NRC Generic Letter 1987-16
MEMORANDUM FOR: NRR Project Managers FROM: Frank J. Miraglia, Jr.
Associate Director for Projects Office of Nuclear Reactor Regulation SUBJECT: TRANSMITTAL OF NUREG-1262, "ANSWERS TO QUESTIONS AT PUBLIC
MEETINGS REGARDING IMPLEMENTATION OF TITLE 10, CODE OF
FEDERAL REGULATIONS, PART 55 ON OPERATORS' LICENSES",
GENERIC LETTER 87-16 Enclosed is Generic Letter 87-16 which transmits NUREG-1262. NUREG-1262 represents office practices and policies on how the staff will implement the rule governing Operators' Licenses and Conforming Amendments (10 CFR 55 and
50). The views expressed in the report are intended as guidance, and are meant to reflect the rule and its statement of considerations. The views are not intended to interpret the rule or any of its provisions, nor does the document increase or decrease any requirements of the rule.
The generic letter does not require that any actions be taken by the Project Managers; it is being distributed for information only.
Frank J. Miraglia, Jr.
Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
Generic Letter 87- DISTRIBUTION:
Central Files OLB Reading JAWachtel LAWiens JNHannon JWRoe FJMiraglia RStorostecki T R
OFC :ADTi -:ADRMRR . : :
_____~~-
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NAME :RStar5 tecki:FMi gla : :a DATE :12N E87 :11/ &87
_ .
- 2- In addition to the above changes from the original answers described in NUREG-1262, as of the date of this letter NRC involvement in requalification examinations is under review, and changes to the guidance presented at the public meetings is being considered. Therefore, answers given in the section titled "Requalification and Renewal' should be considered subject to change.
If you have any questions, you should contact the NRC Project Manager for your facility.
Sincerely, Original SI..., hr Vi~2 J. ., ,I r Frank J. Miraglia Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
NUREG 1262 DISTRIBUTION:
Central Files JAWachtel LAWiens JNHannon JWRoe FJMiraglia RStarostecki A4AleA "? 0S4o
7 e-7,1-4 .
DW/nereg 1262/JERRY3 OLB:DLPQ OLB:DLPQ OLB:DLPQ* DIR:DLPQ ADI .NRR
JAWachtel :kw* LAWiens JNHannon JWRoe* R~tarostecki * ~lia
9/28/87 9/28/87 9/29/87 10/7/87 lq/q /87
- See previous concurrences OFFICIAL RECORD COPY
UNTED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON. D. C. 055 November 12, 1987 TO ALL POWER AND NON-POWER REACTOR LICENSEES AND APPLICANTS FOR LICENSES
Gentlemen:
SUBJECT: TRANSMITTAL OF NUREG-1262, "ANSWERS TO QUESTIONS AT PUBLIC
MEETING REGARDING IMPLEMENTATION OF TITLE 10, CODE OF
FEDERAL REGULATIONS, PART 55 ON OPERATORS' LICENSES"
(GENERIC LETTER 87-16)
On March 25, 1987, the Commission published a final rule governing Operators'
Licenses and Conforming Amendments (10 CFR 55 and 50), with an effective date of May 26, 1987. From April 9 to April 20, 1987, the staff conducted a series of four public meetings to discuss the implementation of this final rule, associated Regulatory Guides, and Examiner Standards. These meetings were announced via Generic Letter 87-07, which also transmitted an advanced copy of the final rule.
The purpose of the meetings was to discuss the implementation of the requirements of the rule and related issues. At each meeting, a formal presentation by the staff was followed by an open forum in which the staff responded first to questions that had been submitted in writing in advance of the meeting, and then to questions raised from the floor. Announcements were made at each meeting that any questions that remained unanswered at the conclusion of the meeting could be left with the staff in writing for a subsequent response;
and that the questions and answers from all of the meetings would be consolidated in a NUREG and disseminated to interested parties.
Accordingly, verbatim transcripts of each meeting were made, and these questions and answers, together with those submitted at the close of each meeting, were collected and edited as NUREG-1262. This NUREG is appended to this letter.
NUREG-1262 represents office practices and policies on how the staff will implement the rule. The views expressed in the report are intended as guidance, and are meant to reflect the rule and its statement of considerations. The views are not intended to interpret the rule or any of its provisions, nor does the document increase or decrease any requirements of the rule.
The preface to the NUREG states that NRC staff discussions held since the final public meeting indicated several areas in which the answers given might have been misconstrued or subject to misinterpretation. It goes on to state that any such answers were revised during preparation of the NUREG, and that such answers were identified in the report by an asterisk next to the question number.
-2 -
In addition to the above changes from the original answers described in NUREG-1262, as of the date of this letter NRC involvement in requalification examinations is under review, and changes to the guidance presented at the public meetings is being considered. Therefore, answers given in the section titled "Requalification and Renewal" should be considered subject to change.
If you have any questions, you should contact the NRC Project Manager for your facility.
Sincerely, Frank .iragli r.
Associate Director for Projects Office of Nuclear Reactor Regulation Enclosure:
%7<iROUTING AND TRASMITIAL SUP .9/26/87 T (Name, ofiesymbol, roo b Initi s Dat bUilding. Agency/Post) mnmDt I. Jerry Wachtel - Concurrence_-c
2.3 Len Wiens - Concurrence .q
'- . John Hannon - Concurrence
4. Jack Roe-- Concurrence- S._Rich Starostecki - Concurrence
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Coordintio Investigate Signature
-6.Frank Miraglia - Concurrence/Sigature Susie. -
. t3fctk- ei s SUBJECT:. TRANSM!ITTAL-OF NUREG 1262,
"ANSWERS TO
-QUESTIONS AT PUBLIC MEETINGS REGARDING.
-
IMPLEMENTATION OF TITLE 10, CODE OF
-FEDERAL REGULATIONS, PART 55 ON1OPERATORS'
LICENSES"t J
DO NOT use this form as a RECORD
(N me. rg. lear nces and similar actions FROM: (Name, Org. sYmbol. Agency/Post) Room No.-Bldg.
. .Jerry Wachtel. ;.>- 0fp-83>1-:
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NUREG-1262 uniwedwML rDaled.JA
- Answers to Questions at Public Meetings Regarding Implementation of Title 10,
Code of Federal Regulations, Part 55 on Operators' Licenses U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation
~p~RE:
. - .
NOTICE
Availability of Reference Materials Cited In NRC Publications Most documents cited in NRC publications will be available from one of the following sources:
1. The NRC Public Document Room, 1717 H Street, N.W.
Washington, DC 20555
2. The Superintendent of Documents, U.S. Government Printing Office, Post Office Box 37082, Washington, DC 20013-7082
3. The National Technical Information Service, Springfield, VA 22161 Although the listing that follows represents the majority of documents cited in NRC publications, It is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Docu- ment Room include NRC correspondence and internal NRC memoranda; NRC Office of Inspection and Enforcement bulletins, circulars, information notices, inspection and Investigation notices;
Licensee Event Reports; vendor reports and correspondence; Commission papers; and applicant and licensee documents and correspondence.
The following documents in the NUREG series are available for purchase from the GPO Sales Program: formal NRC staff and contractor reports, NRC-sponsored conference proceedings, and NRC booklets and brochures. Also available are Regulatory Guides, NRC regulations In the Code of Federal Regulations, and Nuclear Regulatory Commission Issuances Documents available from the National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
Documents available from public and special technical libraries include all open literature items, such as books, journal and periodical articles, and transactions. Federal Register notices, federal and state legislation, and congressional reports can usually be obtained from these libraries.
Documents such as theses, dissertations, foreign reports and translations, and non-NRC conference proceedings are available for purchase from the organization sponsoring the publication cited.
Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Division of Information Support Services, Distribution Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555.
Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available there for reference use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards Institute, 1430 Broadway, New York, NY 10018.
NUREG-1262 Answers to Questions at Public Meetings Regarding Implementation of Title 10,
Code of Federal Regulations,
.Part 55 on Operators' Licenses Manuscript Completed: June 1987 Date Published: November 1987 Division of Licensee Performance and Quality Evaluation Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
ABSTRACT
This document presents questions and answers based on the transcripts of four public meetings (and from written questions submitted after the meetings)
conducted from April 9 to April 20, 1987 by the staff of the U.S. Nuclear Regulatory Commission. The meetings discussed implementation of the Commission's final rule governing Operators' Licenses and Conforming Amendments (10 CFR
Parts 55 and 50). The rule became effective May 26, 1987 and is intended to clarify the regulations for issuing licenses to operators and senior operators;
revise the requirements and scope of written examinations and operating tests for operators and senior operators, require a simulation facility; clarify procedures for administering requalification examinations; and describe the form and content for operator license applications.
iii
TABLE OF CONTENTS
-Page S R C
A ............. . . . . . . . . .. . . . . .. . iii PREFACE ............................................................. vii INTRODUCTION . ............... .. ix ACRONYMS AND INITIALISMS .................... xvi GENERAL ISSUES PERTAINING TO 10 CFR PART 55 .......................... 1 Background to the Regulation .................................... 1 Definitions (Subpart A, Section 55.4) ........................... 3 Communications (Subpart A, Section 55.5) . 3 General 'Exemptions (Subpart B, Section 55.13). 4 APPLICATIONS ...................... .. .... ..... ..................... 7
-How to Apply (Subpart'D, Section 55.31; NRC Form'398) .............
Medical Examination (Subpart C, Section 55.21) .................. 18 Certification (Subpart C, Section 55.23; NRC Form 396) .......... 19 Incapacitation Because of Disability or Illness (Subpart C,
Section 55.25) 21 Documentation (Subpart C, Section 55.27) ........................ 22 Regulatory Guide 1.8 and ANSI/ANS 3.1 ......... . 22 WRITTEN EXAMINATIONS AND OPERATING TESTS ......................... 31 General Issues (Including Learning Objectives and Examination Question Bank) ........... ' 31 Written Examinations and Operating Tests (Statement of Considerations) ............................................... 33 Written Examination: Operators (Subpart E, Section 55.41) ....... 35 Written Examination: Senior Operators (Subpart E, Section
55.43) ................... ............ 38 Operating Tests: Content (Subpart E, Section 55.45(a)) ......... 40
Waiver of Examination and Test Requirements (Subpart E,
Section 55.47) ................................................ 41 SIMULATION FACILITIES ................................................ 42 Written Examinations and Operating Tests: Implementation (Subpart E, Section 55.45(b)) ................................. 42 Regulatory Guide 1.149 .......................................... 50
ANSI/ANS 3.5, 1985 .............................................. 52 Simulation Facility Certification (Including Performance Testing, NRC Form 474, NUREG-1258) ............................ 55 v
TABLE OF CONTENTS (Continued)
Page LICENSES ............................................................. 68 Special Senior Operator Licenses (Including Instructor Certification) ........................................ 68
"Actively Performing the Functions of an Operator or Senior Operator" . .................................................... 71 Conditions of Licenses (Subpart F, Section 55.53) ..... .......... 73 REQUALIFICATION AND RENEWAL ........... ................................. 82 Requalification and Renewal (Statement of'Considerations) ....... 82 Renewal of Licenses (Subpart H, Section 55.57) ..... ............. 82 Requalification (Subpart H, Section 55.59) ...................... 88 CONFORMING AMENDMENTS IN 10 CFR PART 50 ... 115 OPERATOR LICENSING EXAMINER STANDARDS (NUREG-102i).117 REFERENCES ........................................................... 122 APPENDICES
A Generic Letter 87-07 .A-1 B 10 CFR Parts 50 and 55 -- Operators' Licenses and Conforming Amendments .B-1 C Regulatory Guide 1.134 -- Medical Evaluation of Licensed Personnel for Nuclear Power Plants .C-1 D Regulatory Guide 1.149 -- Nuclear Power Plant Simulation Facilities for Use in Operator License Examinations. D-1 E Regulatory Guide 1.8 -- Qualification and Training for Personnel for Nuclear Power Plants .E-1 vi
1%-)
I PREFACE
On March 25, 1987, the U.S. Nuclear Regulatory Commission published in the Federal Register (52 FR 9453) revisions to 10 CFR 55 to meet NRC responsibili- ties under Section 306 of the Nuclear Waste Policy Act of 1982. The rule, Operators' Licenses and Conforming Amendments, became effective on May 26, 1987 and is intended to:
1. clarify the regulations for issuing licenses to operators and senior operators;,.
2. revise the requirements and scope of written examinations and operating tests for operators and senior operators;
3. require a simulation facility;
4. clarify procedures for administering requalification examinations;
and,
5. describe the form and content for operator license applications.
From April 9, 1987 to April 20, 1987, the NRC staff held four public meetings to discuss implementation of the requirements of this rule and related issues.
Those attending asked numerous questions which the staff answered. This docu- ment presents the answers to those questions taken from the transcripts of the four meetings, as well as to written questions which were submitted at the con- clusion of the meetings. The-questions are grouped to eliminate excessive duplication. However, where different questions addressed similar concerns, they were retained in this report if they provided clarification or a different perspective. Questions related to Regulatory Guides, industry standards, and other documents associated with the rule are included with the applicable por- tion of the rule.
This report attempts to retain the intent, tone, and nuance of each question without reproducing each verbatim from the transcripts. In-some cases, ques- tions submitted or recorded by the transcriber contained unintended or inad- vertent factual errors. When identified, these errors were corrected. Simi- larly, verbatim answers in the transcripts have been edited where necessary for clarity and conciseness.
NRC staff discussions held since the final public meeting indicate that the answers provided to questions in the area of "Conditions of Licenses," spe- cifically the proficiency requirements in 10 CFR 55.53(e), may have conveyed the impression that the staff advocated minimum shift staffing, and that this might have been-construed to be counterproductive to safety. The apparent confusion stems from the definition of "Actively performing the functions of an operator or senior operator" in Section 55.4 of the regulation, which appears to tie the proficiency issue to a minimum staffing requirement in the facility licensee's technical specifications. 'The intent of the 10 CFR 55.53(e)
requirements regarding maintenance of active operator or senior operator status is that personnel maintain proficiency by actively performing the functions and duties of the licensed operator positions. Because facility licensees assign to a shift more than the minimum number of operators required by their Techni- cal Specifications, concerns have been raised since the public meetings that vii
10 CFR 55.53(e), if implemented in the manner discussed at these meetings, might discourage utilities from augmenting shift crews.
It is not NRC's intent to discourage augmenting shift crews; clearly, this.
practice can result in a significant safety enhancement. However, assigning a large number of operators to a shift could reduce the range of responsibili- ties of any one operator to a level where sufficient experience in directing -
shift operations and/or in manipilating controls is not being obtained. NRC's intent in 10 CFR 55.53(e) is that operators taking credit for watchstanding on shift to maintain an active license engage meaningfully and fully in the func- tions and duties of the positions required by the Technical Specifications.
The intent is not to have licensees augment a shift with a contingent of opera- tors whose main purpose is to acquire the minimum number of watches to meet
10 CFR 55.53(e) requirements. Their role is to fulfill the duties that the facility licensee judges are necessary and prudent for safe operations.
Facility licenses can take credit for more than the minimum number of watch- standers required by Technical Specifications provided that there are admini- strative controls which assure that functions and duties are divided and rotated in a manner which provides each watchstander meaningful and significant oppor- tunity to maintain proficiency in the performance of the functions of an opera- tor and/or senior operator as appropriate. Normally, more than one additional watchstander at each Technical Specification position would not be considered acceptable with respect to the proficiency issue.
Any answers to questions on this subject that were raised during the public meetings, and which might have conveyed the impression that NRC advocated such minimum shift staffing, have been revised in this report to reflect the staff's position as clarified above. Such answers'are identified in'this report by an asterisk next to the question number.
Similarly, NRC staff discussions held during the preparation of this report have identified a number of answers given during the public meetings which either mis- stated an NRC policy or may have been open to misinterpretation. These answers have been revised for this report and are identified by an asterisk next to the question number.
The views expressed in this report represent office practices and policies on how the staff will implement the rule. These views are intended as guidance and are meant to reflect the rule and its statement of considerations. The views expressed are not intended to interpret the rule or any of its provisions. Al- though any request for formal interpretation should be sought from the Office of General Counsel under 10 CFR 55.6, the NRC staff may provide informal guidance as needed and as appropriate. This report does not impose any requirements on facility licensees nor does it replace or supersede any existing regulations.
II INTRODUCTION
This rule (10 CFR 55) represents a significant move toward less prescriptive regulatory requirements for utilities that have accredited training programs and acceptable simulation facilities. It attempts to differentiate clearly between training programs sponsored through industry initiatives by the Nuclear viii
Utility Management and Resources Committee (NUMARC) and the Institute for Nu- clear Power Operations (INPO), and Nuclear Regulatory Commission (NRC) licens- ing and examination requirements. One of the most important changes to the regulation is the flexibility it affords licensees in reviewing the content of continuing training (requalification) programs, and tailoring those programs to the needs of the job incumbents. This degree of flexibility represents a major change from the way NRC has implemented regulations in the past in that it relies on industry initiatives to provide both training and qualifications for license applicants. With this rulemaking NRC has moved out of the area of specifying training'program content and qualifications 'for instructors.
INPO Accreditation It is a precedent-setting move, and NRC is pleased that the industry has taken this initiative to improve its training of licensed operators and others.
Although moving out of the training areas potentially leaves a void, particu- larly as it relates to some of the more prescriptive requirements used in the past, NRC has placed great importance in the INPO accreditation process. In
- its review of INPO accreditation criteria, the staff has concluded that they are equivalent to NRC's. If a utility implements an accredited training pro- gram, the accreditation will constitute the basis for NRC acceptance of that certification from a responsible utility officer, as indicated in Generic Letter 87-07.
The Appeal Process NRC is also implementing a change to the appeal process for operator license
candidates to clarify the process. The following figures describe the proposed appeal' process.
Figure 1. NRC's appeal process has always permitted both informal reviews and hearing rights on issues which were in dispute between the candidate and the examiner.' Informal reviews were conducted by regional management and, when requested,-further review was conducted at NRC headquarters. The exercise of hearing rights, described in 10 CFR Part 2 of the Commission's regulations, becomes operable should there be a license application denial.
Figure 2.- Informal reviews and hearing rights are available to the candidate for any adverse action, whether for a failure of the written examination or operating test, or for an application rejected for other reasons. The informal review will go first to the regional Division Director responsible for the operator licensing function, and then, should the candidate so choose, to the Director, Division-of Licensee Performance and Quality Evaluation (DLPQE).
In the past, on occasion,'NRC has not completed action on appeals in a timely manner and, in some cases, candidates have not submitted information that is necessary to review an appeal.. We have tightened up the schedule by allowing
20 days for the candidate to decide to appeal and 30 days for informal manage- ment review..'
Figure 3. Those schedules will work as follows. The day that the candidate gets the notification letter of a failure or notification of a rejected appli- cation, we have called day zero. He has 20 days to decide whether to request an informal review.
ix
If the candidate does not act within that 20-day period, the notification letter automatically converts to a Proposed Denial of License Application, which will avail him of-hearing rights under 10 CFR Part 2 of the Commission's regulations.
If he requests an informal review, he submits the information to the responsible regional division director, who reviews it, and either sustains or overturns the examination failure or the rejected application.
If it is sustained such that the situation is still adverse to the candidate, he may, then, request another informal review. The-second letter he received would, in the manner similar to the first, become a proposed denial after
20 days. If, during the 20-day period after he receives the letter from the regional Division Director, he decides to ask for an informal review, he sub- mits the requested information to the Director, DLPQE, where another review of the merits of his contentions would be conducted.
