 17 observations that are made during the operating test. I 18 don't have anything else on this. 19 MR. RUSSELL: Rather than breaking for lunch 20 now, what I wou 3 d 31ke to do is have John Munroe go over 21 some of the other changes to the Examiner's Standard. 22 And, then,-we wi33 break for lunch, and come back and 23 take questions. And we w333 start with some of the 1 24 questions that have been pre-submitted, or questions l 25 that we received during the break, that we have not j
( Page 86 1 1 answered.
^ l<- t id ' 2 MR. MUNROE: Jerry Wachtel and Ken Brockman-3 are_ going to be handing out the handouts for this 4 presentation. There will be no overheads for this one, 5 but the handout should be sufficient. Basically, let me 6 star't off with some general comments, which I think will I
7 be pretty obvious, even without the handout. They are B on the handout, but the way. 9 The Examiner's Standards have to be changed in l 10 certain areas, and as just was previous discussed, the 11 300 series is being changed because of_our change in the 12 operating test to meet the new Regulation. Revision 13 four'to the Exami ne r 's Standard will be a complete 14 reissue of the Standards. There will not be a partial 15 reissue of just changed Standards, it will be an entire 16 reissue, Standards that have changed and have not 17 changed. 18 The common changes in the Standard, and there 19 are going to be a f ew of those, simulation f acility now 20 substitutes where the word simulator used to be. And 21 that is obvious, based on the new Regulation. The 22 paragraph numbers that related to the old 20 CFR 55 will 23 change to correspond to the nex 10 CFR 55. Facility 24 licensee substitutes for the prior term of licensee. We 25 have also made grammatical correctior.s where the wording I-4
Page 87 1 was poor. And we have added a statement numerous
< l
_. 2 P3 aces, that-after nineteen -- after May of 1992, 3 operating tests will not be administered on other.than 4 an acceptable simulation f acility, which is stated in 5 the Rule.
- 6. Thus, as you can see from the general 7 comments, most changes result from Part 55 revisions. I 8 think I can te)I that almost everybody has the handout, 9 now, and that is essentially the first page of the 10 handout.
11 The first Standard that has a significant 12 change, and jt has to do, primarily, with our 13 requirements, not yours, is Examiner's Standard 204, 14 ' procedures for post examination activities. And this 15' incorporates a f orm ca3 3 ed simu3 ation f acility 16 evaluation feedback, and the form is the simulation 17 Facd33ty Fide 31ty Report. This is a report that we have 18 to prepare, and submit to Headquarters within thirty 19 days after we complete the examinations. 20 And, basically, the purpose of the form, is to 21 document problems that we, as Examiner, see during the 22 course of the simulator exam; and also, concurrently, 23 ddentified with the he3p of your simulator instructor, 24 who is running the machine with us. The purpose of the 25 report wd33 be used by the NRC Simulation Facility l.
1 Evaluation Team, which, ce part of its function, will do I
,_ 2 periodic reviaws at certified, or approved simulation l
l 3 facilities, tc comply with 30 CFR 55. l l 4 The report may generate an audit, depending on 5 the degree of problems on the simulator exam, although 6 it may not. B a s'i c a l l y , we have to provide specific 7 data, b'ut include as sauch deta'il as possible. And what 8 we are 3 coking at i s -- wha t 'we are also l ooking a t , as 9 well as the simulator, as it performs, for example, 10 during transients. We. are also looking at physica3 11 fidelity. In other words, did the control room switches 12 match the Jocation on the simulator? In functiona3 13 fidelity, how does it perform during abnormal, normal, 14 and emergency conditions. 15 Basica3ly. that's the form, and that 's rea 3 3 y 16 our problem, and we will submit that. The next Standard 17 that we are invo3ved with, is Administration of 18 Examinations of Multi-Unit Power Stations. And, quite 19 simp 3y, the change here is, some of the words in the 20 Regulation that have to do with what must -- the three 21 conditions, per 30 CFR 55.47, that an applicant must 22 have to get a waiver. Some of the words have changed a 23 31 t t l e bi t. And we have just added those words int o the 24 Standard. 25 Essential 3y, it wi31 be business as usual for
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I { Page 89 1 administration of exams at multi-unit power stations, I I L_ 2L There is no significant change if you are a multi-unit 3 power station, and you have been getting dual unit 4 exams, you w333. continue to get dual unit exams, l 5 Examiner's Standard 107, Pre-Administration 6 Quality Assurance Program. One of our check-offs, now, 7 'js that we review to insure we have a representative 8 samp31ng of the items listed in the Regulation. i 9 Ultimately, this representative sample wil 3 be 10 determined by the Examiner's Handbook, which is NUREG u 11 2121. That Handbook is not issued at this time. Until
'12 that time, we w133 be utilizing the Examiner's Standards
'13 as they. exist, for instance, in the 200 series, which 14 de31neates the percentage of questions, and the areas 15 that we wil3 investigate, as our guide for the l 16 representative sample.
17 Examiner's Standard 109, Eligibility l 18 Requirements. The changes, the wording of the five j I 19 significant reactivity manipulations, to five ) l 20 significant control manipulations, to match the i 21 Regu3ation wording. It eliminates the requirement to ! 22 submit training experience and education details, that's 23 b3ocks twe3ve and thirteen, on the 398 Form, for
/' 24 programs that are INFO accredited, and have an
'i l
25 acceptable simu]ation facility. And for a p3 ant- l
. . . .a
1 ' referenced almulator,.that would be'one that has been o l- _. 2 certified via the certification form. 3 It extends the term of license to six years, 4 for renewal. It adds an. Item to be looked at, with 5 regards to an individual's past performance, and with 6 regard to whethe'r it's been satisfactory, or not. And, 7 also, for renewals, it specifies an operator must pass a 8 comprehensive requalification written exam and operating 9 test, administered by the NRC, at least once during the 10 time of the license. And, once again, these words are 11 straight out of the Rule. 12 On Examiner's Standard 203, this is the 13 Standard that has to do with -- the part that's changed 14 has to do with the mat eria) we request f or the wri t t en J 15 examination, and operating examination development. An 16 item has been added to.the Enclosure.One, to what's l I 17 typically call the ninety day letter, which we send to 18 you. Enclosure One delineates the material we need for l 19 the examination, and the item that's been added is 20 identification of any known performance test failures 21 that have not yet been corrected on the simulator. 22 And Examiner's Standard 301, John just talked 23 about that, and so we won't go ever it any further. The 24 form is being developed, and the Standard must be . 1 25 changed to match the form. Requalification, the key l l
1- thing here~10, it reiterates, once egain, that.all m: _ .2 operators must be' examined by the NRC prior to licence 3 renewal. And there is a maximum of six years between 4 the NRC exams. We talked about that just a second'ago. 5 And that NRC exams -- requal exams will be 6 conducted randomly, in conjunction with replacement exam 7 site' visits. In the past, we have tried -- the Standard 8 has talked about, basically, gearing our exam -- our 9 requa3 examination effort to the program. Typica33y, 10 what that means, is the facility gives their annua 3 i 11 written examination in November, we try and gear our on-12 site visit to that time frame. This a33ows us to, 13 basica] 3 y, make better use of our manpower, and if needs 14 arise, to come out and give the examination, other than 15 during the example of the November time frame. 16 So,.there is a possibility that some 17 examinations for requalification may be dove-tailed in 18 with hot 31 cense rep 3acement exams, such that if your 19 requal ends in December, and we're coming out in June, 20 we may, additionally, conduct the ES-603 requalification 21 examination program, to make better use of our 22 resources. 23 And that is, in essence, the changes to the 24 Examiner's Standard. As you can see, a lot of them are 25 simply word and number changes, to match the Regulation i i I __ .__-__.__4
Pcge 92 1 identically. Some with no intent changes in many areas. f 2 Other do have intent changes, due to the Regu3 ation have 3 intent changes. Basically, I think that we are' ready to 4 break for lunch. 5 MR. RUSSELL: Is 12:30 enough time for 6 'everyone to get lunch -- between now and 12:307 7 MR. GIBSON: Who would like more time than 8 12:307 (No response.) Be back at 12:30. 9 (Whereupon there was a pause for luncheon.) 10 11 12 13 14 15
)
16 17 18 I 19 20 21 22 23 24 26 l
Page 93 1 AEIEEEppE
,r 1 2 MR. MUNROE: Okay, I think we are ready to 3 start the afternoon session. If I could have your 4 attention. The afternoon session is a little off the 5 agenda, as you- can tell, because we finished up some of 6 the others we had, in the morning. So, basically, the 7 ' afternoon is going to be a question and anUwer period, f
8 We have a panel', here, to help answer the questions, if 9 necessary. j to At the start of this, however, we will not 11 necessarily open the floor for questions i m m e d i a t e l y., 12 al though you will allow to ask questions. We have had I 13 submitted to us, for this meeting, three sets of 14 questions, One set from the Southern States Nuclear 9 15 Training Association, one set from South Carolina 16 Electric and Gas, and one set from KMC. And what we 17 were going to do, is use those questions that were j 18 submitted in accordance with the Federal Register to 19 kind of guide the topics along. We may not get to every 1 I 20 single question on here, but the questions that we do J 21 not get to will, indeed, be answered in the NUREG i 22 that's put out. 23 There may also be some analogous questions 24 from organization to organization, because they, L 25 obviously, did not necessarily bounce their questions l l
+
l
Page 94 1 against each other. That-being kind of the afternoon.
. i,
_ 2 If you desire.to ask a question, for transcribing 3 purposes, what we need is for the individual, as best he ! 4 can, to make his way to one of the two microphones in l 5 the aisles. Pr6 vide his name, company affiliation, and 6 the part of the Regulation, or Reg Guide, or whatever, 7 they are referring to in their-question. And that w133 l 8 he]p us keep track for our answers in the NUREG. .! 9 So, to start off -- well, the questions wil] ; 10 be b3ocked into three major groupings. The first ; 11 grouping w131 be questions that bear primarily on the 12 Rule, 30 CFR 55. The second set of questions w$33 be 13 those which are also associated with the Rule, but i I 14 hinge, primarily, on the simulator part. And the third ) I 15 . part, obviously, is with the Rule, also, but hinge in i 16 the-area of requa). I 17 So, I'33 open up -- I guess what I'm going to l 4 18 do, is I'm going to read the questions. If you can't 19 hear me, or don't understand the questions, fee 3 free to 20 say so, and I'll do it again. I'll try to enunciate as 21 best I c an. And I'm going to start of f with the j 22 Southeastern Nuclear Training Association submittal. 23 And I '. m sure some of the people out there may have that. 24 The first question had to do with 25 supplementary information and background. And the
Page 95 1 quest ion was , "Wil 3 the issue of revision 10 CFR 55 l- I E 2 cance] NUREG 0737, NUREG 0094, and the Denton 3 3etter? If so, will references to these documents be 4 removed from NUREG 10217" 5 Basically,. when NUREG 2 021 was gone through, ; 6 references, and the items left in 1021, are those items 7 which are required to be there by the Regulation, or Reg 8 Guide 1.8. The items from NUREG 0737 and 0094 that 9 are superseded are on3 y those-items that have to do wi t h i 10 the operator licensing area in those documents. So, 11 those documents are superseded. Reg Guide 1.8 items are 12 those that are' incorporated into NUREG 1021, rev four. 13 And some of those items, though, may be very similar to 14 what was there in the past, due to NUREG 0737, or-New 15 Reg 0094. 16 For examp3e, four years of power plant 17 . experience was in the NUREG 0737 and Denton l e t t e r 's , 18 and it's stil3 in Reg Guide 1.8; and it's stil3 in New 19 Reg 1021. Are there any questions? I won't ask for any ; 20 questions every time, but if there are questions, just 21 shout them out, or identify yourself. 22 Then we go on to another Rule question, 23 Subpart A, Section 55.4, "When the operations manager is 24 31 censed, shou 3 d technical advisors or licensed
]
25 instrbetors have to become members of a shif t crew to
Page 96 i maintain an active license?" To maintain an active ;
.I' I
_ 2 31 cense, they do. To maintain their license, they ! 3 don't. Okay, to maintain their license,.they just have i 4 to maintain the conditions of their license, which j 5 include being up to date in requal. But to maintain the l 6 license active, they must meet the time requirements of t 7 the Regulation. ! 8 "Do these personnel require an active license, 9 if they must maintain a license for technical 10 specifications or FSAR?" They must have the license for 11 the Technical Specifications, but it doen not have to be l 1 12 " active" per the Regulation. ! i l 13 "Do these personnel have to replace a member i ja of a shift crew to meet the watch Standard requirements l t i 15 of 3 0 CFR 55.537" Yes, t hey do. I f t h e'y w i s h t o g o l 16 back and actively direct, or. manipulate, as an SRO, or I 17 to manipu3 ate as an RO, they, indeed, have to meet the ! 18 requirement prior to going back and directing, and 19 manipulating, if their license was no longer active. In j! 20 other words, if they are not maintaining the five twelve 21 hour shifts per quarter, or, I beideve, it's seven eight . I l 22 hour shifts per quarter, indeed, they have to go back i 23 and activate their 31 cense by going on shift in that i 24 Position for forty hours. I 25 "Does an app 31can t f or a license have to be a E I
Page 97 l l' i member of the shift crew to obtain a license?" No. l I I _ 2 Basica 3 3 y, an app 31 cent de esn't have to be a member of ! 3 the shift crew to obtain it, the facility just must 4 eertify that there is, indeed, a need for him to have 5 that license. 6 "Is there any intention to limit the number of 7 licensees at a facility?" No, again. The facility { 8 determines the number of licenses they need at the 9 fac335ty by certifying.-the need for cuch a license. 10 "If a facility licensee does not have an -l 11 approved systems approach to training, SAT, can 12 operators be trained and 31 censed?" Yes, they can. 13 UntJ3-the program is accredited, they still have to 14 abide by their current approved program, as upgraded by 15 the requirements of the Regulation, and we will st113 16 31 cense those individuals. 17 "If the SAT process is evaluated to be l
.l l
18 unsatisfactory during inspection, can operators be l 19 trained and licensed?" Basically, that will have to be 20 determined on a case by case basis. If your program is 21 deemed to be unsatisfactory, it would obvious 3 y depend 22 on the -- what the problems are, whether we would issue I 1 1 23 -- we have given a 31 censing exam to an individua 3 who 24 has completed an unsatisfactory program. It's highly 25 un31kely that if we deemed it to be unsatisfactory, that l
Page 98 1 we would. But that would depend on a case by case h 2 basis, and the specifics involved. 3 "Are appeals a -- okay, well, we already 4 talked about appeals, so I'm going to skip that one. I 5 assume that was answered. 6 "Will the current Region requirements for 7 complete licensee hitnory on Form 398 for license 8 renewa3 be reduced to the data included in the OMB g approval, 3150-00907" Basically on the 398, if you have 10 an INPO accredited program with an acceptab3 e simulator, ji which is approved or certified, you can eliminate giving 12 us inf ormation under b3 ocks twelve and thirteen, with 13 .the exception of the five significant control 34 manipu3ations. That sti)) must be included. Yes, sir? 15 HEARING ATTENDEE: (Mr. Williams) This deals 16 with renews), not initial. 17 MR. M11NR OE : Okay, for renewa3, the same -- ig for renewal, the same rules would apply with the -- 19 there is a block specifica3 J y on there for renewal, 20 kay? The only dif f erence would be -- and later on, 21 there is another question that has to do -- a similar 22 question that has to do with renewal, that changes are 23 going t o be made such that you do not have to provide 24 information back to, for example, 1976, for a person who i 25 was origina3Jy licensed in 1976, you only have to l
i Page 99
.1 provide the.information from-that last period of license
. I.
i 2 renewal, the training he has received. 3 The regulation specifically asked for' the 4 hours -- the on-shift hours, or the experience that he 5 has received for renewal, there will be a block on the 6 398 to provide that information. If-you are -- that's 7 all you will have to provide if you meet the two other j g criteria, having been INPO accredited, SAT program, and 9 the approved simulator. If you are not, then you will 10 have to provide the other data, I believe. Yes, sir. 11 HEARING ATTENDEE: You also missed the last' ; 12 question in 5 5.4. Are you going to hold that for 13 simulation?' 14 MR. MUNROE: Yeah, we are going split it up j 15 Anto three parts. And I guess I better remind you, if
-l
. 16 yu could, once again,zcome up to the mies. I realize 17 it's tough to think of that when you are asking these l J
18 questions, but it will help us on the transcribing part. I 19 We will come back to the simulator question. ' 20 "Is a senior Operator License required to move 21 fuel in a dry storage area, or away from the reactor 22 vessel?" Okay, the Regulation doesn't specifically talk I 23 about the dry storage area, or, further, the refueling 24 po 1. Basically, the answer is, if there is a potential R 25 for criticality, a senior operator would be required to j l- __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
Page 200 1 be there. And in some instanc@a, in a refuel pool, y 1
- i. 2 - there:As the potential, due'to arrangement of some of 3 the' fuel, that you could have-that ~ situation. If not, 4- no. The Regulation specifically talks about in and out 5
f the vessel, I believe. 6 "Can the licensed senior operator, who 7 supervised fuel' handling, will be a senior operator 8 licensed for fuel handling, only?" Yes. g subpart E. "If the facility operator career 10 path program considers all non-licensed opera tors . t o be 11 license candidates, can the non-licensed operators 12 manipulate the controls under the direction and in the
- 13 present of the reactor ope ra t o r 's senior operator if 14 he/she is not currently in a hot licensedJelass?" No.
15 He must of ficially be enrolled in the hot license class. 16 Simply being an NLO, who is designated in a career path, 17 to go up through a licensed operator class is not 18 sufficient to meet the intent. 19 Specifically, the individual must be enrolled 20 in the hot license class. 21 MR. RUSSELL: Let me add to that. More i 22 importantly, he must have completed the necessary 23 classroom, or indoor simulator training in accordance 24 with the way you sequence training prior to manipulating i 25 the controls of the facility. That is, you may not l l 1 i
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1 [- Page 301 3 perform the practica3 factors out of sequence with
- d. l i 2 respect to training. That's why we want them to be in 3 the training program, if manipulating the controls is 4 part of the training program.
5 MR. MUNROE: Yes, sir? 6 HEARING ATTENDEE: George Madden, Florida 7 Power and Light. If the operator is in a licensed 1 8 class; has completed the know3 edge and the simulator g portion; al though not a planned evolution, a evolution 10 of opportunity arises to do activity. Can he be -- 11 perform those for the training program, and take credit? 12 MR. RUSSELL: yes.
+
13 HEARING ATTENDEE: Gene Karlson, . Florida Power i j4 Corporation. The Part 55.57, went back under Subpart A 15 that John just covered. The last question, in order to 16 renew a license, the applicant shall provide written 37 evidence of the approximate number of hours tnat the 18 licensee has operated the facility. Over a six year 19 period, that could be a horrendous record keeping l 20 problem, in order to keep track of how many hours he has 21 operated the facility. Is that -- how accurate a number 22 are you looking for? 23 MR. MUNROE: John? l 24 MR. HANNON: I understand the present I 25 Regulation was a two year term. You are presently
Page. 102' 3 submittingfthe. approximate number of hours for a renewal b'i 2 Application. We are not asking, here,.that more than
.3 that be done. So, whatever you have been doing in the 4 past, if you wou3 d simp 3 y expand it to cover the six 5 Year Period, that's wha t to expect.
t 6 MR. MUNROE: "With regard to Section 55.23 7 Subpart (c), who is the authorized representative?" 8 The authorized representative is the highest level of 91 corporate management who signed the application. And I 10 be3deve 55.23 -- John, has that to do w'ith the medica 3? gg MR. HANNON: Yes. I i 12 MR. MUNROE: It will be the same person who 13 signs t he 398, basically, and it will be the same person 34 who signs the 396. Yes, sir. l 15 HEARING ATTENDEE: Two: signatures on 398? 16 MR. MUNROE: I didn't hear what you said?- a 17 HEARING ATTENDEE: There are two signatures, 18 one from -- 3g DR. SHANKMAN: One is the applicant. " 20 HEARING ATTENDEE: -- the training department, 21 and one by the Vice President. '
. 22 MR. MUNROE: True, and that one from the Vice 23 President, I be31 eve, in parentheses, and italics print, 1
24 says the highest leve3 of corporate management. 25 Although I could be wrong, I think that's what it says, i
)
Page 303 j -So, tha t would be the same individual. If you look at i
,a-I 2 the new 396, that_same phraseology is next to that 3
signature name. 4 HEARING ATTENDEE: Joe Johnson, TVA. For a 5 multiple unit site, can that signature on the 6 application be from the individual responsible for 7 operations, the highest individual at.that sight. So, 8 that you could have dif f erent signatures,-if you had 9 Sequoia, you would have a different signature than if 10 you had Brown's Ferry? 11 MR. RUSSELL: Yes. 12 MR. MUNROE: I beideve so, yes. 13 HEARING ATTENDEE: (Mr. Johnson) Okay, t hel. , 14 this is important,-because we're getting ready to file 15 s me. S , we can file them for the individual 16 responsible for operations, the highest at the sight? : 17 MR. MUNROE: Yes. 18 HEARING ATTENDEE: (Mr. Johnson) Thank you. 19 MR. MUNROE: The next question asks -- if ; 20 there are no more questions on that area, the next 21 question has to do with 55.25, which is incapacitation 22 because of disability or 111 ness. "Where is the 23 licensee (operator) notified that he/she is responsible 24 to notify the facility Ideensee of a medical i 25 disability?" He is responsible, and you are responsible
PsDe 104 3 to make the notification, basically. There is nothing I _' 2 .in the Regulation that says ~dt is duty to do that, but 3 the disability -- we must be notified of the disability 4 within thirty days. And, basically, you must set up a 5 system to insure that that is done. 6 HEARING ATTENDEE: Lee William, from. Alabama 7 Power. I think the root question is, there, is if an g , operator has some' condition in accordance with three g four that could be termed as a disability, i.e., an to epileptic conditaon, say, and he goes out and seeks n medical treatment on his own, and the facility licensee 12 doesn't . find that out -- in other words, how does the 13 operator know he has a responsibility to tell the 34 utility that his medical status has changed?
- 15. MR. MUNRON: You should set up a system that 16 he does know that. It is his responsibility not to 37 operate that plant in a disabled condition. I realize 18 it says that the f acility licensee shall notify the i ig Commission, but I believe that, logically, he should 20 have enough responsibility, that if he has a problem gi like that, to realize it, and tell you, if it's not 22 obvious. And procedures should be set up to insure that 23 occurs. Susan? !
L 24 DR. SHANKMAN: There is nothing in the i 25 regulation -- the direct answer to your question is that 1 - __-_- - _ _a
i Page 105 i i 3 there is nothing in the Regulation that ob11 gates the 1 2 Perator, or the senior operator to let the facility j i 3 know. But there is an obligation for you, on the 4 reoccurring medica) examination -- the biennia 3 medica 3 5 examination, if somebody was an epileptic, you would 6 have some follow-up tracking of that condition. 7 HEARING ATTENDEE: (Mr. Williams) And that 8 doesn't bother me, because that w113 come out. However, g there is that interim period of time when we, as the 10 fac131ty 31censee, would not know. 33 DR. SHANEMAN: Right. Yes, that's true. 12 MR. RUSSELL: The clearest answer i s ., if you 13 don't know, you have no affirmative obligation to report
,4 ft. It's on3y wjthin thirty days of becoming aware of 15 the diagnosis, and that's what we're interested in you 16 reporting.
17 MR. MUNROE: Yes, sir. 18 HEARING ATTENDEE: Lacy Pauley, TVA. Is, 19 under 50.74, is the licensee definition there the same 20 as the licensee definition to 10 CFR 557 21 MR. MUNROE: 50.747 22 HEARING ATTENDEE: (Mr. Pauley) Or is th2s 23 talking about the facility licensee? 24 DR. SHANKMAN: State your question one more 25 time?
Page 106 l . j HEARING ATTENDEE: (Mr. Pauley) I'm sorry. L 2 The reason I bring this up, 50.74 says that the licensee 3 is responsible for notifying the NRC of disability or 4 3 3 31:ess . 5 DR. SHANKMAN: Yes, that IAcensee, in that 6 context, the definition for licensec in Part 50, is in 7 the beginning of Part 50, and t ha t 's the same as the g definition of facility licensee in Part 55. 9 HEARING ATTENDEE: (Mr. Pau3ey) Thank you. 10 HEARING ATTENDEE: George Madden, FPL, again. 11 The part seven -- the 50.74 requirement, you have set up 12 some direction as to sending al3 correspondence for the 13 P rt 55 to the Region. However, because thds Part 50 1 14 requirement, should we be sending that on to the 15 document control desk, in accordance with Part 50.4, 16 which became effective on January of 19877 All 37 correspondence required under Part 50 was supposed to go 18 to the document contro3 desk, with a copy to the 19 Regiona3 Administrator? I 20 DR. SHANKMAN: Yea. In fact, in the amendment 21 to -- in the addition -- the conforming amendment, it 22 says, according to 50.4. Obvious 3y, communications 23 under that part have to conform to the communications 24 regu]at$ng that part. t 25 HEARING ATTENDEE: Ben Lake, TVA. Relative to
Page 107 3 medica] disability, if the individual has a medical i 2 Problem during the period of his Ideense, for instance a 3 broken arm, does it matter whether we report this to 4 NRC, whether he is carrying on licensed duties, or where 5 he is not carrying licensed duties? In other words, if 6- he is training individuals in a classroom, do we stil] 7 have to report it, or only if he's carrying on licensed g duties per Tech Specs. 9 DR. SHANKMAN: Well, I guess I'm not exact]y 10 sure what your question is. If he has a r. inactive 11 13 cense, and he's not in the control room, and he is not i 12 performing active licensed duties, I think the answer to 13 y ur question is no. 14 HEARING ATTENDEE: (Mr. Lake) If he's got an 15 active license, but at the moment, he's got a temporary 16 disability, but he's not carrying a tech spec licensed ! 17 p sition? I 18 DR. SHANKMAN: WeII, it's when he's on shift 19 that we have to know about. j 20 HEARING ATTENDEE: (Mr Lake) Only if he's on l 21 the shift, that's what I wanted. The Regulation didn't 22 say, and it l ooked like the Regulation wanted us to i 23 notify NRC, regardless. And that's the reason I'm 24 asking that question. 25 MR. RUSSELL: Usually, that if he has a i l
l Page 308 3 temporary disability, that would preclude him from I, (1 2 Performing duties, he's not to perform those duties with 3 that temporary disability. We need not know about that, 4 it's temporary. When you return him to watch standing 3 duties, if he has been absent for a period of time, you 6 control that process with the forty hour parallel watch 7 standing, with the certification being maintained on g file. It's only a permanent disability that we would g have to be notified. 10 DR. SHANKMAN: As a corollary, you probably 33 have a fitness for duty program. And, so some temporary 12 conditions might be covered by the fitness for duty 13 jssue. 14 HEARING ATTENDEE: (Mr. Lake) Okay, on the 15 return to active status, the forty hours, I've got a 16 ques tion on tha t , also Do we have to certif y t o the 17 NRC that he has carried his forty hours? What are the 3p requirements -- what do we need to do on that? 39 MR. MUNROE: I believe that's a question that 20 comes up later, and the answer is that you certify, but 21 you do not have to certify to us. However, that 22 certification must be available for us to inspect, to 23 Andicate that, indeed, the individual did do his forty 24 hours under instruction. Did do his plant tour, I 25 believe it's mentioned in there, also, et cetera,
1 whatever else must be done, so that we can inspect it, y, l' _ 2 to assure that it's been done. 3 MR. RUSSELL: The intent is a simple 4 memorandumLto file, which wou3 d go in that i ndi v i dua l 's ; 5 file, that you maintain in his records on site. 6 MR. MUNROE: Yes, sir. 7 HEARING ATTENDEE: William Downs, Georgia 8 Institute of Technology. I have two questions. The 9 experience requirements for license, are they 10 app 31 cab 3e, also, to research and training reactors? 11 MR. MUNROE: John? 12 MR. HANNON: You go ahead. 13 DR. SHANKMAN: All right, the requirements for 14 test and research reactors have not changed. Whatever 15 has been approved in the past, in terms of eldgdb5lity 16 requirements, continues for your test and research 17 reactor. The eligibility requirements in 1.8 refer to 18 power reactors. 19 HEARING ATTENDEE: (Mr. Downs) And on Form . 20 398, since we don't have simu3ators, are we required to 23 comp 3etely fil] out the form? 22 DR. SHANKMAN: What you have been doing 23 currently w131 continue to be acceptable. 24 HEARING ATTENDEE: (Mr. Downs) Okay, thank l l 25 you. 9
Pogo 110 1 DR. SHANKMAN: In fact, let me expand, for aJ3
; I - 2 test and research reactors, for the record, we don't 3
intend to change the process, except in terms of being 4 re-examined during the six year license. 5 Requalification programs basically stay the same. We 6 still intend you to use 15.4 for selection and training, 7 and medical. And we've adjusted the requirements for 8 maintaining active duty to six hours, and we've also 9 adjusted the four hours and six hours to come back to 10 active duty. 11 MR. MUNROE: Okay, the next question a3so 12 deals with 55.25. "How is an individual returned to 13 active licensed duties after the medical disabili ty has 14 been corrected, but a portion of the requal progran. has 15 been missed?" Before he returns to duty, if a portion 16 of the requal program has been missed, and he is not up 17 to date on the requalification, then he must become up 18 to date on requalification. 19 !