If the candidate's examination failure or application rejection is sustained, a Notice of Proposed Denial of License Application will be issued. The candidate can then request a hearing under 10 CFR Part 2.
When a Proposed Denial has become effective, the applicant can choose to accept the Proposed Denial, waive his hearing rights, and have the denial become final.
It takes an affirmative action by the candidate to waive his hearing rights through an NRC form letter which provides information about the date of his examination, his docket number, and the like. He simply signs the letter and returns it to NRC.
Or, the applicant may request a hearing. In order to implement the hearing process, he would have to notify the NRC Office of General Counsel. The Exam- iner Standards will contain sample letters and procedures that describe this process. The 80-day time frame for this process does not include mailing time.
We will be using certified mail, request return receipts, and will place the correspondence associated with the appeal in the docket file.
In addition, we will provide copies of all relevant correspondence to the facil- ity licensee's authorized representative who signed the application. This will be done at the time we mail it out to the individual. The reason for this is that the authorized representative is a part of this process, in that he cer- tified the completion of training. Further, the facility reviewed a written exam and provided comments on the exam and the answers.
Figure 4. This figure shows the proposed denial/hearing process, beginning with the administration of the examination. NRC will complete the grading, make an initial determination within 30 days, and mail the results to the candidate.
If the candidate requests an informal review, he must send in a complete infor- mation package to the responsible regional division director. He has 20 days to decide to make the request, and 10 more days to submit the information. The regional division director would review the submittal and make a determination within 30 days. If the regional division director sustains the failure or the application rejection, the candidate could at that point request an informal review by the Director, DLPQE, a hearing, or accept the results. If the candi- date accepts the results, NRC would issue a final denial and put it into his x
docket file. After the required length of time from the date of final denial (immediately in the case of an application denial) he could start the reappli- cation process.
Alternatively, if the candidate requests an informal review by the Director, DLPQE, he must submit the requested information within the prescribed time.
The Director, DLPQE, would make a determination within 30 days. If the Direc- tor sustains the failure or the application rejection, NRC would issue a pro- posed denial. At that time the candidate would have the option of requesting a hearing or accepting the results.
This process is more formal than past practice. A candidate may not reapply under the provisions of 10 CFR 55.12 until he has a final denial in hand. The only way he can get a.final denial is either to agree with the staff's proposed denial, waive his hearing rights and accept the outcome, or go to hearing, where an independent determination will be made in his case. The types of hearings under Part 2 may vary from informal to formal adjudicatory hearings. It is the candidate who controls the process. It is the staff's responsibility to ensure that the candidate understands his rights. E
The review process-as outlined is currently under staff review for ways in which it can be expedited.
xi
INFORMAL APPEAL PROCESS AND HEARING
RIGHTS
Can be stopped at any point by candidate accepting
(
proposed denial and waiving hearing rights.
Candidate may reapply following examination failure only after application finally denied under 10
CFR 55.35.
- Candidate accepts Proposed Denial
- Hearing decision - Final Denial Candidte may reapply at any time for rejection of
(
application for reasons other than examination failure.
Figure 1
INFORMAL APPEAL PROCESS AND HEARING RIGHTS
Process has been -clarified to assure candidate understands his rights Applicable to any decision by the staff adverse -
to the candidate x.
Applicant always has :the right to 'request
- -informal regional management review X- informal headquarters management review
- formal hearing before an administrative judge Schedule specified to ensure timely action upon C
informal review
- 20 days for candidate to decide
- 30 days for informal review Figure 2
INFO:RMAL APPEAL
A _
PROCESS
L _A_
AP_S AND
AND _P HEARING
. .P_.% .S. P I C:: HT
W.-.
a a I
0 DAYS Notification of Examination failure or Application rejection
+ 20 DAYS Request informal review by Region
(
X + 60 DAYS Notification of Region's review results
+ 80 DAYS Request informal review by Headquarters
+120 DAYS Notification of Proposed License Denial c
+140 DAYS Request for Hearing NOTE: Does not include mailing times Figure 3
Figure 4 PROMED LWCMS! *NzAMU1fAi "s
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ACRONYMS AND INITIALISMS
ANS American Nuclear Society ANSI American National Standards Institute BOP Balance of Plant BWR Boiling Water Reactor CE Combustion Engineering CRD- Control Rod Drive.
DLPQE Division of Licensee Performance and Quality Evaluation EOP Emergency Operating Procedure ES Examiner Standard FSAR Final Safety Analysis Report GE General Emergency IE Office of Inspection and Enforcement (NRC)
INPO Institute of Nuclear Power Operations K/A Knowledge and Abilities LER Licensee Event Report NLO Nonlicensed Operator NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation (NRC)
NTOL Near-Term Operating License NUMARC Nuclear Utility Management and Resources Committee OJT On-the-Job Training OMB Office of Management and Budget PWR Pressurized Water Reactor Reg Guide Regulatory Guide RG Regulatory Guide Requal Requalification RO Reactor Operator RWP Radiation Work Permit SAE Site Area Emergency SAT Systematic (or Systems) Approach to Training SFEP Simulation Facility Evaluation Procedure SRO Senior Reactor Operator STA Shift Technical Advisor Tech Specs Technical Specifications TSD Training System Development UE Unusual Event xvi
GENERAL ISSUES PERTAINING TO 10 CFR PART 55 Background to the Regulation Q. 1. The Supplemental Information to NRC Generic Letter 87-07 states that,
"These rules supersede all current regulations for operator licenses." Are training requirements from Mr. H. R. Denton's March 28, 1980 letter superseded by the new rule?*
A. The rule supersedes all requirements where those requirements are less restrictive. Where individual commitments are more restrictive, you must fol- low those commitments until you change them.
In some cases that change may require an amendment to the license. In other cases it can be done by yourself under 10 CFR Part 50.59, and you simply inform us of what you're doing. That would include any change within your authority to do under Part 50.59 that does not constitute a reduction in the effective- ness of the program, because it's being done to conform to the rule. Addition- ally, as a matter of-interest, we are no longer, under the rule, permitted to certify instructors.
Q. 2. Will the revision to 10 CFR 55 cancel NUREG-0737, NUREG-0094, and the Denton letter? If so, will references to these documents be removed from NUREG-1021?
A. NUREG-1021, "Operator Examiner Licensing Standards," has been reviewed and the items left are required by the Regulation, or by Regulatory Guide 1.8. The items from NUREG-0737 and NUREG-0094 that are superseded have only to do with operator licensing. Items from Regulatory Guide 1.8 Revision 2, will be incor- porated into NUREG-1021 when Regulatory Guide 1.8 becomes effective on March 31,
1988. Some items may be very similar to what was there in the past, due to NUREG-0737 or NUREG-0094."' For'example, four years of power plant experience are incorporated into NUREG-0737 andbDenton's letter, and it's still in Regulatory Guide 1.8 and NURtG-1021.
Q. 3. Is it true that the NUREG-0737 requirements being incorporated in 10
CFR Part 55 are only those that relate to operator training and licensing?
A. The requirements pertain only to operator licensing, not training.
Q. 4. We also make commitments in NUREG-0737 for training and mitigating core damage of other work groups. Also, there is training related to STAs. For in- stance, Reg Guide 1.8 talks'about the number of shifts that an STA must serve.
So, nothing in this regulation affects these commitments even though there is some reference to it?
A. Yes, that's correct. It does not modify those prior commitments regarding training for STAs and other work groups.
- H. R. Denton, NRC, Letter to All Power Reactor Applicants and Licensees.
Subject: Qualification of Reactor Operators,. March 28, 1980.
Q. 5. If NUREG-0737 is still applicable in areas not applicable to regulations for operator licenses, are you going to publish a NUREG that supersedes NUREG-0737 in those areas?
A. No, we'll not issue a new NUREG that applies to the areas that have not been superseded.
Q. 6. Are experience requirements in NUREG-1021 for the RO and the SRO super- seded by this change?
A. No. NUREG-1021 will be revised to'reflect the'changes that have been adopted in ANSI 3.1 as endorsed by Regulatory Guide 1.8. We anticipate these changes will be made in about one year.
Q. 7. Can licensees file an FSAR amendment for Commission approval to modify existing initial licensing and requalification'training programs?
A. Yes. See Generic Letter 87-07 for guidance on how to file such FSAR
amendments.
Q. 8. What other means are available for filing for program changes?
A. You can write a letter and say that you have substituted an accredited training program, which is performance-based, for the previously NRC-approved program, and indicate the date(s) your new program was accredited. See Generic Letter 87-07 for further guidance on how to submit such a letter.
Q. 9. Our FSAR commits us to ANSI/ANS-3.1-1978.
A. Recall that this Regulation and associated documents supersede all prior requirements. The rule identifies the Regulatory Guides that are part of the rulemaking package. The implementation of Reg Guide 1.8, which endorses, with exceptions, ANSI/ANS 3.1, 1981, takes effect March 31, 1988, to allow for a phase-in period.
Q. 10. Will we do anything different in the inspection of requalification ac- tivities due to the end of the two-year moratorium in INPO accreditation? Has the new rule been timed to coincide with the end of the two-year period?
A. This issue is currently under advisement by the Commission. No decision has been made to date. Publication of the regulation was independent of the two-year period.
Q. 11. Is failure to meet an INPO program requirement that was in the benchmark- accredited program grounds for issuance of a Notice of Violation?
A. Failure to meet INPO Guidelines, or loss of accreditation status through action taken by the National Nuclear Accreditation Board, will result in further evaluation by NRC. Such failure in itself would not be grounds for a Notice of Violation. However, per the "Policy Statement on Training and Qualification of Nuclear Power Plant Personnel" (50 FR 11147), "Nothing in this Policy State- ment shall limit the authority or responsibility of the NRC to follow up on operational events or place any limit on NRC's enforcement authority when regulatory requirements are not met."
Definitions (Subpart A, Section 55.4)
Q. 12. Why did you change terms from "reactivity manipulations" to "control manipulations?"
A. For the purposes of Part 55, "controls" refers to the controls that affect reactivity or power.
Q. 13. By what means are utilities to determine NRC's interpretation of "refer- ence plant" as it applies to multi-unit plants at one site (from the same vendor and vintage)? It seems that compliance with Part 55 is contingent on a clear interpretation of this term.
A. The definition of "reference plant" has been provided in Section 55.4 of the regulation. Section D, which is the implementation section of Regulatory Guide 1.149, provides clear guidance for the use of one simulation facility for more than one plant or unit, since each plant has a unique docket number.
The greater the similarity between the units, of course, the more likely it is that you'll be able to submit one certification form for each, identifying any exceptions as necessary against ANSI/ANS-3.5.
If your operators are dual-licensed, certification,. with exceptions, would be considered satisfactory for multiple units or plants. If your operators are not dual-licensed, it is still possible to certify with exceptions, although more work may need to be done to justify acceptability of the simulation facility for the conduct of operating tests.
Q. 14. In the discussion of the term, "plant-referenced simulator," mention was made of the simulator being required to use controlled copies of procedures?
What do you mean by the word control?
A. Controlled copies refers to procedures that are identical to those you use in the control room of the plant, and are maintained current through adminis- trative control.
Q. 15. Do they necessarily have to be up to date to the minute or to the hour?
A. We expect them to be up to date.
Q. 16. As far as the references go?
A. Yes.
Q. 17. Revisions?
A. Yes.
Communications (Subpart A, Section 55.5)
- Q. 18. Section 55.5(b)(2)(iv) states that applications and correspondence should be submitted to the Regional Administrator. Should copies be submitted to the Regional Section Chief for Operator Licensing?
A. No. Copies of applications and correspondence under Section 55.5 need not be sent to the Regional Section Chiefs.
Q. 19. Is Form 474 to be submitted directly to the Director of the Office of Nuclear Reactor Regulation (NRR) in Washington, D.C., as opposed to Regional Administrators?
A. Yes. We made a conscious effort to ensure that Form 474 certifications and the applications for approval be submitted to NRR at Headquarters. Offi- cially, they should be filed in accordance with 10 CFR Part 50.4, which spe- cifies that those submittals go to ATTN: Document Control Desk, Washington, DC 20555.
Q. 20. Who specifically receives the certification referred to in Generic Letter 87-07, the region or headquarters?
A. Generic Letter 87-07 describes the form of notification to the NRC, which basically is a letter telling us that you have an INPO-accredited program, or an otherwise systematic approach to training at your facility. That submittal is made to NRC Headquarters in accordance with 10 CFR 50.4. It comes to the Director of the Office of Nuclear Reactor Regulation, and is to be submitted in accordance with 10 CFR 50.4, ATTN: Document Control Desk, Washington, DC 20555.
Q. 21. 10 CFR 50.4 is explicit regarding written communications and volume reduction; however, this part of the regulation seems to be inconsistent with
55.5. Which regulation do we follow?
A. For communications concerning 10 CFR 55, licensees should follow 55.5.
General Exemptions (Subpart B, Section 55.13)
Q. 22. With regard to Section 55.13, can you clarify the intent behind these exemptions?
A. Yes. There are certain skills and knowledge that an operator must have, for example, to perform a reactor start up. Hopefully, he would understand some reactor theory, the effects of subcritical multiplication, and other as- pects of the controls he is manipulating.
If the candidate has not completed those phases of training, he should not per- form reactor startup, whether or not it's included in the instruction. That's the concept. Now, if in your program, information is transmitted to him such that he is prepared to perform the funct'ion because he understands what he is doing -- he has either had the systems training, or he's had the theory train- ing, or he's gotten it in some other earlier program, such that you are assured that the sequence of training is appropriate and the potential for him making an error is small--then the exemption applies.
We don't want to repeat an event which occurred a few years ago where an in- dividual performed a startup soon after entering training. They had a high startup rate, short-period transient, and the individual did not understand what he was doing. He had no appreciation for the procedure because he had not received the appropriate on-the-job training for the evolution. There were NUREG-1262 4
two concerns with that event: First, they put the plant at risk because some- one manipulating the controls didn't know what he was doing and, second, they provided negative training.
The sequence of training that leads to on-the-job-performance is important.
That approach is consistent, by the way, with the INPO accreditation process and criteria. If you look at the objectives in INPO 85-002 for on-the-job training, you will find that they intend that the person adequately understand the task before performing it.
Q. 23., Can trainees manipulate facility controls under the appropriate super- vision of licensed personnel?
A. If their training program leads to a license if carried to completion, they may manipulate controls under instruction if they have been properly trained. Properly trained means that the sequence of training that has led them up to that point is appropriate for the manipulations they perform.
Q. 24. In Section 55.13, Item 1, are you using training and education interchangeably?
A. No. Students at test or research reactors receive training on a reactor as part of a course of study to further their education. They may manipulate controls as a part of that course of instruction.
Q. 25. With respect to Section 55.13, is someone who is in a course, but from a visiting institution, considered a student? Would a group of high school students visiting a university for a couple weeks to familiarize themselves with the school be considered students; that is,could I sit them down at the control panel and tell them what steps to go through to operate the panel?
A. Both groups are considered students. There are colleges and universi- ties that have exchange programs with high schools and other institutions where you bring students in to attend courses. If these students attend some part of classroom training, and as a part of that activity they manipulate the controls, then that's part of their instruction as students.
We want to avoid the situation where an individual comes in off the street without any training and starts manipulating the controls.
Q. 26. If the facility career path program considers all nonlicensed operators to be license candidates, can nonlicensed operators manipulate the controls under the direction and in the presence of the reactor operator's senior opera- tor if the candidate is not currently in a hot licensed class?
A. No. The candidate must officially be enrolled in the hot license class.
Simply being a nonlicensed operator on a designated career path is not suffi- cient to meet the intent without being enrolled in the hot license class.
More importantly, the candidate must have completed the necessary classroom or simulator training in accordance with the appropriate training sequence prior to manipulating the controls of the facility.
Q. 27. If the operator is in a licensing class, has completed the classroom and the simulator portion, and has an opportunity to take part in an unplanned evolution, can he receive credit toward the training program for that participation?
A. Yes.
Q. 28. Is a senior operator license required to move fuel in a dry storage area, or away from the reactor vessel?
A. The Regulation doesn't specifically talk about the dry storage area or the refueling pool. It specifically talks about moving fuel in and out of the vessel. If there is a potential for criticality, a senior operator would be required to be there, as in some instances in a refueling pool. If not, no.
Q. 29. Can the licensed senior operator who supervised fuel handling be a senior operator licensed for fuel handling only?
A. Yes.
t it,P;L. , .T
APPLICATIONS
How to Apply (Subpart D, Section 55.31; NRC Form 398)
Q. 30. For a person who has dropped his license, what, if anything, must be done to later upgrade his status to an SRO beyond meeting the requirements of an accredited SRO training program?
A. He must submit completed Forms 398 and 396 and be examined as an SRO.
Q. 31. Has Form 398 changed?
A. Not yet, but'a change is in process. It is scheduled to be available for ordering by the end of May 1987.
Q. 32. Will the current Regional requirements for complete licensee history on Form 398 for license renewal be reduced to the data included in the OMB
approval, 8150-0090?
A. If you have an INPO-accredited program with an acceptable simulation facility (approved or certified), you can eliminate giving us information under blocks 11, 12, and 13, with the exception of the five significant control mani- pulations. Those still must be included.
For renewal, the same rules would apply; there is a block specifically on the Form for renewal. You will only have to provide information on candidate train- ing, education, and experience dating from that last application for a license renewal.
There will be a block on the Form 398,to indicate the number of on-shift hours, or the experience that has been received. That's all you will have to provide if you meet the two other criteria, i.e., having been INPO accredited, and hav- ing an acceptable simulation facility. If you do not meet these two check points, then you will have to provide the additional data on training, educa- tion, and experience.
Q. 33. On Form 398, since test and research reactors don't have simulators, are we required to completely fill out the form?
A. What you are currently. doing will continue to be acceptable. For all test and research reactors, there is no change to the process except in terms of license operators being re-examined during the six year license.
Your requalification programs basically stay the same. We still intend for you to use ANSI 15.4 for selection, training, and medical certification. We've also adjusted the requirements for resuming an active license to six hours of parallel watch-standing.
Q. 34. I understand that the designation of the authorized'representative for a facility is changing. Is that true?
A. We will accept, as the authorized representative, the senior individual on site responsible for operations. ISome companies have a vice president on site, some have a site manager. Others may choose to designate someone at a higher NUREG-1262 - 7
level, and send it off site to the corporate office. That is acceptable to us.
It is also acceptable for it to be done on site. It need not be the same authorized representative who requests license amendments under Part 50.
There is, under the facility license, only one authorized representative;
generally that is somebody at the corporate level, a senior vice president. If that is the authorized representative for the facility, that's who signs Part 50
license amendment requests and makes other certifications. We will accept, for Part 55 licensing, the senior person responsible for operations on site.
Please note a new requirement on Forms 396, 474, and 398. Above the signature there is now a statement that any false statement or omission in this document, including attachments, may be subject to civil and criminal sanctions, to the person signing it. The statement says: "I certify, under penalty of perjury, that the information in this document and attachments is true and correct."
That's why we're adjusting the requirement so that the person on site, who's closer to the information, can be absolutely sure when attesting to the accuracy of the information.
Q. 35. Is it the intent of the Commission to limit the number of licensees at a facility to a specific position?
A. No. It is the facility licensee's decision as to whether to have a person in a licensed position or not, and how many of them are needed. We will not question the judgment of facility management.
Q. 36. Is it the NRC's intent that the facility licensee identify organiza- tional positions as needing an NRC Operator License beyond those required by Tech Specs?
A. No. The facility licensee determines the need for whom they want licensed beyond the requirements of the Technical Specifications. However, all indivi- duals who are licensed must be enrolled in the facility licensee's requalifica- tion program.