"What other medica 3 disability requirements !
1 20 app 3 y to a 3 I shift licensees required by technical ' 21 specification?" The Regu3 at j on applies to both active 22 and inactive licensees -- well, I tell you what , the l 23 question was just answered by Mr. Russell, in that if a 24 person is an inactive licensee, and h e 's not going to 25 use, then the disab133ty does not have to be reported,
Page ill 1 1 as such, unless you intend to return'him to on-shift
, .i .1 2 duties; if I correctly paraphrase your answer.
3 MR. RUSSELL: That's correct. That would only 4 be the case where you have a disability, that you want 5 to have a condition included in the license, such that 6 he could perform licensed duties with the medica 3 7 condition, because of some other compensatory measure. 8 In most cases, we would expect a temporary disab131ty to 9 either correct itself with time, through medication, or 10 some other means, and that he wou3d not stand watch -- 11 that is, direct the activities of others or manipulate 12 controis with the temporary disability. 13 MR. MUNROE: 55.27, "Can private. physicians 14 maintain medica 3 records for the fac131ty licensee, as 15 is-currently practiced?" That responsibility can be i 16 de3egated'to them, but it is, indeed, your 17 responsibility to insure the records are available for i 18 inspection. j 19 "If so, what requirements must a private 20 physician meet to maintain these medical records?" The 21 same answer as just given, must be -- you must set up a 22 system such that they are maintained, and that they are 23 ava13ab3e for inspection when needed. 24 "10 CFR 31(a)(4) -- oh, I'm sorry. 25 HEARING ATTENDEE: Excuse me, going back to l ~ , I , u _
; Page 112 1 the1-- Lee William, f rora?A l abama Power. Going back to i
I 2 the medical records maintained.by the physician. When 3 you Jook at some of the' commitments that the utilities 4 have as f ar as record retentio}n in fire proof vaults, et
" x, . .,
5 cetera, I ~ don' t 'f ee l that the physician's' of fices meet
,x 6 those r e gt,i r eme n t s . But, yet, this is a qualification 7 . record, cs\ defined by that ANSI Standard.
8 MR. RUSSELL: Y e s'.
"N s
," s 9 HEAhtNG ATTENDEE: (Mr. Williams) And t ha t 's 10 really what the question is almed towards. Are we going t
11 to have t o ,' you know, be providing the physiciar; some 12 type o f ' 'd Y e' p r o o f storage, or how do wochandle that
. ,s 13 aspect of.'this record keeping? 3
,3 MR. RUSSELL: I made $ recommendation to INPC'
} \ 15 approximately two weeks ago, or three weeks ago. And
, N
< (W the recommendation was that industriec develop an s
.g, ,
s. 1 17 examination report fort. which would, in fact, cover the s
% \
13 'are,as(in the ANSI Standard,' And have that report of 1 , s N s 4 ; \10 examination submitted from the medical examiner to the !,
'h0 [g' . f a c 111 t to y , retain., That you don't have his complete s . ', !
j 4 21 nedical history, so'that you do not get into other ' 5 4 22 'haspects of information about that individual, the common a 1 23 co) ; 'or whatever,,that he may'have had. i We are s, - 1
\x t 24 ' ! jnterested in ani examination for those areas covered by l s
25 the Standard, foh which theie may be 1 medical th' Si 1 1 . I _ l... -
Page 123 1 disability. I i 2 That's what the responsible officer is 3 certif ying, and I believe if there were some type of an 4 Andustry-wide form, that would assure that the doctors s who perform the ' examinations are covering all of those 6 areas, that that would be a lot bet ter than giving the 7 guy an ANSI Standard, and having him come up with each 8 time. That's the type of examination report, that's 9 signed, that we are expecting to be able to inspect on 10 s3ght. 11 HEARING ATTENDEE: (Mr. W1111ams) What was 12 the response from INFO' 13 MR. RUSSELL: They are considering it. 14 HEARING ATTENDEE: (Mr. Williams) Lee Adams? 15 MR. RUSSELL: I haven't heard from Lee. 16 MR. MUNROE: Section 5 5.3 2 (a)( 4 ) , " W h t. t is a 17 Commission approved program?" One that is INPO 18 accredited, or NRC approved. l 19 "Does accreditation by the National Academy { i 20 for Nuclear Training meet the requirements of this 21 Subpart?" Yes. ; 1 22 "If so, can you loose Commission approval of { 1 1 23 accreditation is maintained?" If you loose Commission 24 approval, ful whatever reason, then you can, even though 25 you maintain accreditation with INPO, you may, if you 1 1
Page 114 1 have~o problem which causes us to withdraw our approva3, l i i 2 t h er4 .you have a problem. 3 MR. RUSSELL: The simple answer is, we choose 4 the vehicle of us approving,,even though it's automatic, 5 based upon the 5 accreditation Board, because of the 6 circumstance which may occur, where an accredited 7 program is not being adequately implemented. And we 8 nd that through an inspection activity. So, the 9 answer js yes, you'can be accredited and Joose NRC 10 approval, based upon failure to adequateJy implement. 11 Our intention is to communicate those findings 12 to INFO, as we have, and to let the INFO process 13 init3 ate the remedia) action. We d on ' t intend to get 14 into that mode, but we do expect you to implement, as 15 the National Accrediting Board expects you to imp 3 ement L 16 your accredjted program. 17 HEARING ATTENDEE: Lee Wil 31am, f rom A]abama 18 Power. Would that inspection that you are addressing, 19 Mr. Russe 3 3, be wj th the 2 2 2 0, I believe is the 20 guideJine? 21 MR. RUSSELL: That is correct. We have 22 reviewed that w i t 's INPO. We have had a number of 23 L discuss 3ons with them on it, and we have been using that 24 for our post-accreditation review. 25 MR. MUNROE: 55.33(a)(5), "What $sa L_ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _
Page 115 i significant control manipulation?" Significant control I-I 'l- 2 manipulat 3cns are defined in Reg Guide 1.8. 3 "Must the five control manipulations be 4 different?" Reg Guide 1.8, I believe, again, asks f or a 5 diversity. So, 'therefore, the intent is.to have 6 different manipulations, but not necessarily required. 7- "How long a period can pass bef ore the five B control manipulations must be completed, before the 3 9 written exam and operating tests are completed?" John? 10 MR. HANNON: If I understand his question, I 11 believe the correct answer would be up to six years. If 12 we, f or example, had given a shut down license t o a 13 plant that had been experiencing an extended shut down. 14 And we had given a license to a candidate who was 15 constrained to shut down mode, he could actually serve , 16 out the term of that license for, you know, a period of 17 six year. So, I think that's the extreme answer to this 18 question. 19 MR. MUNROE: And I believe John has also 20 answered, "What is the definition of extended shut 21 down?" 22 MR. HANNON: Yes, an extended shut down, is 23 any shut down that would be longer than the tradning
, 24 program that the operator, or candjdate, was supposed to l i
25 be under. If you have a three month shift for training, a l
Page 336 1 and the plant do not availablo for the three month 2 period, then that woult be considered an extended shut 1 down. 4 HEARING ATTENDEE: George Barnes, Carolina 5 Power and Light. As far as the five significant control 6 manipulations are concerned, what's going to constitute 7 evidence? 8 MR. RUSSELL: The intention is, that that be 9 document in the OJT qual cards as part of the training 10 program. What we have seen on many of the OJT qual 11 cards, is they simply put a performed coding next to the 12 signature, and somebody on shift signs that that 13 dndividual did perform that, and that's sufficient 14 evidence. f 15 HEARING ATTENDEE: (Mr. Barnes) Okay, thank 16 you. 17 HEARING ATTENDEE: Steve Frye, Duke Power 18 Company. What I am hearing is, is you don't have to 19 have the five significant reactivity manipulations prj or 20 to initial license issuance, is that correct? 21 MR. MUNROE: No, that's not correct. 22 HEARING ATTENDEE: (Mr. Frye) Well, my-23 question is, going back to Subpart B, I heard a while 24 ago that it was said that you had to complete the 25 injtdal simul ator and classroom training prior to being i
Page 117 1 a3 J owed a non-licensed operator to manipulate the 2 contro3s from the control room environment. How can a 3 person get their initial license, then? Because I think 4 the time could -- you do your simulator training, the 51 classroom training, the NRC exam time, there is not much 6 time-left in there, after the simulator portion, to 7 complete the five reactivity manipulations. 8 MR. RUSSELL: There are two conditions that 9 could' occur, and I would -- I don't want to address cold 10 33 censing, because that's a separate issue. It's on3y-11 f or hot license. If the individual has not had the 12 opportunity to perform control manipu 3 ations on shi f t 13 because of extended shut down, we would consider 14 examining him. And if he passes that exam, we may $ssue 15 a license which is conditioned to shut down, o 16 or we may decide to wait, if he is going to 17 complete those control manipulations in the next' thirty 18 days, and issue a license, then, without condition, 19 based upon him completing the five significant control 20 manipulations. We, in those cases, expect the contro) 21 manipu3ations to be completed prior to submission of an 22 app 31 cation. It is only by exception, and only when the 23 individua3 did not have the opportunity to perform the 24 control manipu3ations as a part of his training program. 25 HEARING ATTENDEE: (Mr. Frye) These control
Page 118 I manipulations have to be done on the plant. -It's not 2 acceptab3e to have them done'-- 3 MR. RUSSELL: That is correct, they may not be 4 done on the simulator. They must be done on the
~5' facility.
6 MR. MUNROE: Part 5 5.3 2 (a )( 6), "Why is the 7 licensee applicant no longer required to sign the 396 8 form, certifying that he/she has no. felony convictions?" 9 I don' t -ha v e an answe r as t o. why i t's not on there. 10 , However, ,it is a condition of a ldcense, per Part 11 5 5. 5 3 (g ) , that he must notify us within thirty days 12 about a conviction or a feJony. So, should he get a 13 license, and he had a prior felony, he's required to 14- notify us of the prior felony. 15 HE Al iNG ATTENDEE: George Barnes, Carolina 16 Fower and Light. You give us a little common sense 17 3eeway on the medica 3 disability, as far as informing 18 you, but we don't get that same leeway, here, as far as 19 knowing of the conviction, versus knowing of -- 20 MR. RUSSELL: If the guy has been convicted of 21 a fe3ony, he's likely going to ja13, so he's not going l 22 to be at work, so that would be a pret ty clear 23 Andication to the facility. The other thing is, is that 24 the clearance for unrestricted access, since these 25 individua 3 s wou3 d have unrestrjeted access, you are i
Page 119 1 going to be receiving information that relates to such i 2_ things as convictions of felonies, so you will have 3 access to that information. i 4 HEARING ATTENDEE: (Mr. Barnes) But not 5 necessarily with' thirty days, is what I'm trying to get
- 6. at.
7 DR. SHANKMAN: You are talking about two 8 separate things. It is the operator who is required tc 9 Jet us know in thirty days -- 10 HEARING ATTENDEE: (Mr. Barnes) Okay. 11 DR. SHANKMAN: -- as a condition of his or 12 hers license, after receiving the license. 13 HEARING ATTENDEE: (Mr. Barnes) Okay. 14 DR. SHANKMAN: If we're talking about the 396 15 Form, you, as the facility licensee, certifies to us 16 that they have not had, prior to their initial 17 application, or during -- if this comes in with renewal. 18 Now, we expect that during that time, since you receive 19 the data on criminal history with the new FBI reporting 20 system, that you would know. 21 HEARING ATTENDEE: (Mr. Barnes) So, we don't 22 assume any liability for not notifying you within that 23 thirty days? 24 MR. RUSSELL: The situation is the same, if 25 you don't know, and you didn't have a reasonable basis l
.,,i mi ,. . . . . ...
............_i.
Page 120 E 1 .tO.know -- 2 HEARING ATTENDEE: (Mr. Barnes) Okay. Okay. 3 MR. RUSSELL: -- we're not going to hold you-4- Jiable for.that. The issue is,_if-you get a criminal 5 history check that shows the guy has been convicted of a 6' felony,.we expect you to teII us. I 7 HEARING ATTENDEE: (Mr. Barnes) Thank you. 8- DR. SHANKMAN: Right.
-9 HEARING ATTENDEE: Lacy Pauley, TVA. You may 10 have just answered my question. If we put up an 11 app 31 cant f or a 1icense, and he has had a f elony f 3 f teen-12 years ago, is that still reportable, and would he -- if 13 he had t aken a 31 censing exam, and was ready t'o receive 14 a 31 cense, Would he have to notify you within thirty 15 days, assuming we did not know that?
16 DR. SHANKMAN: After he receives his license, 17 he has to let us know within thirty days. .You have to 18 let us know when you submit a new 396 Form, for renewal. 19 Okay, if you know. 20 MR. RUSSELL: With the example you are giving, 21 if the individual knew that he had been convicted in a 22 felony in the past, and he did not report that on the 23' initial app 31 cation, his application would be considered 24 incomp]ete, and it may be the basis f or revoking his i 25 license, t _ -
Page 323 1 HEARING ATTENDEE: (Mr. Pauley) Okay, that 2 requirement is -- 3 MR. RUSSELL: He would have withheld 4 information. 5 HEARING ATTENDEE: (Mr. Pauley) That 6 requirement is on the initial applications? 7 MR. RUSSELL: Yes. 8 HEARING ATTENDEE: (Mr. Pauley) Okay. 9 MR. MUNROE: 55.42, "Why are written 10 examinations on3y taken in part from learning 11 objectives?" The hope is, eventually, to take the 12 entire written examination from learning objectives. 13 However, at this time, there are many instances where 14 the learning objectives are somewhat incomplete, or 15 inadequate, we feel. So, we utilize the K&A Manuals 16 which we have, NUREGs 3322 and 1123, to supplement the 17 3 earning objectives. 18 "What Jimits on materials requested from the 19 facility licensee exist, if any?" We will be 20 reasonable, but there are no 33mits. Typi ca l l y, we go 21 through the list with the facility, and indicate what 22 Atems we need. We are not going to ask for the who3e 23 31brary, in any case, or every print on the facility. 24 However, we may need more ma t eria 3 a t times than what 25 you issue the student to learn the plant, because we
Page 122 I
-1 have to get familiar with different plants, which have 2 slight anomalies from one type vendor to another. So, 3 we may need more in-depth material.
4 "The i t ems on 55.41(b)(10) and (13) ha ve 5 previously been" senior operator knowledge. What level 6 of ~ knowledge is expected for the reactor _ operator?" 1 7 Well, 5 5. 41 ( b) ( 10 ) , part of that has already been 8 operat or knowl edge; normal, abnormal and emergency l 9 operating procedures for the facility. I believe the 10 part you are referring to is the administrative ~part. 11 The reactor operator would be tested f or the depth of l 12 knowledge required for his job position in the 13 administrative area.
, He does get involved with 14 administration at times.
. i 15 And Part (33), procedures and equipment 16 available f or handling and disposal of radioactive !
17 materials and effluents. That would, once again, be 18 geared to what his job requires are, if any, as an RO at 19 your nite. 20 Section 55.43. John, do you follow on the 21 list, there? 1. 22 MR. HANNON: Yeah. l 23 MR. M11NR OE : Okay, could you take that one. 24 MR. HANNON: The question is, "The commission ! 25 policy Statement on Technical Specifications and ( l
9 PGge I33 i , 1 Improvements may. resul t- in a substantial increase in f; 5 2 scope and documentation. W131.any effort be made to 3 35mit the knowledge. required of' senior operators to 4 those elements of the t'echnica3 specification basis that' 5 are essential for safe operation?" Yes, we do have an
-6 ongoing-program, where we are looking at the issue of 7 wha t needs t o be examined a t .the SRO . level, as opposed.
8 t o the RO level . And we are working with the people'in 9 the Tech Specs.and Review Branch, that are developing 10 these new Tech Specs; and would intend to make sure that 11 we are producing'a performance based exam' . 12 - That's not to say that there won't be some ( 13 additional exam material that comes from the new tech 14 specs. But, again, it w313 be performance-based,'and we - 15 will provide ample guidance to the examiners, in the 16 Examiner's Standards, as this program develops. 17 HEARING ATTENDEE: Lee William, Alabama Power. 18 As I recall, going back in history for some time, at the 19 early days, when we were developing standardized tech 20 specs, the requirement was that an operator know from 21 _ memory, and be abin to apply one hour or less action 22 statements from the Tech Specs. Since standard tech 23 specs have come in, and the advent and the expansion of
, 24 those, there are now in excess, and we13 over a hundred 25 one hour or less action statements from Tech Specs.
q
-___ J
Pogo 324 i< 1- Is the Po31cy, or ' the guidance f rom the 2 Comm3ssion st333 the same,.to commit those to memory,
~
3 even in light of that , and recognizing that the 4 utilities do not operate in that, in a performance mode. 5 'And do not rely on him, and require him not to act fron. l 6 memory in that situation? 7 MR. RUSSELL: WeII, the question,is very 8 general. And I don't believe that that kind of a 9 genera 312ation is appropriate in describing what is 10 perf ormance based knowledge that an operator needs to 11 know. Specifically, if the information is appropriate 12 t o his job, if it is covered first, and it's in the K& A 13 cata3ogues, he shou 3d be expected to know that 14 Information. 15 If it is not -- that is, there is not a 16 specific knowledge or ability associated with it, then 17 31 may be required in one hour for an action statement, { 18 but there may be other indications that cause him to 19 3ook into the Tech Specs. The method you use . i' 20 procedura 3 3 y in the plant would be the method that would 21 be fo3 lowed, that would be appropriate on performance 22 based testing. 23 We don't have any blanket rules that say, 1 24 thou sha 3 3 memorize everything that could bappen through 25 Tech Specs that has to be done in less than an hour.
]
1
Page 125 i That is not a policy. 4 2 HEARING ATTENDEE: (Mr. W1111ams. A33 right, 3 so, if the utility, then, has established some internal 4' guidelines of what they expect of the individual, you 5 will accept those guidelines for the' purposes of written 6 examinations, if~I understand your statement? 7 MR. RUSSELL: Or we would have an issue that
~8 we would discuss wi th the u tili ty, tha t we would want to 9 revise the guidelines.
10 HEARING ATTENDEE: (Mr. Williams) Okay, can 11 we s u bn.i t that in advance of the written examination, ; 12 then, and agree somewhere up front?
- 13 MR. RUSSELL: It can part of the materials j that you submit in accordance with tho ninety day i
14 ! 15 3etter, and we would consider that in developing the 16 exam. 17 HEARING ATTENDEE: (Mr. Williams) Okay, thenk 18 you. 19 HEARING ATTENDEE: Lacy Pauley, TVA. 55.43, 20 which is about SRO license, 55.43, number three, or 21 (b)(3), says, "The facility Idcensee procedures required
- 22 to obtain authority for design and operating changes in 23 the fac135ty. What is the intent of this? Is this for 24 the SRO to understand a 3 3 of the process that goes about '
i 25 in obtainjng a change -- a design change for the I
Page 126 1 licensee, is that -- I 2 MR. RUSSELL: Most importantly, there are 3 administrative procedures which would allow, for 4 example, two SRO's on a back shift to make a change to a 5 procedure, as long as they don't change the intent of 6 the. procedure. Or, there may be other aspects of the ' 7 50.59 review process, for which an SRO'is held 8 accountable for knowing. He is the shift supervisor, on 9 sh3ft at the time, responsible. for those activities. 10 And j t 's tha t type of administrative procedure we'are 11 addressing. 12 HEAPING ATTENDEE: (Mr. Pauley) Okay, so ( 13 we're ' t a l king about temporary alterations, not design 14 c h a n g e e,, or 31 cense changes -- permanent license 15 changes? 16 MR. RUSSELL: He needs to understand what he's 17 approving, when he approves the work to be done in the 18 p3 ant, that he has a process that supports him in that. I 19 Where, in essence, looking principally at those things 20 which he changes, where he may deviate from a procedure, 21 or approve an alternative approach. I t 's the 50.59 type 22 process, and how those changes are controlled, and what 23 it means when he signs off, approving a work package, or 24 anythjng else which may change the desj gn of the 25 facility, or change the way the facility is operated by l i ___________-___ _ i
Page' 327 1 the procedure. 2 MR. HANNON: -I wou3d a3so point out that there 3 has been no change in this area f rom the previous Part i 4 .55. 5 HEARING ATTENDEE: (Mr. Pauley) Okay. 6 MR. MUNROE: 55.43, another question, "What 7 maintenance activities are included-in 5 5.4 3 (b) ( 4 ) ? " 8 (b)(4) talks about radiation hazards that may arise 9 dur.ing norma 3 and abnorma3 situations, including 10 maintenance activities, and various contamination 11 conditions. Or ce again, we can't delineate every item 12 that he would have to know. A common item may be an 13 RWP, okay? He may be responsible for signing off, 14 either as concurrence or approval, depending on the 15 facility, on the RWP, so he wou 3 d be expected to have 16 know3 edge in that area that would be specific to the 17 site. 18 55.45, "Wil3 operating tests have learning 19 objectives based on f acility licensee learning 20 objectives?" Once again, we wilI try and incorporate 21 learning objectives into the examinations for operating 1 22 tests, but some experience recently has been that 23 learning objectives are not as extensive in that area, 9 24 as they are in other areas. So, we have to supplement 25 that, and will supplement it with the K&A Catalogue. l f ... .. . .. .
Page 128
- 1. DR. SHANKMAN: John?
2 MR. MUNROE: Yes. 3 DR. SHANKMAN: Just to clarify, we don't i 4 intend to use learning objectives as learning 5 objectives. Wecare going to make them testing 6 objectives. So, there will always be that modification. 7 MR. MUNROE: "Is there a definition of plant 8- equipment that could effect the release of radioactive j i 9 materjals to the environment, per 10 CFR 5 5.4 5 ( a ) ( 8 ) ? " ' 10 Once again, we can't tel1 you every piece of equipment 11 that is testable in that area. There are many systems 12 that, and many controls that an individual can operate, i 13 t h ei t could cause a release, and he is required to 14 understand that. And I can't delineate every item that 15 js testab3e or not testable. 16 "Does 10 CFR 5 5. 4 5 ( a ) ( 10 ) imply that operators 17 must perform exposure shielding calculations?" That 18 depends, once again, on how it is done at your facility. I 19 If, for example, you have an on shift health / physics 20 individual to do tha t , or maybe an STA does i t if an ( 21 emergency arises, then we would not ask them to do the J 22 obie3 ding ca3culation. But if the individual -- the SRO 23 checks it, then we may ask him to check one. I 24 "10 CFR 55.47, what is a comparab3e faci 31ty?" 25 J,hn? l i l l 1
Pego 129 1 MR. HANNON: This goes to the waiver of k examination and test requirements. 2 And the only answer 3 I ha ve on that , is we would have to look at each waiver l 4 on a case by case basis, and make a determination as to 5 whether or not the facility was, for licensing purposes, 6 close enough. 7 MR. MUNROE: Section 55.53, "If a licensee is 8 not maintaining an active license at the time of license 9 expiration, what are the requirements fro renewal?" If 10 he is not maintaining an active license, he still must 11 meet all of the requirements for renewal in 55.57(b), I 12 believe. However he does not have to be active to get ( 13 his license renewed. He must be, most importantly, 14 current in the reqvalification program, but he does not 15 have to be active to have his license renewed. 16 "How, and to whom, is certification made under 17 55.53(f)?" This has to do -- 55.53(f) has t o do, once 18 again, with returning the individual to an active 19 status. And I believe we said earlier that no 20 certification has to be made to us. But a s 21 certification, indeed, must be made. And, typica11y, I i 22 believe we said go on file for inspection purposes.
, j l
23 yes? l 24 HEAR M3 ATTENDEE: Paul Rushton, Georgia 25 Power Company, a question on the same subject. As I ; i h
Page 130 1 read these requirements, here,.it would appear that once 2 a quarter, an indjvidual couJd spend forty hours on 3 shift under the direction of the licensed operators. 4 And the facility that he had done so, and that his 5 status in the requal program was current. And by doing 6 so, he could maintain an active license, and spent, 7 essentially, forty hours a quarter on shift, instead of 8 the fdfty-six to sixty spec 3fjed in other parts of the 9 Regulations? Is that true, or could you comment on 10 that? 11 MR. RUSSELL: That is true, that could be 12 done. That's not what we are intending. The issue is 13 we wanted to make 1t easy f or people to maintain a 14 license. And that's a decision that the facility makes 15 with respect to the commitment of time to the 16 requalification program. If the facility wants to 17 commit an additjona3 forty hours for him to be para 3 3 e 3 i 18 watch standing in a control room, in addition to the 19 requa3dfication program, so that he can say he's active, 20 and they want to, each quarter, put another 21 certification into his file, that's the f acility's 22 choice. 23 Our jntent was, to make it a minimum of seven 24 watches, at eight hours, or five watches at twelve 25 l hours, to maintain profic3ency of those who are actua3Iy l 1 ( . . _ . . . . . .. .. .. .