Q. 37. Does an applicant for a license have to be a member of the shift crew to obtain a license?
A. No. An applicant doesn't have to be a member of the shift crew to obtain it, but the facility must certify that there is a need, for him to have a license.
Q. 38. In answer to the question: "Are experience requirements in NUREG-1021 for the RO and SRO superseded," you said, "no, that there were experience re- quirements that would still apply." Is that still in effect even if you have an accredited program?
A. The accreditation process has its own experience requirements identified within that program. For those facilities which have an INPO-accredited program and a simulation facility acceptable to the NRC, you do not have to designate on the Form 398 those experience requirements for those individuals. You need only check the blocks associated with the simulation facility and the accredited program.
Q. 39. Other than as stated in 10 CFR 55, are there any other requirements that must be included in initial or continuing training programs-for licensed personnel?
A. Yes. All previous'iequirements are in effect-unless superseded by the rule, until the training program is accredited.
Q.--40.' Is accreditation by INPO's National Academy of Training sufficient?
A. As indicated in-Generic Letter 87-07, if it is based on a systems approach to training, it is sufficient. We believe that a program developed following the INPO guidelines for continuing operator training for licensed operators, issued in October, constitutes an'adequate basis for concluding that the pro- gram has been developed in accordance with the systems approach to training.
If you follow that,'and youware accredited, that's sufficient.
Q. 41. Is'the systems approach 'to training development referred to in the new
10 CFR 55 based on the systems approach described in NUREG-1220 or on INPO
standards?
A. It's both. The Commission has specifically endorsed the INPO accredita- tion objectives and criteria as-being a systems approach to training.
NUREG-1220 simply repeats the criteria that are contained in the policy state- ment. It then has subordinate questions that we use for information gathering to determine whether a systems approach to training is in place.
There have been questions in the past about the level of detail we are looking for in some areas. They generally relate to conditions and standards associated with learning objectives and whether you need to develop K/As or not.
We've reached agreement with INPO on that process; on how you're back-fitting existing programs that do not have K/As but have learning objectives.
In general the agreement has been that if it's a new task or new training, it should be developed with K/As. If it's an existing task or training, a panel of subject matter experts (job incumbents) could conclude that the existing training programs adequately cover the material, and therefore,'it need not be back-fit.
Q. 42. Generic Letter 87-07 speaks of substituting an accredited training program for initial and requalification training programs previously approved by NRC. What if the initial training program was never formally approved by the NRC?
A. By virtue of your having been issued a license, your training program, as described in your. FSAR, can be considered NRC-approved. If you subsequently submitted a change to your program for NRC approval, you can assume it was approved, unless NRC has notified you to the contrary.
Q.'43. Is this true even if it's not currently in the updated FSAR?
A. Yes. See Generic Letter 87-07 for guidance on how to revise your current training program to conform to the new regulation.
Q. 44. Programs developed using a systems approach to training are, by intent of the systematic approach, subject to revision on the basis of feedback and input to the system from legitimate sources. Once a training program is accred- ited and appropriate certifications are made to the NRC, do subsequent revisions to these programs need to be certified to the Commission?
A. No. For accredited programs, the particular evaluation, feedback and modification of your program is part of the process. For those programs that are not accredited or SAT-based, then, in accordance with 50.54, you will have to notify the Commission when you make changes that would decrease the scope of that program.
The program of record is the program to be implemented until such time as you change it, whether it be an SAT-based program or an NRC-approved program. We do not intend for the change process to be used after the fact, to justify what training has already been done; that is, a failure to implement your existing program -- you cannot get out of that failure-to-implement loop by going back and changing it after the fact.
Q. 45. Is it the Commission's intention that approved training programs will continue to be approved until accredited, and that the use of the simulators referenced therein will be acceptable for use until May 26, 1991?
A. Yes.
Q. 46. If a facility licensee does not include an approved systems approach to training, can operators be trained and licensed?
A. Yes. Until the program is accredited, they still have to abide by their current approved program, as upgraded by the requirements of the Regulation.
We will still license those individuals.
Q. 47. When the new rule becomes effective, will all training programs pre- viously accredited by the National Nuclear Accreditation Board be considered approved in accordance with the final policy statement on training and qualifi- cation of nuclear power plant personnel?
A. Yes, but for clarification, they won't be approved in accordance with the policy statement; they will be approved in accordance with the regulation, with the intent as expressed in the Statement of Considerations that if you have been accredited by the National Nuclear Accreditation Board, you're considered to have NRC approval.
Q. 48. Will utilities with INPO-accredited training programs be required to submit these programs to the NRC for approval?
A. No. Programs that have been accredited by INPO are assumed to have NRC
approval. All that is needed is an update to your FSAR in accordance with
10 CFR 50.71(e)(4). However, programs must be available for NRC review and inspection on site.
But since it is still Commission approval that you need, there may be cases where an accredited program is not implemented appropriately and, therefore, NRC approval might be removed.
NUREG-1262 10
Q. 49. If the utility has an INPO-accredited operator training program, but does not yet use a simulation facility acceptable to the Commission, will an application that states that the operator training program is accredited by INPO and gives details of the simulator instructions be adequate for the license application?
A.' The Form 398 will have a block on it 'to indicate'whether or not'the appli- cant has graduated from an INPO-accreoited training'program. If the answer is yes, and'the facility has an approved or a certified simulation facility, then the information on education, experience, and training need not be filled out on the Form 398.
On the other hand, if the individual is a graduate of an INPO-accredited train- ing program and the facility does not have an approved or certified simulation facility, then all that information will need to be submitted.
We would like you to begin certifying simulation facilities early on, and since nearly everyone has accreditediprograms with graduates, the process gets much simpler when you reach those two major milestones; otherwise, it stays diffi- cult with'you providing all of the details', which we subsequently review to verify eligibility, training and experience.
Q. 50. If the facility certifies the training program as being based on the SAT process, will NUREG-1220, "Training Review Criteria and Procedures," audit findings and comments be considered violations of 10 CFR 55?
A. If we did go to an accredited program, and we used NUREG-1220 to do a post-accreditation audit, and found problems, they would be addressed in one of two ways. Depending on their severity, they would be either left to the utility to resolve with'INPO or, if they were of a more severe nature, we might ask for a performance-based inspection. Depending on the results of that in- spection, there may or may not be any need for enforcement action.
Q. 51. If the SAT process is evaluated to be unsatisfactory during inspection, can operators be trained and licensed?
A. That will, have to be determined on a case by case basis. If your program is deemed unsatisfactory, it would obviously depend on what the problems are.
Q. 52. When filing an application, the facility is required to provide evi- dence that the applicant has successfully completed the facility licensee's re- quirements to be licensed as-an operator Or senior operator.
Part of the training program is'not complete prior to filing the application for the license due to the Examiner Standard (NUREG-1021) guidance-to file an application 60 days prior to the examinations. This has been acceptable in the past due to the statement on the application above the facility repre- sentative signature. It states that: 'The individual has or will have com- pleted by the time of the examination all the required training." Will this continue to be an acceptable approach-under the new rule?
A. No. This will-not be continued. The Form 398 will be revised to remove the words "or will have."
NUREG-1262 11
The Commission has stated in the rulemaking that the authorized representative certifies that'the individual has completed all training. It's not.a future completion, and we don't want to get into situations such as "at the time I
signed it I thought he was going to complete, but he didn't." You'are certify- ing that training is complete.
We have had some experiences in the past where commitments that were made were not completed, and they resulted in significant enforcement actions associated with the failure to complete training programs, even after examining, let alone at the time of examining.
Q. 53. The Regulation requires INPO accreditation for NRC approval, while Mr. Denton's Generic letter 87-07 requires that the training program be both accredited, and based on an SAT process. Which is the governing document?"
A. The Regulation governs. The Generic Letter just restated what was in the Regulation. To receive relief under the Regulation, the program must be based upon a systems approach to training. And some of the earlier plants, which were accredited very early, were based upon the INPO guidelines, and noti.upon the INPK accreditation objectives and criteria as endorsed by the Commission in the Policy Statement.
In that case, what they are doing now by way of updating their program and revising it, and the fact that they now understand the process, would be the basis for them to certify to us that they have, indeed, done it on an SAT
basis. They need not go back and wait until the next time through with the Accrediting Board.
Q. 54. Is a Commission-approved training program defined as an INPO-accredited training program, or are there other criteria for approval by the Commission of a utility's training program? How is a training program approved by the Commission?
A. NRC is getting out of the approval process for training programs. If there is an INPO-accredited training program, it only needs to be certified to us as indicated in Generic Letter 87-07. If a utility wishes to submit a revision to the present NRC-approved training program and asks for an NRC review and ap- proval of that, while we are not prepared to do that now, we would probably have to deal with that using the SAT-based, performance-based approach spe- cified in NUREG-1220.
To clarify, if a utility has a program that has been accredited by INPO, we ex- pect that it will be the program of record. The Commission endorsed this pro- gram based upon the industry commitments to improve training, and the Commission is moving out of the role of reviewing and approving training programs.
The staff does not see that there'is any need for, or value in, doing a review to come up with a lesser regulatory standard, because SAT-based programs are now the standard of record with NRC. 'Ifyou are accredited, we expect you to follow the accredited program. We have revised the approach to the inspection of training programs, and we do not expect you to maintain a lesser standard'
for licensing with NRC than you have for training the people.
NUREG-1262 12
Therefore, the staff would consider a review of amendments or modifications to the cold license training program, which is SAT-based, and we would use as guidance in doing that review the kind of information that is contained in NUREG-1220, or you could propose that you have done it in accordance with the TSD process, which INPO is using. If you show that it's comparable to that, we would also consider it. That is a vehicle for getting a Commission approval of a performance-based or SAT-based program on a case-by-case basis for a cold plant. We don't mean to exclude you from being able to do performance-based training.
Q. 55. -Are you still going to want Form 398 60 days prior to an examination?
A. We want to get to the point where, if you are accredited and have an approved simulation facility, all that is required is the certification. No prior review of the application will be necessary to determine eligibility, so the time between submittal of the application and the conduct of the exam could be very short.
However, until then, the Region needs time to review applications to determine whether the candidate is eligible, and to have an opportunity to interact with the training department to supplement that application in some cases. In those instances, we're still going to want to see it on the order of 60 days prior to the examination to start the review. However, we cannot take action on an application until the final completed application is filed.
Q. 56. There is one situation where you say you can administer the written exam and operating test but not issue a license until required evidence of con- trol manipulations is supplied. It would seem a logical extension of this to allow us to put somebody up who hasn't completed all the requirements, pass him, and-make the request, "Do not issue a license until he's subsequently certified."
Does that make sense or is that completely prohibited?
A. The exception for manipulating the controls to which you refer is only for the individual who has not had an opportunity to perform the manipulations be- cause the facility has been in extended shutdown. It is a condition beyond that candidate's control. However, we are moving into the role of accepting facility certification, and we want that certification to be unconditional. So the two situations are not comparable.
Q. 57. With respect to the logistics of submitting NRC Form 398 only after all program requirements have been completed, and; in addition, having to submit it 60 days prior to the examination date, would a reasonable compromise be to submit the 398s, unsigned by the facility, merely for a screening by the region, given that the the 60-day requirement is due to the time involved in such a screening? We could then follow them up once the program's been com- pleted, maybe a day or a week before the examination, for approval by the Region.
A. Although those types of issues need to be worked out on an individual basis, it is preferable not to have licensing decisions made upon draft materials, par- ticularly when there may be changes to them during the 60-day time frame.
Advance copies (unsigned) may be submitted on a case-by-case basis if there is a concern about a particular candidate's eigibility, experience, or training.
NUREG-1262 13
However, what we review and base our licensing decisions on should be the ,
application as it is submitted. The Regulation does not provide for review of drafts and other documents along those lines.
The time between submission of the document and when the candidate takes the examination appears to be the issue that's of greatest concern. There is one way you can shorten that time frame. Certify your simulation facilities early.
That's one of the things that we would like people to pursue. The other thing we can do is to expedite the review, give the applications a review when they first come in, and see if we can't shorten the time needed since we can shorten the submission times between the time it has to come in and when we finalize for the exam. In other words, we will reconsider the 60-day time frame that was in the earlier version of the examiner standards in light of this requirement.
Q. 58. If a facility has an accredited initial program that's SAT based and has a plant-referenced simulator acceptable to the staff, then the time between submittal of the application and the exam can be of the order of a couple weeks?
A. Well, we're going to need to know well in advance of that how many candi- dates there are for licenses, but the review for eligibility, training and experience requirements is significantly reduced if all we have to do is look at two blocks on the form.
The intent of the rulemaking is to make the application process easier, and to put the burden of the determination of completion and eligibility on the facil- ity, rather than on the staff, and accept that certification.
The issue that is significant is one of managing our own resources and knowing how many candidates are going to be put up and how many examiners we have to arrange for. Because it's a resource-intensive effort, we have to know, at.
about the time of the 90-day letter, how many candidates you are going to have for an exam on a given date. However, we don't need to know the specifics of who is being scheduled for the exam at that point.
Q. 59. Is there any difference between an "approved simulation facility" and a
"certified simulation facility?"
A. In the context of applications, there is no difference. An acceptable simulation facility is one that is either certified or approved.
- Q. 60. What is a significant control manipulation?
A. Significant control manipulations are defined in Regulatory Guide 1.8.
Examples can be found in items A-F of 55.59(c)(3) (On-the-Job Training for Requalification), although that's not an inclusive list. Basically, "signifi- cant control manipulations" involve situations that affect either power or reactivity, and that require manipulation of controls. Therefore, the plant should not be shutdown when these manipulations are performed, except for those manipulations required for fuel handling.
Q. 61. Will manipulations on a simulator be adequate?
NUREG-1262 14
A. Those five control manipulations have to be performed on the plant, unless the plant has not completed preoperational testing and is in its initial start- up test program.
Q. 62. Where does the requirement for five reactivity manipulations on the plant come-from? Why can't they be performed on the.simulator?
A. The control manipulation on the plant has been required for some time.
That's not a change. We have now put it in the Regulation to make it explicit.
In fact, for a long time, if you had not performed a start up and shut down of the plant, we actually had you perform them as a part of the NRC examination.
So this is not, per se, a change in practice.
Q. 63. Must the five control manipulations be different?
A. Regulatory Guide 1.8 asks for diversity. Therefore, the intent is to have different manipulations; however, this is not necessarily required. If reactiv- ity manipulations are repeated, this fact should be indicated in the comment section on the application.
Q. 64. As far as the five significant control manipulations are concerned, what's going to constitute evidence?
A. Documentation on the OJT qualification cards consisting of a simple "per- formed" code next to the signature of someone on shift is sufficient evidence.
Q. 65. What constitutes an-extended shutdown?
A. An extended shutdown would be anything that is long enough to prevent an applicant from completing required manipulations or training prior to taking the examination.
As an example, if the plant is in a refueling outage that lasts for a year and the candidate did not get an opportunity to perform the control manipulations because the plant never got to Mode 2 or Mode 1, we would consider giving that individual an exam, and even issuing him a license limited to shutdown conditions.;
When he completes the control manipulations on a hot plant, we would then re- move the condition on his license that limits it to shutdown. We do not intend to penalize individuals because of an extended outage, but we also don't intend to give waivers for what's clearly a requirement of the regulations.
Q. 66. If you have to complete the initial simulator and classroom training prior to allowing a nonlicensed operator to manipulate the controls from the control room, how can a person get their initial license? After the time needed for your simulator and classroom training, and for the NRC exam, there is not much time left to complete the five reactivity manipulations.
A. This applies only to a hot license. If the individual has not-had the shut opportunity to perform control manipulations on shift because of an extended down, we would consider examining him. And if he-passes that exam, we may issue a license which is limited to shutdown.
NUREG-1262 15
Q. 67. Will startup and shutdown experience gained on a certified simulation facility be considered adequate experience for operator and senior operator candidates?
A. Yes. The same answer applies to the use of an approved simulation facility.
The application goes to whatever is in your NRC-approved training program, or your INPO-accredited program for startup and shutdown experience.
Q. 68. How much time can pass before the five control manipulations must be completed before the written exam and operating tests are completed?
A. Up to six years. If, for example, we had given a shutdown license to a plant experiencing an extended shutdown, and we had given a license to a candi- date who was constrained to shutdown mode, he could actually serve out the term of that license for a period of six years.
Q. 69. Does NRC intend to make start-up certifications a part of the operating test for every new licensed applicant? If so, what is the status of the pre- sent start-up certification?
A. Start-up certifications are done on an audit basis, and it is left to the chief examiner to determine which initial license candidates will be audited.
Therefore, there are no changes from our past practice.
Q. 70. For NRC licensing examinations which have already been scheduled for the remainder of 1987, will relief be granted from the new requirement that all training program requirements be 100 percent completed prior to the submittal of NRC-398 and NRC-396 forms? These 1987 licensing exams were scheduled in the fall of 1986.
A. Forms 398 submitted after May 26, 1987 must comply with the new regulation.
Q. 71. What kind of "written request" is discussed in paragraph 55.31(a)(3)?
A. An authorized representative of the facility licensee is required to re- quest that the written examination and operating test be administered to the applicant. This request may be included in the transmittal letter forwarding the applications to the NRC. In order for the NRC to approve such a request, the facility licensee must provide suitable facilities for the administration of the written examination and operating test.
Q. 72. If an approved training program based on SAT is used for initial or re- qualification training pursuant to 55.31(a)(4) and 55.59(c), are there any NRC
imposed minimum training requirements? Of specific interest is the 3 months of on-th-job training for initial training and the annual requirements of
55.59(c)(3)(i) and (ii)?
A. There are no additional requirements provided that the response cited in Generic Letter 87-07 is filed and the facility plans to or has incorporated INPO guidelines86-025 and 86-026. We are aware that INPO guideline 83-022
"PWR Control Room Operator, Senior Control Room Operator and Shift Supervisor Qualification" does contain the three months on shift training period.
NUREG-1262 16
Q. 73. Reg Guide 1.8 endorses ANSI/ANS 3.1 for ROs and SROs. In reviewing the ANSI/ANS 3.1 annual and biennial manipulation requirements, it-was noted that the ANS 3.1 manipulation list does not agree with the 10CFR55 manipulation list for five manipulations. This deviation was not stated as an exception in Reg.
Guide 1.8. Please clarify whether Regulatory Guide 1.8 should have taken ex- ception to this deviation.
A. The five manipulations specified in the rule are necessary for eligibility, not for requalification.
Q. 74. At a minimum, five significant control manipulations must be performed which affect reactivity or power level. For a facility that has not completed pre-operational testing and the initial startup test program as described in its FSAR, the Commission may accept evidence of satisfactory performance of simulated control manipulations as part of a Commission approved training pro- gram by a trainee on a simulation facility. If the facility is in an extended shutdown, the NRC may administer the examinations, but may not issue the li- cense until the required evidence of control manipulations is supplied.
Do we need to submit waivers since we don't have full power license yet? Does this apply only to initial license candidates, or to all license holders, e.g.
renewal? Does the NRC accept in lieu of the above simulator manipulations the use of a research reactor?
A. If a plant has not completed the initial startup test program, successful completion of an approved training program on a simulation facility satisfies this requirement, and no waiver is required.
These requirements apply to initial and replacement license applicants. Re- quirements for renewal of licenses are covered in part 55.57. For plants that have completed their initial startup test program, applicants must complete the control manipulations on their actual plant.