Page 131 l
- -1 directing the activities, or manipulating the' controls.
i k' 2 It's a proficiency issue, it's not a license renewal 3 jssue. 4 4 MR. MUNROE: Yes, sir? f 5 HEARING ATTENDEE: Jeff Davis, (phonetic) 6 Georgia Power. In that same area, the original proposal 7 had nothing in there about the five twelves or the seven 8 eights, is there a basis for this in any sense; and why ' 9 weren't we given an opportunity to comment originally on 10 this? 11 MR, RUSSELL: There were extensive comments, 12 origina11y, on the actively and extensively engaged. 13 HEARING ATTENDEE: (Mr. Davis) That is correct 14 MR. RUSSELL- The practice in the past has 15 been for a minimum of one shift, essentially, per month, 1 16 three per quarter, was the previous practice. That was ~ 17 deemed by the Commission to not be sufficient, as a part 18 of their review and determination of the final Rule, and : 19 they increased it to what you see now in the Rule. 20 HEARING ATTENDEE: George Barnes, Carolina 21 Power and Light. As far as this active and passive 22 status is concerned, it seems like one of the things you i 23 brought up repeat edly is this need f or a license, bu t we 24 let the facility determine the need for the license. 25 So, we've got this facility that's got twenty-seven
Page- 132 1' S R O 's maintaining a passive license for eighteen years. 2 Is there going to be any problem in the f uture with 3 that, say, like the instructors? You usually want to 4 have them licensed, but you don't want to let them go 5 for two hundred-and forty hours a go, to maintain that 6 license, if you could get away from it, right? Because 7 that means more money, if you have to let them go. 8 So, could that be a future issue, of you don't 9 have a need, now, for these people? 10 MR. RUSSELL: That is up to the company to 11 determine, and that's why we specifically made it a 12 condition of application. If the company determines ( 13 that they don't have a need, and they don't wish to 14 spend the resources'for the time requalification 15 trainjng, they simply inform us that they no longer have 16 a need, and the license automatically terminates. 17 HEARING ATTENDEE: (Mr. Barnes) But as far as 18 maintaining passive status, you could do that until you 19 retired from a company, basically, the way it's 20 written? ' 21 MR. RUSSELL: That is correct, as long as the 22 company wants to make a commitment to the individual 23 participating in requal, and being examined, et cetera. 24 HEARING ATTENDEE: (Mr. Barnes) Okay, thank i 25 you.
Page 333, 1 MR. MUNROE: Another question on 55.53, "Are-1- I 2' 'any. al l owances made in 5 5. 5 3 '( f ) .for off shift licensed 3 ' personnel who are involved in daily operation 4 supervision?"' No. Those individuals are eitherlin an 5 active status, or they are not. If they are not in an 6 active status, being a daily operations manager, or an 7 operations superintendent does not convert them to an 8 active status. 9 55.53, again, "Does a Idcensee who is not 10' actively performing the functions of an operator or 11 senior operator for one quarter have to perform ooth 12 forty hours of shift function under the direction of an
.l ,. 13 operator or senior operator, and the minimum watch 14 standing requirement of 55.53(e)?" Once he's --
if he 'l 15 is not acti vely. perf orming,. and he's not under an active 16 status, to return to active status, he must stand his 17 forty hours, at which point his clock start 9'for the
- 18. additiona] --
for the next quarter, and then he starts
- 19. again, maintaining his active status with the amount of 20 time required to do so, such as five twelve hour shifts, i
'21 10 CFR 55.57, "Does the completed Form 398 22 include the license entire operating history, or only H 23 the operating history during the period of the current 24 license?" I think we answered that prior. That's an 25 analogous question, so I'll go on.
r -
c Page 334-1 HEARING ATTENDEE: Mike Shelley, with System 1 l._ 2 Energy Resources. In light of what you just said, ;
- 3. concerning the forty hours completion on shift, under 4
the supervision: and then his clock starts again for his 5 seven eight hour periods, I believe the Regulation 6 states per calendar quarter. Okay, say, this individual 7
- . goes through this in the last month of that quarter.
8- Does he have to complete that seven eight hour shifts 9 before that month is up, or does he start during the 10 next calendar quarter? l 11 MR. RUSSELL: The simple answer to the 12 questjon is, if he's done forty hours of parallel watch 13 q standing in a quarter, he's active in that quarter. And 14 the next cal endar quarter, he would need to stand either
!S seven eight hour watches, or five twel ve hour wat ches.
16 The regaining of proficiency allows him to go back Snto 17 an act$ve status to stand the watch. He does not have 18 to do both in the same quarter. That is, he does not 19 have to do forty hours under instruction, plus stand 20 seven eight hour watches, or five twelves, in that 21 quarter; it goes to the next one. 22 MR. MUNROE: Another question on 55.57, "What 23 written evidence is required to document the hours that q 24 l a licensee has operated the facility?" The control room j i 25 logs would be sufficient. Shift turnover sheets would i 1
Pago 135 1 be sufficient. There are probably.other examples, but 2 those are two easy examples that would indicate the 3 individual has put in his time as required. There is a 4 statement that the requirements of 55.53(f) have been 5 met sufficient do meet 5 5.5 7 ( a ) ( 3 ) . 6 55.57(a)(3) has to do with renewal of 4 7 licenses, " Provide written evidence of the applicant 's 8 experience under the existing 13 cense, and the 9 approximate number of hours that the licensee has 10 operated-the f acili ty." I believe John answered that a 11 little bit earlier, and the detail that we expect from 12 that, as 1 recall. And I think his answer, if I can 13 paraphrase is correctly, was no more or less than what 14 we were expecting at this time, is that correct, John? 15 MR. HANNON: Yes. 16 MR. MUNROE: Okay. "Can the requirements of 17 55.57(a)(4), (5), and (6) be certified on Form 398? 18 Well, 5 5.5 7 ( a ) ( 4 ) and (5) relate to the individual 19 satisfactorily completing a requal program, and 20 discharging his responsibilities competently and saf ely. 21 Those two items can be certified on the 398 form. The i 1 22 (6) item, " Provide certification to the facility 23 13censee of medication condition and general hea l t h ," 24 specifically relates to the 396 form. So, obviously, 25 the sixth item would come in under the 396 form, and not
o Page 136 b ' I the 398. ___ 2 "If a licensee has not met the requirements of 3 5 5. 5 3 ( f ) , can the license be renewed under 4 55.57(b)(2)(3)?" Yes, it can, if he meets all of the 5 requirements f or' renewa l . It does not recall an active 6 license to be renewed. And I believe we answered that 7 earlier. 8 "What would the basis be for continued need?" i 9 And I believe we answered that, also, earlier. And i 10 that's as determined by the utility. ) 11 The next Section is Section -- no, is Reg l l 12 Guide 3.8. And I believe, John, can you start and j 13 handle those questions? 14 MR. HANNON: The question is, "Are documents 15 referred to, such as NUREG 0737, still required as 16 references?" The Reg Guide 1.8 revision that is with 17 the Rul e wou ld only -- it takes the eligibility 18 conditions, and supersedes NUREG 0737, as it relates 19 to operator Ideensing. So, those -- any references to 20 0737 have been superseded wi th the Rev 2 of Reg Guide 21 2.8. 22 MR. MUNROE: Okay. 23 MR. RUSSELL: Let me expand on that, because 24 there may be some aspects of NUREG 0737 which have 25 been committed to in a facility training program, and
i,- k Page 137 L p 1 the initial-program may not yet have been accredited. i
- 2. Those c o m m .'.t m e n t s are still in effect. They are_part of 3 the approved program, and until that program"As 4 superseded by an accredited program, and you provide the 5 letter to the staff, as is described in the generic 6 letter which forwarded the Rule.
7 MR. MUNROE: "Do c.3ndidates upgraded to senior 8 operator loose their active license status per 5 5. 5 3 ( e ) 9 while standing watch as an extra operator for three 10 months?" The answer to that would be yes. If he does L 11 not maintain his requirements as an RO, he looses his 12 active status, if he is under instruction as an SRO. 13- "Do radiation protection personnel now require ( 14 'three years experience per ANS 3.1-1981, even if tech 15 specs require less experience? John? 16 MR. HANNON: The requirements for radiation 17 protection personne3 in Reg Guide 1.8, are the same as 1 18 those included in ANS Standard 18.1 of 1971. 19 MR. MUNROE: "Can STA maintain active status, 20 as defined in Section (c)(1)(j), if the three shifts per 21 quarter are performed with the plant in a shut down, or i 22 outage condition?" John, once again? ' 23 DR. SHANKMAN: I'm assuming that you mean to l 24 maintain status as an STA, right? t 25 MR. HANNON: That's the way you want to answer I
Page 138 1 it? _ . . _ . 2 -DR. SHANKMAN: Right. So, yes. Now, we're 3 going to get a clarification. 4 HEARING ATTENDEE: Paul Rushton, Georgia Power 5 Company. Going back to the question Mr. Russell q 6 answered last, I got a little confused. The question 7 had to do with the applicability, and the implementation 8 of Reg Guide 1.B. Could we go through a step-wise 9 progression, preferably in chronological order, for a 10 utility that is not accredited, and is following the 11 current regulatory guidelines, and approved FSAR. And 12 when we want to go from a non-accredited status to an 13' accredited status, what would be the step-wise 14 progression, and the changes in the regulatory 15 environment be for us? Is the question clear? Did it 16 make sense? 17 MR. R11S S E LL : Yes, and it's quite simple. The 18 date you receive accreditation from the Academy, you 19 would send in a letter to the NRC, that says, we've been 20 accredited on this date. You then start following that i I 21 program, and the previous training program is 22 superseded. You need not even tell us about it until 1 23 the next update, which is required pursuant to the 24 l' Regulations per your FSAR, which is an annual, or once 25 each two years update, I'm not -- whsteVer that update 1
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[ u Page 139 L h i schedule is, in the Regulation, you would then tell us 2 at t' hat point in time. 3' But you can, by simply sending a letter saying L l 4 that you were accredited on, and you were implementing 5 that program,. It instantaneously supersedes'any prior 6 commitments to the' NRC by way of additional training. 7 HEARING ATTENDEE: (Mr. Rushton)- In the l j 8 meantime, we continue our commitment to Reg Guide 1.8, f 9 Revision Number One, as approved in the FSAR? a 10 - MR. RUSSELL: You may have some situations, ( 11 and I'm aware of this for some facilities, where they 12 h a' v e technica] specification commitments to the Dentor, 13 letter, or to ANS 3.3, or some other r equirement that 14 wou3d be superseded by the accreditation process. That 15 wou 3 d take not only a let ter coming in saying we are 16 accredited, but, also, a request for an ainended, in t h i e, 17 case, an administrative amendment, to the technical 18 specifications, to remove references to superseded 19 documents. And that would be processed by the P3 ant q 20 Manager, in n FSAR, and they would then be superseded. 21 HEARING ATTENDEE: (Mr. Rushton) But, again, 22 my question in the meantime, Rev One of Reg Guide 1.8 is 23 our commitment as approved in our FSAR7 l l i 24 MR. RUSSELL: That is correct. Your 25 commitment, as approved in the FSAR, is what is binding. 1 9
.. . .__--________-__-_-_______A
l Page 240 H O . I 1 P J us, any of the more restrictive requirements in this >7o y 2 Ru3e making. 3 NEARING ATTENDEE: (Mr. Rushton') Right, I 4 understand. 5 MR. RUSSELL: Okay, until such time as not-6 only you are accredited, and you tell us, through a 7 letter, that you are accredited. And at that point, you 8 then make changes pursuant t o 50.59, to remove things 9 from your FSAR, and your program. Those cases where you 10 need to amend a 31 cense, you~ submit the application for 11 amended, to strike the Sections in the Tech Specs, or in 12 the J.icense, which have been superseded'by. 13 accreditation, ( i 14 HEARING ATTENDEE: (Mr. Rushton) Okay, and 15 then, sir, upon achieving the accreditation status, we 16 wou3d become committed to Reg Guide 2.8, Revision Number 17 Two? 18 MR. RUSSELL: No. Reg Guide 2.8, Rev Two goes 19 into effect f or all facilities, as is indicated to the 20 forward to the Reg Guide, and I believe it's one year 21 after publication, right? i However, if you have an I 22 accredited program, you are no longer obligated to 23 fo)3ow the Reg Guide. So, you can put the Reg Guide 24 aside, and forget it. You, now, must implement what you 25 have committed to the Accrediting Board, okay? We have J
Page 141 1 looked at-that information, and we've concluded that 1 ,. E' 2 INPO guide 31nes in this area are equivalent to the staff ! (' 3 guide 3 Anes previously in your regulatory guides. 4 So, we are just-saying, you now meet the 5 industry commitments through INPO. And recall that the 6 industry, through NUMARC, committed to the Commission, 7 to ANS 3.1-1981, for experience requirements. And 8 that's covered in Generic Letter 84-16. INPO's 9 guide]jTes are consistent with those commitments of the 10 industry. 11 HEARING ATTENDEE: (Mr. Rushton) That 12 answered my question. Thank you very much. 13 HEARING' ATTENDEE: Steve Warren, Duke Power. 14 The FSAT. update f o 3 3 owing accreditation, it would not be 15 necessary to have the extent of detai3 in that update, 16 as previously is the case, is that correct? 17 MR. R11S S ELL : It can be b3ank, except for the 18 fact that I was accredited on. It need not say 19 anything, other than you were accredited, and the date 20 you achieved the accreditation. All records associated 21 with your training program, fo13owing accreditation, are 22 aval3able to the staff on site, for review; they need 23 not be submitted. 24 HEARING ATTENDEE: Johnny Smith, F3orida Power 25 Corporation. Going back to the question on, does the
Page 342 1 gent 1eman, whi3e'.he.1s.An SRO upgrade, go through an 2 inactive status? Okay, he goes to.an. inactive status, 3 no problems there. But while he is'in an SRO upgrade
, 4 f or come time or ten months, he is not of ficia21y in the 5 requalification' program. How is that going to affect !
6 that inactive status? 7 MR. MUNROE: What-you have to do with regards 8- to that is, if'your upgrade program meets the objectives 9' of your requaJ program, you can, then, take credit for to that. However, if there is a differential in fact,. 11, maybe your upgrade program is more intensive in many. 12 areas. However, there are many areas -- there might be l 13 some areas, t ha t are not covered at a 3 3, but are covered L 14 in a requalification program, and that individual is no 15 3onger current in requalification, is that correct, 16 John? 17 MR. HANNON: Yes, and they would have'to, in 18 order to resume active status, you wou3 d have to do 19 whatever remedia3 training would be necessary to bring 20 them up to current.with the roqualification program. 21 MR. MUNROE: l Simp 3y being in the upgrade 22 program does not, necessarily, compensate for the l 23 ! requa31fication program. 24 MR. RUSSELL: I hope that t ha t 's not an issue 25 that we f ace very of ten, because I would expect that i
Page 243 1 most cand5 dates that go into an upgrade program would 2 rece3ve a' license as a senior operator. And upon the 3 date they receive a license, they can go in and 4 manipulate the controls, and direct the activities of 5 others. So, it's only the situation where there would 6 be a period of time after his training, say, before he 1 7 gets a license, when'you may want to use him as a l 8 reactor operator, and you may have to stand some 9 parallel watch with the reactor operator before resuming 10 duties. And t ha t 's the point in time when you would 11 have to certify that he had completed the necessary 12 requirements of the reactor requalif3 cation program, jf ( 13 t here are any aspects that were not covered in the SRO 14 operating tra$njng. 15 MR. MUNROE: The next question has to do with 16 Reg Guide 2.134, and I believe Mr. Russell already 17 answered $t. And that is, "What is a full medical 18 examination report?" 19 Okay, now, basically, we've gone through the 20 submittal from the Southeastern States Training 21 Assoc 3at j on f or the areas that have to do with the Part 22 One of what we were going to talk about, which was the 25 Rule, in general. Now, we're going to talk about the 24 simulator part of the Rule. And, pretty much, Jerry i 25 Wachte3 is gojng to answer most of those questions. i
Page 144 1 The first question l's, "What procedure must be 2 f ollowed to determine whether a two' unit site will 3 require only one p3 ant-referenced simulator?" 4 MR. WACHTEL: There 3s considerable guidance 5 on this at the - in Reg Guide 1.249, the Section called 6 " Implementation." It says, that if a facility licensee 7 wishes to use a simulation facility at more than one 8 nuclear power plant, it must demonstrate to the NRC in 9 Jts certification, or in i t 's application, that the , 10 . differences between the p3 ants are not to significant 11 that they have an 3mpact on the ability of the 4 12 simu3atjon fac13Jty to meet the requirements, and the 13 gujdance, of ANSI /ANS 3.5-1985. 14 There are a 31st of indicators that ;an be 15 used as part of your demonstration, to demonstrate that i 16 there are not some sign $ficant differences, and one of t 17 the key things tha t we will use to look at, is whether [ 1 18 or not we issue dua.), or mu] tiple licenses for your l 19 operators of those facilities. 20 MR. MUNROE: The next question on simulator, 21 has to do with 10 CFR 65.45. "Are the provisions of 22 5 5.4 5 ( b)( 2 )(1) , and 5 5.4 5 ( b ) ( 2 ) (111) mutually exclusive? 23 In other words, if the utillty plans to meet the 24 provjsions of 5 5.4 5 ( b) ( 2 ) (131 ) , by purchasing a 25 simulator during the forty-six month perjod, does the l l l l
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Page 145 l 1 utility need to submit a plan per (b)(2)(1) for the t 2 simu.la t or t o be used until the plant-referenced 3 simulator is certified?" 4 MR. WACHTEL: The simple answer to that is no. 5 'If you are interiding certify a simulation facility on 6 Form 474, and you've got forty-six months from the 7 ef f ective date of the Rule to do that, you do not need 1 8 to submit to us a plan, or an application, prior to that 9 time. 'I f , however, in the course of our keeping an eye i 10 on things, we do not see any evidence that there are i 11 plans in the works for a certified simulation facility, 1 12 and if we have not seen a plan f rom you f or a non-13 certified simu] at ion f acillty, we ' l l probably get in l 14 touch with you to find out what your intentions are. j 15 MR. MUNROE: And correct me if I'm wrong, but 16 the last question is -- on Reg Guide 1.149, that has to i 17 do wjth a simulator, is, "What level of simulator 18 capabjllty must be reported and tested if a simulator l 19 has considerable simulation capability, much greater 20 than ANSI /ANS 3.5-3985 requirements?" 21 MR. WACHTEL: We are requiring that the 22 capability of the simulation facility be such that it 23 could meet the requirements of 20 CFR 55, and ANS 3.5, l 24 as endorsed by Reg Guide 3.149. To the extent that any s 25 particu3 ar simulation f acility has capabilities and 1 i i
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page 146 1 features that exceed those minimum requirements, .you do
- p. 2 not'need t'o te]3 us what they are. You do not n e e'd to I
3 certif y them to us, and we will not need to inspect 1 4 against them. l l 5 HEARING ATTENDEE: Lee W1311am, f rom Alabama 6 Power. In-the event that were to take place, we had 7 something that was beyond 55/3.5, we did not test and 8 certify it, then would that area of simulation !
- 9. capability be utilized in examining the operators?
10 MR. RUSSELL: Possibly. . J 11 (Laughter.) I 12 Let me give you an example of how that might i 13 occur. Let's say that ANSI /ANS 3.5-1985 for a transient 14 basica 3 3 y requires a parameter to move in a certain 15 direction, that you don't get spurious alarms, et 16 cetera. The standard is rather 3cose with respect to 17 mode 31ng for transients. And if you go beyond that, and I 18 you have something which is closer to an engineering 19 tool, that you cannot only predict the direction of the i 20 parameters, but a 3 so have a rather good tolerance on its i 21 va 3 ue as compared to what you would expect f rom a 22 transient. 23 Just because you have the better display of 24 the parameters, does not mean that we're not going to 25 expect that particu3ar scenario to be examined, or say i ___________---------_____________--------J
Page 147 1 it's outside the scope of what we would conduct. And if 1 1__ 2 you are ab3e to go into the area of, say, severe accidents, which we don't currently cover in the 4 requirements, we may not be examining in that area.
~
5 Tha t 's an issue as to the scope of the emergency 6 procedures, or whether tha t's appropriate for the 7 control room crew, or that's appropriate for the tech 8 support center, the accident assessment function, and 9 that's the difference. So -- 10 HEARING ATTENDEE: (Mr. Williams) I think 11 that's what the rea) question is. For instance, when -- i 12 I know in our vintage simulator, when we purchased it, 13 the limitation on the vendor that supplied it was, build 14 it to plant design. But sometimes some of the scenarios 15 go'beyond design basis, and I can't say whether it's 16 correct or' incorrect. I have no basis to certify it. 17 MR. RUSSELL: We will still be examining the 18 on design basis, because you must do that in order to 19 get into symptom based procedures, and function 20 restoration guidelines, as a matter of fact. And we 21 want to be able to see an operator's ability to use 22 those emergency operating procedures, in particular. 1 l 23 For example, at Westinghouse, the critical functions of 24 the function restoration guidelines. 25 If you look at tha t , in reality, that already J
.Page 148 1 puts you beyond the Chapter 15 design basis, transients, l !
.I 2 and evaluations.
3 HEARING ATTENDEE: (Mr. Williams) Is there 4 any guidance coming to the utilities as to how we get 5 there? 6 MR. RUSSELL: We're eso rk ing on that with INPO, 7 currently, and we are having discussions in the area of 8 training, as it relates to severe accidents. We are 9 having discussions about scope of emergency procedures, 10 also. 11 MR.'WACHTEL: One other point with regard to 12 that. There is one item in ANSI /ANS 3.5-1985, which is 13 endorsed in our regulatory guide, and is also contained 14 in our simulation f acility evaluation procedure, that 15 indicates that there is a requirement for some means or 16 mechanism within the simulation f acility to notify the 17 simulator operator, when the simulator has exceeded the 18 capabi]ity of its modeling. And that's one of the 19 things that we would be looking at in our inspections. 20 HEARING ATTENDEE: Paul Rushton, Georgia Power 21 Company. This morning it was mentioned that the License l 22 Examiners would be filling out a simulator fidelity 23 feedback report, I think it was called. Could we 24 request that those reports be included in the 25 l examination packages, or our copy of them, when they 1 l.
Page 149 I 1 returned to us. I I 5 l 2 MR. RUSSELL: They will be. ' l 3 HEARING ATTENDEE: (Mr. Rushton) They wila l 4 be? Thank you. 5 HEARING ATTENDEE: Lacy Pauley, TVA. Jerry l 6 may have already answered this question, but since it l 1 7 applies to my plant, I want to make sure that I've got 8 the right answer under 55.3 5( 2) and (3). (2) is a 9 schedu.le for a facility licensee, is (3) is a s c h e d u .l e 10 of facj]ity applicants. At Watts Bar, we are a facility ; 11 applicant, since we have not loaded fuel yet. Does this 12 mean that we submit a. plan for certification? g 13 We've got a simulator coming in shortly af ter 14 we load - or when we propose to load f uel. And we may ! 15 not have -- you know, we may be wanting to' examine 16 operators within three or four months after the : 17 e.imu3ator arrives on site. Does that mean it has to be 18 certified, or does that means we can propose a plan with I 19 the app 31 cation for license? j i 20 MR. RUSSELL: You can tell us what you are 1 l 21 going to do with your application for license, but, in ! l 22 fact, you are not required to have a certified 23 simulator, or a simulation facility, until the 26th of 24 May, 1992. s 25 HEARING ATTENDEE: (Mr. Pa'u l e y ) Okay. Very
Page' 150'
)
1-- goud. Thank you. 2 MR. RUSSELL: The Ru3e, which requires that to 3 be. in place by tha t t i m e~, i f an app 3.i can t 'is in t he J 4 pi pe l i n.e ri gh t now, is not going to have to do things 5 faster t han t he 'res t of the people out there, that 6 already have plants operating. 7 HEARING ATTENDEE: (Mr. Pauley) So, I cou3d 8 be treated as a licensee right now? 9 MR. RUSSELL: Yes. 10 HEARING ATTENDEE: (Mr. Pauley) Thank you, t 11 MR. RUSSELL: This part of the rule is 12 intended more of the guy who might apply five years f rom 13 - now, that we don't have an application currently under 14 review. 15 HEARING ATTENDEE: Ken Rusick (phonetic), 16 Westinghouse. A couple of questions for Jerry. When
'17 w133 the inspections --
the officia3 inspections start? 18 Wi33 they start before certification takes place? 19 MR. WACHTEL: No. There wilI be no -- there 20 .are two minimum criteria. They wil3 not start before 21 this guidance has been out f er six months, and they w13 3 22 not start until we have received the first certification 23 form, or the first app 31 cation for approval. 24 HEARING ATTENDEE: (Mr. Rusick) Okay, another 25 question, the operator / examiner feedback form that was l _.-_-________J
Page 152 3 discussed, will that be.used to determine the status of ( 2 current simulators?. 3 MR. WACHTEL: No. s 4 HEARING ATTENDEE: (Mr. Rusick) In some way? 5 MR. WACHTEL: No, the guidance to the 6 Examiners 1s that that will be applicable only to 7 sfrulation facilities that have been certified, or have 8 applied for approva1. 9 HEARING ATTENDEE: (Mr. Rusick) So, is it 10 true that if I wait for forty-six months to certify, 11 that's an advantage to me? 12 MR. RUSSELL: No. It's not an advantage, 13 because you are going to have to be providing 14 substantia) additiona3 inf ormation f or every app 31 cation 15 tha t you sent in, and we are going to be still reviewing 16 that, and making determinations on individual app 31 cants 17 and candidates. 18 HEARING ATTENDEE: (Mr. Rusick) But, yet, you 19 won't inspect us? 20 MR. RUSSELL: I won't inspect your simu3ator, 21 but I'm certain3y going to be keep close tabs on your 22 applicants. 23 HEARING ATTENDEE: (Mr. Rusick) Unt13 the 24 forty-six months are over? l 25 - MR. HANNON: But i t 's my understanding, that l
Page 152 1 even today,. with the present vintage of simulators, that ( 2 you still are experiencing feedback reports, a3though 3 informa3, in~the exam' review process. So, I would
'4 expect that to continue, if the Examiners have a prob 3 em 5 in conducting the operating test at your facility, you 6 can expect to see some feedback in that regard, even 7
though it won't be the formal thing that Jerry is 8 ta3 king about. 9 HEARING ATTENDEE: George Barnes, Carolina 10 Power and Light. In ES-109, you talk about the 11 e31gib331ty requirements. And in there it says, if you 12 have an INFO accredited. program, and an approved 13 ( sJmo3ation fac131ty, instead of saying a certified 14 simu]ation facility, what does that mean? Is there anv 15 difference? 16 MR. WACHTEL: What we should say, and we may 17 ha v e been a li t t l e cloudy on our terms. We should say 18 an accepted simulation facd33ty, or an acceptable 19 simu3ation facility. And an acceptable simulation 20 facility is defined as one that is either certified, or 21 approved. 1 ) 22 MR. MUNROE: Okay, the last part has to do 23 with requalification. John, that's on page six, at the 24 bottom third, Section 10 CFR 55.59, 1 25 MR. HANNON: The first question is, "What is l
Pcge 153 l L 1- required for Commission approval of a requalification j l > .j i 2 Program?" I beJieve we may have already answered that. l 3 In fact, nothing is required, you simply certify to us 4 that you have an' accredited program, and that's 5 sufficient. 6 "Is the National Academy of Accreditation ' 1 i 7 sufficient?" As indicated in the Generic Letter 87-07, I 8 ff it is based on a systems approach to training, yes, 9 that is sufficient. Do you want to add anything to 10 that? I I 11 MR. RUSSELL: I think we covered it ear 31er. 12 We believe that a program which is developed f ollowing 13 the INPO guidelines for continuing operator training, 14 for licensed operators which was issued in October, 15 constitutes an adequate basis for conc 3uding that the 16 program has been developed in accordance with the 17 systems approach to training. And if you fo3 low that, 18 and you are accredited, that's all we need to hear. 19 MR. HANNON: "Is a comprehensive written 20 examination required once every twenty-four months?" i 21 And the answer is yes, at a minimum. And i t can be 22 given in a segmented program, provided that the sum of 23 the parts equals the whole. At the end of the twenty-24 four month period, it can be demonstrated that you have J 25 equiva J ent 3 y provided a comprehensive examination. I i _____ ____ Q
Page 154 1 1 MR. RUSSELL: you have question over here. 2 MR. HANNON: I'm sorry. 3 HEARING ATTENDEE: George Barnes, Carolina .) 1 i 4 Power and Light. As far as the INPO document, I think, I 5 86-025 is concefned, continuing training, you just say 6 as long as you are f ollowing the guidelines. How 7 speci fic should we be, or how -- should we 3 ook at 8 verbatim compliance of the guidelines, or just in 9 genera 3. 10 -MR. RUSSELL: There is a hierarchy of criteria 11 within the INPO program, starting with objectives. Then 12 you have erjteria, and then you have guidelines. You 13 must meet the intent of the objection.
, Okay, t ha t 's a 1 14 sha33. Okay, when you get down to the criteria, you may 15 not meet, verbatim, some of the criteria, but you may 16 have a3 ternate methods. When you get down to the 17 guide 31nes, you are, again -- that's, ba si ca l l y , INFO 18 saying a way that would, they believe, would be 19 acceptable, and meet the intent of the criteria, and the 20 objectjves.
l 21 In your program, you have mechanisms for 1 l 22 reviewing and deciding how you put that process in j 23 place. l The fact that you are accredited is evidence to 24 us that you understand how to use that process, and 25 those guidelines. We don't need to see the details, l L j l L i t .-_----- -_-- ---- a
i Page 155 L 1 based upon the f act that you have been through i t i' 2 accreditation, and you understand what the objectives 3 are. 4 The principal goal f or revising the requal 5 Programs is to a'11ow f eedback f rom operating problems, 6 Particularly 3 d censee events, plant design changes, 7 procedure changes, and other aspects of training for 8 wh3ch there is a demonstrated need to be factored back-9 in the program, and not be constrained to X number of 10 hours in a eJass, because that's wha t 's been required in 11 the past. 12 We are a 3 so very $ nterested in a f ront end ( 13 analysis, looking at tasks, and deciding which of those 14
. tasks are appropr$ ate for continuing training, based upon 15 such criteria as, importance of the task, frequency 16 being performed, et cetera. I t 's that analysis process, 17 looking at that program on a frequency up to twenty-four 18 months, and deciding what you are going to cover.
19 That's the process that we're looking for, and we think 20 that the TSD process, and INPO's training systems ; i 21 deve] op manual, the IfiPO guidelines for continuing 22 training, the criteria and objectives for accreditation ) J 23 constitute an adequate basis for the staff to conclude 24 that if you are accredited, and you know what you are ! 1 25 doing, then you can say, yes, I've done it in accordance l l
Page 256 [ l-I' with the systems approach.
\ l '
2 In.accordance with the systems approach means, 3 I'm no longer fo3Jowing the proscriptive requirements of 4 Appendix A to Part 55 that ma.y have been in existence at 5- the' time it was' accredited, because they didn't want to l 6- change it, Yet, because there was concern about being l 7 inspected'against it. 8 HEARING ATTENDEE: (Mr. Barnes) You've 9 answered my question. The biggest thing I was worried 10 a bou t ,- there were a 3ot of numbers thrown around in 11 twenty-six, and a lot of other things thrown around, i 12 which we tend to get back-doored into. You know, i
', 13 someone comes in and says,-we told you we were going to '
14 f o] ] ow t his, or you ought to f ollow this. And i f we 15 don't do it, but our program success rate is there -- we i l 16 are very successful -- l 1 17 MR. RUSSELL: Don't 3ook to the NRC to give 18 you relief from what INPO's programs are. ; 1 19 (Laughter.) 20 . HEARING ATTENDEE: (Mr. Barnes) We33, you 21 s a i d i t 's a g u id e li ne. Okay, if I say, hey, put in 22 eight hours of simu3ator time, and INPO says a hundred 23 and twenty, but we're doing okay with eighty. 24 MR. RUSSELL: That's between you and INPO. 25 HEARING ATTENDEE: (Mr. Barnes) Okay, l l l
Page 157 1 MR. RUSSELL: Okay? What I'm saying is, that i
\ I 2 we have confidence in the process as we have seen it, 3 now, in evaluating in a number of facilities. We are !
4 going to try and stay out of the business of reviewing 1 5 and approving training programs. We want to look at the 6 product that comes out at the end; the candidate and his ) 7 abilities. We may get back into training programs, if 8 we see performance deficiencies on the job, through an 9 event, or something else, through our inspection 10 program. 11 We have devel oped guidance -- what we ca] ] our i 12 series of questions, in NUREG 1220, as.to how we're ., 13 going to go about inspecting. So that you know what you 14 consider to be fair game for us to look at. But we are 15 not in the mode of endorsing, telling INPO what to do. I 16 That's between the Accrediting Board, and INPO, and the ! 1 l 17 facJ1111es. And you can take that up with the next l 18 meeting with INPO. 19 HEARING ATTENDEE: Gene Karlson, Florida Power f 20 Corporation. The new 10 CFR 50.50(4)(1)(1) requires us, 21 I believe, to notif y you of any scope change in our 22 program. Since we are not defining for you what our 1 23 program is now, what is it that you are looking for? 24 MR. RUSSELL: Two aspects. Let's say that you i 25 are using an NRC approved program today, and you make a
I Page 158 i 1 modification to that program to conform to the l 1 l 2 ReguJation. That is, you go from an annual written I 3 examination, to a comprehensive examination each two 4 years. You may do that pursuant t o 50.59, and simp]y ; 5 amend your FSAR'to the.next update, to show that. Or,
-6 preferab3y, you would be accredited, have completed your 7 review of your requal program, and confirmed it as a !
8 systems approach to training, and used that vehicle. 9 Both of those may be done pursuant to 50.51. 10 They do not require amendments to licenses. It is only 11
$n the case that you must make a submittal to us, that 12 you have, in the past, committed to something that's a :
-l 13 part of the licensing document. For instance, some 14 f a c.13 5 t i e s do have the Denton 3etter incorporated in the 15 Tech Specs, associated with staffing on shift, and some 16 other things.
17 You need t o l ook a t tha t on a case speci fic 18 basis for your utility. Our intent is, that you be able 19 to do most of those under 50.59. They would not require 20 review and approval by the staff in advance of your 21 implementing the change. 22 HEARING ATTENDEE: (Mr. Karlson) Previous 3y 23 the 50.54($) said, a decrease in scope, frequency, or 24 ! , duration. Fow a33 you are saying is scope. I assume \ { 25
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that we can -- J l _________ _----_--------------_--------------------------------------l
I Page 359 1 MR. RUSSELL: -The reason for that, is the Rule 1
- I -2 specifies that thou shall have for duration no longer l
l 3 'than two years, and it must be followed, so duration is i 4 specified in the Regulation. Your program that you use 5 through INPO describes content. Duration is still 6 specified in the Regulation. You may not have a requa3 7 program, or a continuing training program that is 3cnger 8 in duration than two years. That's why t ha t 's not 9 covered. 10 HEARING ATTENDEE: (Mr. Karlson) Or frequency 11 of the' parts 7 12 MR. Rt1S S ELL : That's covered by the systems l 13 approach.to training, where you look at the task that is 14 performed, and you decide what that is. And that's why i 15 excluded the c 3 assroom OJT and examining portion of 16 requa3. If you certify that your program is done in 17 accordance with the systems approach to training. 3 1 18 HEARING ATTENDEE: (Mr. Karlson) A33 right. ) 19 MR. HANNON: Just for completeness, let me run 1 20 t hrough -- I think we may have answered some of these l I 21 final questions, but to make a point on the l l 22 comprehensive written exam, although you may be given 1 23 ' segmented exams in your requalification program, you 24 should be aware that if the NRC does come and conduc t a 25 requalification exam at your facility, it will be, 1 l
Page 160 l 1 indeed, a comprehensive written exam, and an operating 2 test.
-3 The next question has, I think, been answered.
4 "Will requalification exams be administered to non-5 approved-requaldfication programs?" It's not ---I -- I I 6 guess we need to understand what you mean by non- I l 7 approved requalification programs. As we see it, now, 8 there are no such animals. They are either -- you are 9 either operating under presently approved -- NRC 10 approved Appendix A, the requal program, or you have an 11 INPO accredited SAT based requal program, and there 12 can't be anything outside of that. 13 "So, will f acility licensees be allowed to
-{ l 14 base the requalification program on the identified 1
15 weaknesses from a systems approach to training?" Yes. I 16 "Must plant control manipulations during the ! 17 requalification period be documented on Form 3987" The 18 documentation hasn't changed in that -- for that 19 particular item of the 398 Form, you still have to 20 certify that-the control manipulations were done. Only
]
21 in t he case where there would be exceptions to t he 22 guidance in the Reg Guide would there need to be some 23 amplifying comments made. 24 For example, if you did five similar type 25 manipulations, and you concluded -- you evaluated that
Page 163 1 concluded that was: acceptable, you might want to I.
\
2 point that out in the comments section on the 398. 3 HEARING ATTENDEE: William Downs, Georgia 4 ' Institute of Technology. Most of the manipulations that 5 are listed in the Regulation are not applicable to us. 6 We are still operating under the ten manipulations in 1 7 two year, that we have been in the past? 8 DR. SHANKMAN: If that was in your approved 9 requalification program, that's would -- 10 HEARING ATTENDEE: (Mr. Downs) That's what 11 we're operating under, now. 12 DR. SHANKMAN: Yeah, it would still maintain j 13 whatever is approved. 14 HEARING ATTENDEE: (Mr. Downs) Okay. ' 15 MR. HANNON: One final question, here, is "How are microfilm records authenticated to meet i 16 17 55.59(c)(5)(ii)?" They are by an authorized 18 representative of the facility. That's the answer. 19 HEARING ATTENDEE: Roger Baldwin, Virginia I l 20 Power. We have heard many references to writing the NRC ' 21- a 3etter, saying we now have an accredited program. To l 22 whom should these letters be addressed? 23 MR. RUSSELL: Letters relating to the training 24 program, which are involved in operating licensing 25 should be addressed as a Region. Those things in the I
)~
Page f16 2 1 Rule that relate to the simulator should be addressed E 2' t o Headqua r t ers. We. would like to have a copy of the 3 1etter to the Regions provided.to Headquarters. That's
- 4. on3 y in the case where you do not need an amendment to 5 your facility 1"Icense, okay? If you need an amendment, 6 you Mre going to have to f ollow the normal amendment' 7 . process to Washington.
8 HEARING ATTENDEE: (Mr. Baldwin) Right. 9 'M R . RUSSELL: That is, if you have made a 10 commitment, and it's in your Tech Specs, incorporating a 11 reference to the Denton letter, for instance, to remove u 12 that from ynur Tech Specs wi 3 3 - take a 31 cense amendment , 13 in accordance with the normal process for amending 14 3 1 c e n s e t, , with number of copies, the application, et 15 cetera. 16 If you do not requjre an amendment, or you can ; 17 do it under 50.59, and it's related to operator 18 licensing, then the Regulation specifies that you send i 19 that to the Regional Administrator. 20 HEARING ATTENDEE: (Mr. Baldwin) Okay, 21 understood. A second question, please. The generic 22 3 et t er 87-07, has some language that is a 35tt3e 23 confusing. We've heard about the -- wel.1, it speaks of 24 substituting an accredited training program for initial 25 and requa]i fication training programs previous 3 y
--- a
Page 163 1 approved'by.NRC. Now, our requalification program has 2 been approved by the NRC in the past, but we've never l l
- 3. had the initial training program approved by the'NRC.
4 Is that a slip of phraseology? 5 MR. RUSSELL: That's not correct. The initial ! 6 training program.is described in the FSAR, as part of 7 the. application. At the point you got your license 8 issued,. you had, in fact, an approved training program, ! 9 and it's part of.the cold licensing, and it dates back 10 in history to when you started. But you did ha'is a 11 t raining program that was approved by the NRC at the 12 time the facility received its first license, , l 13 HEARING ATTENDEE: (Mr. Baldwin) Although, 1 14 it's not currently in the updated FSAR. { 15 MR. RUSSELL: That's because the updated FSAR a 16 is not a legal and binding document. The document which j 17 controls is the application, which is referenced in the-18 license on the date you received the license. 1 i 19 HEARING ATTENDEE: (Mr. Baldwin) Understood. 20 Thank you. l 21 MR. RUSSELL: And the updated FSAR has a value
)
22 to keeping it current, to make it easier for subsequent 23 amendments, et cetera. But the actual legal document is ] , 24 the FSAR, as submitted, and amended prior to licensing
- - 4 1
25 in all of the letters, and other documentation that 1
, 1 i
i i
-1 1
1 Page .164 1 comes ~ with'it. I 10 2- HEARING ATTENDEE: (Mr. Baldwin) Thank you. 3 HEARING ATTENDEE: Mark Sheppard, Florida 4 Power and Ligh't. In the process of written. exams, we l 5- receive a copy 6f the test, after its been administered. t 6 and as part of the documentation, we are provided with 7 the 3 earning objectives of the source documents from 8 which these questions were derived. I'm wondering, in 9 the area of simulator examinations, if we wouldn't be i 10 provided with that same. documentation, since we'go to i 11 the effort to develop scenarios that are based on l 12 jndustry events, LER's, 3 earning' objectives that we've 13 derived from our program that when you design your 14 simu3ator exams, they wouj d also be based upon these 15- same precepts. And that when you leave,.we would have ' 1 16 that document. 17 MR. MUNROE: We current 3 y f d 3 3 out, in 18 attachment three and five to the current Examiner's ! 19 Standard, which de31neates the objectives which the ' 20 event we are' performing is trying to accomplish. Those 21 have been provided to a3 3 of the jndividua3 s who have l 22 L failed the examination as a matter of course. The i 23 - individua3s who passed the examination, we have on3 y 24 provided the attachment three, which is the delineation 25 l of the overa33 exercise, itse3f, ma 3 f unction by 6..... . . . . . ,
Page 365
)
1 malfunction, or over-ride by over-ride. And we have not 2 been providjng the' attachment fives to the individual 3 who passed. a If you request, we can provide you a copy of :
)
5 attachment f i v e s~, which contain our objectives for that ! 6 examination, once we complete the examination writeup 7 effort. 8 HEARING ATTENDEE: (Mr. Sheppard) Also, in i 9 that same vein, we use that document in our review of 10 the exam to make our comments within the five working 11 days. Would that also apply in the simulator exam? 12 MR. MUNROE: The comment procedure has been 13 Ilmited to the written examination by the Examine r 's I i 14 Standards. We have not -- you can comment, obviously, 15 on our exam -- on the simulator, and we are more than 16 willing t o list en to what you have to say. But we have ! 17 .) not been going through a formal comment procedure for 18 the simulator in the same mode. One of the reasons is, [ 19 the simulator examination is an on-going thing during 20 the course of the week. And the written examination is , i 21 given typically, although not all the time, but typical 22 in the first day. And, usually, by the end of the week, l \
\'
l 23 you provide us with your written exam comments, and that i 24 expedites the grading process. 1 l 25 The simu 3 ator exam, we have not solicited 1. 4 i I
Page 166 1, comments as far as written comments, but'if you' choose. 2 to -- if you desire to make - them,_. we'l l be~more than i [ 3 wi))ing to listen to them. 4 HEARING ATTENDEE: (Mr. Sheppard) I-have one 5 other question.' Reg Guide 1.8, which endorses certain 6 positions through ANSI 3.1-1982 for training and 7 qualifications, in that ANSI Standard the experience 8 requirements are different than as are stated in the ! 9 Examiner's Standards. For instance, for a reactor i 10 operator, ANSI 3.1 of '81, requires three years power 11 plant, one of which is nuclear. And I believe it says 12 two years as a non-licensed operator, with six months as l ( 13 a non-licensed operator at the facility. 14 Is Reg Guide endorsing those eligibility 15 requirements, also, or just training? {
.I 16 DR. SHANKMAN: Can you be more specific? I 17 would like to look at what you are-saying?
18 HEARING ATTENDEE: (Mr. Sheppard) I believe l j 19 in the ANSI Standard 3.1, the 1981 version, if you look 20 at the experience requirements for reactor operator, 21 it's three years power plant, one of which is nuclear. 27 And then there is other verbiage, about being a non-23 3dcensed operator at the facility. , 24 MR. RUSSELL: We'l l look at that one, and come 1 25 back and give you an answer.
s , Page- 167 a fis 1 MR. MUNROE: We're going to take a. break, now. 4' 2 And I think Susan can, maybe, spend.some time on it. l 3 So, why don't we take about a twenty-five minute break, ! l 4 and we'll get to Dan when we come back, then. l (. 5 (Whereupon 'there was a pause in the proceedings.) 1 1 ,p 6 MR. MUNROE: Okay, l e t 's start again, and I dl > W 7 think when we left off, Dan Moore, here, had a question. 8 So, I guess we can go with Dan, first. : i 9 HEARING ATTENDEE: Okay, Dan Moore, Georgia )
.10 Power Company. I want to ask you a question about l 11 documentation of exams, that we give at the Plant.
1
-12 Under the requal program, I believe the exams are -- it i 1
13 says that we must keep the student's answers for the I 14 period of the license. Does this mean that we must keep 15 those exams as a quaJity record, which means we keep it 16 f or the lif etime of the plant, or are you saying tha t we 17 keep it'for the. term of the license? 18 MR. RUSSELL: It's for the term of the i 19 operator's license. And in this case, for example, his 20 records would include six operating test examination 21 forms, and three comprehensive written examinations in I 1 22 l his individual file, until such time as his license is j q 23 renewed, and then you start over again. Now, if you use I a 24 a segmented examination in lieu of a comprehensive exam 25 for each requal program, and you have more written exams - 1 I l
Page 268 1
'than~three, then . tha t 's a function of how y o u'. s t r u c t u r e .
'2 your program. I t 's only for.the. term of that individual.
3 '31 cense. 4 : HEARING' ATTENDEE: ,(Mr, Moore) So,.you are 5 saying for any operator exams that we administer, once 6 we are past the'renewa 3 stage, we cou3 d destroy those as 7 3 ong as we have quality records to back up the f act that 8 he had t h e- exam'-- in other words, the grades, and so 9 forth? 10 MR. RUSSELL: The fact that he was in a 11 requs 3 3 f 3 cat ion program .before, and you certified that, 12 yes, you could put.them in-other quality records. 13 HEARING ATTENDEE: (Mr. Moore) I guess one
.14 t hi rig I'm not making clear. On even initis3 exams that 15 we give, operators, are we required:to keep the exam,
.16 3tse3f, or can we'just keep a summary that goes $n his 17 hjstory fj3e -- a summary of his grades, and things 3ike 18 this? I don't know if I --
I -- we keep his master 19 exams -- we keep a copy of the ahswer of the master, but 20 are we required to keep the-individual student exams, 21 and h$s answers? i 22 MR. RUSSELL: I'm not sure that I recognize e 23 d3fferentiation. It sounds to me like you want to have 24 some kjnd of a. summary that says, he got this grade on f 25 the exam, and keep a master copy of the exam? ) j i 1 4
Page 169 1 HEARING ATTENDEE: (Mr. Moore) We keep a l I i- 2 course performance summary -- 3 MR. RUSSELL: And you are only talking about 4 doing that outside of the current license? 5 HEARING ATTENDEE: (Mr. Moore) Right. 6 MR. RUSSELL: Okay, that seems acceptable. ; 7 Our requirement is only that it be maintained during the ; i 8 duration of the current license, and when you get that 9 license renewed, you may eliminate that stuff out of 10 that file, and start over. 11 HEARING ATTENDEE: (Mr. Moore) So, you are 12 saying we could do that on the initial -- once he get s a 13 Jicense, we could do that on the initial files, too? 14 MR. RUSSELL: That is correct. 15 HEARING ATTENDEE: (Mr. Moore) Okay. 16 MR. RUSSELL: It's for the term of that 17 license that it's to demonstrate that you've met the 18 commitment, or the requirement of the Regulation to 19 conduct operating tests, and comprehensive written 20 examinations during the term of that particular license. 21 That starts on the day he gets the Ideense, or it starts 22 again on the day he gets a license renewed. The records 23 prior t o those times can be handled in a manner similar 24 to what you described? 25 HEARING ATTENDEE: (Mr. Moore) Thank you. l l
page 370 1 MR.'MUNROE: Yes, sir. I
\ F 2 HEARING ATTENDEE: Bi 3 l Whalen, Florida Power 3 and Light. It appears we have a transition problem that 4 may, indeed, present for the utilities kind of a " Catch 5 22". Our past requal programs, for those of us who 6 don't have p3 ant-ref erenced simulators, have not 7 included an operating test, they have included some 8 operating evaluations, but not a pure test in the 9 context of the new Regulation. Some of the currently 10 31 censed operat ors wi 3 3 be up for renewa3 immediate3y, ,
11 as soon as the new 10 CFR 55 goes into effect. 12 W133 there be a transition period during which 13 it would be possible to get a waiver f or those 14 personnel, becauss they w13 3 not have had an operating 15 test. We do not ,,a v e a simulator certified by the NRC 16 that we can use to conduct an operating test. And, in 17 fact, I'm not even sure under the -- the way I read the 18 new Regula tion, we could go to our current of f site 19 simulator, and use it to conduct an operating test. 20 So, how do we address renewal of licenses f or 21 the period of time between now and when we get our 22 plant-referenced simu3ator; or will there be some time 23 after which we wi33 have to do an operating test? 24 MR. R11S S E LL : I think the answer is pretty 25 straight forward. I think the time frame between the l l l l l l l _ _ _ _ _ _ _____ _ _ _ _ O
! Page 273 j 1 effective date of the Rule, and one year following, ki 2 during that period of time, an individual may not have a yet had an annual operating test, and you may put him up 4 for a license renewal. Okay, after one year has 5 transpired, everyone should have had an operating test. ) 6 Now, the issue of whether an operating test is on a 7 simulation facility, or it's an operating test that's 8 conducted on the plant walk through portion. 9 Now, you will be required to do at least the 10 plant walk-through portion. The issue of doing it on a 11 simulation fac1]ity, that would be required by May the 12 26th, 1993. Prjor to that time, if you certify a 13 simu lator be f ore then, you would a l so do i t on the 14 simulator. If you are currently using a simulator, and 15 we are conducting examinations on it, we expect you to 16 continue to do so, and within one year of the effective 17 date of the rule, start examining candidates, using your 18 current simulator as a part of the operating test for 19 the requalification program. 20 Now, I hope that covered it. 21 MR. HANNON: Let me add just, also, that you 22 have to make sure that the" documentation that you 23 provide f or that annual operating test addresses all 24 twelve items in the new Regulation. So, the 25 documentation form that I discussed this morning, the
b Page 372 1 1 157, is one way that we are going to be doing that. And i f l
\ 1- 2 you can use alternate ways, but you must make sure you 3 document a33 twelve items. j i
4 HEARING ATTENDEE: (Mr. Whalen) Okay, now, j 5 during the year -- this one year' period of transition, 6 do we document, by exception, and ask for a waiver on 'l 7 our requests for renewa37 Would that be the appropriate i 8 way to hand 3e that? 9 MR. R11S SELL : Let us take that question, and 10 address that in the written response. My intent, right 11 now, wou3d be, pre 31minar13y, to say no, that that wou3d l 12 not tur required. I think that would just be creating 13 paper for paper's sake. But we'33 specifica33y address 14 that in the transition process, and address it in the 15 Exa m i ne r 's Standards, which w133 be effective on the 16 26th of May. 17 HEARING ATTENDEE: (Mr. Whalen) Okay, thank 18 you. 19 HEARING ATTENDEE: Paul Rushton, Georgia Power 20 Company. My question has to do with instructor 21 certifications. As I understand it, in the already , 22 accredited utilities, an instructor wi 3 3 considered to 23 be certified to teach licensed operators after they I 24 complete the accredited training program. In the case 25 of a ut13ity that doesn't have their operations programs
Page 173 1 accredited, yet, could you outline what the requirements 41 4 l' 2 wil] be. I can't find them anywhere. 3 MR. RUSSELL: Now, the requirements are 4 basically those which were in existence before the 5 ef f ective date 6f the Rule, and that is, to either have 6 an individual who has competed a training program 7 comparab3e to-that-of an SRO, and been examined on it. 8 We used to ca33 that instructor certification. Or be a 9 .1icensed senior operator, who is currently enrolled in a
'10 reque] training program.
11 Because of the f ac t that we no longer are 12 going to be giving instructor certifications, you then-13 have on3y the option of.using a 31 censed operator to ( 14 teach those course. We are not going to give any 15 further i ns t ruc t or 's certifications, that's not 16 permitted under the Rule.
-j
-17 HEARING ATTENDEE: (Mr. Rushton) So, training l
18 instructors must be 1Acensed operators? ) { 19 MR. R11S S E LL : Until such time as you get I l i 20 accredited, or some other way of getting~ subject matter l 21 expertise through your accredited program, wh5ch 22 includes instructor training. We are not going to 23 specify that for an accredited program. But you may 24 have a program on record today, in which you have l \ 25 committed to the requirements to the Denton 3etter, l _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - _ _ - - _ _ - - _ _ =
Page 174 1 which said you were_ going to do certain things to insure-2- subject matter expertise in instructors. And that was, 3- to either use a 31 censed senior reactor operatc:, or an 4 A ndj v 3 dual who has been exam.ined by the NRC to the same 5 leve3 as a sen16r operator.- ! 6 We are not going to-examine without issuing a 7 3icense, f 8' HEARING ATTENDEE: (Mr. Rushton) WJ33 people 9 who are' currently certified by virtue of the fact that. 10 they have previous]y passed a senior reactor operator 11 examination somewhere, and thus demonstrated their 12 competency, w333 they continue to be considered as
', 13 certified to teach?