- Q. 75. How will NRC evaluations of INPO-accredited programs affect NRC's willingness to allow use of a Commission approved program developed by using a systems approach to training? Notwithstanding the generality of. this initial question, please address the following two specific situations within the answer.
(1) How would an "unfavorable" NRC review of an accredited program affect a facility's ability to use an approved program in lieu of paragraphs
55.59(c)(2)., (3) and (4) pursuant to 55.59(c)?
(2) How will the NRC determine that a requal and/or initial program is based on a SAT during their evaluations? Of particular interest is the evaluation of element (5). under the 55.4 definition of SAT.
A. For clarification, an INPO-accredited program and an NRC-approved program are the same. (1) Unfavorable NRC review may be due to a number of conditions as outlined in the Commission Policy Statement of March 20, 1985, and continuing evaluations using NUREG-1220 or examinations administered by the region.
NUREG-1262 17'
An unfavorable review would not have any direct effect on your program. NRC
would work with INPO to resolve identified deficiencies. However, NRC has dis- cretionary enforcement authority under the Policy Statement, and this could be imposed if continuing problems were identified as a result of performance-based inspections.
(2) The criteria used by NRC may be found in NUREG-1220.
Q. 76. Will any combination of significant control manipulations be acceptable as dictated by the facility's modes of operation during which the applicant is in training?
A. Refer to Reg Guide 1.8 Regulatory Position C.1.h for guidance on what the Commission considers to be acceptable.
The acceptability of any alternatives will have to be determined on a case-by- case basis by the facility and indicated in the comments sections of the application.
Obviously, some significant manipulations may not be possible in Mode 4 of a plant. It may be possible in Mode 5 or 6, whichever you use for refueling, in the case of a fuel-handling foreman, so it's going to have to be on a case-by- case determination.
Q. 77. In the staff's presentations under Training Program Approval, it was mentioned that in order to implement §55.31(a)(4) and §55.59(c), the next annual FSAR update could delete training program details. Please clarify what (event or achievement) is meant by "implementation" of §55.31(a)(4) and
§55.59(c): what would the staff expect to see in the FSAR update different from that information which would be provided under Reg Guide 1.70 and the basis for development of the information sought (Reg Guide 1.70, Standard Review Plan, etc.). Should utilities assume that besides stating that the training program is INPO accredited the FSAR should retain revised program details in accordance with details sought under Reg Guide 1.70?
A. The staff plans to revise Section 13.2, Training of NUREG-0800 to provide guidance for information contained in revisions to the FSAR. There are no plans at this time to revise Regulatory Guide 1.70. In lieu of additional guidance at this time the staff recommends that the licensed training programs which are accredited and are based on a systems approach to training only need reference Generic Letter 87-07 and the dates the programs were accredited.
Plans for certification of simulation facilities should also be included.
With regard to other training programs contained in Section 13.2 of the FSAR,
those training programs listed in the March 20, 1985 Commission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel which are accredited need to reference the date of accreditation. For those facilities which are developing programs under the accreditation process the FSAR should identify the programs and provide the dates that SERs were or are planned to be submitted.
Medical Examination (Subpart C, Section 55.21)
Q. 78. How long before administration of a license exam must an individual have had a medical exam?
NUREG-1262 18
A. The form verifying the medical exam should come in at the same time the license application comes in. It will be good for six months from the date it is signed by the physician; waivers, as stated in ES-111, will apply.
Q. 79. Assume a physician may not desire to release personnel medical data due to a patient-doctor relationship. What does the utility do if the information is treated as privileged by the physician?
A. The Privacy Act Statement contained in NRC Form 396, "Certification of Medical Examination by Facility Licensee," does not allow for privileged infor- mation being withheld by the facility or the physician if it is requested by NRC. It is the utility's responsibility to ensure that the records can be made available for inspection. Utilities should ensure that the physician under- stands this requirement.
Q. 80. For individuals who are currently under either license conditions or letters from the regions to submit continuing medical follow-up information (e.g., quarterly blood pressure readings) for review and analysis, do these conditions continue to apply after May 26, or should the individual submit this information to the utility's physician for evaluation and analysis (without a copy to the regions)?
A. Continue to report quarterly blood pressure or other restrictions. High blood pressure or other restrictions are usually associated with some remedial programs (diet, medication, or a combination) and should result in normal or ac- ceptable conditions. At that time the physician can request termination of these reporting requirements.
Certification (Subpart C, Section 55.23; NRC Form 396)
Q. 81. Has NRC Form 396 changed?
A. Yes. A copy of the new version has been distributed-to everyone at the public meetings.
Q. 82. Must a Form 396 be submitted for every license application?
A. Yes, but the detailed medical information only has to be submitted when a conditional license is requested.
Q. 83. Under the new Rule will you receive a Form 396 only upon license renewal?
A. That is correct. We expect to receive a Form 396, "Certification of Medical Examination by Facility Licensee," at the end of the appropriate license period, when the-renewal application is submitted.
Q. 84. Is the examining physician an authorized representative of the facility licensee and thus allowed to complete and sign an NRC Form 396?
A. No. The Form 396 does not have a place for the physician to sign. The physician's name and license number-are required, but the authorized representa- tive is the highest level of corporate management who signed the application.
That will be the same person who signs the Form 398.
NUREG-1262 19
Q. 85. Can Form 396 be held by the licensees for the two-year update or do they have to be submitted to the Commission? If the latter, how often do they have to be submitted?
A. You don't have to keep the Form 396 on file,.but you must keep some docu- mentation that the medical exam was performed and that the operator meets the ANSI standard. The Form 396 is only the means by which you transmit that in- formation to us upon renewal of a six-year license.
Q. 86. For a multiple-unit site, can the signature on the application be from the individual responsible for operations, the highest ranking individual at that site? So that you could have different signatures; i.e., Sequoyah appli- atiTons would different signatures than those of Brown's Ferry?
A. Yes.
Q. 87. Will the Commission develop a protocol to ensure that detailed medical records will be forwarded to the NRC medical experts and not made available to lay persons?
A. This is an issue for which industry initiative may be appropriate, and it has been discussed by NRC, INPO and the accrediting board.
The staff needs to have assurance that the medical examination was done In accordance with the ANSI standard. The staff does not need to see the private medical record from the doctor, because it may include other medical informa- tion not related to the standard, or may get into the area of privileged in- formation between doctor and patient.
It might be appropriate for the industry to develop an examination form which would track the standard, such that the doctor would provide a statement to the responsible officer that the examination had been completed and which would identify the areas evaluated. Such a report would be all that is necessary for the individual's file, and it would be available on site.
If, in the case of a request for a license condition based upon some medically disqualifying condition that can be accommodated through medication, therapy, or something else, the doctor would submit the examination form and any addi- tional supporting information for the staff medical doctor to review to make a determination as to whether to issue a conditioned license.
That information would be handled in the same manner as we now handle confiden- tial information that is covered by the Privacy Act. Once submitted to NRC, the information would be exempt from further public disclosure, and it would be the basis for our review.
We don't anticipate developing any new protocols for handling that type of information, but we recommend that you have evidence available on site showing that the medical doctors conducted the examination in accordance with the ANSI
standard, or that you provide the physician a copy of the standard and let him complete whatever form you use now for that type of examination. It's only a suggestion. The actual requirement is that the examination be conducted in accordance with the standard.
NUREG-1262 20
Incapacitation Because of Disability or Illness (Subpart C, Section 55.25)
- Q. 88. Must the felony blocks on Form 396 be completed in order for the form to be considered complete and to be accepted by the NRC?
A. The form has been revised to delete the felony blocks. A certification the is now required that the individual meets the safeguards requirements of facility.
Q. 89. Will a standardized form be provided by the Commission for notification of disability- or illness?
involved A. The intent is that licensees keep the records. We don't need to be a when someone breaks an arm or may be out for an extended illness. If it's temporary condition, no notification is required.
in- We ask the question, "can the operator perform licensed duties?" If the question in your mind, we would dividual is going on shift, and there is any tell say submit a revised Form 396 to describe the condition/remedy. We may if you it's not necessary to make a ruling on it. But you can have a problem you don't notify us and some individual has a problem in performing licensed we duties. If a person is to resume duties after a disabling condition, then would need to be notified with a Form 396.
individ- Q. 90. What is the relationship between the facility licensee and the The Regu- ual with regard to responsibility for notification on medical issues?
the lations indicate that we have a 30-day notification period upon learning to diagnosis. The question really is, what's the mechanism for the facility become aware of the diagnosis; and what responsibility does the individual licensee have to make that notification to the facility? There's the potential to get into a problem if we don't learn of a licensee's medical condition.
disabled A. It is the operator's responsibility not to operate that plant in a the condition. The Regulation says that the facility licensee shall notify re- Commission, but we believe that, logically, the operator should have enough be set sponsibility to tell you there's a problem. Facility procedures should up to ensure that that occurs.
senior There is nothing in the Regulation that obligates the operator, or the on operator, to let the facility know. But there is an obligation for you, the biennial medical examination, to identify and report disabling medical conditions.
Q. 91. If the individual has a medical problem during the period of NRC the to if the license, for instance a broken arm, does this need to be reported operator is not carrying on licensed duties? For example, if he is training individuals in a classroom, do we still have to report it, or only if he's carrying on licensed duties per the Tech Specs?
A. It's when that person serves on shift that we have to know about a dis- him ability. Usually, if he has a temporary disability that would preclude from performing regular duties, he's not to perform those duties with that him temporary disability. We need not know if it's temporary. When you return NUREG-1262 21
'-V
to shift duties, if he has been absent for a period of time, you control that process with the 40-hour parallel shift duties and maintain the certification on file. It's only in case of a permanent disability that we would have to be notified. In that circumstance you want to include a qualification in the license to allow the operator to perform licensed duties with the medical con- dition if some compensatory measure effectively offsets that condition.
Q. 92. Can an individual be returned to active licensed duties after the medi- cal disability has been corrected if a portion of the requal program has been missed?
A. The operator must be current in the requalification program before he returns to duty, and he must receive 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch standing.
Documentation (Subpart C, Section 55.27)
Q. 93. The utilities must maintain some records in fire proof vaults. I don't feel that the physician's offices meet those requirements. Yet this is a qualification record, as defined by that ANSI Standard. Are we going to have to provide physicians some type of fire proof storage? How do we handle that aspect of this record keeping?
A. We recommended to INPO, and they are considering the development of, an examination report form which would cover the areas in the ANSI Standard and which would be submitted from the medical examiner to the facility for retention.
Q. 94. Can private physicians maintain medical records for the facility licensee, as is currently practiced?
A. You may choose to delegate that responsibility to them, but it is, indeed, your responsibility to ensure that the appropriate records are available for inspection.
Regulatory Guide 1.8 and ANSI/ANS 3.1 Q. 95. When we want to go from a non-accredited status!to an accredited status, what would the step-by-step progression, and the changes in the regulatory environment be for us?
A. The date you receive accreditation from the Academy, you would send NRC a letter that says "we've been accredited on this date." You then begin that program because the previous training program is superseded. You need not tell us about it until the next FSAR update, which is required pursuant to
Simply send a letter saying that you were accredited, and the date of accredita- tion, and certify that your requalification program is based on a systems approach to training; this supersedes any prior commitments to NRC by way of additional training.
NUREG-1262 22
it would not be necessary Q. 96. -For the FSAR update following accreditation, was the case, is to have the extent of detail in that update, as previously that correct?
the information about the A. That is correct. It can be blank, except for other than you were accredited, date of accreditation. It need not say anything, records associated with your and the date-you achieved the accreditation. All to the staff on site training program,' following accreditation, are available for review; they need not-be submitted.
in accordance Q. 97. If the facility does not certify its training programs revised and how do I
13 be with Generic Letter 87-07, when must FSAR Chapter do it?
and-at that time, you must A. The Rule becomes effective on May 26th, 1987, program. So, there would comply with the new provisions in the requalification with 10 CFR 50.54(i)
need to be a change to the FSAR submitted in accordance chose not to certify the and 55.59(c), to conform to the regulation, if you training program.
in the Policy State- The Commission endorsed the INPO Program for accreditation was accredited and certified ment. We said we would accept a program after it A utility that perceives they to be based on a systems approach to training. on the docket because get some advantage by leaving an old training program That is not consistent with that's all NRC is going to inspect is misguided. We do not require that you the intent of improving training in the industry. but we do expect you to tell us all the details about an accredited program, implement them.
to have one standard for NRC,
We have heard rumors that some facilities intend the Commission's intent in the and a different standard for INPO. That is not to the Commission's atten- Policy Statement and we would bring such a practice program when it is tion promptly. We expect you to follow the accredited will be of concern both to INPO
accredited. Failure to implement that program and to NRC.
FSAR Chapter 13 changes Q. 98. Will NRC be prepared to approve or disapprove 55 requirements?
within the 60 days allowed for implementing 10 CFR
have an accredited program A. The approval is effective automatically, if you approach in accordance with and have certified that it is based on a systems from the Commission on GL 87-07. You shouldn't expect to see any response rule, with the exception of changes that are implemented as a result of this of something in your Technical any license amendments which are required because that have a more restrictive Specifications. There are a number of facilities that for which they would requirement in their Technical Specifications than to obtain relief is per- have to apply; amending their Technical Specifications change in order to con- mitted under the rule. It would be an administrative to be acted on within 60 days form with the Regulation. But it would not have the Technical Specifications.
and would be processed as any routine change to based on a systems approach, If you do not plan to certify that your program is with 10 CFR 50.54(i).
we cannot'act on it until we receive'it in accordance NUREG-1262 23
It will then be reviewed in the usual way. In this case, it would not be rea- sonable to expect it to be completed by May 26, 1987.
Q. 99. But in the meantime, is Revision 1 of Regulatory Guide 1.8 our commit- ment, as approved in our FSAR?
A. Yes. Your commitment is that which is approved in the FSAR. It is binding, as are any of the more restrictive requirements in the Rule, until you are ac- credited and so inform us by letter. At that point, you can make changes pur- suant to 50.59 to remove things from your FSAR and your program. When you need to amend a license, you submit the application for an amendment to strike the sections in the Technical Specifications or in the license which have been superseded by accreditation.
Q. 100. Upon achieving accreditation, would we then become committed to Regulatory Guide 1.8, Revision 2?
A. No. Regulatory Guide 1.8, Rev. 2, goes into effect for all facilities, as is indicated in the implementation section of the Guide, on March 31, 1988.
However, if you have an accredited program, you are no longer obligated to follow the Guide. At that point, you can put the Regulatory Guide aside, you now must implement your commitment to the Accrediting Board. We have but looked at that information, and we've concluded that INPO guidelines in this area are equivalent to the staff guidelines in Regulatory Guides.
Q. 101. This question addresses NRC approval of training programs. Do revi- sions to requal programs which reduce their scope require NRC review and ap- proval per 10 CFR 50.54.i-1 if the program is INPO accredited? And can the term "reduction of scope" be clarified?
A. NRC review is not required if the program is accredited and is certified to be based upon a systems approach to training. Element 5 of the SAT includes revision of training in order to meet the needs of the job incumbents; there- fore, we expect you to update your program based on this feedback.
The intent is that if you are SAT based, and are revising the program based upon an evaluation of the needs of the trainees, that the result of that eval- uation is the program you are going to conduct. And you have a basis for that evaluation. Reducing the scope does not apply. The intent is to give you the flexibility to modify the program in order to provide the training that you, the facility licensee, determines appropriate for your job incumbents.
We have seen that process work through the INPO-accreditation process. We have confidence in the process. And even though we are sure that there are going to be cases where there is content left out, where we are going to have some concerns about something not having been covered, the process is there so that you can cover what's needed.
The training and the feedback process you provide will permit the training to be job-relevant. It is training which the trainees agree is important.
Probably the only exception is for the instructor who has had that training.
But the old test-out exemption is gone. You can't-take an exam, do well on it, NUREG-1262 24
misses a portion of and eliminate training in'a systems approach. If someone you may use some- the training program because he has been ill or been-away, that he has covered thing like a required reading program and a test to ensure basis, it refers the material. But when the Rule says training on a continuing by the accrediting to whatever cycle you have designed that has been accepted board.
would prefer, after you NRC has separated itself from the training review. We in place to us, are accredited, that you certify you have a systems approach is all that we need and eliminate the details from your FSAR. Certificationprocess are the vehicle because the periodic reviews through the accreditation that the separation of for keeping your training programs current. We thinkof this rule-making.
training from examining is the most significant part the accreditation process, Q. 102. There are a lot of documents involved withthat your program is less so if an IE inspector came in and said, "We think than the scope," what is he basing that on?
IP 41701, which requires A. Regional inspectors are governed by inspection module to your program thriough the a performance-based inspection. If you make a change and updating your pro- accreditation process using the mechanisms for revising that you're revising gram, based upon feedback and need, and that's the reasonscope.
it, we don't see that that is an issue of lessening the program when it was The lessening of a scope issue had to do with the old of hours the classroom regulatory-based, where we required a certain numberone of modeling the program rin and certain types of content. The approach now is one that has been endorsed based upon performance and need, and the process is the extent that you need to by the Commission through the policy statement. To performance, that's change the program based upon feedback of your own appropriate.
administering a comprehen- If you-have an approved program today that calls for to a comprehensive writ- sive written exam annually and you want to change that for concluding that that ten exam every two years, the regulation is the basis is simply conforming to is acceptable; that is not reducing the scope. Thatregulation either through the regulation. You can make changes to match the There are a few facili- the 50.59 review process or by amending your license. associated with a ties which have commitments to operator training programs Technical Specifications. If staffing requirement section in Section 6 of the request to the Commission you are in that category, you can submit an amendment to conform to the for an administrative change to your Technical Specifications do less if it is, in fact, a requirements of the regulation, but you may not than what's currently in requirement in your license now. You can't do less can do a 50.59 review to the license. If it's in your approved program, you conform to the regulation.
training, I have determined Q. 103. Let's say that in my systematic approach to the requirements. I com- that it doesn't take three years of experience to meet is appropriate, and plete the program with whatever experience we determinehave the experience re- have to we've got an accredited program. Do we still them if we have an quirements in our program? Do we still have to meet accredited program?
NUREG-1262 25
A. The industry, through NUMARC, has made a commitment to NRC in both training and qualifications. We did not take exception to the three-year requirement for experience. In the past we have accepted two years for reactor operators.
On the effective date of Regulatory Guide 1.8, March 31, 1988, we would expect people to meet ANS 3.1 unless they have already committed to that.
Within the accreditation process, there is a hierarchy of guidelines just as within the regulations. An acceptable way of meeting the regulation, as it relates to experience requirements, is by conforming to ANS 3.1. Another way is through the accreditation process, which also has guidelines.
In the case of a review and approval by the Staff, we would look at any bases for waivers of those requirements and alternatives that are proposed. In the accreditation process, the mechanisms are already built in for you to do that yourselves on a case-by-case basis.
So accreditation criteria for entering into training as it relates to qualifi- cations are described in the INPO training guidelines for each position. They articulate what the entry levels are for training and have in that process a mechanism for granting waivers to certain requirements.
The Commission, through this rule making, has said, "We will accept the can- didate at the end of training if he is certified to have been a graduate of an accredited program." We have done that through promulgation of the policy statement on training and qualification and an endorsement of the accrediation program. That means that you control the review and waiver process, through your vehicle with INPO. Now, if you want to deviate significantly from the INPO guidelines, I would suggest that you need to contact INPO and they may need to contact NUMARC if you want to come up with a radically new interpretation.
But, in fact, if you have a basis for what you're doing which is documented, and you do that on an individual basis, we do not intend to second-guess your judgement. In fact, we would not see it on the application when you have both an accredited program and a simulation facility acceptable to the Commission for the conduct of operating tests.
That's a major change in the way we have done business in the past; it puts a lot of trust in the industry through the self-initiative of INPO and NUMARC
in order to provide both training and qualifications.
Q. 104. Have the experience requirements to sit for an RO or SRO exam stated in Reg Guide 1.8 and NUREG-1021 changed?
A. Yes, in that the experience requirements are not operative if you have an accredited program and have certified your simulation facility. ES-109 will be changed under the revision to NUREG-1021 and under Regulatory Guide 1.8, which becomes effective March 31, 1988 for nonaccredited programs.
Q. 105. Will NRC change any of the eligibility requirements in the Examiner Standards for taking the SRO exam discussed as a result of implementing 10 CFR
55? This question is being asked in light of the fact that 10 CFR 55 supersedes previous regulations. Specifically, will NRC require that someone have one NUREG-1262 26
for an SRO?
year of experience as an RO before entering the training program ANSI/ANS 3.1-1981 requires a minimum of six months.
if a facility A. Yes, there is a change to the eligibility requirements except In that case, has an accredited program and an acceptable simulation facility.
program.
the requirement goes away because it becomes part of your accredited the experience Q. 106. The way I understand the Examiner Standards presently, plant experi- of power requirement to take a reactor operator exam is two years three years ence, one of which is nuclear. ANSI Standard 3.1-1981,-specifies years The two remaining of power plant experience, one of which is nuclear. be as a should be as a nonlicensed operator, and of that,' six months should the license. So, that nonlicensed operator at the facility for which you seek whereas in the would be in my interpretation, a three-year requirement now, past itfwas a two year. Is that correct?
the board in A. That is correct. The standard had not been imposed across in their to that standard
1981: There are some facilities that have committed version of the application, and were reviewed against that standard. A previous because we had not endorsed Examiner Standards was based upon ANSI N18.1-1971, ANSI 3.1. This rule making process endorses ANSI 3.1.-1981.
Standard 109 Q. 107. And the same applies for the senior operator. Examiner that one says four years, and ANSI 3.1 says three. So, you will be changing also?
Reg Guide 1.8 cites a A. The Reg Guide takes exception to the ANSI Standard.
four-year requirement for experience for the SRO.
- Q. 108. Reg Guide 1.8 endorses certain positions through ANSI 3.1-1981 for requirements training and qualifications. The ANSI Standard has experience instance, for which are different from those in the Examiner Standards. For plant experi- a reactor operator, ANSI 3.1 of 1981 requires three years power as a non- ence, one of which is nuclear. And I believe it says two years at the facility.
licensed operator, with six months as a nonlicensed operator or just Is the Reg Guide endorsing those eligibility requirements also, training?
for reactor A. We have not taken exception to three years of experienceto three years for operator. We have endorsed the ANSI Standard with respect SRO. That's the RO, but have taken exception by requiring the four years for between the Exam- same as the practice has been. We recognize the difference Standards will be iner Standards and the Reg Guide in this area. The Examiner which is changed to coincide with the implementation date of the Reg Guide, March 31, 1988.
applicable also Q. 109. 'Are the experience requirements for operator licenses to research and training reactors?
changed. Whatever A. The requirements for test and research reactors have not continues has'been approved in the past, in terms of eligibility requirements, Regulatory for test and research reactors. The eligibility requirements in Guide 1.8 refer to power'reactors.
NUREG-1262 27
Q. 110. I have an accredited SAT-based program. The simulator should be avail- able next year and will meet ANSI/ANS 3.5 Standards. It's my understanding that we are okay because we meet those three elements, SAT, INPO accredited, and our simulator should meet your standards. Am I correct, that in meeting those standards, I don't have to worry about the ANSI Standards requiring two years as a nonlicensed operator with six months at the plant?
A. No, that's not entirely correct. While you don't have to submit that in- formation to NRC, the industry, through NUMARC and INPO's training guidelines and accreditation, has standards comparable to those in the-ANSI standard.
Therefore, we feel that the qualification requirements are still being met.
The only difference is that you don't have to submit all that information to us.
We had a case recently where an individual was a graduate of an accredited pro- gram but did not meet the experience eligibility requirements. His plant ex- perience was that of a chemist, a position not comparable either to that of a control room operator or a shift engineer. We denied the application, and it was denied on appeal. We aren't going to see that kind of information in the future, and we expect the industry to police itself with respect to ensuring that the NUMARC commitments are, indeed, met. Because we are stepping out of that area, and not requiring it to be submitted, does not mean that you can relax your standards.
Q. 111. In the example that you just gave you were apparently talking about an SRO candidate, and I was referring, primarily, to RO candidates. In the past, particularly for those who weren't committed to the 1981 version of that ANSI
Standard, there was no requirement for RO candidates to have been nonlicensed operators. Now we are faced with the new requirement, and I've got a group of people who are in training now, who don't necessarily have that background.
A. There is one aspect of the accreditation process that you may be missing.
And it's a part of the process that pertains to meeting NRC eligibility require- ments. The accreditation process does include a mechanism for you to exempt, or waive aspects, based upon having performed an evaluation of the candidate's experience and/or testing. That is the same kind of process that we use in making a judgement, on a case-by-case basis, about eligibility, where a person didn't cross all the "t's" and dot all the" i's".
We are looking for you to use that same process. You may choose, for a docu- mented reason, as a part of your program, to waive a portion of the require- ment, based upon experience and/or testing. That is a part of the accredita- tion process, and-we understand that, and we expect that to continue. And the only difference is, you don't have to submit it to us to request a waiver.
Q. 112. Will NRC continue to accept one year as a Navy reactor operator, engi- neering watch supervisor, etc., as meeting the one-year reactor operator ex- perience requirement, if one year remains as a requirement?
A. Yes.
Q. 113. The definition for related technical training in ANSI/ANS 3.1 says,
"Formal training beyond the high school level in technical subjects, associated with the position in question, such as acquired in several programs, including utilities, and others. Such training program shall be of a scheduled and NUREG-1262 28
planned length, and include text materials and lectures." All of our programs meet that definition of related technical.training, and yet we can't count it for experience. Why not?
A. Experience is an eligibility requirement. If the person has the experience and the qualifications, then he goes into a training program. You have mecha- nisms, through your accreditation process, where you look at the entry levelpro- into your training program. You can count time and training prior to thatwhich gram, but we have not been giving credit for experience for the training is required and has been approved by NRC as a part of the specific program leading up to license eligibility.
Q. 114. Do radiation protection personnel now require.three years experience per ANS 3.1-1981, even if Tech Specs require less experience?
are A. The requirements for radiation protection personnel in Reg Guide 1.8 the same as those included in ANSI Standard 18.1 of 1971.
letter Q. 115. About five years ago, we all wrote our response to the Denton Now if and said that we would do specific punch list items to train our STAs.
we have an approved STA training program, per INPO, the old prescriptive'hoursis in that we'committed to no longer apply. However, if that punch list itemthat our FSAR, we need to remove-it "per the INPO-accredited program." Is correct?
A. That is correct, as it relates to licensed operator programs and other by the programs for'which you have made training commitments which are coveredboth Commission's Policy Statement on training and qualifications. And in indi- cases, it is simply a 50.59 type review to amend or update your FSAR to the STA
cate the date on which you received accreditation, for instance,,for on position. The only exception relates to the CommissionPolicy Statement engineering expertise on shift or the use of the dual role SRO/STA compared C.1.j.
with a separate STA, as indicated in Reg Guide 1.8, Regulatory Position Q. 116. When an applied science degree is being considered, what constitutes to be an acceptable degree? How do we know what specific degree allows someone an instant SRO or whether he must first be an RO?
in, A. The staff reviews those and we' use our best judgment, as do the people feel an application. If you the regions, in making a determination based on by re- that an application has been unfairly rejected, you can request reviews a re- gional and headquarter's management...If you want to bring it up through view, we can certainly do that on a plant-specific basis.
you won't Q. 117. Is it true that in.the'future it won't be-a problem, because will you check up on us? If we send an application in saying.someone's an SRO,
it accept the application because you won't know what degree he has because won't be listed?
A. It's our understanding that the determination will be made in accordance program.
with guidelines that have-been established under your INPO-accredited NUREG-1262 29
The Commission has made a determination that we're going to trust the industry and let the industry programs be operative in the area of training and qualifi- cations under the policy statement. We understand generically what those com- mitments mean, and we've reviewed them quite closely.
If we find that they're being abused, either through an inspection program or through any other vehicle, that's going to cause grave concern as to whether the industry is able to police itself and act responsibly, given what we have delegated to you through those programs.
We've been on team visits and at board meetings and we've seen utilities being put through their paces to describe what mechanisms they use to review and make determinations about the eligibility for candidates to enter into training and whether they are qualified to perform in that job position.
What we're saying is that we believe that.process is the appropriate one to use.
If you do that in a straightforward, rigorous manner, that's what we're looking for. We're not going to nit-pick and second-guess your judgments, provided you have an adequate basis for them and provided they are consistent with what has been approved generically through the accreditation process and the guidance that INPO has issued.
Q. 118. Are documents referred to, such as NUREG-0737, still required as references?
A. Revision 2 of Regulatory Guide 1.8 supersedes NUREG-0737 as it relates to operator licensing. However, there may be some aspects of NUREG-0737 which have been committed to in a facility training program, and the initial program may not yet have been accredited. Those commitments are still in effect. They are part of the approved program, and remain so until that program is super- seded by an accredited program, and you provide the letter to the staff, as is described in Generic Letter 87-07 which forwarded the Rule.
Q. 119. It seems that Regulatory Guide 1.8 says a diploma or equivalent is required only for the shift supervisor and senior operator. ANS 3.1 requires only a high school diploma for licensed operators. Is that what you intend?
A. Yes. The intent of the exception taken in regulatory position C.1.d. was to eliminate the 30 and 60 semester hours of college-level education from the shift supervisor and SRO positions. The definition section in ANS 3.1 includes the General Education Development Test as the equivalent to a high school diploma, and it would be acceptable for all three positions.
Q. 120. 10 CFR 55 provides allowable training exceptions from this rule if a systematic approach to training is used. Reg. Guide 1.8 however, does not state that there are allowable training exceptions from following ANSI/ANS 3.1 for ROs and SROs. Please explain why exceptions were not allowed for RO and SRO training when a systematic approach is used.
A. Exemptions are allowed under Section D, Implementation, of Regulatory Guide 1.8, which states that the guidance in Section C does not apply to those training programs which have been accredited under an accreditation program which has been endorsed by the NRC.
NUREG-1262 30
K>
WRITTEN EXAMINATIONS AND OPERATING TESTS
Question Bank)
General Issues (Including Learning Objectives and Examination If so, how?
Q. 121. Will the format of the written exams change?
is not expected to A. At the present time the format of the examinations under way which may lead to change, although there are numerous initiatives process.
format changes in one way or another as we refine the Reports (LER) will be in- Q. 122. The exam content states that Licensee Event and communicated to cluded in the exam. How is the scope of LERs determined the individual taking the examination?
LERs. We would sample A. We expect your training program to include relevant be limited to those.
from your learning objectives, but we would not necessarily plant and try to adapt We would not take an LER from a significantly different either training needs or it to your plant. But if there were LERs that reflectthe exam process. It may operational safety, we are going to include those in be in the written exam or on the operating test.
a consistent level of de- Q. 123. Will there be any effort by NRC to ensure tail in the facility's learning objectives?
the quality of learning A. Yes. We have a major effort under way to evaluate a significant issue be- objectives that are submitted for an exam. This isin learning objectives.
cause we have seen a large spectrum of differences have been reviewing the As a part of our examination development efforts, we for the 90-day quality of the learning objectives submitted with materials as a feedback mechanism letters. We're evaluating their quality and using that is working.
into the evaluation process for how well accreditation we'll use other Where we find that the learning objectives are not adequate, We intend to evolve materials. Where they are adequate, we will use them.exam solely using the over time to the point where we can construct an NRC
facility learning objectives.
program to INPO and We have also opened our examination development training examinations and on others, providing information to them on how we construct are also activities the training that we're providing to examiners. There objectives.
underway within INPO to improve development of testing written examinations based Q. 124. How does the Commission intend to implement in the learning objectives upon the knowledge, skills, and abilities identified duties?
derived from the systematic analysis of licensed operator of Considerations, to reach A. It's our intent, as expressed in the Statement become the major the point where the training program's learning objectives according to a scheme that looks source for our examination. We want to sample and abilities, and we have at the most important job performance, knowledge, there's a supplement to that area documented with our K/A Catalogs. In fact, the same sections as the BWR Catalog.
the PWR Catalog being published that has NUREG-1262 31
In addition, we asked a PWR and BWR panel of subject-matter experts to rate the testing emphasis they thought we should have. That rating forms the basis of NRC's sampling plan, so we will sample the most important job content. What we expect in terms of conditions and standards of performance will be driven by the learning objectives, and that will form the basis of our testing objectives.
The only slight difference between testing and learning objectives has to do with the context in which you judge performance, because one is a time-limited testing situation, and the other might allow a longer training or job perform- ance period.
We don't want our exam to be devoid of contact with your training program. The purpose is to get to the same spot. Of course we reserve the right to look at LERs and other events, and to further investigate other questions, with your assistance, manuals, license amendments, or other materials, because even if we judge our question in terms of your learning objectives, the material to de- velop the question and the answer has to come from something other than the learning objective.
Q. 125. What, if any, utility actions will NRC require to incorporate utility learning objectives into the NRC testing objectives?
A. The better your materials are, the more closely they are keyed to our K/A
catalog, the easier it is for us to use them. But we're not going to require any actions. In the 90-day letters that go out prior to the administration of an exam, we're requesting that learning objectives be submitted, and we're evaluating them, and if they are appropriate for use in our exam, both the written and the operating test, we would employ them to the extent that they are consistent with our sampling plan in the Examiner's Handbook and the K/A
Catalogs.
We've been training examiners to look at learning objectives and to use them for testing objectives. To the extent that you can provide material to the examiner where the learning objectives provide a standard of performance and you key the training materials in which the material to develop that question is available, and if you know a K/A in the catalog with an importance rating that's above 2.5, you will have provided the basis for developing a good ques- tion and a good examination.
Our experience is that the learning objectives may have conditions and standards of performance, but the supporting training materials are not there to develop the appropriate questions or they're cast in such a way that it's unclear whether they are related to a K/A associated with job content having a rela- tively high safety significance.
We also did not want to see the "enabling objectives," because these are for training purposes and are not grounded in job performance. We want objectives that are "terminal," and have to do with job performance; and the better the material is that you supply, the closer our exam will mirror those objectives.
We've spent a great deal of time looking at how one judges a question based on the learning objective so that the question will elicit the kind of performance or knowledge or response that lets us infer that the person has mastered that particular aspect of the job.
NUREG-1262 32
~.) I
which announced the There's a related issue. We issued Generic Letter 87-01, and indicated the mechanisms availability of the NRC Examination Question Bank, what's contained in the by which utilities could request the information on indicated a mechanism bank on their facility or similar facilities. It also we have inaccurate ref- for you to update questions on the bank, either where erences or the design of the facility has changed.
two years old because some We purged the bank of questions that were more than quality standards. In some cases, of the older questions did not meet today's for a particular utility.
we have only four or five-examinations on the bank in your comments and/or questions We want to improve that and are interested creating your own ques- for the bank. We'll also provide the bank to you for that's in a format which is tions. To the extent you provide us information that directly, either through compatible with loading into the bank, we can do we can't give you di- hard copy or electronically. But for security reasons,the need for an industry rect access to the bank. We have discussed with INPO that could be a source initiative to validate.~a set of plant-specific questions for NRC exams.
of what they Q. 126. If the utility has established some internal guidelines for the purposes of expect of the individual) will you accept those guidelines written examinations? - -
with the utility, that A. Yes. We would havelan issue that we would discuss conform to our testing we would want to revise the guidelines if they did not statements with high blueprint based on the job-related knowledge and ability safety significance.'
examination, and then come Q. 127. Can we submit that in advance of the written to an agreement-somewhere up front?
in accordance with the A. It can be part of the materials that you submit the exam.
90-day letter, and we-would consider that in developing on writing the Q. 128. You mentioned a training program for the examiners who's teaching learning objectives Howiis that program being instructed;
that?
multiple choice questions, A. We started several years back working on writing the regions, twice at and have beenidoing one-week training sessions in all the one-week training headquarters, and once each for contractors. During testing objectives and session, examiners converted learning objectives into practiced writing testing objectives.
INPO staff participate and We've shared that information-with INPO and have had that we're using to take the materials back-with them, so the information or even through the staff develop examinations is available to you through INPO,
if you want to request it.
Written Examinations and Operating Tests (Statement of Considerations)
D, Written Examinations Q. 129. In the Statement of Considerations, under Part derived from job-task and Operating Tests, it says: "Learning objectives
7-1 NUREG-1262 33
v- analyses should form the basis for licensing written examinations and operating tests at a facility. Ultimately, the NRC testing objectives will reflect fa- cility licensee-developed learning objectives. In the interim, while programs are being developed and reviewed for accreditation, the NRC has activities underway to improve the content validity of NRC examinations and operating tests." Will NRC commit to solely using the learning objectives for plants that have accredited operator programs?
A. No. The rule states that the learning objectives will be used in part, but that other things, like LERs, etc., will also be used.
Q. 130. Why are written examinations only taken in part from learning objectives?
A. The hope is, eventually,' to take the entire written examination from learn- ing objectives. However, at this time, there are many places where the learning objectives are somewhat incomplete or inadequate. So, we utilize LERs and other training materials, such as lesson plans, system descriptions, and procedures, to supplement the learning objectives.
Q. 131. When will NRC activities underway to improve the content validity of NRC examinations and operating tests be complete?
A. We view this an an ongoing activity. We have a number of initiatives scheduled for completion in this fiscal year, including the revised Handbook (NUREG-1121), passing-point workshop, and the supplement to the PWR K/A Cata- log (NUREG-1122) to conform to the BWR K/A Catalog (NUREG-1123).
By the end of this fiscal year, a number of milestones toward meeting that objective will have been met. But this is a continuing process, as we work toward a common understanding of what's necessary for assessing job perfor- mance. With the advent of the K/A Catalogs, we've made significant improve- ments in basing test content on the operator's performance-based job require- ments: that is the essence of content validity. We have used a systematic process involving subject matter experts. We have supplemented the PWR Cata- log, which now has a theory and component section similar to that in the BWR
Catalog.
In addition to that, we have been looking at alternate ways to sample the con- tent of the NRC written exam. At present ES-202 and 402 weight all four sec- tions of the exam equally. We've looked at a way of sampling according to the sections in the Catalog. The differences would reflect differences between RD
and SRO positions. We'll sample more heavily in plant systems for ROs and more heavily in emergencies that have fewer normal and more integrated plant responses for SROs. The final decision on that will be made based on the recommendation of a Panel made up of industry representatives and NRC contractor personnel that will meet May 18th through'the 22nd.
We will consider the panel's recommendations to us before we make any recommen- dations to change the format of the NRC'exam. That sampling plan from our Cata- log and your input on your learning objectives should, in fact, be the essence of a content-valid exam.
NUREG-1262 34-
Q. 132. I've heard different people say that all NRC exams are now basesi'on the K/A Catalog.' Are all NRC Examiner-Contractors held to that Catalog as a standard?
A. Examinations prepared by Contract Examiners are reviewed in the Region so the standard for the regional Examiner and the Contract Examiner is not dif- ferent. Like regional examiners, the Contractor Examiners are required to write-an examination which meets the-requirements of-the Examiners' standards, which now reference the Catalog and will, in-a future revision,'also reference the handbook.'