14 MR. R11S S ELL : Yes. But when it comes time 15 'when they come into us af ter the ef f ective date of the 16 Ru3e, and they wou3d 31ke to have their certification 17 renewed, that's not going to happen, because there is no 18 such certification any longer. 4 19 HEARING ATTENDEE: (Mr. Rushton) But these 20 certifications do not expire? 21 MR. RUSSELL: They do. They have a two year, l 22 and we have been' renewing them. 23 MR. M11HR OE : We]3, we had for a while, but we 24 secured doing that recently. 's 25 MR. RUSSELL: We have for a while, but we have l
Page. 375 1 stopped doing that. The Rule makes that final, that t s 2 there is no renewa3, anymore. 3 MR. MUNROE: The original ones were issued 4 with a term of two years. Subsequent to that, and I'm 5 not sure how long after that, we starting issuing them 6 with no expiration date on it. 7 HEARING ATTENDEE: (Mr. Rushton) So, then, if 8 I may be perf ect 3 y clear, here let me come back to this 9 point. Someone who has passed an SRO exam given by the 10 NRC at some point in the past, is considered certified, 11 or not? 12 MR. RUSSELL: For the purpose of meeting your 13 training program commitment of having an individual who 14 has know3 edge 3 eve] comparable to that of a senior 15 reactor operator, I would say the answer is yes, j 16 provided the individua3 is maintaining currency in the- ) i 17 requaJification program, with respect to any changen 1 j ( 18 which would affect his know3 edge base. 1 19 HEARING ATTENDEE: (Mr. Rushton) Very good, 1 4 20 thank you. 21 MR. RUSSELL: I believe that's consistent with 22 what INPO is looking at in the instructor training. I'm i 23 going to s5t down and 3ook at that, also. l L 24 HEARING ATTENDEE: Steve Frye, with Duke Power 25 Company. And my question is concerning the annua 3 L
Page 176' 1 operating e x a m .- And'I was wondering, by definition, b 2 what constitutes an operating exam?' .Since 1979, at-Duke 3 Power, in our NRC approved requal programs in a31 three 4 of our locations, and all, we administer.what is' called 5 an accident assessment exam.- I t 's. an operational type 6 exam, which is documented by' written examination, which 7 ~ tests the operations individually on their knowledges 8 'and how they can operate the plant, implement 9 procedures, djagnose a situatlon, a transient, an 10 accident, or whatever. 11 And I was wondering, by definition, does this 12 meet the annua 3 operating exam. criteria? This has also 13 been J ocked at by a couple of your NRC individuals, as 14 far as taking the subjectivity'out of an operating exam. 15' MR. R11S S E LI, : I understand the examining 16 process that you use, where you combine it with a 17 simu.lator, and you freeze it, and.then you evaluate your 18 diagnostic capabilities by having them describe what's 19 going to happen, and then you restate the simulator, and 20 find.out.Af that's what happened. l 21 HEARING ATTENDEE: (Mr. Frye) No, sir, what 22 we do is --
- 23. MR. R11S SELL : That may meet part of the 24 requirements for an operating test, but you need to look 25 at what is specified in the Regulation, by way of i1 iiii9 . .: i. _ . . . . . .. . . . ......! . . . . _ . ..s . _ . . . . . , . .- . , , , . . . 7., ,._ . . , . l
Page 377 1 observed behavior for the operating test. and assure yourse3f that the way you are implementing covers for 2 3 those twelve items for requal, for an operating test 4 HEARING ATTENDEE: (Mr. Frye) As 3ong as it 5 meets the -- - 6 MR. RUSSELL: The start up, shut down is the 7' only portion that's dropped out. But control board 8 awareness, familiarity, those kinds of things are stil 3 ' 9 being assessed. And that's why we said, we'are revising 10 our forms to be in conformance with the Rule. You need 11 to 3 cok at your program, and you judge whether you have 12 met those twe3ve items for the operating test for 13 requa3 14 HEARING ATTENDEE: (Mr. Frye) Okay, as long 15 as it meets the twelve items specified, then? 16 MR. RUSSELL: That is correct. That's the 17 c:r i t e r i a , the twe3ve items specified in the Regu3ation. 18 HEARING ATTENDEE: Art Friedman, from Virginia 19 Power. I want to ask a couple of questions related to 20 the NRC administered requa3. What is, and we talked 21 about this a lit tle bit at break, but I wou 3 d like to 22 get it on the record. I asked if it wou3d be possib]e 23 f or an individual to be selected twice during the, say, 24 s3x yes period before a33 other individual 3deensees 25 were selected once? l _ _ _ . _
Page 178 1- (Laughter.) I f 2 MR. MUNROE: And I be3deve the answer was, 3 that we would obvjously intend to try and select other
~4 people, who have not been selected randomly, before we 5 would select an-$ndividual a second time.
6 MR. RUSSELL: That is correct. That's the 7 Intent. 8 MR. MUNROE: But that does not preclude him, 9 necessarily, if we got everybody else, he may very well . 10 be selected twjce. 11 MR. RUSSELL: Yeah. I'f we've been through a 31 12 of the peop 3 e that have six year licenses, and we are 13 stiJ3 samp33ng, $t 3s possib3e f or an individual to be 14 examined twice. 15 HEARING ATTENDEE: (Mr. Fr3 edman) Okay. So, 16 dt's random, but the pool from which the random 17 selections are'made gets sma33er as peop3e are selected? 18 th R . RUSSELL: Or 3 t could get larger, based 19 upon more six year 31 censes being issued. 20 HEARING ATTENDEE: (Mr. Friedman) Okay. 21 Right. Right. 22 MR. RUSSELL: At some point in time, it w13 3 23 reach a equilibrium 3 eve 3, where everybody has-a six 24 year 31 cense. 1 25 HEARING ATTENDEE: (Mr. Fr$ edman) Okay. And,
--------------------------------}
Page 179
.J 1
1 then, what would happen if, by chance, an individual j 1 I weren't se3ected during the six year period? 2 3 MR. RUSSELL: Tha t 's one that's interesting. 4 We wou3 d probab3 y have to consider that he had made a 5 timely applicat3on for renewal, and as a result, his I i 6 existing 31 cense would remain in ef f ect, and we would 7 not issue a new license, until we had examined the 8 individua3. l 9 HEARING ATTENDEE: (Mr. Friedman) Okay. ! 10 MR. RUSSELL: It's the timely application for l 11 renewa3 provision. The mechanism we wd33 use, is we
.I wj]3 go to his docket file.
12 The examination of record 13 that he did pass wou 3 d be in the docket fil e, and tha t 14 wou3d be the basis for renewing the license. If there . 15 Asn't one in the docket file, we wou3d have to examine 16 him prior to renewing the license. 17 HEARING ATTENDEE: (Mr. Friedman) Okay, 18 thanks. Another question is, what occurs when an 19 individual fails the NRC administered requal? 20 MR. MUNROE: When the individual fails the NRC 21 requa3Afication exam, the standard, basically, is sp35t 4 22 up into three criteria.. It's a satisfactory program, an 23 unsatisfactory program, and a marginal 3y satisf actory
., 24 program. However, one common thread, I believe, in i
l 25 there, is t ha t we at least expect the individua 3 to-- 1 J
Page 180 1 we ask, rather, that the individual be given accelerated 4 2 retraining, which is typically in everyone's program. 3 And what has generically happened, is the 4 facility has indicated they would remove that individual i 5 from licensed activities while they gave him his 6 accelerated retraining. Now, what the outcome is after 1 7 that depends on how your overall program was graded.
- 8. If, for example, it was graded on satisfactory,
)
9 typically, we would go on back, as well as taking a 10 second sample to basically evaluate the ef f ectiveness of 11 your accelerated trainings. We have always included 12 those f e 31 ows who f ail ed t he firs t time a t our t es t , as 13 kind of the non-random sample. They are kind of in 14 there again. . 15 I f you are S AT, wha t we have t ypically done 16 is, indicated to you that you should retrain him in 17 accordance with your program. Indicate to us when that 18 is done, and all we would ask is to see a copy of the I 19 exam that you plan -- if it's a failure in the written 20 exam, to see a copy of the exam prior to administration. 21 And wha t we typicall y l ook f or t here, is that if there 22 are generic weaknesses, for example, on the tests that 23 were identified, we would expect those generic 24 weaknesses -- not the exact same questions, but in the 25 same type of areas, to be covered. 1 I
Page 181 1 We are not sitting there re-writing your test 2 for you, thcugh. In other words, if those generic 3 weaknesses weren't c overed by a n oversight, we would a flag it, and mayte say, they had a weak point in bases 1 5 of emergency response guidelines. You would consider 6 adding some questions in that area. 7 HEARING ATTENDEE: (Mr. Friedman) Okay, one 8 final question -- excuse me. 9 MR. RUSSELL: Let me supplement that, because i 10 jt is specifica31y covered in the Regulation under the 11 t5tJe of additiona3 training. 12 HEARING ATTENDEE: (Mr. Friedman) Okay. l 13 MR. RUSSELL: Under 59(b). And the 14 conditional word is may, and what John has just 15 described is what has been the practice, as to when we 16 have required additional training prior to resumption of 17 watch standing duties. The intent is, is that for an
'18 individual to fa13 the exam, which is job incumbent, 19 whether it be an NRC exam, or it be one of your exams, i 20 that he not stand watch again until he has received l 21 remediation, and a determination has been made that he 22 is now performing satisfactorily in that knowledge area, i 23 or that performance area.
i 24 That's consistent with the continuing training i 25 guide]$ne that INFO has issued, and that's the intent. 1 i i
l .- Page 182 I 1 The question is who does it, okay? In some cases, we're i 2 going to a3 low the' licensee to do the re-examination, j 3 and return the individual to watch standing. In other L 4 cases, we will decide that we will re-examine before the l. e 5 indi Adua3 returns to watch standing duties. And what 6 John h3s described is some of the through process we go 7 through in a case by case basis of making that 8 determination. 9 HEARING ATTENDEE: (Mr. Friedman) Okay. And 10 just one fina) question on that topic, is there any 11 miniruum time period that's going to be invol ved bef ore a 12 person gets jnto the poo], after getting initial 13 33 cense,. before going up for the requa37 14 MR. BUSSELL: The day he gets his six year 15 33 cense, it starts then. 16 HEARING ATTENDEE: (Mr. Friedman) Okay, 17 that's -- the clock starts then. Okay, thanks a lot, I 18 appreciate it. 19 MR. MUNROE: Other individuals, that if we go 20 out and give a requalification program a'udit, and there l 21 are ind$vidua3s on site with two year licenses in 1 22 effect, they are also in the pool to be randomly 23 seJected f or an eva 3 uation of the requalification l l 24 program, in accordance wi th Examiner's Standard 603. l 25 So, don't assume that only six year peop3e are up for
Page 183 1 i bat, maybe. Yes, sir. 2 HEARING ATTENDEE: Gene Karlson, Florida Power 3 Corporation. In regulation Part 55.57, your renewal is 4 going to be based on having past the comprehensive 5 requal exam and' operating test administered during the ' 6 term of a six year license. I believe that Mr. Munroe ! 7 interprets that, or' interpreted that this morning, to 8 mean, that an exam will be given at least once every six 9 years. 10 MR. R11S S ELL : Well, that 's what the Commission 11 has stated. The Commission has directed the staff that , 12 we shall examine on a random basis a t least once each J 13-sjx years, and that's why we know that some people may 14 have an exam more than once in six years. 15 HEARING ATTENDEE: (Mr. Kar3 son) But that's 16 not what this -- this says that sometime during that six ; 17 i year period, he wi31 get a test. That may be the first l 18 year through the sixth year, but in the next time he is j 19 renewed , he may be -- it may be as much as eleven years 20 apart? j 21 DR. SHANKMAN: If you will look under II. 22 HEARING ATTENDEE: (Mr. Karlson) What 23 Sect $on? j L 24 DR. SHANKMAN: In the Statement of 25 Considerations, II(8)(iv), the last sentence says, "The
Page 384 1 NRC wil] administer these requalification written k' _)I . 2 examinations and operating tests on a random basis, so l 3 that no operator or senior operator will go longer than 4 six years without being examined by the NRC once a s3x 5 year license is' issued." i 6 HEARING ATTENDEE: (Mr. Karlson) Okay. 1 7 MR. RUSSELL: That's a direction from the I I 8 Commission to its staff, and I w331 administer the f 9 program. 10 HEARING ATTENDEE: (Mr. Karlson) I was just 11 wondering where that clarification was. 12 MR. RUSSELL: That's the same way we hand 3e 13 the clarification on the INFO status, in the Statement 14 of Considerat3ons that goes with the Rule, describing 15 intent. 16 HEARING ATTENDEE: (Mr. Karlson) A33 right. l l 17 In continuing a}ong w3th the requal tests, there was an 18 art 3c3e in "Nuc3 ear News", in January, 1987, page forty-19 two if you have it in front of you. Probably you don't. 1 20 But it says the average pass rate f or the industry on 21 requalification exams administered by the NRC is 22 seventy-eight per cent nation-w3de. ES -- Examiner's I l 23 Standard 601 says that jn order for a requalification 24 program to be eva3uated as satisfactory, eighty per cent 25 or more have to pass. Th3s indicates that the $ndustry, I I i
Page 385 I 1 . nation-wide, has less than a satisfactory requal ,
.I i ' i 2 program?
3 MR. RUSSELL: Well, no, because the statistics l 4 that " Nuclear News" used are somewhat questionable in my 5 mind. Last yea r' we had seventeen facilities that we ; 6 evaluated, and five of them f ell in the marginal or 1 7 unsatisfactory category, because they had substantially l 8 higher feilure rates. So, a few are causing the 9 nations 3 statistics to be different. It was similar the 10 year bef ore, when we had five f acilities that were in 11 the marginal or unsatisfactory category. 12 We evaluate the programs, and the program Q 13 eva3uation is' based upon whether eighty per cent or more ; l 14 pass. It's not based upon the average scores of the 15 candidates taking the exam. In other words, if you exam 16 ten candidates, and two fail, you have eighty per cent 17 overall, and we determine that program is satisfactory. 18 The average score on that exam may be seventy-eight per 19 cent, the two guys that failed were in the sixties, and j 20 everybody else was above eighty. l 21 So, statistics, and I get very leary of how j 1 22 statistics are used. 23 HEARING ATTENDEE: So, this (Mr. Karlson) 24 information, in here, may not be accurate? l
.25 MR. RUSSELL: It's not accurate.
Page 186 1 MR.-MUNROE: Okay, the second submittal that i EI 2 we're going'to go through is a submittal sent in by 3 South Carolina Electric and-Gas Company. This is a
'4 relatively short one. yes, Susan?
5 DR. SHANKMAN: Excuse me, John, We promised to 6- answer his question. 7- MR. MUNROE: Oh, I'm sorry, that's right. 8 MR. RUSSELL: We discussed before the break, 9 about --
'10 MR. MUNROE: Sorry about that.
11 MR. RUSSELL: -- the experienced requirements 12 for the reactor operator in the ANSI Standard. And we 13 have not taken exception to the three year experience 14 for reactor operator, and I'm not suve that I understand 15 the question. Was the questjon intending to imply that 16 we wanted four years.for a reactor operator? We're-17 endorsed the ANSI Standard with respect to three years j 18 f or RO, and that's f our years for SRO. Tha t 's t he same i 19 as the practice has been, so I'm not sure that I
)
20 i understand the question. .
'l 21' HEARING ATTENDEE: Mark Sheppard, F3orida 22
( ' Power and Light. The way I understand the Examiner's 23 Standards presentJy, the experience requirement to take 24 a reactor operator exam is two years power plant l 25 experience, once of which is nuc3 ear. ANSI Standard l l L. .
i Page '187 I . 3.1-1981, ) 1 is three years of power plant experience, one l . l l C i of which is nuclear. 2 The two remaining years should be 3 as a non-licensed operator, and of that, six months 4 should be as a non-licensed operator at the facility for 5 which you seek t~h e license. So, that would be, in my 6 interpretation, a three year requirement, now; where'in 7 the past it was a two year. 8 MR. EllSSELL: That is correct. The standard l 9 had not been imposed across the board in 1981. There 10 are scme facilitjes that have committed to that standard 11 in thej r app 31ca tion, and were reviewed against that 12 standard. 13 HEARING ATTENDEE: (Mr. Sheppard) Okay. 14 MR. RUSSELL: A previous version of the 15 regulatory guide, or the Examiner's Standard was based 16 upon, I be]deve, it was 18.1-1971, because we had not 17 endorsed 3.3. This rule making process endorses 3.3. 18 HEARING ATTENDEE: (Mr. Sheppard) Our FSAR 19 commits us to 3.1-1978. 20 MR. R11S S ELL : Yeah, but recall that this 21 Regu]atjon, and the associated documents supersede all 22 prior requirements. That's right in the rule, itself. 1 23 And 3t identifdes the regulatory guides that are part of
]
4 24 the ru3e making package. Now, for purposes of 25 jmp3ementation, the implementation of Reg Gujde 1.8, i l
f.. Page 188 1 starts, I believe, one year from the date of l , I
.h.J 2 publication, because there is a phase in period.
3 HEARING ATTENDEE: (Mr. Sheppard) On one of 4 the s.lides you put up earlier, listed the now and the 5 thens. And unde'r eligibility, it had previously was l 6 Examiner's Standard 109, and in the future would be 7 thal, or if you had an accredited program, with an 8 acceptab]e simulator. Well, Examiner's Standard'109, I 9 _be]Seve, says two years power plant experience? 10 DR. SH ANKM AN: It wil 3 be revised as of April, 11 3987, to conform with the Rule, so, and the Reg Guide.
- 12. HEARING ATTENDEE: (Mr. Sheppard) A 1.1 right.
13 And the same applies for the senior operator, Examiner's 14 Standard 109 says four years, and ANSI 3.1 says three. 15 So, you wj)) be changing that one, also? 16 MR. HANNON: The Reg Guide takes exception to 17 the ANSI Standard, 1.8 cites a four year requirement for 18 experience, for the SRO. 19 MR. MUNROE: Yes, sir. 20 HEARING ATTENDEE: George Madden, Florida 21 Power and Light. On the simulator certification form, 22 and also on the medical 396 form, the authorized 23 representative, as you -- in the Rule it says the 1 24 authorized representative, in the from you say, the l 1 25 highest level of corporate management for operations. l l
Page 189 1 Do you have any plans to change the f orm to be
\:'l 1
2 consistent, as today you said that the highest level on 3 the site is an acceptable level of management for the 4 certifications that have to be done on the 396, and also 5 on the medica] forms. 6 Most of the utilities, and at Florida Power 7 and Light, corporate management means people off s i t"e , i. 8 at corporate headquarters. And the highest level of 9 facility, or site management, or plant management, would
- 10. be people on the actua3 facility site?
11 MR. RUSSELL: I don't believe it's necessary 12 to change the wording. We intend that it be acceptable 13 that the highest responsible official on site is 14 acceptable for Part 55 certification. 1E HEARING ATTENDEE: Steve A 31en, Carolina Power 16 and Light. I've got a couple of things on the requal, j i 17 50.59, that I wou]d 31ke clarification on? Once, under l 18 the 3ecture topics, it says, applicable portions of , 19 Title 10, Chapter 1, Code of Federal Regulations, is one I 1 l 20 of the 3 ec ture t opics. Can you be a little bit more [ l 21 specific as to which ones, or is that up to the plants l 22 to determine. 1 l 23 MR. RUSSELL: You just cited the NRC Rules and 24 Regulations, whjch includes such things as Tech Specs, 25 and amendments to 3icenses, and things like that. So,
- l. ,
Page 190 1 1 there are a whole slew of Tit le 10. And it also r I
'- I 2 inc]udes radiation protection standards, things like 3 that, Part 20.
4 HEARING ATTENDEE: (Mr. Allen) Okay, t 5 MR. RUSSELL: The subject matter of those 6 lectures is not very well defined at the top leve]. 7 It's a list of subject areas. 8 HEARING ATTENDEE: (Mr. Allen) Okay. All 9 right, the second is on-the-job training. It says, 3oss 10 of eJectrica3 power is one of the manipu3ations that 11 needs to be performed. Is that off site? Or -- and it 12 also says, degraded power sources, does that mean ha3f 13 of your emergency bus is lost, is it a total blackout? 14 It's Item (1), under on-the-job training. 15 MR. BUSSELL: It may be both. That is, 3t 16 cou 3 d be a tota] loss of electrical power, or it cou3d 17 be loss of power, particu]arly buses or consoles. 18 HEARING ATTENDEE: (Mr. Allen) So, if we want ! 19 to run those scenarios, either one would meet that? 20 MR. RUSSELL: That is correct. 21 HEARING ATTENDEE: (Mr. A13en) Okay. ; 22 MR. RUSSELL Also, be careful of the notes, 23 because it specifies in the Rule, in that Section, that 24 you may not do casual ties on the plant , all right ? I 25 mean, it's obvious, but the break out in the Regulation
i a i PQge 392 i specifies that everything b'elow a loss of coolant is an 2 accident. The malfunctions and faults is done on a 3 simulator. But the permissive part is for the other 4 manipulations, which are control manipulations, state 5 throughout, those may be done on the plant,.or on a 6 simulator. 7 MR.-MUNROE: Yes, sir? 8 HEARING ATTENDEE: Paul Rushton, Georgia Power 9 Company. One of the questions from the southeastern i 10 Regional Training Managers had to do 'S defining what ' 11 the five reactivity manipulations required were. And I 12 think John answered as, they are defjned in Reg Guide
*. 13 1.6. I found it in here, finally, and it defines them 14 as, " Start ups, shut downs, large load changes, and 15 changes in' rod programming, are some examples, and could 16 be accomplished by manually using such systems as rod 17 contro), chemical shim control, or recirculation f l ow."
18 That's kind of a very broad definition, and I was 19 wondering if there was any background, or other 20 information, that might be associated with the words 21 that are in here, that might help us to understand. 22 And is it your intention that this represents 23 a change to Regulations that we have f ollowed in the 24 past? I'm wondering if the past practice as for getting 25 there five reactivity manipulations are still
Page 192 . 1 acceptable?- d
.t 2 MR. RUSSELL: They are, provided they are done 3 on.the p3 ant.
4 HEARING ATTENDEE: (Mr. Rushton) Yeah, they j 5 -- I mean, they'have always been required. This, I 6 don't think, is a change for a hot plant. 7 .MR. RUSSELL: Well, it's also very similar tc 8 the Items (a) through (f) in the on-the-job training for 9 requa)ifjcatjon. We have typically seen that there are i 10 many more practica) factors that are performed as a part 11 of on-the-job training to get qualified. It's not an 12 jnclusive 31st. It's an examples of the kinds of things 13 wh3ch would affect either power, or reactivity, which is 14 something which constitutes manipu3ating the controls. 15 HEARING ATTENDEE: (Mr. Rushton) So, it's -- 16- genera 31y, past practices are still acceptable? 17 MR. FUSSELL: Yes. 18 HEARING ATTENDEE: (Mr. Rushton) Thank you. 19 MR. MUNROE: We're going to do the South , l 20 Caro 31na E 3 ect ric and Gas Company questions. It wd33 be i 21 relatively short. The first question has to do with "Is 22 it the intent of the NRC that the f acility licensee i 23 identify organizatJona3 positions beyond those required ! 24 by Tech Specs, as needing an NRC Operator License?" And 25 the answer is no. You determine the need for who you l - - - _ _ . .__----_-____m
Page 193 1 want to have an Operator License beyond the requirements l 2 of the Technica3 Specifications. The second question 3 would be answered if there was an affirmative answer to 4 the first one, and since there is not, then skip the 5 second ques t i on .' 6 The other part on the Ru3e 16, "What amount of. 7 detail will be required on a licensee application form, 8 NRC 3967" And I believe we've a 3 ready addressed that at 9 Jeast twice, I think. The other questions on here, I'm 10 going to turn over to John Hannon. i 11 MR. HANNON: The first question, " Generic [ 12 Letter 87-07 on]y requires INPO accreditation for NRC 13 approva], while Mr. Denton's letter requires that the 14 training program he both accredited, and based on an SAT 15 process. Which is the governing document?" If I l 16 understand the question, the guidance in Generic Letter 17 87-07 was suggesting that if you have an INPO accredited 18 program that has not been based on an SAT process, then 19 in order to have it accepted by the Commission, you must 20 make it happen that way. ! 21 That would also go to a requalification 22 training program. That you might have gotten -- it 23 might have been based on the proscriptive requirements L 24 in Appendix A of Part 55, and you kept that in place 25 while you were getting your INPO accreditation. So, ' ) [ l
Page 194 j 1 1 1 what we want to see is an indication.from you that your I,
\
I 2 programs are both INFO accredited, and based on SAT. l l 3 That would include both requal and initial training 4 programs. q l 5 MR. RdSSELL: As far as which one' governs, the 6 Regulation governs. The Generic Letter just restated 7 what was in the Regulation. And to receive relief under 8 the Regulation, the program must be based upon a systems 9 -appr oach to training. And some of the earlier plants, 10 for example, O'Conee, which was accredited very early, 11 was based upon the INPO guide 3 d nes, and not based upon 12 the INFO accreditation objectives and criteria, which 13 were endorsed by the Commission in the Po31cy Statement, i 14 So, in that case, what they are doing now, by 15 way of updating their program, and revising it, and the l 16 fact that they now understand the process, from what ; i 17 we've seen in other facilities, would be
- the basis for l i
18 t h e rn to certify to us that they have, indeed, done it on , i 19 an SAT basis. They need not go back and wait unt13 the 20 next time through with the Accrediting Board. 21 MR. HANNON: And the second question, "If the 22 f ac1]ity certifies the training program as being based 20 on the SAT process, w133 NUREG 2220, " Training Review f 24 Criteria and Procedures," audit findings and comments be 25 considered vio3ations of 10 CFR 557" We touched on that i
l Page 195 f I ! s 1 ear 31er today, and in response to a question from the 2 floor, my concept is, that if we did go to an accredited-3 program, and use the NUREG 1220 to do the a post { 4 accreditation audit, and we found problems, that they 5 would be addressed in one of two ways. Depending on t i 6 their severity, they would be either left to the utility l l 7 to resolve, with INPO. l 8 Or, if they were of the nature that we were 9 concerned, we might ask for a performance based 10 Anspection to take place. And depending on the resuJts 11 of that inspection, there may or may not be any need for 12 enforcement actJon. 13 Okay, the third question has several parts. 14 "If the facility does not certify their training 15 programs: 16 Part A, when must FSAR Chapter 13 be revised?" Mr. 17 Denton's letter was not clear in this area, if the 18 facility elects not to certify the training program. ; 19 Okay, the Ru] e becomes ef f ective on May the 26th, of 20 1987, and at that point, you have to comply wi th the new 21 provisions in the requal program, for example. So, l 22 there would need to be a change to the FSAR submitted, l I 23 to conform to the new requirements in the Regulation, if l 24 you chose not to certify the training program. 25 MR. RUSSELL: Let me expand on that, though,
; f.
jV 1-
. /y .
7 , Page 196 e s I because the quest' ion .is implying *.somet511ng which is y b
,_ f 2 f a i r l y f u n d a.'m e n t J. The Commi s sir.)n that endorsed the
/ E )
3 . Policy Statement -- to the Policy'# Statement, 'or. endorsed i i ) 4' the'Po1Acy Statement on.the,TNPO. Prog am for-
\ ,e ?
5 a c c r e d i t a t i e'n . We ' ha v e 'j s a l d ,' t h a t we wou'Id accept that'
,(
'4 js j
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.s
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6 program after be[ng.4ccre61'ted.> c y y 1, + i , 4 A utility t}$at' perceivas they get some 7 + a, , <
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Page 197 a l L MR. HANNON: I' Okay,'Part B, "WII3 afchange to I k 2 FSAR Chapter 23'(to satisfy new 30.CFR 55 requirements}' 4; 3 be considered a decrease in the scope of an approved 4 operator requalification program requiring prior NRC 5 approval, in accordance with 10 CFR 50.54(1)?" 6 D R '. SHANKMAN: No. 7 MR. RUSSELL: A simple no. 8 DR. SHANKMAN: Yeah, no. - 9 MR. RUSSELL: Okay. , 10 MR. HANNON: That issue is addressed in the l 11 Preamble,.where it indicates that this Rule supersedes 12 a33 nther previous requirements. So, the fact that the . 13 Ru 3 e may have caused a decrease in your requal program, ! 14 has.already been sanctioned by the Commission, by 15 approving this Rule. 16 Okay, the next, . item C, "W133 the NRC be 17 prepared to approve or disapprove Ff'3R Chapter 13 i 18 changes within sixty days allowed f or imp 3 ementing 10
~9 1 CFR 55 requirements?" The approval is ef fectively l
20 automatic. You shouldn't expect to see any response 21 from the Commission, from changes that are implemented 22 as a result of this Rule. 23 MR. RUSSELL: With the exception of any I 24 31 censed amendments which are required because of 25 something in your Technica3 Specifications, there are a i
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{ Page 198 j l l 1 number of facilities that are in that situation, where f __ 2 they have a more restrictive ~ requirement-in their 4 1 3 Technical Specifications than they would have to apply 4 l for; and amended their Tech S.pecs to obtain readef that j 5 js permitted under the Rule. And it would be an 6 administrative Tech Specs change, in order to conform 7 with the Regulation. 8 MR. HANNON: But the point is, it would not i 9 have to be acted on within sixty days. It would take a 10 norma 3 course. I don't know of too many administrative 11 Tech Specs changes that get turned around in that short i 12 of time span. i 13 I t em D, " Wha t amount of detai 2 will be 14 required on a License Application, Form 3987 Until I ' in 9 15 mistaken, that's been adequate 3y covered. 16 MR. MUNROE: I think so. Yeah, I answered 17 t h a t', John, earJier. I be3deve that c om p .l e t e s the 18 South Caro]ina Electric and Gas Company questions, and 19 the 3 ast set of questions that we'll go over is the i 20 questions submitted by KMC. 1 l 21 The first question has to do with current 2 y 22 approved training programs. And the question is, "Is it 23 the Commission's intention that these programs w313 24 i continue to be approved unt33 accredited. And that the { 25 ! use of the simuJators referenced therein w333 be _-_ -__ D
Page 199 4 1 acceptable for use until May 26th, 19917" f ( 2 HEARING ATTENDEE: (Mr. Col 3 ins) John, can I 3 interrupt you, please? 4 MR. MUNROE: Oh, yes, sir. 5 HEARING ATTENDEE: Yeah, Paul Collins, KMC. 6 You have answered many of the questions dur.ing the 7 previous discuss;on. Let me give . ou a list of those 8 that have not been answered, and you can just skip to 9 those. 10 .MR. MUNROE: Okay. I 11 HEARING ATTENDEE: (Mr. Co l .l i ns ) Nine and 12 ten, sixteen through twenty-six, and twenty-eight, and 13 thirty. l 14 MR. MUNROE: Sixteen through thirty-six?
- 15 HEARING ATTENDEE: (Mr. ColJins) Twenty-eight 16 and thirty..
17 MR. MUNROE: Okay, 3et me get myse3f squared 18 away, here. Nine and ten. "W133 SRO licensed 19 individuals that are norma 3 3 y a part of the RO shift 20 operating crew be allowed to retain active status as , 21 ROs/SROs, while they hold a SRO 3deense?" If the 22 individual stands watch as an RO, he maintains an active 23 stat us as an RO, but not as an SRO. If he stands wat ch 24 as an SRO, he maintains an active status as an SRO and l' 25 an RO.
i Page 200 l
' l 1
3 1 Number ten, "Is the following interpretation {
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2 correct? The utilities beideve that SROs who are i 3 current in the requalification program, and hold valid $ 4 but not active licenses may perform SRO administrative l 5 duties, such as' approval of procedure changes, plant , 6 design changes, classroom and simulator instruction, et 7 cetera, even those these individuals are not considered j F' 8 part of the operating shjft crew?" 9 Yes, they can do all of those things, but they 10 cannot, if they are not active, they cannot manipulate ; 11 or direct in accordance with their license, until they 12 reactivate. That was nine and ten, and, then, Jerry, 13 why don't you start on -- do you have a copy of it? 14 MR. WACHTEL: Yeah. 15 MR. MUNROE: I think sixteen starts with the 16 sjmu3ator questions, j i 17 MR. WACHTEL: Yes. Okay. Let me read the -- 18 MR. MUNROE: Excuse me, Jerry. Go ahead. 19 HEARING ATTENDEE: I woul d like -- William , 20 Downs, Georgia Institute of Technology. I would like to 21 ask a clarification on that. At our facility, we have 22 only two licensed people right now, we have two SROs, 23 and I'm one of them. If I st and wa t ch as the RO, that 24 does not count towards my active time as an SRO7 We 25 would have to reverse positions?
Page 201
- MR. MUNROE:
1 Standing watch as an RO, if you g p t I- 2 are an SRO, on] y counts towards maintaining yoursel f 3 active towards the RO. If you want to maintain yourself 4 in both positions, you have'to stand the watch as an 5 SRO. So, I think what you-said is correct, you would 6 have to reverse with your counterpart. 7 HEARING ATTENDEE: (Mr. Downs) Okay. 8 MR. WACHTEL: Okay, let me start in, and read 9 the introductory remarks to questions sixteen through 10 eighteen. "An entity has constructed and is operating a 11 plant-referenced simulator that meets the provisions of l I
- 12. Reg Guide 1.349, and ANSI /ANS 3.5-3985, and has been 13 certified by the NRC for use for operators / senior 14 operetors who operate the reference p3 ant, or are 15 candidates for 31 cense. A utility wishes to use the !
16 above simulator as their simulation device, rather than 17 construct and operate a plant-referenced simulator." i 18 And question sixteen is, "What procedure must 19 a utility f o3 3 cw to obtain approval to use the above l 20 simulator?" Okay, first of all, in the introductory I 21 Paragraph, the statement is made that the simulation 22 f acility has been certified by the NRC. Just for i 23 clarification, the NRC wi'33 not be certifying simulation 24 facj]ities, that would be a certification to the NRC. 25 Secondly, I'm not clear what is meant by the 1 l
Pege 202
'I wordientity. Only facility licensees are to certify 2 simulation faci 3dtjes to the NRC; or request approva) 3 for simulation facilities. If an entity means a 4 facility . 1dcensee'under 20 CFR Part 50, .then that's 5 fine. If it menns some other organizational body, then.
6 that wou3d not be acceptable for certifying, or app)ying 7 for approval of a simulation facility. B' A utility wishing to certify, or wishing to 9 use the above simulator as their simulation device, 10 again, the uti3dty must be the one to certify, or to 11 apply for approval for the use of that simulation 12 fac135ty. It does not matter whether that utility owns 13 .( that simu3ation facility. It does not matter where that 14 simu 3 ation f acility is located, but it is the utility 15 who must certify, or apply.for approval to use it. And-16 I think that's the answer to question sixteen. 17 If that simu3ation facility referred to is 18 referenced to a facd35ty 31censee's plant , then the 19 process to be followed is certification on Form 474. If 20 it is not referenced to the f acili ty ' licensee's plant ,- 21 then the proper approach would be app 31 cation for NRC 22 approval. Submit ting a p3 an within a year, followed by 23 the app 33 cation for approva). 24 Question seventeen says, "Has the staff 25 developed guidance and/or criteria regarding the use of a
Page 203 1 cert ified plant-ref erenced simulator by individuals, 11 i t '2 other than those from the referenced plant?" Again, if l l 4 3 I' understand the question correctly, it is possible for l 4 one simulation facility to be certified, or to be 5 referenced to m' ore than one plant. To the extent that 6 those two plants are the same, it is likely that one 7 simulation facility could be certified. Perhaps certain 8 exceptions on Form 4 74 would have t o be taken,- as part 9 of that certification process. 10 MR. RUSSELL: Let me give two examples where 11 that may be not so apparent. For instance, two plants, 12 which are very similar, are Nine Mile Point, 11n i t One, 13 and Oyster Creek; both comparable plants. It may be 14 t h a.t a simulator could be certified for both, provided i 15 there were changes to the software, that may represent 16 differences in the plant. And this has been done, where 17 they'come up with'different tapes. 18 Another example may be the situation at Indian i l 19 Point, where we have two different licensees operating, 20 essentially, identical plants. You may be able to use j i 21 one simulator for Indian Point Two and Three. Other 22 cases might be the Snups Facilities. Or another case 23 may be a ut ility that has more than one like plant , and 24 they choose to travel to another location, to use the 25 simulator. l l I
Page .204 1 We are not precluding that. What we require I
\ l 2 is that you do the evaluation against the p3 ants that )
l 3 you are referencing that'simu3ator to, and show that 4 that meets the Standard, or meets it with some number of 1 l We are S. exceptions that'you want to certify based on. i 6 not 3 ooking f or a 3 ot of minor exceptions being the 7 basis for submitting plans for review and approval. We 8 recognize there w133 be some exceptions. 9 MR. WACHTEL: And just as further 10 c3ar3fication, we would expect to see separate 474 F orp.s 11 submjtted for each of those certifications. Okay, the 12 introduction to question eighteen says, "Section D. 13 Imp 3ementation of Regulatory Guide 1.149, outlines a 14 procedure to be f o3 3 owed f or a fac131ty 33censee that 15 wishes t o uti J ize a simulation f acility at more than one l 16 nuclear power p3 ant." 17 And question eighteen asks, "Does this . t 18 guidance app 3 y to f acility 31censee that wish to use ' 19 another facility 3 3 censee's plant-ref erenced simulator?" i 20 The answer to that -- the simple answer is yes. But the 21 faci 35ty, as we have just said. must certify that the 22 simulator meets the requirements of the Regulation 23 ANSI /ANS 3.5-3985, as endorsed by Reg Guide 3.349, for 24 hjs p] ant. 25 MB. HANNON: Let me add to that, that one of
Page 205-1~ the things that we were really curious about, and in 2 viewing such a certification, wou]d be the issue of 3 configuration control, and how that is being handled. 4 Because you would have potential f or mul tiple design i 5 changes at a faddlity, and we would have to understand 6 how you are going to assure that the simulation fac311ty 7 . tracks the different plants. ; 8 MR. WACHTEL: The Jong introduction to 9 question nineteen and twenty, let me read the last 10 paragraph of that introduction. "In order for a ut131ty 11 to comp 3 y with ANSI /ANS 3.5-1985, a utility would have 12 to use a f u.3 3 -scope nuc lear powerp] ant contr " room
; 13 simulator. The standard states the f o l .1 swing under 14 SectJon 2. Scope: "A 3 so excluded are part-task, or i
15 31mited scope simulators, intended to specialize 16 training or f amiliariza tion." This means that non full- ; 17 scope simo 3 ators would c.learly be excluded from the 18 Standard, and, hence, a simu3 ation f ac131ty that does ) 19 not consist sole]y of a full-scope simulator has no , 20 guidance or standard which a uti.11ty may use to obtain l 21 NRC approva), g 22 The previous statements lead us to the i 23 fo)3owing conclusions:" And then there is question 24 nineteen, r.hich states, "If NUREG 1.249 and ANSI /ANS g 25 3.5-1985 become the only standard for determining the 1 l
Page .206 1 acceptability of a simulation f acility, the simulation 2 fac311ty must be a f ul 3 -scope simulat or, is that 3 correct?" The answer is no, that is not correct. } 4 NUREG, which is really a Reg Guide 1.249, in regulatory l 5 position (c)(2),' within the document, takes exception to 6 those segments of the Standard that were just cited. 7 The Reg Guide says that simulation facilities, 8 as defined in Section 55.4 of the Regulation; and, 9 r e m e rn be r , that that jucludes the plant, and potentially 10 other simulation devices, should me applicable ! 11 requirements of the Standard. Also remember that Reg 12 Guide 3.149 is on3y one acceptab3e means of meeting the 13 re,1uirements of the Regulation, and that- facility 14 35censees may propose other approaches to meeting that 15 under the Regu3ation. ] 16 We would intend to eva3 uate those simulation 17 fr.j)itjes which are other than certified plant-18 referenced simu3ators on a case by case basis, once we 19 get to the point of dealing only witfh the applicab3e i 20 portions of the Standard. 21 Questjon twenty says, "If NUREG 1.149 and 22 ANSI /ANS 3.5-1985, do not represent the only standards 23 for determining the accept abd 31ty of a simulation 24 f a c i ).i t y , wi31 the NRC identify the minimum standards 25 and criteria that are acceptable to them for non full-
Page 207 1- scope simulators?" 4
'I k 2 The simple answer to that is no, this is going 3 to be done on a case by case basis. But in all esses, I 4 such non full-scope simulators- would be required to meet 5 the requirements of the operating test in Section 6 55.45(a). And I think that covers that section.
i 7 MR. MUNROE: Okay, on question. twenty-one, we 8 basjeally shift back, I believe, into an area that 9 discusses significant control manipulations. The 10 pa rag r aph t ha t precedes it seems to me to be a 3 5 t t 3 e 11 confusing, in that it talks about requalification on-12 the-job training, and, then, also ta.1ks about the five ., 13 significant control manipulations, and what device to 14 use. 15 The.five significant control manipulations, 16 the device that has to be used is the real plant. The I 17 other manipu'ations may be done on the simulator. The i 18 question itself states, "Does the NRC agree that each ! 19 utility shou 3d define their specific set of significant j 20 control manipulations in their program descriptions to 21 satisfy the ru3e stated in 55.31(a)(5)?" And I be)$ eve i 22 we've answered that question, when we indicated Reg i k 23 Guide 1.8 would give the guidance. And I think we i 24 clar$f$ed jt again for Mr. Rushton, from Georgia Power, 25 a little 3ater. i
i 1 L Page 208 ; 1 1 Question -- j
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l' 2- MR. HANNON: John? l l 3 MR. MUNROE: Yes. 4 MR. HANNON: Let me also point out that there '! 5 is a statement in the preamble to that question that 6 indicates that, maybe,-the NRC has a preferred training 7 device for OJT. And that is not the case. The 8 Regu3ation would not -- I don't think I can conclude 9 that from reading the Regulation. We really don't care !
.i 10 which training device you use. You can use the p] ant, 11 except for the casualties that Bill mentioned earlier, i 12 or you can use the simu3ator. We don't rea33y have a
( 13 preferred training tooJ. 14 MR. MUNROE: Question twenty-two is, " W 1.1 3 any 15 combination of the above manipulations be acceptable, as 16 djetated by the f acility's mode of operation during 17 which the app]Acant is in training?" And I'm really not 18 sure exact.ly what manipu3ations we're referring to, but, 19 once again, the five significant control manipulations 20 ha ve t o be done on the rea l pl ant -- the actual plant. 21 And, typica 3 J y, that 's going to be in mode one or two, 22 a 3 though I can conceive of it being in mode three during 23 e start up and/or shut down. 24 As far as the other manipt3 ations dictated by 25 the on-the-job training part, they may be in the modes
Page 209 1 that the plant gets into, when you get into the l' 2 transients, such as LOCA, which covers very many modes. 3 Okay, question twenty-five, and we'll come back to 4 twenty-three and twenty-four in a moment, which have to 5 do with the simulator. 6 Twenty-five, "Will start up and shut down 7 experience gained on a plant-referenced simulator be 8 considered as adequate start up and shut down experience 9 for operator and senior operator candidates?" The 10 answer to that, jf I understand this question correct)y, 11 is yes, provided, once again, that the five significant 12 contro] manipu]ations are done on the real plant. And 13 if you get your start up and shut down experience, and 14 those are brought out in Reg Guide 3.8, but if you do 15 that on a simu J a t or, tha t will be acceptable, if you do 16 the five significant control manipu]ations specified by 17 3.8 on the actua) p] ant. 18 MR. HANNON: There is one thing that may help 19 clarify this, and that is that we make a distinction 20 between eligib311ty for NRC licensure, for operators, 21 and training. And what we are talking about with these 22 five significant control manipulations is an eligibilit y 23 issue, as opposed to a training issue. 24 MR. MUNF0F: The next -- 25 MR. RUSSELL: John?
Page 230
-1 MR. MUNROE: Oh, I'm sorry. -k M 2 HEARING ATTENDEE: Pau) Rushton, Georgia Power 3 Company. The Reg Guide still says reactivity 4 manj pulations, not control manipulations. Earlier, we 5 talked about control manipulations. I think those, if I i
6 am correct, are part of the requal program. but i 7 reactivity manipulations are still required for the 1 8 .eligibjldty requirements, is that correct? 9 MR. RUSSELL: Contro3 manipulations, the I i i 10 Regulaijons in the Atomic Energy Act defines controls as 11 those thing which effect power or reactivity. Okay, and 12 when we say significant control manipulations, we mean
- 13 manj pulating the contro3s that cause reactivity changes, 14 or power changes. They are the same th$ng, we just 15 clarjfied it, because some people thought that a33 that 16 was required was changing reactivity. You may be ab3e 17 to change power without a steady state change in 18 reactivi ty, you may do it at the same leve 3, f or 19 examp3e.
j 20 So, we think i t 's a bet ter use of the language ; l 21 of defining control, and what is a control manipulation, t 22 that causes an effect on either reactivity or power. 23 l HEARING ATTENDEE: (Mr. Rushton) But your 24 jntention, then, is not to change what we are doing? t' 25 MR. RUSSELL: That is correct.
a ] I
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1 -HEARING ATTENDEE: (Mr. Rushton) I had gotten ) i i 2 the impression, I guess, mistakenly, from this morning's j 3 conversation, that you intended to broaden the scope of a 4 what counted? 5 MR. RDSSELL: You may broaden the scope of 6 What counts, yes, and that would be-acceptable. We are 7 not narrowing it, and by that context, I,mean.we are not 8 changing it. 9 HEARING ATTENDEE: (Mr. Rushton) Okay. 10 MR. MUNROE: Question twenty-six asks, "Wj l ] I 11 start up and shut down experience, as requested in 55.3 3 12 (a)(4), gained on a non plant-referenced simulator be 13 considered as adequate start up and shut down experience 14 for operator-and senior operator candidates?" And the 15 answer I have to that, if the training program that you 16 have in existence, now -- the approved training program 17 addresses that,.then that wou3d be acceptab3e. 18 Jerry, could you answer twenty-three and 19 twenty-four, which I think has to do with the simulator? i 20 MR. WACHTEL: Twenty-three says, "Does the NRC ! 21 agree with the uti3ity interpretation that they may use i 22 the plant-referenced simulator as the preferred device 23 when it comes to requalification training program's on-24 the-job training contro3 manipulations?" I think the 25 word pref e rred is something that we do not agree with, i
Page 212 1 It's not a preferred device, it's considered to be j t
? equal.
3 And twenty-four, "Does the NRC agree with the 4 u +.111t y i n t e rpre t a t ion t ha t they may use.the non plant-5 referenced simulator as the pref erred device when it 6 comes to requalification training program's on-the-job 7 training control manipu3ations?" Again, the word 8 preferred, we would think of as being equal. And this j
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9 18 acceptab3e on3y until Par t . 55.4 5(b) is implemented, 10 and the cert i fied or approved simulation facility is in 11 place. 12 Once that occurs, the non p3 ant-referenced 13 simulator wouJd no longer be acceptable. 14 MR. BUSSELL: There is an interesting nuance 15 for the control -- the on-the-job training in items (a) 16 t hr ough (f). And if you Jook at the Rule, under on-the-17 job training, I'm usually following a list. There is a 18 3 3 t 13 e v , which says, " A simula t or may be used to meet j 19 requirements of (c)(3)(1), and (c)(3)(ii) of this 20 Section, if it reproduces the general operating i 21 characteristics of the individual f acility involved, and 22 the arrangement of the instrumentation and controls of l 23 the simulator is similar to that on the facility 24 invn3ved." s 25- This difference permits the use of the non _ __ _ j
Page 213 1 plant-referenced simulator for start up, shut down, and l- 2 other things which are not related to casua3 ty contro3, ; 3 even after you have certified your simulator. And it 4 specifies that you must use it, that is the certified 5 simulator, for the. operating test, and for Subparagraphs 6 (g) through (aa) of the Section, where (g) is the : 7 casualties. 8 And, so, you may use a simulator other than a 9 p3 ant-ref erenced simulator, even though you have 10 certifled it for control manipu3ations for requals. But 11 you must use the plant-referenced simulator for 12 casua3tles, af ter the ef f ective date of the ru3e, in j l 13 3993, or after you have certified. It provides you some l l 14 f3exib531ty during periods of time where your simu 3 a tor ' I 15 may not be avai3able for doing routine control 16 manipulations. i 17 MR. M11NR OE : Okay, the last two questions are 18 questions number twenty-eight and number thirty, and, 19 John, could you address those? 20 MR. HANNON: Okay, "What guidance will the j 21 Commission provide to the facility licensees and the 22 staff that Section II.F(2) is Commission policy?" p 23 That's part of the preamble to the Rule, and it's not 24 po31ey, it is, in fact, what the commission has 25 sanctioned in the Rule, if you look at Part 55.4, and l t L.
Page 234 1 Part 55.53, and 55.57. And number thirty, also? s l 1_') 2 MR. MUNROE: Yeah, number thirty, a3so, and I 1 l 3 think that wil3 be it? ! 4 MR. HANNON: "Will the Commission develop a 5 protoco) that w'ill ensure that detailed medical records i 6 will be forwarded to the NRC medical experts, and not l 7 made available to lay persons?" We've already auggested l 8 that this is an item that we thing should be addressed ! t 9 by.the industry, and have made that suggestion to INPO. 10 DR. SHANKMAN: I'm not exactly sure if the ! i 11 question is implying that the medical records go through 12 the Operator Licensing Section, before they are I; I 13 referring to the NRC medical examiner, and it's not a l 14 doctor to doctor communication?
.5 HEARING ATTENLEE: Susan, Pau3 Co] lins, KMC.
s 16 No, the question was, really, are Inspectors going to 17 come ou t and ask to look at medical records, just to see 18 jf there are complete medical records? Or is there ; 19 going to be some sort of protoco3 where the NRC says, 20 please submit half a dozen medica 3 records, or a dozen 21 medica 3 records of your 31 censed personne) to the 22 Headquarters, where you have to go through an 23 administrative procedures, I know, and then you would I 24 g 3 ve them to your medica 3 examiner, just -- just as a
)
25 check. ' That, indeed, the guys are being exam 3ned per i I
Page 225
- 1. .the Standard. !
I' i'l' MR. RUSSELL: 2 It will probably be some of 3 each, Paul. The simple answer is, that Inspectors may j d 4' . request to see medica 3 records on site, and identify I p 5 some' subset.of t' hose records to be reviewed medically, 6 to determine if there.is a disqualifying condition. At 7" that point in time, the facility would transmit those i 8 records to the NRC. We wou3d control them, they are l 9 covered by the Privacy Act; as far as.preclud3ng release 10 to other individua 3 s tha t don't have.a need to see or ' I 11 use them. We.would transmit them to the doctor. Have j t 12 an independent eva.luation done of them by.the doctor, 13 and base any actions we would take on that doctor's 14 revjew. 1
'15 We w333 not be using non-medically qua 3 3 fied i 16 '. peop 3 e to do eva 3 uat ions . of . the content of the record.
17 We wi31 clearly be using NRC Inspectors to do a review, 18 to see if there is, in fact, a' signed examination on I 19 f d 3 e that shows the guy was examined by a doctor on a 20 certain date. 21 MR. MUNROE: I be.lieve that concludes all of 22 the questions from the KMC submittal, and those, 23 basica13y, are t he three submit ta.l s that we intended to 24 go through that we received in the Region, prior to the {
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i 25 meeting. 3 guess the floor is open for questions at 1 i
Page 226 s i
-1 this pojut. Are you all leaving? No, I guess not, i j
i i 2 HEARING ATTENDEE: (Mr. Karlson) Tomorrow l 3 morning, we're having another half day session, and I l 4 th3nk Bill Russe 31 said that,we shou 3 d have a13 of the d
.5 questions in by' 5 :00 o'c 1'ock ' t onight , if we_ wanted-them 6 included in the --
7 MR. RUSSELL: I ind3cated, during the-break, 4 8 to the Region Two personnel, that if there were 9 additjonal questions that we had not answered by close 10 of ')usiness today, or that came up during tomorrow's 11 meeting, that they wanted to be referred, that we would 12 incorporate those into the NUREG. My intent, with the 13 N t1 R F G , is not on 3 y t o answer all of the ques t j ons, but 14 also to provide un$ form guidance, and to make sure a33 15 f3ve Regions are following the same script. 16 HEARING ATTENDEE: (Mr. Rushton) That was 17 gojng to be my comment. Not on3y are the questions l 18 3mportant, but the answers to the questions, we are l 19 finding, are even more important. 20 (Laughter.) 21 DR. SHANKMAN: Are you submitting the answers, l l 22 too? 23 HEARING ATTENDEE: (Mr. Rushton) No, I'm not. 24 Thot's the hard part s l 25 DR. SHANKMAN: Just checking. 4 _________m._ - _ _ _ _ - _ - _ _ _ _ -
Page 237 1 HEARING ATTENDEE: (Mr. Rushton) Could. I
' 't; 2 somebody -- what is -- what weight does NUREG 2021 3 carry?
4' MR. HANNON: That's the Examiner's Standard, 5 and its purpose'is to insure uniformity and consistency l 6 amongst the Regions, and during the conduct of 7 Examination Programs. 8 HEARING ATTENDEE: (Mr, Rushton) Okay. I 9 MR. RUSSELL: Since I issue it, let me i 10 descrj be how I see i t being used, and maybe that wil) 11 make it clearer. 12 HEARING ATTENDEE: (Mr. Rushton) All right. l 13 MR. RUSSELL: It provides direction to the 14 Regions on how I expect them to conduct the operator 15 Jicensing function. We can -- we review the Regions 16 using that Standard. It does not impose new ; 17 requirements That is, the requirements that are 18 addressed in the Examiner's Standard flow from other , 19 documents, whether it be a Regulatory Guide, or a Rule, i ( 20 or Regulation, et cetera. l-21 That's why many of the changes that John 22 Munroe described, from the Examiner's Standards, are I l 23 changes resu3 ting from the change to the Rule, the I il 24 higher order document. It is policy on how to handle i 25 St. It describes the process, for instance, for 1
I Page 218 I 1 hand 31ng appeals, and-th'e review process. As it relates i 1 I ( 2
~
to th'e hearing process, and the description there, in l l 3 Standard 332, that's based ~upon Part Two of the l 4 Commission's Rul es of Practice, in how we conduct 5 hearings. So, -- ' 6 HEARING ATTENDEE: (Mr. Rushton) Let me give 7 you an example, and l e t 's see if we're all on track, 8 here. 1 9 MR. RilSSELL: Okay. 10 HEARING ATTENDEE: (Mr. Rushton) I believe ! 11 it's E x cs m i n e r 's Standard 109. It says that training i 12 that is conducted as part of a license program cannot 13 count for experience. But ANSI /ANS 3.1-1983, which je 14 what the Commissioners have said -- have to3d us to use, 15 a l low related technical training to count for 16 experience. So, it appears that Examiner's Standards 17 are -- what are the Commissioners expecting? That the i I 18 training program i t, not going to count, or that it is 19 going to count? I t 's not clear that ES-109 is in 20 comp 31ance with 3.17 21 MR. M11NR OE : The training time that doesn't j r 22 count as experience is the training time that is ; 23 required by the approved program for the individua3 to ; I 24 receive that Jicense which he submits. Related 25 technica3 training is training he may have recejved for
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L 1 [ .,.. Page- 219 i another position, such-as auxiliary operator, which we k 2- do count up to a certain percentage. 3 HEARING ATTENDEE: (Mr. Rushton) Well, here-1 4 -
.I mean, the definition i n 3.1 says, " Formal training I 5 beyond the high' school level in technical subjects, i
6 associated with.the position in question, such as I y acquired in several programs, including utilities, and
-8 others. Such training program shall be of, a scheduled 9 and planned length, and include text materials and 10 J ect ures." A31 of our programs meet-those --
that i 11 definition of related technical training, and yet we '
- 12. can' t count ^ it for experience, and I d on ' t understand 13 why not?
14 MR. RUSSELL: Experience is a e31gib135ty 15 . requirement. i 16 HEARING ATTENDEE: (Mr. Rushton) That's true. i 17 MR. RUSSELL: You should meet the -- i t 's 18 qua3dfications and training. If the person has the 19 experience and the qualifications, then he goes into a
- 20. training program. You have mechanisms, through your 21 accreditation process, where you look at the entry level 22 into your training program. What we are saying is, you 23- can count time and training prior to that program, but 24 we have not, as a matter of practice, been giving credit 25 for experience for the training which is required, and !