We are sensitive to feedback from the exam process.- We look at the facility comments generated during the exam review process. We intend to be very re- sponsive'to comments that point out any differences between a contract exam and one administered by NRC examiners.
.1\
- Q. 133.- Is the new rule going'to 'change the format of the exams (e.g., largely essay-type)?
A. The new rule does not alter the format of the exam. The current Examiner Standard, ES-202, permits a maximum of 25 percent objective-type questions (e.g. multiple-choice, true-false), a maximum of 25 percent longer essay-type questions, and a minimum of 50 percent short-answer questions in Sections 2-4 and 6-8 of the exam. Exam Sections 1 and 5 (reactor theory and thermodynamics)
can consist of a greater portion of objective-type'questions.
We're working on'the issue of a generic exam--a prototype, objective exam for theory and component operation. '
Q. 134. Have you pilot-tested Form 157. or have'you had any'practice with it?-
A. No. The new Form 157 will be available after May 26. We'll be revising-it as necessary, based on our feedback from field use.
Written Examination: Operators (Subpart E, Section 55.41)
Q. 135. The items in 55.41(b)(10) and (13) have previously been for senior operator knowledge. What level of knowledge is expected for .1 the reactor operator? 7' '
A. Part of 55.41(b)(10),'has been for operator knowledge in that it concerns normal, abnormal, and emergency operating procedures for the facility. For the administrative part, the reactor operator would be tested for the depth of knowledge required for his job position in the administrative area because operators get involved with administration at times. And Part (13), "Procedures and Equipment Available'for Handl'ng and Disposal of Radioactive Materials and Effluents," would also be geared to RO'job requirements at your site.
Q. 136. Part 55.41, "Content," does not specifically address that licensed operator candidates need to know Technical Specifications, yet the examiner
'standard, Section ES-202, discusses the need to know Technical Specifications.
What -isthe reason for this difference? Is ES-202 correct in its application for Technical Specification knowledge?
I NUREG-1262 35
A. Section 55.41(5) addresses the Technical Specifications. We expect opera- tors to use Technical Specifications as appropriate to their job. Reactor opera- tors, as in 55.41(5), are expected to know limiting conditions, particularly those things they should recognize and communicate to the SRO in a timely manner.
The same thing goes for the SRO. We don't expect SROs to be engineers. So required job performance in your systematic evaluation, plus our K/A Catalog, should give you an idea of the level of specificity. We intend to revise the examiner standards to give our examiners better guidance. Right now, it's not as clear as it could be, but required job performance is the key, and if, for some reason, you feel you use Technical Specifications differently than we can interpret, you should call that to the Region's attention and discuss it long before the exam occurs.
There is clearly a difference between our expectations for ROs and SROs by virtue of SROs directing the activities of others. The SRO must know all aspects of license conditions. He approves work, work orders, and other things which require a knowledge of Technical Specifications beyond the material covered in the operator's written exam.
We don't expect the SRO to be able to develop a basis for a requirement on his own. We expect him to understand what the requirement is, and be able to carry it out. That's the difference that we tried to articulate in these two sections.
An RO doesn't have to know about approving surveillances, yet surveillances are covered in the Technical Specifications. An RO does need to know about limits on operation of the plant, as they relate to the list of items under the written examination.
Q. 137. For facilities that have an approved INPO-accredited performance-based training program, what percentage of the written and/or oral exam questions administered by NRC will come from the facilities' objective-based exam bank, or at least from the facilities' training objectives? From Attachment A (to Generic Letter 87-07) it appears that all the exam questions for accredited facilities will come from the facilities' training objectives.
A. Eventually, we'd like to use the facilities' learning objectives. But, it's our experience that we have varying degrees of polished objectives. We've also found that even when there is a good objective, where the conditions of performance and the standards of performance are explicit, and the learning and the mastery is all tied to job performance, the supporting materials submitted with the 90-day letter do not allot examiners to develop the kind of question that will elicit the appropriate material to decide whether the candidate has mastered that objective. So while the objective may be good, the supporting material isn't sufficient to develop the right kind of question.
We're working on this. And we key the content of our exam right now to the K/A
Catalog. We do not sample those items that have been found to have a low im- portance to safety. But we have to rely on your analysis to help determine what's important on a plant-specific basis.
And this is where there's some breakdown at the moment. The better the learning objectives in terms of their explicit statement of conditions and standards, the better the supporting material, and the better it's tied to our Catalog, the better the whole system works.
NUREG-1262 36
But don't read into that that we would-be limited to those objectives. We would sample, we would tie it to those'objectives; but if there isn't an objective in the safety-related system that we think is important, we may create our own test objective and cover it on the exam.
We're going to try very hard to ensure that it is safety related, it is opera- tionally oriented, and it is performance based. Obviously we would want to have good justification for asking that kind of a question.
Many of you have used the INPO Job Analysis in your own plant-specific analysis.
And part of the reason that we tied our analysis at the generic level to the INPO Analysis was so that the system names and numbers, and the resulting material, would be easily keyed at the plant-specific level to the K/A Catalog.
Q. 138. What will the Commission do to ensure that operator exams are both valid and reliable from a psychometric perspective? '
A. Many things. One: We're working on a sampling plan developed by subject- matter experts that will better reflect the job'of the operator as opposed to, the four evenly weighted written exam sections currently in the Examiner's Standard.
Two: We'll be sampling only those items that received a high importance rating to ensure the exam's content validity.
Three: We have a meeting on May 18th in which we're bringing together another panel of experts first to evaluate our proposed sampling plan and document the basis for our passing point.
Four: We are conducting continuous, extensive training with our examiners on writing and reviewing questions, and we are evaluating feedback from the industry on the quality of our examinations.
Finally, we are continuing to make improvements to the exam question bank, which will include a validation process using statistical techniques to eliminate poor questions.
Q. 139. The statement of considerations makes the following statement: "Ulti- mately, the NRC test objectives will reflect facility licensee developed learn- ing objectives.. ." With an INPO-accredited program already developed from a job-task analysis'(JTA), does our training standard (site-specific learning objectives) supersede the NRC Knowledge and Abilities--Catalog? How do we get regional concurrence that they will test to our training standard?
A. It's our intent to use site-specific learning objectives as the basis for our testing objectives. However, if we detect errors of commission or omission in the site-specific reference material (including learning objectives), we obviously will not shapeour exam content to those errors.
Q. 140. Criminal violation only covers persons who willfully violate the Atomic Energy Act or NRC's regulations, and does not'apply to situations such as discussions after an examination is administered or when a previously admin- istered examination is used as a practice exam. What is the attitude of the NRC concerning distribution of the facility's examination bank to the examinees?
NUREG-1262 37
A. NRC has no specific policy concerning the distribution of the facility's own examination bank to their examinees. While some portion of training may be given using previously administered examinations as references, this should not be interpreted as NRC endorsement or acceptance of such a practice exclusively.
Written Examination: Senior Operators (Subpart E, Section 55.43)
Q. 141. The Commission Policy Statement on Technical Specifications and im- provements may result in a substantial increase in scope and documentation.
Will any effort be made to limit the knowledge required of senior operators to those elements of the Technical Specification basis that are essential for safe operation?
A. Yes. We have an ongoing program looking at the issue of what needs to be examined at the SRO level, as opposed to the RO level. And we are working with the people developing these new Tech Specs and intend to make sure that we are producing a performance-based exam.
That's not to say that there won't be some additional exam material that comes from the new Technical Specifications. But, again, it will be performance based, job relevant, and safety-significant material, and we will provide ample guidance to the examiners, in the examiner standard, as this program develops.
Q. 142. When we were developing standardized Techical Specifications, the re- quirement was that an operator know from memory, and be able to apply "one- hour-or-less," action statements from the Tech Specs. Since standard Tech Specs have come in, there are now well over a hundred one-hour or less action statements from Technical Specifications. Is the policy, or the guidance from the Commission still the same, to commit those to memory, recognizing that the utilities do not rely on nor require the operators to act from memory in that situation?
A. We are dealing with performance-based knowledge that an operator needs to know. Specifically, if the information is appropriate to the job, if it is in the K/A Catalogs with a high importance rating, he should know that informa- tion. If there is not a specific knowledge or ability associated with it or those that are have a low importance rating, then normally it would not need to be examined. However, there may be procedual steps or other indications that cause him to look into the Technical Specifications. The method you use procedurally in the plant for these indications, through performance-based testing under certain circumstances, such as procedural or event-related pro- blems, would be the method that would be followed by NRC. We don't have any blanket rules that require memorization of everything in Technical Specifica- tions that has to be done in less than an hour. That is not our policy.
Ensuring that our examinations are operationally oriented and job related is our policy.
Q. 143. Senior operators are required to know the facility operating limitations in the Technical Specifications and their bases. If and when the Westinghouse Owner's Group completes development work and gains acceptance for the Technical Specification MERITS program, this will vastly increase the bases section of the Technical Specification. Will the NRC position change regarding the require- ments to know the Technical Specification bases if this new program is implemented?
NUREG-1262 38
A. No. As we implement improvements to Tech Specs, we hope to reduce their size'substantially as a result of this program and to do a better job of describing the why's associated with the limits and the underlying assumptions that relate to them.
We hope that in the long run we will better define the knowledge that a senior operator should have related to the Technical Specifications and their bases.
We don't'expect that the volume of the bases to increase to several three-inch notebooks. It should be significantly reduced compared with what's contained'
in the FSAR. It's going to require a topical report submission and an approval by the staff before-it can beimplemented on a plant-specific basis. We will be looking at generic bases',' and'there will be an opportunity for utilities to comment.
Our intent is not to add superfluous information; it needs to be related to the job.
Q. 144. Section 55.43(b)(3) refers to the facility licensee procedures required to obtain authority for design and operating changes in the facility. What is the intent of this? Should the SRO understand the process-the licensee goes about in obtaining a design change?
A. There may be administrative procedures which would allow, for example, two SRO's on a back shift to change a-procedure, as long as they don't change the intent of the procedure. Or, there may'be other aspects of the 50.59 review process which an SRO is-held accountable for knowing. He may be the shift supervisor, on shift at the time, responsible for those activities. And it's that type of administrative procedure we are addressing.
Q. 145. Therefore, are we talking about temporary alterations, not design changes, or permanent license'changes?
A. He needs to understand what he's approving when he approves the work to be done in the plant. 'We're'looking principally at those things which he can ap- prove; deviatation from a procedure, an alternative approach, etc. The 50.59 type process, how those changes are controlled, and what it means when he signs off to approve a work package, is likewise important. This process may change the design of the facility, or change the way the facility is operated by a procedure. For clarification, there has been no change in this area from the previous Part 55.
Q. 146. What maintenanceiactivities are included in 55.43(b)(4)?
A. Section (b)(4) talks about radiation hazards thatrmay arise during normal and abnormal situations, including maintenance activities, and various contami- nation conditions. A'common item may, for example, be a radiation work permit (RWP). He may be responsible for' signing off, either'in 'concurrence or approval, depending on the 'facility, on the RWP,'so lie'would be expected'to have site- specific knowledge'lin that'area.
Q. 147. Part 55.43 does not specifically address emergency plan implementation.
This is addressed'in Part 55.45. Will the senior operators continue to be asked to classify events, given a'specific scenario, into four categories (UE, Alert, SAE, GE) from memory on the written examinations?
NUREG-1262 39
A. Item 5 in Section 55.43(b), stipulates that SROs must be able to address the "assessment of facility conditions and selection of appropriate procedures during normal, abnormal, and emergency conditions." However, neither ROs nor SROs are required to classify events from memory.
Operating Tests: Content (Subpart E, Section 55.45(a))
Q. 148. Is there a definition of plant equipment that could affect the release of radioactive materials to the environment, per 10 CFR 55.45(a)(8)?
A. There are many systems and many controls that an individual can operate that could cause a release; operators are required to understand these systems and controls, which are the responsibility of licensed personnel.
Q. 149. Does 10 CFR 55.45(a)(10) imply that operators must perform exposure shielding calculations?
A. That depends on how these calculations are made at your facility. If you have an on-shift health physicist or, in an emergency, an STA, then we would not ask operators to do the shielding calculations. But if the SRO typically checks such calculations, then we may ask the SRO to check one.
Q. 150. Items 12 and 13 of Section 55.45(a), were reworded to include the phrase "as appropriate." What is the significance of this phrase for the Com- mission to classify this change as "major" in the final Regulation?
A. The comparison that we're making in the Statement of Considerations, Sec- tion IID(2), is between the proposed rule published in November 1984 and the final rule. Items 12 and 13 were significantly rewritten between the proposed and the final rule. To clarify, we have made sure that you're held accountable for performing as appropriate to the assigned position. So ROs are not expected to pass a test at the SRO level.
Q. 151. How will you evaluate Item 13, "Teamwork," in the operating test? I'm talking about the operating test itself, when you have to evaluate one single candidate on how he reacts and interreacts with the team?
A. You could put some licensed operators on the team with him, and we would just put an examiner with the individual taking the exam. You could have one of your instructors standing there, as we have done in the past.
Q. 152. How would you evaluate this if we didn't have a simulator?
A. It is the responsibility of the examiner to structure his operating test scenarios for the Integrated Plant Operations portion of the test that would create situations that would challenge the candidate in competencies G
(communication/crew interface) and H (responsibilities/supervision). Obviously this would require a discussion format since the operating test without a simu- lation facility is a one-on-one test. For example, a scenario could have an SRO candidate evacuate the control room. He would then be expected to shut down the reactor from the local shutdown panel. He should be able to talk through how he would utilize his resources, including direction, communication, and report backs. Questions would be phrased as follows: What would you direct NUREG-1262 40
the BOP to do? What reports"do you'expect to receive from the RO upon reactor trip? How would you verify a questionable report from the BOP/RO? How do you evaluate the licensed operator's use of nonlicensed operators during local operation of an auxiliary feed pump?' '
Q. 153. Part 55.45(a) contains a new.evaluation criterion which requires an applicant to demonstrate the ability to function within the control room team as appropriate to .the assigned position ard in such a way that the facility li- censee's procedures areiadhered to and so-that the limitations in its license:
and amendments are not violated. Is this criterion intended to be evaluated using the manipulation criteria-addressed on the operating examination report contained in ES-302 which requiresthat an applicant: (1) follow procedures,
(2) observe and check instrumentation, (3) exhibit dexterity and a feel for console operationsi. Or, will this evaluation be addressed in afuture revision of ES-302?
A. This criterion is addressed in the operating test using the existing ES-302 with the new'Form 157.' -Sped fically, the 'form identifies, in competencies G and H (both with and without a'simulator),, the 'evaluation of communication/crew interaction and responsibility/suppervision.!
Waiver of Examination and Test Requirements (Subpart E, Section 55.47)
Q.: 154. In 10 CPR 55.47, what is a qomparable'facility?
A. This question addresses the waiver of written examination and operating test requirements. We wouldilook at each waiver on a case-by-case basis, and make a determination as to whether or'not the facility was, for licensing pur- poses, "'close enough."'
- , ; ,~ ~ ,- - ' . '
NUREG-1262 41
SIMULATION FACILITIES
Written Examinations and Operating Tests: Implementation (Subpart E,
Section 55.45(b))
Q. 155. Will NRC continue to examine operators on plant-referenced simulation facilities following the effective rule date, but prior to the submittal of the simulator certification?
A. Yes. If we're giving exams on your simulator now, we will continue to do so.
Q. 156. Will NRC examine operators on nonplant-referenced simulators for those utilities that have accredited training programs and use a nonplant-referenced simulators between the date that the new rule becomes effective and simulation facility approval by NRC is achieved?
A. We anticipate no change from what we're doing today.
Q. 157. Our facility will not have a plant-referenced simulator available for training until the first quarter of 1990. It is assumed that operating tests will consist entirely of plant walk-throughs until such time as a plant ref- erenced simulator is certified. Is this a correct assumption?
A. Yes, but in the event the utility were to start using that simulator to evaluate candidates prior to the time at which they chose to certify it, we'd have no problem with the examiners using it to conduct operating tests.
Q. 158. Are the provisions of 55.45(b)(2)(i), and 55.45(b)(2)(iii) mutually exclusive? In other words, if the utility plans to meet the provisions of
55.45(b)(2)(iii) by purchasing a simulator during the 46-month period, does the utility need to submit a plan per (b)(2)(i) for the simulator to be used until the plant-referenced simulator is certified?
A. No. If you intend to certify a simulation facility on Form 474, you have
46 months from the effective date of the Rule to do that, and you do not need to submit to us a plan, or an application, prior to that time. If, however, we do not see any evidence that there are plans in the works for a certified simulation facility, and if we have not seen a plan from you for a noncertified simulation facility, we'll probably get in touch with you to find out what your intentions are.
Q. 159. We currently have a site-specific simulator, and it has been used to administer the simulator portion of the operating tests. Do we have 46 months from the effective date of the rule to submit Form NRC-474, "Simulation Facility Certification"? Will the simulator tests continue to be administered on our noncertified simulator before we submit the Form 474? Under what conditions would NRC refuse to administer operating tests on the simulator?
A. Yes, you have 46 months to submit Form 474, and, yes, the simulator will continue to be used for the conduct of exams until you submit that Form 474 or until you reach the four-year deadline. NRC would refuse to administer operat- ing tests if the simulation facility has not been certified by the deadline or if, after it has been certified, an inspection proves that it is unable to meet NUREG-1262 42
the requirements of conducting an operating exam.- And, if certification is pulled, then it needs to be recertified.
Q. 160. For simulators that are not plant specific, when the regulation goes into effect in May,iare you going to start giving nonplant-specific simulator exams?
A. No. We do not intend to administer such exams. Those few plants without plant-referenced simulators will be handled on a case-by-case basis.
For clarification, once a utility begins to use a simulator to evaluate its operators, we would retain the option to use it to conduct our operating tests, even though it may not yet be approved or certified.
It's our intent to continue with business as usual from the effective date of the regulation until such time as you either have-an approved simulation facil- ity, or you have certified a simulation facility. Or, of course, the four-year deadline arrives.
In other words, if we presently conduct operating exams in a walk-through because you do not have a plant-referenced simulator or you do not have an acceptable simulation facility, we-would continue to conductexams on a walk-through basis.
But if you do obtain a simulation facility between now and the date that you chose to certify it, if you find the simulation facility is acceptable for your use in evaluating operators then we will find that same simulation facility.,
acceptable for our use in evaluating operators, even prior to the time it is certified or approved.
One other clarification. It does not matter who owns a simulation facility, or where it is located--the key is the plant to which it is referenced. And the facility licensee'is the one who must certify that simulation facility for use regardless'of whether that facility licensee is the owner of that simulation facility or not. -
Q. 161. Several simulators are still in the manufacturing pipeline, to be de- livered in the next two years, while a few are still just beginning their pro- curement activities. Is this plan required within one year regardless of whether the utility is in the process of procuring a simulator?-
A. The plan referred to is required only for those utilities which are not planning to submit a certification on Form 474. If you are procuring a certi- fied simulation facility, there is no plan required and there is no application for approval required, regardless'of where in the pipeline your procurement is.
If you are not procuring a simulation facility that is to be certified on Form
474, then there is a plan required and there is an application for approval.
Then the answer is yes, we'would expect that plan to be submitted to us within'
one year of the effective date of the regulation, regardless of where you may be in the procurement cycle.
Q. 162. Consider the'utility undergoing the simulator procurement process right now'. There is certainly the realistic possibility that that simulator will NUREG-1262 43
not be delivered and declared ready for training until sometime in 1990. At that time it will be approximately two and a half years since design data freeze.