Page 220 1 has been. approved by the NRC, as a part of the specific Ir K 2 program leading up to license eligibility. 3 And the guidance, I guess, that's the best 4 interpretation of that would be the industry submittal 5 that came in from NUMARC, which was' endorsed in Generic
'6 Letter 84-16, where they even proposed factors for how j 7 you count prior technical experience, or training. For 8 instance, the time that's credited for Navy technica]
9 training, prototype training, things like that, and how i 10 that's used. 11 HEARING ATTENDEE: Clyde Brewer (phonetic), 12 f rom TV A. When NRC comes in to give the utility 13 reque 3 d fication exams, and they f all in between the s 14 sixty and eighty per cent, and they are rated margina). . 15 After the utility modifies their program, and re- l 16 examines those failures, and come out with a 17 satisfactory, is that -- does NRC change that from a ; i 18 margina) to accept program 7 19 MR. MUNROE: The marginally satisf actory 20 rating was based on the examination given, in accordance 21 with ES-603. What you have done, after the fact is to, l 22 basically, we have identified -- we tried to evaluate 23 the program, and in doing the evaluation, we have 24 identified indjv$ duals with weaknesses, which require i 25 some remedial training, which you have given. Them
Page- 221 1 i completing the remedial training will not cause us to k 2 revise our eva3uation. Two years hence, when we come 3 .back and do another evaluation, hopefully eighty. per 4 cent wi33 pass at that time, and you wi13 be evaluated 5 as satisfactory: 6 MR. GIBSON: Generally, that evaluation and 'I 7 conclusion stands until we come back and re-evaluate, 8 either by inspection or re-exam. 9 HEARING ATTENDEE: (Mr. Brewer) Even though 10 our program has been modified to cover those weaknesses 11 that you discovered? 12 MR. GIBSON: Your program may, indeed, no 13 longe) be margina 3 3 y acceptable. But until we come back 14 and independent eva3uate, that remains our conclusion of 15 record, , 16 MR. RUSSELL: It's a snapshot in time, of what l 17 we perceived of the program at that time. There have 18 been cases where we have issued an inspection report, 19 where we found a weak or unsatisfactory program. Where 4 20 we have had additional interaction with the utility, 21 which has been documented in a subsequent inspection 22 report, that has c o n e .l u d e d that the program is now 23 satisfactory, that has occurred, but it is always a 24 resu3t of going back, and re]ooking, and reaching a new 25 conclusion, based upon the additional work.
Page 222 1 So, that the conclusion is based upon what is j l. A 2 done, _and the' performance at the time that the 3 requal j fication exams are given, and it does not look at 4 the successive remedia3 action, unless we go back and 5 re-examine, and conclude from the examination 6 performance that it has been successful, or reinspected. 7 HEARING ATTENDEE: (Mr. Brewer) So, the only i 8 way we can get that changes, is for you to come back to 9 gjve another exam, is that what you are saying? '1 10 MR. SUSSELL: Or come back and inspect that 11 area, and reach a conclusion based on inspection. 12 HEARING ATTENDEE: (Mr. Brewer) And could we ( 13 ask for that, or we were -- l 14 MR. R11S S E LL : Sure. That wou3d be 15 interesting, to have someone ask for us to come in and 16 inspect. 17 HEARING ATTENDEE: Ken Holmes, with Georgia i 1 18 Powe) Company. My questions deals with the 19 imp 3 ement a t ion of 10 CFR 5 5, the part that deals with 20 the requalification program. Most facilities have an 21 NRC approved requalification program by the fact of 22 being in the FSAR. For utilities that cannot certify i 23 their requalification programs, either because their 24 program -- requalification program has not been approved 1 l
Page 223 1 66-25 requirements for SAT; how will we implement 20 CFR { i t. ( 2 55? 3' 'MR. RUSSELL: You wi31 continue to f ollow your 4 approved program -- your program of record, as is 5 document in the'FSAR, unti.1 such time as_you either j t 6 modify it, bring it up to the INPO guidelines in 86-25,
.7 or some other action to modify it. Tha t 's one way of 8 doing it. You may be able to discuss with INPO other i 9 alternatives. You may be app 3 e to app)y a TSD process to to $t, .that does something different than what's in 86-11 25.
12- HEARING ATTENDEE: (Mr. Ho3mes) Okay. 13 MR. RUSSELL: But you follow the program of 14 record, as modified by the Rule. j 15 HEARING ATTENDEE: (Mr. Holmes) As modjfded 16 by the Rule, there is no requirement to modify the , i 17 documentation, we just have to follow the new ru.le? l I I 18 MR. RUSSELL: That is correct. You must 19 f o31ow the new Ru 3 e, or your exist $ng program, whichever 20 is more restrictive. But you may perform a 50.59 review 1 21 to bring your ex$ sting program in conformance, and 22 simp 3y submit that. Or, if you need an amendr".t to the 1 23 [ 31 cense, you request the amendment, and you wou3d have 24 an administrative change approved to put your program in 25 conformance with the Rule. ( i ___ _ __ - --_ _ a
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'h J Page 224 l'
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l' HEARI![6/TTENDEE: (Mr. Holmes) Thank you.
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- s. - HEARING ATTENDEE: Joe. Johnson, TVA. In an i y r%(
() j j
- s. 3l 3 attemiti ($
2i, guess, Bill, s to try to change the flavor, I i g..
'4 think . it'.e prJ na ryk, y,du know, questions and answers
, ,- . t i, 5 around here tod'ay slave been those of us trying not to r ) ,
1 6' h a v e 's v i o'l a t i o n . But I guess what I really want to go I 7 on-record'as saying,'is my commitment is for safe J: S operation ,as I think yours is. 9- When I thdak about that popu .l a t iori o f licensed 10 ~ uperators out there, that are not necessarily t 11- rel>reserit ed jn this room. This is all of the trainers, 12 su I'in just trying to pause long enough to say, if I was 13 one. And now they're going to give me a license, and 4 14 I got .i t f or six years, t ha t 's a pl us. And i f_ I 15 understand the words that were written in the l 16 Regu]ation, it says, then, that I have to pass a l 17 coml>rehensive , equal written exam and operating test i 18 'adnij n i s t e red by the Commission during the term of my six 19 year license. 20 And I read that, and that 's what was 21 attempted, ,I don't understand,-necessarily, the 22 Stateme'nt of Considerations. I don't understand those 23 words. But, then, if I look at what they said, and 24 Susa n, poi n t ed t ha t ou t , tha t i t says the NRC wil l s. 25 aaminister these requal written examinations and L _ _____ ___ _U
l Page 225 o 1: operating tests on a random basis, so that no operator, b 2' or', senior operator will go longer than six years. 3 I don't want to get caught in semantics, but 4 you and I.both know that that means'that you are going 5 to have to have'it within five years the first time. 6 And, then, if I get one within five years, that 's ' going
.7 to start my clock, so that I can't go more.than six 8 years,- that!s not --
and, you know, with all due respect 9 to individua 3 s writing Regulations, clearly the 10 paragraph in the Regu3 at d on, the Eng3ish 3anguage j 11 doesn't infer.whatever that Statement of Consideration 12 is. l L ( 13 But just one second, because'I'm trying to get' 14 a f J a v dr. In the olden days, the NRC tested every two 15 years requal, and the operators, the human beings out 1G there, were incredibly drum-head tight, unti3 somebody 17 was random 3y se3ected. And, then, at 3 east'they had 18 relaxation for two or three. years, depending upon 19 whether-everybody had gotten accredited. And, then, the 20 concept was, again, the NRC was coming in. 21 And we can argue about competence, and we can 22 argue about ripping somebody off a midnight shift, and 23 thinking they can pass the fina3 exams. So, I'm just 24 asking philosophical 33y, unless somebody corrects me, I'm i 25 not under the impression that these words, that NUMARC, ) I
Page 226: 1
'or1certain the operators,. or anybody else, had an 1.
O 2
' opportunity t6 critj gue these particular two paragraphs 3 prior.to.having seem them here.
]
I 4 Now, that may be showing my ignorance, .I don't l 5 know. But'I kn'ow somei.of the' things were digested after 1 6 the~first comment per16d. And, so, the real issue is, 1 1 7 is this so-called requal testing, testing the 8 requalification program, or is it testing human beings 9 e.v ery . six yea rs. And .I" guess ' we have- to philosophi ca ll y 10 : l ook a t what the int ent is. And I f eel that i t may have-11 been.a step backwards in the anxiety level of that 12 enormous popu3ation of operators out there, from what I g 13 perceive here, is going -- ehey are going to be up' tight ! 14 every sing 3e year. : 15 Because if I understand the arithmetic, it 16 appears to me that'as a minimum, the NRC is going to 17 have to give a requal t es t once a yea r, 'i f I ha v e 18 requested a hot 31 cense test once a year. Now, if I'm r_- 19 wrong- , I wou3 d certainly appreciate it being explained 20 to me. 21 MR. R11S S ELL : No, your perception is quite 22 accurate. The Statement of Considerations is the 23 vehicle that the Commission used to provide directions s 24 to the staff, on how it wished the staff,to' implement 25 the Regulation, which has always permit t ed the staff to
'l c page 237 l
1 administer requalification examinations. The fact that M Y I 2 the requa 31fication examination has been made a l 3 condition of 31 cense renewai is new. But that has 1 4 always been. authorized for the commission to perform 5 that. 6 Wha t we ha ve done, is we'hav e cl e.a rl y > 7 indicated that that is what is going to.be happening, .l 1 8 because there was s'ome concern in the past, that why me? j 9 l Why not this other guy 7 How did you decided? Who makes l 10 the chojce? By putting it in the Regu26 tion, and 11 indicating that that's clearly what.the intent is, it 12 becomer, clear that ev eryone wi l l', .at some time during that s3x year Jicense, be examined by the NRC in order 13 14 to have his.31 cense renewed. 15 In addition, as part of the direction to the i 16 staff, on how to implement the program, since we are I
.I 17 excepting for two written tests, and five operatjng 18 tests per six years, a certification by the facility, 19 the staff wi33. continue to examine in some c a s e s'. That i
20 is, we wj)) .just choose not- to accept the f acili ty's 21 certification at that time, and we will examine the 22 individual. There may be some cases where an individual 23 wi3 3 be examined more f requently than once each six 24 years. ( 25 The reason for that is just as you described. i
Page 228 I
'1 If he's examined in the first year on one license and t I ki 2 the'next six year .l d cense comes along, it would be 3 possib3 e .f or him to go to the last year of the second 4, .)
six year license,'and go more than ten years'without. 1 l 5 'being examined.- ' That's not what the Commission'has ! 6 directed the staff to do. And we will keep track of how 7 f requent 3 y an individual is. examined, and.we wil1 8 administrative 3y' insure that no individual goes more 9 than six years without being examined.by the NRC. , 10 HEARING ATTENDEE: (Mr. Johnson). I wou3d just I 11 Jike to repeat what you just said. If he gets his 12 3dcense renewed, and is tested in the first year, my i 13 arithmetic says that he can't go but one year beyond his s 14 renewal. And if you look at it, then, c3early, the 15 frequency is going to be greater, by definition, than 16 once every six years. 17 N MR. RUSSELL: That's why we use the word at 18 Jeast once during a six year license. 19 4 HEARING ATTENDEE: (Mr. Johnson) We33, you l 20 know, that's obviously why I don' t understand the s 21 Statement of Considerations, because I'm just concerned 22 about.those people. 23 MR. RUSSELL: I think you understand it. It 24 says that we're going to do it so that nobody goes more J 25 than six years, and that 's going to mean that some are I A __ . __ J
o < Page 229 1 going to get examined more than once in six years. 3 I SI 2 think the $ssue 1s, you don't 33ke what the words say, 3 rather than you don't understand them. 4 HEARING ATTENDEE: (Mr. Johnson) I'm not' ; 5 convinced t h a t 'i t 's not counter-productive to safety.
'6 Secause I think it 's that enormous population out there, 7 that we're trying to insure safety. I think that's a-8 rea3 obligation of this organization.
9 HEARING ATTENDEE: My name is John Benjamin, 10 f r orr. C a r o ] i n a Power and L3ght Company, at the Rob 3nson 11 Plant. I would 3ike to bring up, one more time, the 12 3ssue of exemptions $n in CFR 55 Part B. The reason'$s 13' that, wha t 's been said so far is -- may cause me a 14 sign 3fjeant change $n the way I train the rep 3 acement 15 operators. And I wou ld J ike to approach .$ t a 3 5 t t J e bi t 16 different3y, by descr$b3ng the trajning program we have 17 for indtja3 33censees, and ask you when in that process 18 the person cou3d manipu3 ate the controls as a trajnee.
, 19 And I have a plane to catch, so I can't go too 3ong, so j 20 don't worry.
1 21 (Laughter.) I 22 Basically, the person in an operator program 1 23 would qus31fy as an auxiliary operator, first. And to 24 do thai , he would get a basj e systems c 3 ass very ear J y 25 in his employment with CP&L. Once he qualified as an ( ) - o _ _ _ _ _ _ _ _ _ _ w
i . Page 230 1 1 auxjJ3ary operator, he would be issued his control e t-2 operator qualification cards, that are the systems 3 checkouts f or the various systems involved with 4 reactivity contro3, turbine control, chemical volume 5 control, and the chemical shim process, and so forth and i 6 so on. 7 Early in his process of completing those 1 8 qualification cards, he would go to advance system 9 schoo], wh3 ch wou 3 d give him the system based know3 edge 10 on.those systems. Not necessari3y any of the reactor 11 theory, or any of that type of information on the 12 systems. Once he completed all of those qualification
'; l ')
cards, wh3ch inc3ude things like rod control, nuclear ~ 14 instrumentation, and that type f thing, he would -- he 15 could be se3ected for on-the-job training. 16 And 3 t 's during the on-the-job training phase 17 wher e he would potent 3 a3 3 y man 3pulate the cont ro3 s as a 18 trainee, I th5nk. However, we do the on-the-job 19 t raining be f ore we send him t o wha t we ca.11 our react or 20 operator school, which consists of the theory courses, 21 the heat transfer arid f3udd flow, the fundamental 22 e3ectricity, the radiological control courses, and that 23 type stuff. f 24 Sometime during the classroom phase, du11ng an i 25 appropriate break between courses, we send them to the
Page 232 1 1 simulator, depending on the simulator schedule. They i 1 i 2 come back from the simu3ator, and have a brief review
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3 period, and then take the NRC exam. That's our current 4 program. I guess the question is, where in there do you 5 see the guy being able to manipulate the controls.as a 6 trainee? 7 MR. RUSSELL: I don't want to address it on a 8 program specific basis. 9 HEARING ATTENDEE: (Mr. Benjamin) Right. 10 MR. RUSSELL: Let me identify what the issue 11 js that we were trying to refer to. There are certain 12 ski 31s and knowledges that an individual most have, for 13 example, to perform a reactor start up. Hopefully, he 14 would understand some reactor theory, effects of 15 subcritica) mu3tip31 cation, and other aspects of the 16 controls he is manipulating. 17 If the jndjvidua3 has not completed those 18 phases of training, he should not perform the reactor 19 start up, whether it's under instruction or not under 20 instruction. That's the ccncept that we're trying to 21 describe. Now, if in your program, information is 22 transmitted to him such that he is prepared to perform
)
23 the function because he understands what he is doing -- l 24 he has either had the systems training, or he's had the 25 theory training, or he's got it in some other earlier l
Page 232 1 program. Such'that you are assured that the sequencing J. t 2 of training is appropriate, and the potential for him 3 making an error is small. Then, the exemption app 3 des. 4 And because of different sequences'of 5 training, and different ways the programs are 6 structured, we have said, if you are in an accredited i 7 program; and the program does look at that sequencing of 8 tralnjng, you should not be performing the OJT prac 9 facts unti3 you have had the appropriate portions of 10 classroom and theory training to support the performance 11 of that student. 12 What we don't want to have happen is an event 13 simi J ar to one which occurred a f ew years ago in this 14 Region, where an jndividual who was soon to enter
. l 15 training performed a start up, and, basically, was a 16 part of an opportunity decision by a manager on that i
17 sh3ft. And they had a high start up rate, short period 18 transjent, and the ind3vidual did not understand what he 19 was doing, and did not have an appreciation for the l 20 procedure. 21 Two concerns with that event: One, you put 22 the plant in a situation that was not safe, and that's 23 -the prAmary concern. That you have someone manipulating 24 the controJs who didn't know what he was doing, and 25 didn't understand it. And, two, you just provided l . l
Page 233 1 negative training, that he may repeat, or pick up a bad
)
5 i 2 habit later. And we've had that occasion occur at other )
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3 facj31 ties, where we have had wrong procedures in all l l 1 a the training. l 5- So, t'he sequencing of training, leading up to l 1 6 the performance of practical factors and performance on j 7 the job is important. And that 's what that exemption is , i 8 intended to require, that you hare had that. And that's 9' consistent with the INPO accreditation process, and 10 criteria. And jf you look at the objectives in INPO 85- . 11 002, for on-the-job training, you wi33 find that they 12 intend that the person adequately understand the task he I 13 is going to perform, before he performs it.
]
14 I hope that completely answered your ques 1fon. I 15 I can't address when in your program the appropriate 16 trainjng is provided for that particular task. ) 17 HEARING ATTENDEE: (Mr. Benjamin) I w a r, 18 hoping f or a simpler answer. You had a lot of simple 1
' 19 answers for other people.
20 (Laughter). 21 HEARING ATTENDEE: Lee W131iam, A3abama Power. 22 I be 3 d eve i t was a slide that Jerry had up earlier, 23 Wachte3, that went something like this; that the ] l 24 inabiljty to conduct an exam on a given procedure, ' 25 event, or sys t em would be a condi tion, i f you w j ] ] , that
Page 234 1- wou3d require' accelerated update of the simulator. And 2 my concern is, what events? What systems, or'what ; 3 procedures are we trying to exercise during the 4 simu3ator exam -- what are we talking about, there? 5 MR. WkCHTEL: Well, I think the intent of that 6' was to identify any potential system or scenardo that we 7 could not conduct on the simulator exam, because of the 8 problem with the simu3 ation f acility, without 9 identifying any specific system, or procedure, or event. 10 And i t. wou 3 d be one such that we could not read 13 y find 11 another way to achieve the same goal during the conduct ! 12 of that examination. Such that the process of 13 conducting the exam would be compromised. And we wou3d 14 need to see whatever that system, or procedure or event 15 was, correct it, before we could develop an appropriate 16 exam using it. 17 The word, intending to be specific, or 18 proscriptive in what the description would be. , 1 19 HEARING ATTENDEE: (Mr. Williams) Well, 20 that's my concern. j 21 MR. Rt1SSELL: Let me give you an example of ! i 22 one that occurred, and was identified on a facility ! 23 I examination. It turns out that the plant -- the I 24 simulator was not abJe to adequate 3 y represent flow ( 25 coast down on a 3oss of coo 3 ant. And it made the l 1 l
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Pagez 235 1 response very' unusual, as compared to what was expected, f-1 2 and how the procedures were to be used, because you did 3 not have any coast down. That would not be appropriate
- - 4 to conduct an examination which involved a loss of flow 5 event in'that case. There may be other casualties which 6 we could use.
7 We would not wani to become the situation l' 8 where we would let that exist for the next two years. 9 We may want .to conduct a loss of flow scenario as a part 10 of an exam wjthin the next two years. So, we would
)
11 request that tha t be corrected on a-schedule that is
.12 faster than the norma 3 correction schedule provided 5n 13 the standard, which is a two year time freme.
14 HEARING ATTENDEE: (Mr. Wil J iams) And I 15 think, clearJy, that's the intent, the way it was t 16 worded. But I see it being able to open up some areas [. 17 of disagreement in the future. You know, I 'd o n ' t know c 18 what -- none of us know, I guess, what the next round of 19 the topic of the day is going to be, if you will, 20 whether it's pressurized thermal shock, or what. And 21 our present machines just, you know, were not designed 22 to handle what ever the ne>;t issue is that comes on the 23 forefront. And, so, when you say any event, that can be l 24 troublesome. '
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25 MR. RUSSELL: I would suggest that you look at l l
l Page' 236 1 the NUREG that we distributed earlier this morning, with 2 the examples, and the kinds of things that we did at 3 Nolth Anna. And I hope that that allays some of the l l 4 apprehension. 5 MR. WACHTEL: Remember, also -- 6 MR. RUSSELL: We are intending to make it 1 7 reasonable, such that we can conduct an exam. I i 8 MR. WACHTEL: Remember, also, that this 9 system, or' event, otherwise undefined, is something that 10 you have al ready certified that your machine is capable 11 of dojng. It's something that we have discovered during 12 the course of our inspection, that is, in contradiction ( 13 to something you've told us on your certification. 14 HEARING ATTENDEE: (Mr. W3133ams) Okay. 'Let 15 me shift gears and go back to NUREG 0737. If I 16 understood you this morning, or in the presentation, we 17 said that, really, the 0737 requirements that are being 18 incorporated in the 20-CFR-55 are only those that relate 19 to operator training and licensing? 20 MR. RUSSELL: Operator licensing, not the 21 training. 22 HEARING ATTENDEE: (Mr. Williams) Excuse me. 23 A31 right, to clarify, I'm looking for something, here, 24 we also make commitments in 0737 for training and I 25 mitigating core damage of other work groups. And, also,
Page 237 1 there is training related t o STA's. So, nothing in this 1 i L !
- 2 regu3ation, in any way, shape, form, or fashion affects l
l 3 .that, even though there is some reference to it, t 4 For instance, in. Reg Guide 1.8, it talks about ! 5 an STA, and the' number shifts that he has to pull. j 6 MR. RUSSELL: Yes, that's correct. I 7 HEARING ATTENDEE: (Mr. Williams) Okay. ! 8 MR. RUSSELL: It does not modify those prior 9 commitments. 10 HEARING ATTENDEE: Hel3o. My name is El3 3 , 11 Mill er,- with Fl orida Power and Light, at Turkey Point. 12 And I've got a situation that I thought I heard . iv 13 described today, that I need some clarification on. And i 14 it r e .l a t e s to our shift compliments back at the p3 ant. l 15 If you look at a typical shif t compliment that we have, 16 we ' v e got three supervisory positions, a31 of which 17 require SRO's. But when you take a look at our ooard 18 operators, which you typica 3 3 y see as a mixture; in that 19 some of our board operators are RO's , and others are 20 SRO's. I 21 Typica33y, the reason we.do that, is that we 1 22 want to have.our people be ready to go into a { j 23 supervisory position subsequently. If I am hearing you 24 correct J y, what you are telling me is I now have a j i 25 prob 3em as it relates to maintaining those SRO's on the I
Page 238 1 board. In that, norma 33y, while they are on the board, __ 2 they are f unctioning simp 3 y as a board operator. And 3 with the new requirements, I'm going to have a hard time 4 maintaining their SRO license active, is that accurate? 5 MR. RUSSELL: No, I don't believe t ha t 's 6 accurate. Let me describe the outcome. If the 7 individual is maintaining proficiency as a reactor 8 operator, and he is in that position on the boards, his 9 license as an SRO is active for the manipulation 10 portion permitted under his Ideense. If he has not been 11 in a position for an SRO, directing the activities of 12 others, he may not do that until such time as he's had g 13 forty hours of para 33e1 watch with an SRO. 14 His 3deense, however, requires that he 15 participate in the requal program appropriate to the 16 SRO, which would mean that he would have t raining on, 17 for example, emergency procedures, your emergency plans, 18 radio 3ogical response capability. So, his requal 19 program is what the vehicle is for keeping his license. 20 And meeting the license commitment, he is active in 21 manipulating the contro3s, because he is in the position " 22 of a reactor operator, okay? He not do both. That is, 23 he need not be active as an RO and SRO by doing both. 24 , An individua3 who stands, however, in an SRO ( 25 watch, who is directing the activities of others, is a
1 1, .
., Page 239 j 1 cur rent for both. He may manipulate and direct.
2 HEARING ATTENDEE: (Mr. Miller) Let me 3 paraphrase that back to you, to see jf I understood it. ) l 4 4 So, our board operator., who rea]ly ho3 ds an SRO 31 cense,
)
5 h a s n o g r e a t p r'o b l e m , as long as we, in his requal ) 6 program, continue to' train him at the SRO 3 eve 3. And 7 when it comes time f or him to fill one of those 8- supervisory jobs, at that time we need to give him a 9 f ort y: hours worth of. training -- 10 MR. RUSSELL: Forty hours in pa ra 31 e] , on-
. 11 shift.
12 HEARING ATTENDEE: (Mr. Mj 3 3 er) -- on shift, !
- , 13 j n para 11e] . Okay, and then he may -- we may, at that 14 time, say that his SRO 33 cense is, indeed, active, and 15 he may take one of those supervisor positions?
16 MR. RUSSELL: That is correct. 17 HEARING ATTENDEE: (Mr. Miller) Thank you. 18 May I ask one more question. It relates to a group of 19 hot license candidates that we have in training right 20 now. We just started their training, and they are not 21 rea) J y due to finish training until mid-1987. I have a i 22 concern, because when I l ook a t t he comp.11 men t of the 23- people who are in that training, it's a pretty good
. 24 ' mixture, and not all of them have had background as non-25 Jicensed operators. In fact, most of them haven't.
. _ _ _ _ _ _ _ _ _ _ _ _.___ _ _ w'
l' '! l Page 1240 l' [ l 1 But I do have an accredited program, and it is , t
. I i \ L 2 SAT based. I don't yet have a simulator, but it should l 3 be aval]able for training, and meet 3.5 Standards, at 4 the very beginning of this next year. So, I look ,
5 forward to the time when those people would graduate, 6 and be ready to license. It's my understanding that we 7 are, again, okay, because we meet those three elements, 8 SAT, INPO accredited, and our simulator should meet your 9 standards. 10 Therefore, I don't have to worry about the l 11 ANSI S t andairds ' tha t were described earlier, that relate 12 to the next for two years as a non-licensed operator, i 13 with six moisths at the plant. Am I correct, that, , 14 a g ss j n , in meeting those standards, I don't have to wor ry 15 about the ANSI Standards? 16 MR. RUSSELL: No, that's not correct. I 17 thought I made i t c J ear earlier, while you don't have to 18 submit that information to the NRC, industry, through 19 NUMARC, and INPO, through it's guidelines from 20 accreditation, has comparable standards to those. And, 21 therefore, we feel that the qualification aspects of the 22 requirements are still being met. The only difference 23 js, you don't have to submit all that information to us. 24 We have had a case recently where an 25 individuaJ, who was a graduate of an accredited program,
p Page -241 1 did not-meet the eligibility requirements, based on
<2 e
'xperience. His pJant experience was that of a chemist:
i o 3 not comparable to that of a c o n t r o 1 r o om '. op e ra t o r , or a. 4, shift. engineer, involved in day to day activities of a 5 nuclear power plant. -We denied the application, and it 6 was denied, again, on appeal. We.aren't going to see 7 that kind of'information"in the future, and we' expect ! 8 the industry to po31ce itsel f with respect' to = insuririg 9 .that the NUMARC commitments are, indeed, met. 10 And the fact that we are stepping out of that 11 arpo, and not requiring it to be submitted, does not 12 mean that you re3ax the standards.
; 13 HEARING ATTENDEE: (Mr. M 3 31er) I guest, . we're 14 -- my --
15 MR. RUSSELL: So, that's a very important and l 16 significant area, and one of substantia] discussion .., 17 'oetween myee3f, and.the fu33 Accrediting Board, in 18 p]enary session. I've discussed it with the - staff of 19 INPO. 20 HEARING ATTENDEE: (Mr. Miller) I guess where my quandary comes in, the example that you just gave, as 21 22 the chemist, f or example: obviously, you are talking i 23 about an SRO candidate, and I was referring, primarily, ) l 24 to a group of RO candidates. These RO candidates, in l I i 25 the past, the requirements -- particularly for those of l l j
Page 242 1 those who weren't committed to the -.I guess it was the i I I 2 3983-version of that ANSI Standard -- there was no 3 requirement f or them to have been non-licensed operators l 4 prior to this time. 5 So, now, we are, indeed, faced with the new 6 requirement, and I'm kind of caught in an interesting 7 predicament, that I've got a group of people who are in 1 8 training now, who don't necessarily'have that i 9 background 7 i 10 MR. Rt1SSELL: Let me pojnt out.one aspect of 11 the accred3tation process that I think that you may be 12 nij s s i ng . And 3t's a part of the process that you've
+
13 desjt w3th through the Jabor process f or eligibility 14 requiremeists for the NRC. The accreditation process 15 does inc ] ade a mechan $ sm f or you to exempt , or waive 16 aspects, based upon having perf ormed an evaluation of l 17 th- ca nd i da t e 's experience and/or testing. That is the j 18 same . kind of process that we use in looking a t a case by i 19 case basis, and making a judgement about eligibility, i i 20 where a person didn't cross a33 the t's, and dot the 21 3's. l 22 We are 3 ooking f or you to use that same l 1 23 process, okay? You may choose, for a documented reason, ) i 1 24 as a part of your program, to waive a portion of the { 25 requirement, based upon experience and/or testing. That 4 i l
Page 243 i 1 is a part of'the accreditation process, and we i I
- I 2 understand that, and we expect that to continue. And 3 3 the only difference is, you don't have to' submit it to 4 us, and request a waiver, and get in that back and 5 forth. We are expecting that you would meet the intent 6 for that training.
7 HEARING ATTENDEE: (Mr. Miller) Thank you. 8 HEARING ATTENDEE: Johnny Smith, Florida Power 9 Corporation. Back to the random examinations of 10 Jicensed operators. How f ar in advance will I know who 11 w333 be examined. When w313 I be supplied with the 31st 12 o f names, saying that on this day, these peop3 e wil 3 be 13 examined? 14 MR. MUNROE: What we do -- right now, we 15 intend on giving the exams in accordance with ES-603. 16 And by ES-603, n3 net y days in advance, you will be 17 not3fjed of the examination, per se. And the policy we 18 have used jo typica 3 3y two weeks prior to the 19 examination, ten working days, we have notified you of 20 the individua 3 s who have been randomly selected to be 21 evaluated for the requalification program evaluation. 22 HEARING ATTENDEE: Gene Karlson, Florida Power 23 Corporation. Where does the requirement for five 24 reactivity manipu3ations on the plant come from, rather 25 than be3ng ab3e to do them on the simulator? l !
i I Page. 244 1 1 MR. RUSSELL: In the Regulation.
<l II 2 HEARING ATTENDEE: (Mr. Karlson) W e l ) ~, 1 ;
3 understand that, but wha t 's the basis for it, when we're 4 J l 4 spending ten to. fif teen million dollars to build very, ' 5 very expensive '-- 6 MR. RUSSELL: The basis is, that we have had , 7 experience withLsome of those simulators being used when i 8 there-were procedures that were being used, for example, j 9 in training on the simulator that were different than 10 the procedures that were used in the plant, and other ! l 11 br eakdowns in the training program. And we want to make ' 12 sore that the candidate has, indeed, performed on t he-
; 13 f ac:j 31 t y, manipulating the controls. And that he can, 14 indeed, pe r f o rrn in that situation.
15 HEARING ATTENDEE: (Mr. Karlson) But doesn't 16 the Regul a tion requi re us to be ab J e to use and, in 17 fact, use the plant procedures on the simulator, now? 18 MR. RUSSELL: It does. 19 HEARING ATTENDEE: So (Mr. Karlson) -- 20 MR. RUSSELL: The requirement is for a set of 21 control manipulations, they shall be done on the 22 facility for which a license is being sought. 23 MR. HANNON: Again, i t's an eligibility issue, l 24 as opposed to a training issue. 25 HEARING ATTENDEE: l (Mr. Karlson) But i t 's -- l l e l
1' Page~ 245' I
, .1 you can't separate the two. We've got a class of five
,,_ 2 or of.ej ght candidates,.'and'each one has to do at -!
I
.; 3- Jeast five reac t i v d't y manipu l a tions. That makes forty l
l' 1 4 plant evolutions, or manipulations, that'has to be done ' 5 for.that group'of can'idates. d And I guess our Vice. 6 President is, maybe, asking'the question, wha t -- yoil 7 .know, this very expensive machine that we're maintaining a at a very high 3 eve 3 of fide 13 ty, t ha t we can' t use -- 9 we can't take credit for on this -- we ' re having a hard . 10 time answering the questjon; other than the fact that 11 3i's in the, Regulation. -! 12 (Laughter). 13 MR. Rt1SSELL: The contro] manipulat 3on-on the 14~ plant'has been requ3rud for some time. That's not a 15 change. And what we have done, is we have put it in the 16 Regulation, and we have made it much more spec 3fic and 17 c3earer. That has a3 ways been required, that you have 18 the experience. And, in fact, for a long time, if you 19 had not actua 31y done a start up and shut down cf the .; 20 plant, we actually had you perf orm the start up and shut 21 down as a part of the NRC examination, or a portion 22 thereof. But this is not, per se, a change in practice. 23 It 3 s a change by clearly articulating it in the l l 24 Regulation. ! 25 In the past, there have been cases where it !
Page 246 1 has a 31 be done on the simulator. We had not 2 differentiated between those done on the simu3 ator and 3 those done on the plant. The forms were modified about 4 Apr13 of 3hst year, or prior. It has been a long-5 standing r e q u i r e'm e n t . We expect that the individual has 6 actually manipulated the controls of the plant to which 7 he is going to be licensed. 8 There are a number, and a spectrum of ways you 9 can effect power and/or reactivity; we gave some 10 examp]es jn the Standard. We have seen on-the-job 11 qua33ficetion cards, which are to be completed during 12 the three months the jndividua3 is on shift. A great 13 many of the performed practical factors, which are done 14 during that OJT meet the requirements for significant 15 contro) manipu]ations. We don't believe that this w133 16 have any impact on plants which have performed prac 17 facts on the p] ant, doing it in the job site. 18 We believe tha t you can look at those, 19 particu]ar 3 y those that relate to integrated plant 20 operation, and conclude that they do, indeed, meet the 21 minimum f j ve. I believe that you are going to f j nd tha t 22 you have done, already, significantly more than five by 23 the way you do on-the-job training, 24 HEARING ATTENDEE: Paul Rushton, Georgia Power 25 Company. Our Tech Specs require two senior reactor
1
-l P' age 247 l
q 1 operators and two reactor operators for mode one and two i 2 operation. Typ3 ca 3 Iy, though, we'13 have others l 3 assigned to the shift. One -- to take our reactor l 4 operators, for-example, one is assigned as the reactor 5 operator, and one is assigned to operate the balance of 6 plant, Typically, in our current mode of operation, we 7 have another assigned to monitor our steam generator water 3 eve 3s, and that's a full time job. 8 9 Is jt the NRC's intention that only the two 10 peop]e who are assigned as the ba3ance of p] ant 11 operator, and the reactor operator operator, 12 t heoret ica 31y f 3113 ng the Tech Spec requirement ( 13 posjtions, those are the only two people that are 14 getting credit for being on shift? Or are the others, 15 who are also manipulating the controls, getting credit 16 for being on sh5ft? 17 MR. RUSSELL: The two that are required by the 18 Technica3 Specifications that are on shift, in the 19 positions required, are the two that get credit for that 1 4 20 position. Others.who are manipulating controls, who are ! 21 not in Tech Spec pos3tions, are doing that under the 22 direction of someone who is in the Tech Spec position. , l: ! 23 HEARING ATTENDEE: (Mr. Rushton) That's what 24 I was afraid of. 25 (Laughter).
Page 248 1 HEARING ATTENDEE: Nice try. I I
- 2. MR.' RUSSELL: The regulation was very c3 ose]y 3 Jocked at in that respect. It is only the position 4 required by the Tech Spec, and it's the job function of' 5 that. position. It does not dea 3'with the license the' 6 indiv3dua3 holds.
7 HEARING ATTENDEE: Chuck Alexic (phonetic) I 8 from Carolina Power and Light. I stood up for-two 9 reasons, one, to stretch my 3egs; and, secondly, to ask i 10 a brief question. About five years.ago, we a33 wrote 11 our response to the Denton Jetter, and said that we 12 wou]d do specific punch list items to train our STA's. : 13 And, now, if I understand what we've kind of talked 14 around, now jf we have an approved STA training. program, 1 15 pe r INPO, the o]d proscriptive hours that we did send 16 3etters in on no Jonger applies. 17 However, what we do need to do is if that -- 18 that 3 3 ne punch list item is j n our FS AR, we need to 19 remove it, and say, per the INPO accredited program, is 20 that correct? 21 MR. R11S S E LL : That is correct, as it relates 22 to 31 censed operator programs. And it is also correct 23 for other programs for which you have made training 24 commitments, which are covered by the Commission's 25 Fo3Jcy Statement on training and qualifications. And in
Page 249 1 both cases, it is simply a 50.59 type review, to amend, b 2 or update your FSAR, to indicate the date on which you 3 received accreditation, for instance, for the STA 4 position. 5 HEARING ATTENDEE: (Mr. Alexic) Thank you. 6 MR. RUSSELL: The only exception is as'it 7 re3ates to the Commission Policy Statement on 8 engineering expertise on shift, with the use of the dua3 9 role RO -- or the SRO/STA, as compared to a separate 10 STA. 11 HEARING ATTENDEE: Steve Frye, Duke Power 12 Company. My concern is with the statement Mr. Russel) 13 just said -- not a concern with your statement, but w3th 14 the STA dua 3 role, wj th the shif t engineer. In a 3 3 of 15 our stations, we have engineering expertise on shift, 16 '$ n the function of a shift engineer, who is the STA. 17 And they ho3d a current SEO license. They d3 rect the 18 activjtjes of discip31nes on the shif t, and integrated 19 scheduling type things. Are they not actively 20 performing the functions of an SRO license, by those 21 dut$es, or are they going to have to come back and ! 22 perform as a shift supervisor, on shift? 23 MR. RUSSELL: If they are one of the two
, 24 Individuals required by Tech specs, then what you just i
25 described is acceptable. If they are there as an
Page 250
- 1 engineer on sh3 f t who happens to also hold an SRO
.i
__ 2 . 31 c en s e , and is f ul f131ing the role of an STA, then he 3 3s not active to direct the activities of licensed. 4 operators, But he may direct other things to be done 5 associated with' review of procedures, tag outs, things i a 31ke that. That is, the same thing that can be done by 7 anyone who holds a license, where your commitment, or { 4 8 your procedure is required a license for review and f I 1 9 approv63. 10 There are many cases of ext ra people on day 11 shjft, who do tagging functions, review of procedures, 12 3ine-ups, revjew of records, those kinds of things can 13 he done by tha t indiv j dual, and it does not-require an 14 act3ve 3 J cense to perf orm them. It is only when he 15 -manipulates the controls, or directs the activjties of 16 those individuals manipulating the controls. I believe 17 that thai's your shift supervisor, and your management 18 structure, and it's not the engineer, 19 HEARING ATTENDEE: (Mr. Frye). That's true. 20 Another question along w3 th that, when it comes time to 21 renew the license of our shift engineers, and i t 's been 22 six years. They have maintained all of their requa3 23 requirements, and a33, and their license can be renewed 24 in an inactjve status, without another examination, or 25 what?
Page 253 1 MR. RUSSELL: Anyone who holds a Idcense has 0 b(h 2 to --'you must keep him complete an h.is requa3 program, J V.: t' 3 be' medica l l y f i t , have been examined some time by the
- 4. NRC during the course of that six year license. The 5 requalification examination requirements are independent 6 of active versus inactive' status.
.\ .
7 ' HEARING ATTENDEE: (Mr. Frye) ($3ut inactive 8 status can be majntained during the next gjcense term 7.
.j '
9' MR. RUSSELL: Absolutely.,
..a. s.
f..; ['A 10 ' HEARING ATTENDEE: A simi 3 ar '--\ Lee Wj 3 3 J am, I.' 11 from Alabama Power. A similar question that was raised 12 a 31 t t 3 e- ear 3 d er. For the.SRO 3icensed individus3',-who. 13 is standing shift as'an RO. And it comes up time for 14 renewal, again, hjs SRO ju gojng to be renewed as an cx i 15l AnactJve,
, + I would presume, and we're going to have to
;\ .s
, 161 make some specia] . statement on there, about he's
-[W s
- 17 actua31y serving as an RO7-
{a! w
'E,s 18 MR. RUSSELL: No.
What you do, is you certify 4 j ,s, 19 tha t he has compl et ed his requa l program,; tha t he ha s! -- I
% 1 70 .js current on requa). That's the' basis for renewing his a
21 31 cense,.and the renew'a3 does not reflect either actlv+ 22 or inactive, it is comp 3 etely silent. The only thing 23 you must.have, is that before he resumes duties as an t
' 24 SRO, he must go through the forty' hours, and that has to 25 be in' his docke t f i l e -- not the docket f i l e -- in his s
.g r
.j
_(.a L $\b - _ _ _ _ - -. ____-_____________O
l Page -252
~
1 fj3e, avajlable on site. f I ; iJ 2 HEARING ATTENDEE: (Mr. W1331ams) The new 30 3 CFR 55 goes into effect May-26th, I believe the date is. 4' We're schedu3ed, current 3y, for requa3 exams June the 5 22nd. Are there any changes, due to the change in 55, 6 that we are going to have to look at , or are going to be 7 'inposed on us between those.two dates; d.e., you know, 8 one specific examp3e that comes up, the eva 3 uation f orm
~9 that someone went through this morning, I forget, now, 10 who t was, used on the simulator. I am assuming, then, 11 that wj)) be the evaluation form that will be utilized 12 for us come June?
s 13 MR. RUSSELL: That is correct. 14 HEARING ATTEhDEE: (Mr. Wjlliams) Are there
. i 15 any other changes that come immediate3y to mind to the 16 pane), that wou3d be different f or ue, since the 17 Regu3htjun is changing right there, before our next 18 requal exam?
19 MR. R11S S ELL : No. 20 HEARING ATTENDEE: Wayne Powe33, Carolina 21 Power and Light. One brief question, again, on 22 instructor certification. We have been using a program 23 that we put the instructors through, and we internalJy 24 certified them, and then the NRC came in, and gave them 1 25 another exam. I do not have my programs accredited,
.n z Page 253
+
I 1 yet.- I hope we will' have them done by. the end of the
< J t i 2 year. But.I have people who are in a program right now, 3 the same one we've been using all along, and they are 4 being examined < interna.13y by us next week. And the NRC 1
5 is.not going to'come in, with my understanding, and'give 6- them an NRC exam. 7 My' intention is, to have me certify them, as I
's have done in the past, and put them right into a 9 cl J a s s room, and t hey w13.1 be abl e t o t ea ch. And they
- 10. wi J 3 be in a requa 3 program, what we've been doing f or J
11 yeard. Do I' understand that to be~a correct procedure 12 to take, and'I'm in good shape. 13 MR. RUSSELL: Yes. l 14- HEARING ATTENDEE: (Mr. Powe33) Thank you. ' 15 MR. RUSSELL: And most important, if you are 16' getting ready f or accreditation, you probab3y have i 17 comp 3eted, I wou 3 d hope by now, the soft evaluation 18 report, and are getting ready for a team visit. And as 19 a part of that, you look at how you are create and , j 20 certify instructors. We want that to be a part of the 21 accreditat-lon process, and not a part of the NRC review. 22 We don't want to be involved in training. f 23 HEARING. ATTENDEE: Paul Rushton, Georgia Power , j 24 Company. If we were to .l e t an i ndi vidua 3 's license go l 25 Anactive, would it-also be reasonable for us to let his l r if
Page 25'4 [ 1 . medical requirements lapse? dnd if we wanted to return [ l I I t' 2 hjm to active status, to recertify his medica] j 1 3 requirements, and have him do the forty hours under 4 instruction, before -- f
'3 5 MR. RdSSELL: No, you cannot let his medica 3 6 requirements lapse. He must be medically examined each 7 two years. That is a ccndition of his license.
8 HEARING ATTENDEE: (Mr. Rushton) If there is j 9 a purpose for that, if he is going to continue to be 10 inactive? He is not permitted to go on shift, so there 11 seems to be 35tt3e pojnt to me, anyway, to maintain the i 12 medical status up to date? 13 MR. RUSSELL: How are you goi ng' t o fix - 14 somebody medicaJJy in forty hours. The issue is, that t 15 he is medica 3 3 y f j t t o carry out the duties of a ' 16 3 S censed operator i f you put him in a situation of watch 17 standing to regain bis proficiency. At that po. int in 18 time, he would be permitted to manipulate the controls 19 of the fac333ty, and/or direct actAvity. And it is , i 20 required that the individual who hold licenses be 21 periodica 3 3 y examined; and that examination schedule is i 22 two years. In fact, that's the reason we extended the 23 licens3ng to six years, was to make it coincide with I 24 your multiples of two years, for the medica 3
]
l 25 requ3rement. ) l l l 1 L j l
Page 255' ! 1 ! e 1 HEARING ATTENDEE: (Mr. Rushton). Okay. k 2 HEARING ATTENDEE: Steve Grant, from Georgia 3 P"wer o Company. My question also concerns clarification 4 of active license sta tus. The case is a dual unit 5 P lant. The shift supervisor is the SRO that norma)ly i 6 directs the activities of the operators. We also have 7 an SFO on shift, that is over both of the shift 8 supervisors. He does not normally direct the activities 9 of the operators, but he may, for instance, if the to shift supervisor is out in the plant on a tour. 11 Would his time on shift, in the operator 12 supervisor.poaltlon, over the shift supervisors, count j l 13 as actjve time? 14 MR. RUSSELL: Yes, t ha t 's a position that's i 15 equired. If you look in the Regulations, on staffing, 16 for a dua3 unit site, you have three SRO's for the two 17 unito, he's in one of those positions, and that does 18 qua3ify him. 19 HEARING ATTENDEE: (Mr. Grant) Thank you. l l 20 MR. HANNON: Could I make a quick comment on 21 the issue about NRC requa3 exams, and the impact on 22 safety of operation. And I hope this goes without 1 23 saying, it's our view that if a 11 censed operator is j i 24 going through an effective, continuing training program, ), s 25 then there shou 3d be any concern with that person j 1 I I i j
s Page 256 3 1 'getting an NRC exam. Because our exams are really
. 1I 2 des $gned~to confirm that the individua3 has maintained a 3 minimum acceptable capabi3ity. And if he has beei, going.
4 through a continuing training program, it would be our 5- expectation that he has gone way above the minimum i 6 acceptable. 1 o l
+ 7 So, the NRC would simply be, dur3 ng a requal 8 exam, ver$fying that that individual has the minimum 9 capabi .13 t y. If he's experiencing an effective, ,
10 continuing training program that should, really, not be I 11 a problem. ; 12 HEARING ATTENDEE: (Mr. W 1.131 a m s ) I'm going 13 io beat Joe to the m3c. 14 (Laughter). 1 15 This $s not a question, i t 's a statement. And i 16 as a utiJity representative, I would agree with you. i? MR. HANNON: Okay. I 18 HEARING ATTENDEE: (Mr. W 1.1 31 a m n ) - And I feel 19 perf ectly comf ortable that our operators, and our 20 supervisors on shift can safely operate our units. My 21 disagreement comes in, that the vehicle that you are 22 using to measure the requal program is improper 3y aimed 23 at obtaining those results. I say that from the x 24 standpoint, when we try to focus the requa) program on 25 probJem areas, design change, and events in the t' a
ii { Page 257 i i n d u's t r y , and it's fair 3y narrowly focused, but quite in 2 depth. And'then the. exam comes in, and looks at a J 3 target area beyond that, that has not been covered, for
. ~ i-4 memory /reca33 type things, it's unrealistic, in my mind, 5 to see the. operator be able to pass that, or the senior 6 operator, or anyone else. I i
7 But if the exam were focused on.what the s requa3-program had focused on, then I agree with you a 9 hundred per cent. You ought to be ab3e to p3uck him off 10- shift, and say, here's the evaluation, take it, and be ; i 11 ought to do fine on it. But when i t 's not aimed a t the 12 same materia), very JJttle probability. 13 ME. FUSSELL: I understand your comment, and I 14 recognize t ha t both groups are t rying to move to the ! 15 point where we are using content valid examinations to 16 measure performance. We have a ways to go, and we 17 understand that, we're working on that. I think you a)) 18 have a ways to go in describing adequately what should 19 be the content of the continuing training program. What 20 tasks you expect to be performed, the learning 21 objectives for that program, such that eventua3 3 y we 22 wi33 get to the point where we have closure on the scope 23 and content va)$dity of a requalification examination. 24 Until such time as we get there, there is 25 going to be anxiety. We believe that with the
.1 l
page 258 1 a d m'i n i s t r a t'i v e review process for examinations, that 2 there are adequate safeguards to insure that improper 3 questjons can be chal J enged, <.nd that the questions are 4 appropriate to the job. We.have provided some tools to
- 5. do'that, and they need to be used. And until we get 6 constructive feedback both ways, and recognize that the 7 objective is to measure that individual's performance, 8 the imperfect tools that we are using now aren't going 9 to get much better.
10 And I J ay that out as a cha13 enge to the . i 11 Industry, t o real 3 y take a hard look at the INFO
'2 guidelines'in con 11nuing trajning program, and to 13 consider how that is modified --
or how your program 3s 14 mo:13 f i ed to meet those objectives. It is not redoing 15 injtial training on a two year cycle for everyone: we 16 recognize that, and we've got to do a better job of 17 making 11. e exams to focus on it. 18 And I think some of the issue is the fact that 19 we've had problems wjth exams in the past. I'm 20 expecting that we w111 probab3 y have problems with exams 21 in the future. We have found problems with requal 22 programs in the past, and I'm expecting to find prob 3 ems 23 wjth those programs in the future. But we have not 24 t aker action aga3 nst indiv idua 3 s by way of revoking 25 31 censes, nr other activities. We do expect that until
Page 259
-1 remediation is provided, that they removed from watch
. 1 4
2 standing dutjes, and be brought back up to speed. I I
- And 3 f they f eel that the examination is j 4 unfair, there are mechanisms where they can request and 5 review that examination by the Regional Division 6 Director, and'they can subsequently request a review by 7 myse)f. I am serious about improving the quality of the 8 exams; and to get the content valid. And that's . not 9 going t o he J p the guy that's out in the plant until such 10 tine as he starts see j rig some of them. And I'm s t 313 11 waiting for the first day when the guy says, yeah, that 12 was a f a3 r exam, I just b 3 ew i t. Bu t . I hope to get 13 thete soon.
14 HEARING ATTENDEE: It doesn't happen to us, 15 e3ther. I haven't seen one yet. i 16 MR. MUNROE: Yes, s5r. , 17 HEARING ATTENDEE: J. T. Bryan, Caro 33na Powel 18 and Light. One brief question, on performance tests to i 19 be performed on the simulator in compliance with 3 0 CFR 20 55, what are those set of performance tests, the i 21 spee5fic scenarios and ma 3 functions 7 Could you brief3y 22 clar$fy that? 23 MR. WACHTEI, We're talking about Appendices A 04 and B of ANSI /ANS 3.5-1985, and the list of twenty-five 25 ma3functjons that are contained, I think $t's SectJon ; 1 '
Page 260 1 7 7 7.2.2, don't quot e me on tha t , of the -S tandard. There )
~5 s a clear 3 y defined 13st of mal f unctions- that the 2
j 3' 8 3:nu 3 a't j on - f acili t y needs to perform. 4< HEARING' ATTENDEE: (Mr. Bryan) Is it just 5 those -- that 21st that's in 3.5, only? 6 MR. WACHTEL: Yes. 7 HEARING ATTENDEE: (Mr. Bryan) Or is it that 8 3ist, p3us the diesel Cenerator,-I think, that's covered 9 in 3.1497 What is the -- 10 MR. WACHTEL: The specific list of ma3funct3ons 11 that was'jn an ear 3 der draft of 1.149, is no longer in - 12 3.349. The equiva 3 ent paragraph that's in the f3na] 13- version of 1.249 51mp3y endorses.that paragraph w3 thin 14 tbe Standard that 3$sts those twenty-f 3 ve or so 15 ma ] f unct ions. There is no longer a- 1 14 9 separate list. 16 MR. RUSSELL: Recognize,.however, that some of 17 those ma 3 f unct ions are quite broad. We talked about, 18- ear 31er today, the loss of power. Is that 3oss of power 19 t o a pane] , t o a sys t em, to a component, or loss of all . 1 20 power. Sma33 break LOCAs, you can initiate that from a ! 21 reactor coo 3 ant pump sea), you can initial it from a i 22 steam generator, a tube rupture, a lot of different ways i 23 you can initiate $t. What we are interested in is a 24 representative samp3e of those things. You need not do l 25 a33 possib3e permutations and combinations, okay7 L L L
t . Page 261 1 But you are going to have to look at what you k - 2. are. certifying t o, that's the reason that you are-1 3 submitting test abstracts, and you describe what your 4 testing program is. 5 HEARING ATTENDEE: (Mr. Brycn) So, we wil3 ) l 6 determine which specific scenarios we will run, as long l 7 as we cover those areas? j l
- 8. MR. RUSSELL: That is correct. And you l
9 describe that in your abstract, with your certification, i 10 and you describe the performance tests that you wi31 11 conducting in the future, to maintain the simulator. 12 HEARING ATTENDEE: (Mr. Bryan) Okay, thank
- 13. you.
( 14 MR. MUNROE: We33, thank you very much. It's 15 5:00 o'c l ock, and I believe that's when we were going to 16 end. 17 HEARING ATTENDEE: (Mr. Williams) Bj)3, I 18 would like to say, I sppreciate your time in coming 19 down, and getting us together in these meetings. As you l i 20 mentioned to someone else, I haven't always liked what 21 I'veheard, but at 3 east I think we are a 3 3 get ting the 22 same word, and getting it concurrently, and maybe we 23 understand it better. ; 24 MR. MUNROE: Thank you for coming. ! 25 (Whereupon the above captioned matter concluded.) i
1-CERT I F I CATE 2 STATE OF GEORGIA ; 3 COUNTY OF FAYETTE 4 T,.Delana K. Bruce, certifled Court Reporter l 5 and Not a ry Pub 1'i c, in and for the State of Georgia at i 6 Large, do hereby certify that the foregoing proceedings 7 were taken down by me, as stated in the caption, and the 8 questions and the answers thereto were. reduced to 9 typewriting by me; that the foregoing pages represent a 10 true and correct transcript of the evidence given by the. 11 witnesses, who were fArst duly sworn; that I am not a j 12 relative, employee, attorney or counsel for any of the 13 parties; am not a relative or employee of attorney or l 14 counse] for any of said parties; nor am I financia 3 3 y j 15 interested in the action, t 16 This, the 12th day of A p r i .1 , 1987. I 17 18 ) 19 C( I 20 De3ana K. Bruce, B-798 Notary Public { 21 My Commission Expires: l g December 4, 1990 ) l 23 24 l 25 1 _ _.______________ _ _ _ _ _ _ _}}