In that period it's reasonable to expect that the utility would not be able to meet the requirement of ANSI/ANS 3.5, 1985 that the plant reference simulator be current within 12 or 18 months of the reference plant, to which you are attesting when you sign the material-false-statement on Form 474. Does this mean that this utility would have to submit a plan for an alternative within
12 months of May 1987?
A. We would still expect a certification from those utilities on Form 474, rather than the application for approval. If necessary, you would take excep- tion to meeting some of the requirements of ANS 3.5. These would have to be identified and described, along with a description of when and how they would be resolved. There is a provision on Form 474 for this information to be supplied.
Q. 163. In other words, they would not be held to the statement that says they are or are not in compliance with ANSI 3.5?
A. That is correct. The facility licensee would address them as exceptions to ASS 3.5.-
Q. 164. I didn't see on the proposed Form 474 an area that addresses exceptions.
A. There is such a block on the form. It might not have been on an early version of the form; but on the final version you will see an area near the top which indicates exceptions taken to the standard.
That's not an unusual circumstance just for those who are buying new simulation facilities. Because design modifications are made in the plant, you may at the time of certification have modifications made in the plant that you have not yet put into the simulation facility.
The process provides for reference plant data and design data for the simula- tion facility, and there can be as much as two years' difference between the time these two conform with one another. If you're not in conformance at the time you certify, if there's some exception, identify that in the exceptions sections and indicate on what schedule you're going to correct it.
If we disagree with the exceptions, we'll visit you. But if you've done a reasonable job of identifying them and we still conclude that we can conduct an operating test, we'll accept that certification.
Q. 165. In Section 55.45, implementation schedule and simulation facility cer- tifications, what is the relationship of the two timetables provided in (b)(2)(iii), which is 46 months, and (b)(3)(iii)-, which is 60 days?
A. There is no relationship between them. The 46-month requirement in (b)(2)(iii) refers to. facility licensees, which includes anyone who has a doc- keted application. The 60-day requirement in (b)(3)(iii) refers only to what we call facility applicants, which includes only those without docketed appli- cations. So you can ignore that 60-day requirement.
NUREG-1262 44
Q. 166. Do we have a requirement to certify a simulation facility to NRC prior to its being used for an operating exam?
A. No. You have a requirement to certify a simulation facility to NRC no later than four years after the-effective date of the regulation. Prior to that four-year deadline, it can still be used for conducting operating exams whether it is certified or not..
Q. 167. Due to the extensive use of the simulator for training, there may be times that meeting the 25 percent performance testing requirements within 12.
months of the last set of tests is not possible. What is the allowable time table tolerance regarding this situation? For example, is it permissible to perform 50 percent testing in one year and no testing in the next year, as long as 100 percent testing occurs every four years?
A. The regulation provides, in 55.45(b)(4)(vii) and (b)(5)(vi), that perform- ance testing be done at the rate of approximately 25 percent per year on a continuing four-year cycle. The goal is to ensure the ongoing testing and up- grading of the simulation facility, and to assure that it is maintained on a consistent basis with the status of the plant. You must present to us,. on Form.
474, your performance testing schedule. To the extent that it must deviate from 25 percent per year, if it must deviate, you need to let us know just what those deviations are and we will have to evaluate it case-by-case. It s safe to say that performing 50 percent of the tests in one year, and no tests in the next year would not meet the intent of the regulation.
For clarification, we really don't want to see the minutiae of your performance testing schedule, which tests are to be run on which days of which months.
We're looking at an annualized 25 percent per year basis, and that's the block of time in which we would like to see your performance testing scheduled. Any changes that may need to be made to that schedule, you need to tell us about, based on that annual block.
Q. 168. What is the required retention period for simulation facility-test procedures, modification documentation, and discrepancy reports?
A. Four years is the record retention period. But at any given time, you may have accumulated and held on to more than four years' worth of data, because you are performing your performance tests at the rate of 25 percent per year.
So if you certify, hypothetically, at time zero and then you submit your first four-year report on the four-year anniversary of that initial certification, at that time in year four you can discard the results of the performance testing that you had for the initial certification. Then when you submit-your next four-year report at year eight,.you can discard all the performance testing documentation that you used to submit the first four-year report.
So it's a four-year period, but as you accumulate the tests at 25 percent per year, you're going to be retaining these test results until the time comes at your next report to discard it.
Q. 169. Regarding decertification of a plant-referenced simulator; What process will be used to decertify a simulator? Will-an NRC examiner be able to decertify a simulator based on his observations of simulator performance during an NRC
exam?
NUREG-1262 45
A. No. An examiner will not be able to decertify a simulation facility based upon his observations. He will report those observations to NRC, and the staff may use that information to perform an audit or an inspection. "Decertification"
can occur only as a result of an inspection which finds that the simulation facility is incapable of being used for the conduct of an operating test.
Q. 170. Section 55.45 requires that within one year after its effective date, each facility licensee proposing to use a simulation facility must submit a plan detailing how and when their simulation facility will be developed and submitted for approval. Must a utility that operates dual units at the same plant and that currently obtains a multi-unit operator license from the NRC
submit this plan for the unit not being replicated?
A. The key issue is the similarity of the two units. The availability of current multi-unit licenses would lead us to believe that you do not need to submit an application for approval for the simulation facility for those units.
We in all likelihood will accept certifications on Form 474 with the exceptions noted for each unit.
Q. 171. If a utility with multiple units believes that the units are too dissimilar to support Form 474 certification, what format requirements, if any, does the Commission wish to see in the application for approval?
A. Here is an example of what we'd expect. Let's assume that you have a dual unit control room and that the control rooms are identical with the excep- tion that they're mirror images of each other. Your physical fidelity compari- son in accordance with the standard would identify as an exception the mirror- image layout.
One Form 474 would indicate that the mirror-image issue was a difference, but you conclude that's acceptable for an operating test. And you'd reference the certification form for the other unit; that is, you'd identify all the other exceptions that you may have. So one is tied to the other. That way we get a form that says it's certified for each plant to which it's referenced.
Where you have a simulator now which is on site and which replicates two units, we would expect you to use the certification process.
Q. 172. Several utilities are not planning to obtain plant-referenced simulators.
They prefer to use other simulation devices. Assume that a facility licensee has constructed and is operating a plant-referenced simulator that meets the provision of Regulatory Guide 1.149 and ANSI 3.5 and has been certified to the NRC for use for operators and senior operators who operate the reference plant or are candidates for a license at that plant. A second utility wishes to use the simulator as their simulation device rather than construct and operate a plant referenced simulator. What procedure must the second utility follow to obtain approval to use that simulator?
A. The answer assumes that the utility who wants to use it is treating At as a noncertified, nonplant-referenced simulator. It does not matter who built the simulator, who owns it,where it's located. The facility licensee who NUREG-1262 46
wants to use a particular simulation facility for conducting operating tests is the organization that is required to file a certification or to apply for approval to use it. So in this case, the procedure that the second utility must follow would .be to submit a plan within a year, followed by the applica- tion for NRC approval to use that simulation facility, whether they are the owner of it or not.
Q. 173. Has the staff developed guidance and/or criteria regarding the use of a certified plant-referenced simulator by individuals other than those from the referenced plant?
A. It is possible for-any particular simulation facility to be certified as referenced to more than one plant, to the extent that those plants are similar.
But only the facility licensee who wishes to use a simulation facility-for its reference plant should submit the certification for its use. So if one simu- lation facility is intended to be used by several different licensees for different plants, then we would expect to see several different certification forms coming in, one for each of those facility licensees.,.
Q. 174. Does this guidance apply to facility licensees that wish to use another facility licensee's plant referenced simulator?
A. Yes, but there are some very practical issues that utilities are going to have to address in the area of configuration control, plant design changes, and getting those plant design changes referenced back into the simulator.
Some of those can be taken care of with software, by having a different data pack, tapes, etc. Others are going to be very difficult to take care of where they relate to control board location or systems that you have on the device that are different. Clearly, where two utilities want to use the same simula- tion facility, they are going to have to work out agreements with each other as to how they are going to maintain configuration control such that the same device can be used for the operating test at each utility.
We have not precluded that a facility may certify a simulation facility owned by someone else to its reference plant; but the requirements for having an appropriate configuration control system still exist, and you must still follow the ANSI standard. So that if you get into that mode, you may find it diffi- cult over the long term.
Q. 175. Assume that an entity has constructed and is operating a plant- referenced simulator that meets the provisions of Regulatory.Guide 1.149 and ANSI/ANS 3.5-1985, and has been certified by NRC for use by operators and senior operators at the reference plant, or who are candidates for license.
A utility wishes to use the above simulator as their simulation device rather than construct and operate a plant-referenced simulator. What procedure must the utility follow to obtain approval to use the above simulator?
A. Only facility licensees are to certify simulation facilities to NRC or request approval for simulation facilities. If an entity means a facility licensee under 10 CFR Part 50, then that's fine. If it means some other organizational body, then that would not be acceptable for certifying, or NUREG-1262 47
applying for approval of a simulation facility. It does not matter whether that utility owns that simulation facility. It does not matter where that simulation facility is located, but it is the utility who must certify, or apply for approval to use it.
If that simulation facility referred to is referenced to a facility licensee's plant, then the process to be followed is certification on Form 474. If it is not referenced to the facility licensee's plant, then the proper approach would be submittal of a plan within a year, followed by application for NRC approval.
Q. 176. Title 10 CFR 55.45(b)(4)(i) states, "In accordance with the plan sub- mitted pursuant to Paragraph (b)(2)(i) or (b)(3)(i) of this section, as appli- cable, submit an application for approval of the simulation facility to the Commission, in accordance with the schedule in Paragraph (b)(2)(ii) or (b)(3)(ii)
of this section, as appropriate." What performance tests are required and what standard is used to evaluate whether the tests are satisfactory or not?
A. To the extent applicable even to those simulation facilities that will not be certified, ANS 3.5, as endorsed by Reg Guide 1.149, is the standard to be used. The performance tests include the malfunctions identified in Sec- tion 3.1.2 of the standard to be done at a rate of approximately 25 percent per year over an ongoing four-year cycle; the performance tests that are speci- fied in Appendix A of the standard, also at the rate of 25 percent per year;
and the operability tests identified in Appendix B to the standard that are to be done annually.
The criterion .for the performance of these tests is that the simulation facil- ity must be capable of being used for the conduct of the operating tests which are identified in Section 55.45(a) of the regulation, and the staff will inspect simulation facilities against that requirement.
Our definition of "plant-referenced simulator" differs from the ANSI standard definition in that we require that a simulation facility be capable of being used with the plant's control room procedures, and we would inspect against the ability to use those procedures as well.
Q. 177. Sections 55.45(b)(2)(l) and (ii) state that within one year a plan shall be submitted for a simulation facility (other than a plant-referenced simulator),
and within 42 months an application for use of the simulation facility must be submitted. When will the facility licensee know if the plan for the simulation facility is acceptable to the NRC? What criteria will NRC use to determine acceptability? Can the plan be modified after the first submittal?
A. The minimum acceptance criteria for nonplant-referenced simulators as simulation facilities include the capability for conducting the operating tests identified in Section 55.45(a) and their ability to operate under the use of the control room procedures.
The nonplant-referenced simulator alone or in combination with other devices must demonstrate acceptability for conducting these operating tests using con- trol room procedures.
NUREG-1262 48
The staff will review the plans for such simulation facilities against the criteria specified in the regulation for the conduct of the operating tests;
and to the extent applicable, we will also apply the requirements of ANS 3.5 as endorsed by Regulatory Guide 1.149 even for nonplant-referenced simulators.
The staff intends promptly to inform any facility licensee if the staff's re- view of the plan or the application submitted is not satisfactory for being able to conduct these exams.
We plan to meet with the small group of facility-licensees who have indicated an intention to request staff approval of simulation facilities during the year following the effective date of the regulation and prior to the deadline for their submittal of a plan for application for approval.
Finally, although we expect that our initial meetings with these few facility licensees will result in sufficiently specific guidance that modifications to plans won't be needed after submittal, we don't want to preclude such modifica- tions if the facility licensee judges them to be necessary or desirable.
Q. 178. The preparation of a simulation facility plan will cost money and re- sources. If an submitted simulation facility plan is not acceptable, the NRC
should let the utility know it is wasting its time as soon as possible. If a utility submits a plan for an "approved simulation facility" before May 26,
1988 will the utility receive an-indication of whether or not the NRC will approve the simulation facility? Or, will the NRC approve the simulation facility only after application within the 42-month period stated in the rule?
A. The NRC will review the plan submitted by each facility licensee which proposes to use a simulation facility pursuant to Section 55.45(b)(1)(i). The facility licensee will be provided the results of such review. However, ap- proval of a simulation facility (in accordance with Section (b)(4)(ii)) pro- posed pursuant to paragraph (b)(1)(i) will only be considered after receipt of an application submitted in accordance with Section 55.45(b)(4).
Q. 179. When a simulation facility evaluation is conducted by the NRC, plant operators may be used to perform the operations using plant procedures. In this case, are the operators performing on a "no risk" basis to their licenses?
If not, will the operators receive-credit for an operating test? Could cer- tified instructors be used to demonstrate the simulation facility evaluation test instead of plant licensed operators?
A. During a simulator evaluation, no evaluation will be made of plant opera- tors. If clearly unacceptable performance -isidentified, the operators and specifics of their performance will be identified to the facility licensee for appropriate action. Qualified simulator instructors would be acceptable for demonstrating simulator performance.
Q. 180. When a malfunction is used during training can we take credit for it as a performance test?
NUREG-1262 49
A. If all of the requirements of the Perfomance Test including planning, scheduling and documentation as required on Form 474 are met, credit may be taken for completion of the Performance Test.
Q. 181. Paragraph 55.45(b)(4)(i)(B) states "A description of the cbmponents of the simulation facility which are intended to be used for each part of the operating test" must be included as part of a facility's application for ap- proval of simulation facilities. Please elaborate. Does "intended" mean
"can?"
A. The word "intended" means that the listed component is that which the facility licensee plans to use for the evaluation of a specific one of the 13 items specified in 55.45(a).
Q. 182. Assuming that a utility were to submit a plan to certify a non- reference plant simulator as a simulation facility, what minimum criteria would this facility be required to meet (since operator testing using reference plant procedures would be limited or not possible) and what aspects of the non- reference simulator would disqualify the device from certification as a simula- tion facility?
A. The minimum criteria for approval of simulation facility are contained in
55.45(b)(4)(ii), which requires that it be suitable for the conduct of operat- ing tests for the facility licensee's reference'plant. The operating test requires that the 13 items listed in 55.45(a) be able to be adequately eval- uated, and that plant procedures be used. Further details of simulation facil- ity characteristics necessary for NRC certification are contained in Regulatory Guide 1.149 and ANSI/ANS-3.5-1985. For clarification, a non-plant-referenced simulator would be developed following a plan and then an application for NRC
approval. It would not be certified using NRC Form 474.
Q. 183. For utilities which have not yet received simulation devices from their respective vendors, when will they be required to undergo simulator examina- tions as part of their operating examination? When ready for training? When certified by the utility? When utilized by the facility as an evaluation tool?
Does the above answer change for any facility which currently possesses a simulation device, but asks that it not be used for NRC examinations until such time that it is certified?
A. No simulation facilities will be required to be used in the conduct of operating examinations until May 26, 1991, unless they have been certified to the NRC or approved (after application) by the NRC earlier. However, if a simulation facility is used by the facility licensee as an evaluation tool, the NRC will use it for exams as well. This would hold true despite any request by the utility that it not be used until certified.
Regulatory Guide 1.149 Q. 184. In order for a utility to comply with ANSI/ANS 3.5-1985, it would have to use a full-scope nuclear power plant control room simulator. The standard states the following under Section 1, Scope: "Also excluded are part-task or limited scope simulators intended for specialized training or familarization."
NUREG-1262 50
the This means that non-full-scope simulators would clearly be excluded from of a Standard, and, hence, a simulation facility that does not consist solely use to full-scope simulator has no guidance or standard which a utility may conclu- obtain NRC approval. The previous statement leads us to the following become the only standard for sions: If Reg. Guide 1.149 and ANSI/ANS 3.5-1985 facility determining the acceptability of a simulation facility, the simulation must be a full-scope simulator, is that correct?
takes exception A. No. Regulatory Guide 1.149, in regulatory position (c)(2), Guide says that to those segments of the Standard that were just cited. The Reg (and that simulation facilities, as defined in Section 55.4 of the Regulation meet includes the plant, and potentially other simulation devices) should
-
applicable requirements of the Standard. Also remember that Regulatory of the Guide 1.149 is only one acceptable means of meeting the requirements to meet- Regulation, and that facility licensees may propose other approaches ing the Regulation.
than certified We'intend to evaluate those simulation facilities which are other to the point of plant-referenced simulators on a case-by-case basis, once we get dealing only with the applicable portions of the Standard.
represent the Q.-.185. IfURegulatory Guide 1.149 and ANSI/ANS 3.5-1985 do not facility, will only standard for determining the acceptability of a simulation to them for NRC identify the minimum standards and criteria that are acceptable non-full-scope simulators?
Guide A. Those two documents do describe the only standards. But Regulatory propose
1.149 is a Guide, it is not a regulation. A facility licensee-may than the alternative ways to comply with the regulations in Part 55, other submittal of the information in Regulatory Guide 1.149.
3.5-1985 to Q. 186. Does NRC continue to'endorse the requirement in ANSI/ANS the 25 percent perform annual operability tests? If so, should this be part of testing, or should it be done annually?
the standard A. Yes. We endorse Appendix B on operability testing, and as 25 percent requires, this must be done annually. This is not a part of the performance testing.
plant modifica- Q. 187. Section C4 of Reg. Guide 1.149 specifies that reference update tions be reviewed annually against the simulator and that the simulatorannual review design data be revised as appropriate,,and that the first such licensee's and update should take place within one year following the facility to certification. Does this mean we have until a year after certification or 18 months match the simulator update design database to the reference plant 5.2?
after'simulator operational date, as specified in ANS 3.5, Section database which A. No. According to Section 5.2 of ANS 3.5, you start with a months may, for nonoperating plants, be based on predicted data. Eighteen design data after the simulator is ready for training, your simulator update line before the must include available plant data, unless the simulator is on plant becomes plant, in which case you have 18 months from the date that the is operational operational. In accordance with the standard, it's whichever later, the plant or the simulator.
NUREG-1262 51
Section C4 of Regulatory Guide 1.149 refers not to the development of this update design database, but rather to the annual review of reference plant modifications that are called for in the same Section of the standard, the results of which must be added to the update design database.
The standard says, "Reference plant modifications shall be reviewed at least once per year, and the simulator update design data shall be reviewed as appropriate." Section 5.3 of the standard goes on to say that the simulator shall be modified as required within 12 months. It is this cycle of the annual review'df plant modifications, followed within 12 months by simulator modifica- tion as required, that we expect will begin with your certification on Form 474.
The rest of Section 5.2 addresses when your database must include actual plant data. And the two time schedules are somewhat independent.
You must still base the simulator update design data against the reference plant within 18 months after the simulator is operational. But you must begin your cycle of annual plant review of reference plant modifications when you submit the certification.
Q. 188. Section D, "Implementation," of Regulatory Guide 1.149, outlines a procedure to be followed for a facility licensee that wishes to utilize a simu- lation facility at more than one nuclear power plant. Does this guidance apply to facility licensees that wish to use another facility licensee's plant- referenced simulator?
A. Yes. But the facility must certify that the simulator meets the requirements of ANSI/ANS 3.5-1985, as endorsed by Reg Guide 1.149, for his plant. In review- ing such'certifications, we would be particularly concerned about how you handled configuration control. Because you would have the potential for multiple de- sign changes at a facility, we would have to understand how you are going to ensure that the simulation facility tracks the different plants.
Q. 189. What procedure must be followed to determine whether a two-unit site will require only one plant-referenced simulator?
A. There is considerable guidance on this in the "Implementation" section of Regulatory Guide 1.149. It says that if a facility licensee wishes to use a simulation facility at more than one nuclear power plant, it must demonstrate to NRC in its certification, or in it's application; that the differences be- tween the plants are not so significant that they have an impact on the ability of the simulation facility to meet the regulations in 10 CFR Part 55.45(a), and the guidance of ANSI/ANS 3.5-1985.
There is a list of indicators that can be used to demonstrate that there are not such significant differences. One of the key areas that we-will look at is whether we issue multiple licenses for your operators of those facilities.
ANSI/ANS 3.5, 1985 Q. 190. ANSI/ANS 3.5-1985 requires that performance tests be conducted in the event a design change results in a significant simulator configuration or per- formance variation. What is the NRC's definition of significant?
NUREG-1262 52
its A. Our operational definition is any change to the simulation facility, to fall models or software that might cause the results of performance tests The outside the acceptable performance criteria set within the standard.
or an standard does not define "significant," and for an official definition, pos- official clarification, you need to seek guidance from ANS itself. It's sible that this definition will be clarified in the next revision to the standard, but unless and until it is, we will use our operational definition.
Q. 191. This question concerns the list of required malfunctions in performance testing and ANS 3.5-1985. Are those not more "events" versus "malfunctions"? ven- Do you understand that this causes confusion on the part of the simulator trip dors in that if I was to go to a vendor and tell him that I want a reactor to power malfunction, he's going to wonder what I'm talking about? Do I want How do I
the CRD breakers? Do I want to lose all reactor coolant system flow?
me to per-
-want to do this to create the abnormal event that ANSI 3.5 is asking form? Isn't that really referring to a list of abnormal transients?
A. Yes.
of Q. 192. ANSI/ANS 3.5 Section 3.1.1(7) requires that the simulator be capable cool- rated reactor performing startup and power operations with less than full ant flow. If the facility licensee is not allowed by Technical Specifications to conduct such operations, is this capability still required?
A. No. If a plant is constrained in any particular area'by its Technical capability Specifications, then the simulation facility need not possess-that as it applies to routine operations.
under which Q. 193. The Technical Specifications clearly bind the conditions only needs to the plant is allowed to operate. Am I correct that the simulator be bound by the same parameters?
in A. No. For normal startup and shutdown practical-factor evolutions, the to be outside accordance with your procedures, you-need not model those the context of bounds of the Technical Specifications. The question came up in operation with a recircula-
"N-minus-1 loop operation"; for instance, continued coolant pump tion pump out of service or continued operation with one reactor operation in out of service. You need not model the simulation facility for start up in that mode. It was that mode if you are not permitted normally to with respect to the context for startup.
restoration Clearly, emergency procedures, for example, which go into function guidelines and go beyond design basis accidents are not covered by Tech Specs, able to reasonably model those but we expect the simulation facility to be turn off events. The same holds true when you insert malfunctions. If you bounds of the Technical Specifica- power to a panel, you're clearly outside the So in general, tions. You would not be operating with that panel de-energized.
if you are conducting malfunctions, you may be in that mode.
reactivity co- Q. 194. ANSI/ANS 3.5 Section 3.1.1(9) states that measurement of be efficients and control rod worth using permanently installed instruments performed. What is meant by "'permanently installed instrumentation?"
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A. The question of the meaning of the term "permanently installed instrumenta- tion" is in ANS 3.5, and official definition or clarification really has to come from ANS and not from the Commission.
Our operational definition essentially says that portable or temporary instru- mentation that is brought into the control room for specific modes of operation, such as startup, would not be required as part of the simulation facility.
We intend that you use the normally installed instrumentation available in the control room and not instrumentation associated with special tests.-
So if it's part of your normal plant operating procedures and it's instrumenta- tion you rely on (and we expect that you have instrumentation that falls into that category for calculating rod worth for doing startups) that's what we intend you to use. You need not simulate other instrumentation that is outside the scope of your normal procedures.
Q. 195. ANSI 3.5 Section 3.1.1(10) states that the simulator be capable of per- forming operator-conducted surveillance testing. Are you only considering the remote shutdown panel?
A. Any surveillance that cannot be performed from the control room need. not be modeled. For example, if you're doing a diesel startup from the local panel for the diesel and that's the way you conduct the surveillance, you need not model anything that's done on a routine basis from outside the control room.
Q. 196. Would it be wise to evaluate, for example, the plant's surveillance pro- cedures and identify which of those we think would be applicable to being done on the simulation facility? In other words, generally the operator from the control room would be doing that evolution. Naturally, all of those valves exist on the control board and so on, and you can legitimately perform that.
Would that be acceptable in meeting the intent of Item 10 in the standard?
A. That would be one way of doing it. But if you look at the performance testing, particularly when you're getting out of component testing and into system test- ing, and you're evaluating your capability to actually model the system, a way of doing that would be to see if you can model the surveillance procedures on that.
What you describe is acceptable. You may choose some subset of the surveillances that you can perform on those particular systems to show that those systems are operating within the bounds expected by the plant.
After all, that's where you have a source of data on the actual performance of the system: the records from the surveillance tests that you've conducted on those systems, particularly where they have specifications for flow or pressure or some other characteristic which is modeled in the control room.
Q. 197. Plant data, simulator update design data, and simulator design data:
interpret their relationship this way. Plant data represents the current plant I
configuration including installed and functional modifications. Simulator update design data, call it Data A, is an accumulation of plant data for a fixed time period, such as one year. At the end of the data accumulation, the NUREG-1262 54
v simulator update design data is evaluated and appropriate data is incorporated into the simulator design data by the simulator modification process. We have one year to match the simulator design data to the simulator update design data, Data A. In the meantime, a-new accumulation of data into the next simu- lator update design data, Data B, is begun. Is this a correct interpretation?
A. That interpretation is reasonable. The key thing is that you have up to two years according to the standard to incorporate a plant modification into the simulator. You have one year in which to identify the need for a simulator update, based upon the required annual review of plant modifications; and then you have one more year during which you have to get it incorporated into the simulator modification. So we have possibly two years from the time you recog- nize the need from a plant change to update the simulator until it must be in the simulator.'
Simulation Facility Certification (Including Performance Testing, NRC Form 474, NUREG-128 Q. 198. When will the officialsimulation facility inspections start? Will they start before certification takes place?
A. No. There are two minimum criteria. They will not start before the SFEP
guidance has been out for six months, and they will not start until we have received your certification on Form 474, or your application for approval.
Q. 199. What level of simulator capability must be reported and tested if a simulator has considerable simulation capability, much greater than ANSI/ANS 3.5-1985 requirements?
A. We are requiring that the capability of the simulation facility be'such that it meets the requirements of 10 CFR 55, and ANS 3.5, as endorsed by Reg Guide 1.149. To the extent that any simulation facility has capabilities that exceed those minimum requirements, you need not tell us what they are.
You need not certify them to us, and we will not inspect against them.
Q. 200. In the event we had capabilities beyond ANSI/ANS 3.5-1985 and.Part 55 that we did not test and certify, would those capabilities be utilized-in examining the operators?
A. Possibly. For example, let's say that ANSI/ANS 3.5-1985 for a transient requires a parameter to move in a certain direction so that you don't get spurious alarms, etc. The standard is rather loose with respect to modeling for transients. And if you have something which is closer to an engineering tool, such that you cannot only predict the direction of the parameters, but.
also have a rather good tolerance on its value as compared to what you.would expect from simply meeting the standard, that does not mean that we're not going to examine that particular transient or say that it's outside the scope of, of our examinations. On the other hand, if you are able to go into the area say, severe accidents, which we don't currently cover in the requirements, we may not be examining in that area. The issue is whether that's appropriate for the control room crew, or the technical support center, the accident assessment function, and that's the difference.'
NUREG-1262 55
Q. 201. That's the real question. When our vintage simulator was purchased, the limitation on the vendor was to build it to plant design. Sometimes some of the NRC scenarios go beyond design basis, and I can't say whether the simu- lator's performance is correct or incorrect, I have no basis to certify it.
A. We will still be examining on the design basis, because you must do that in order to get into symptom-based procedures and function-restoration guide- lines. And we want to be able to see an operator's ability to use those emergency operating procedures, in particular.
That already puts you beyond the Chapter 15 design-basis transients and evalua- tions. There is one requirement in ANSI/ANS 3.5-1985, which is endorsed in our Regulatory Guide, and is also contained in our Simulation Facility Evalution Procedure, for some means or mechanism within the simulation facility to notify the simulator operator when the simulation facility has exceeded the capabil- ity of its modeling. And that's one of the things that we would be looking at in our inspections.
Q. 202. In order to get into the emergency operating procedures on most plants, you have to have a variety of different types of failures that are compounded, which go beyond the design scope of the plant as single-failure-proof and would be very difficult to run on a simulator. We have found that in using the emer- gency operating procedures (EOP), we can quickly get outside the bounds of simulation. How do you propose that we address that issue on EOPs?
A. There are two ways: First, the standard indicates that when you go beyond the bounds of modeling, it should indicate that in some way during the simula- tion. Second, we conduct examinations that go outside the bounds of your Chap- ter 15 accidents and transients. That's necessary in order to get you into the function-restoration guidelines.
We intend to see and the regulations require that we understand that an opera- tor can effectively implement those procedures. The tolerances, however, for those procedures are quite large. When you get into casualties, ANS 3.5 essentially requires that the parameter go in the same direction it would go during the actual transient in a plant; that you don't get spurious alarms and that the alarms that are supposed to come in are the ones that you get. It's not time dependent. It's really the ability to look at the parameter and de- cide, based upon that parameter, what procedure you're supposed to be using, and then implement that procedure. We are not looking for a high-fidelity severe-accident simulator in order to be able to exercise the emergency procedures.
Q. 203. This question relates to the definition of "site-specific plant- referenced simulator." What is meant by "it's been designed and uses plant procedures?" With this explanation, could you give me a feeling for whether I
have to delete some steps as inapplicable because of non-modeled systems?
Does that need to be highlighted in my performance testing exceptions?
A. What we mean by "use of procedures" is simply that the procedures that your operators use in the control room should be capable of being run on the simula- tion facility without change. You must be able to use controlled copies of the control room procedures, not copies modified in some fashion or by pen-and-ink NUREG-1262 56
changes. They actually need to be controlled copies.' You can indicate which steps cannot be performed, then you must certify to that. NRC must be able to use the facility emergency operating procedures during the conduct of operating tests. A suitable alternative must be provided in the event of non-modeled sys- tems that are involved with the execution of such procedures in the control room.
Depending on the extent and degree of such discrepancies, it is possible to certify with exceptions as opposed to applying for NRC approval.
Q. 204. In other words, I can't take exception to any step in the procedure because of non-modeled systems?
A. Let's assume that it is a step in the procedure that's used in the control room, but it directs an activity outside the control room. Say the reactor operator tells the auxiliary operator to do something, and you have not modeled that capability in the simulation facility. That would be not applicable.
If it is a step normally conducted from the control room, it is part of the operating procedures for the control room, and it falls into one of the cate- gories-appropriate for the operating test, then you need to model and describe it as a part of your certification of the simulation facility.
If that step need not be used as a part of the operating test, if it's for an ancillary system outside of what we would test on -- you may have something as- sociated with fire suppression or some other system, for example, that's not_
explicitly covered in the items for the operating test -- then that need not be included.
So you have to look at the-scope of the operating test in view of the required capabilities of the simulation facility as described in the ANSI standard. -
Q. 205. Let's assume that in the absence of a modeled system or a modeled cabinet within the control room area, I believe it would be permissible to use the plant to train on that particular component. In essence, I have an excep- tion on my performance test plan, which would normally require the use of that cabinet. But through on-the-job training in the actual control'room, I can give the equivalent of-that training that I would have performed on the simula- tor. Have I gone beyond the plant-referenced simulator category and moved into the-other category here? If so, how do I address that?.-
A. Not necessarily. You need to lQok at whether that system is, for in- stance, a safety system. If it's-not a safety system and it's not otherwise called out in the categories under the operating test, then you need not model that system as a part of the control room. The safe-shutdown panels in some facilities aren't modeled. They are outside the control room. We do not re-
-quire that you model that in the simulator.
There are radiation monitor panels in the-control room and things like that that you may not have modeled in your simulation. We understand that. That should not preclude you from using certification with exception.
You need not necessarily go through the application process. It's when there is some portion of the operating test which requires controls in the control room that are not replicated on the simulation facility that would require you to submit an application for NRC approval.
NUREG-1262 57
Q. 206. Will the operator/examiner feedback form that was discussed be used to determine the status of current simulators?
A. The guidance to the Examiners is that the form will be applicable only to simulation facilities that have been certified, or have applied for approval.
However, even today, with the present vintage of simulators, you still are experiencing feedback reports, although informal, in the exam review process.
And that will continue. If the Examiners have a problem in conducting the operating test at your simulator, you can expect some feedback in that regard, even though it won't be the formal process that will occur for certification or approval.
Q. 207. So, is it true that if I wait for 46 months to certify, that is an advantage to me?
A. No. It's not an advantage because you will to have provide substantial additional information for every application that you submit and we are going review that information and make determinations on individual applications and candidates.
Q. 208. But, yet, you won't inspect us?
A. We won't inspect your simulator, but we're certainly going to be keep close tabs on your applicants. And every time you receive an NRC operating test using your simulator, you can expect feedback through the exam report on the performance of your simulator.
Q. 209. This refers to the accelerated update of the simulation facility that may be required as a result of performance testing. What systems, events, or procedures are we trying to exercise during the simulator exam?
A. The intent was to identify any potential system, operation or scenario that we could not conduct on the simulator exam because of the simulation facility and which we could not readily implement another way during the examination, so that the exam could potentially be compromised or considered invalid. We would need to see that that system, or procedure or event had been corrected before we could. develop an appropriate exam using it. For example, one simula- tor was unable to adequately represent flow coast down on a loss of coolant.
The response was very unusual as compared to what was expected, and on how the procedures were to be used, because there was no coast down. It would not have been appropriate to conduct an examination which involved a loss of flow event in that case. We would not want that situation to exist for the next two years, because we may want to conduct a loss of flow scenario as a part of an exam within that time. So, we would require that that be corrected on a sched- ule that is faster than the normal two-year correction schedule provided in the standard.
Q. 210. I think clearly, that's the intent. But I see opening some areas of disagreement in the future. None of us know what the next round of the "topic of the day" is going to be. And we may find that our present machines were not designed to handle whatever that issue is. And, so, when you say any event, that can be troublesome.
NUREG-1262 58
A. We suggest that you look atiNUREG-1258 that describes the Simulation Facil- ity Evaluation Procedure (SFEP) and the pilot tests. That should allay some of the apprehension.
Also remember'that-this system, operation or event is something that you have already certified that your'machine is capable of doing. We're referring to something we discovered during the course of our inspection that contradicts something you've told us on'your certification.
Q. 211. This question addresses performance tests to be performed on the simu- lator in compliance with 10 CFR 55. What are those set of performance tests, the specific scenarios and malfunctions? Could you clarify that?
A. We're talking about Appendices A and B of ANSI/ANS 3.5-1985, and the list of 25 malfunctions that are contained in Section 3.1.2 of the Standard. There is a defined list of malfunctions that the simulation facility needs to perform.
Q. 212. Is it 'just that list that's in 3.5, only?
A. Yes.
Q. 213. Or is it that list,-plus the diesel generator that's covered in Regula- tory Guide 1.149?
A. There was a specific list of malfunctions in an earlier draft of'Regula- tory Guide 1.149,"but it is gone' from the final version. The'equivalent para- graph that's in the final version endorses the paragraph in the Standard that lists the 25 malfunctions. Recognize, however, that some of those malfunctions are quite broad. -We talked about the loss of power. That could mean loss of power to a panel, to a system, to a component, or loss of all power. Small break LOCAs can be initiated from a reactor coolant pump seal, from a steam generator, a tube rupture, a lot of different ways. What we are interested in is a representative-sample of those things. You need not do all possible permutations and combinations.'
But you are going to have to look at what you are certifying to, that's the reason that you are submitting test abstracts, and you describe what your test- ing program is. '
Q. 214. So we will determine which specific scenarios we will run, as long as we cover those areas?
A. That is correct.'And you'describe that in your abstract, with your certi- fication, and you 'describe-the performance tests that you will conduct in the future to maintain the simulation facility.
Q. 215. Would the Commission find a formal simulator facility review board/
committee (consisting of training management, operations management and senior reactor operators) a-suitable forum for making judgments regarding the simula- tor scope requirements versus training value? For example, ANSI/ANS 3.5-1985 states that all accidents analyzed in the facility's FSAR must be included in plant malfunctions in the simulator's scope. It then later states that this is required only when the simulator is determined appropriate for training.
NUREG-1262 59
However, in a few cases the accidents provide little, if any, training value to an operator. Can a board, such as that proposed, be considered a legitimate forum for making these decisions?
A. We are concerned with the applicability of your simulation facility for the conduct of operating tests, and not as it applies to your training pro- grams. Generally speaking, when you look at the ANS 3.5 document, you can safely substitute the term "operating tests" wherever the term "training"
appears.
Although we recognize that your simulation facility's scope, when applied as part of your training program,, may exceed that which, is necessary for its applicability to use in operating tests, it doesn't matter to us what process you use internally to identify those differences.
We have tried to indicate clearly the minimum requirements for use of your simu- lation facility to conduct operating tests, and it must meet those minimums.
These include the evolutions and malfunctions identified in Section 3.1.2, in the performance test appendix, and in the operability test appendix of the standard, using the required operating test requirements in Section 55.45(a) as the criterion.
However you meet those requirements is your decision to make; and as to whether you need to certify or provide additional performance testing data for anything additional, that's also your decision to make.
You will be submitting performance test abstracts with the Form 474 that de- scribe the testing that you're going to perform.
When you look at the list of malfunctions and you see a malfunction that says
"loss of power," that's very broad. Which ones do you choose in developing the test abstract for various losses of power?
You should look at the testing that you propose and, if possible, combine some of those malfunctions so that you have a smaller number of performance tests than would otherwise be the case and describe how those tests in your abstracts meet the intent of the standard.
In doing that, we would use those tests in making a judgment as to what the capabilities are. That does not mean that we would limit our examinations, however, to those particular tests or scenarios.
Obviously, if you demonstrate that the simulation facility works well for an event at high power and for some tests at low power, we may be able to mix those just as we do now. You have a substantial amount of control in deciding what testing you want to propose for the performance tests and that list of malfunctions is quite general.
In the case of using the panel, that could be an appropriate vehicle for decid- ing what tests are going to be proposed as performance tests. They could be a subset of all the malfunctions the simulator is capable of performing. You may literally have hundreds of malfunctions which you can implement.
NUREG-1262 60
We don't want to see a performance test for each malfunction. We do want be to be sure that all of the malfunctions that are listed in the standard can performed.
a Q. 216. Section 55.45(b)(5)(vi) says a certification report need only include and description of performance testing completed, performance testing planned, the the schedule for conducting 25 percent'of performance tests per year for 3.5- next four years. Is this sufficient,-or must the document conform to ANS
1985 Appendix A?"
A. This question addresses two different issues. The first is the testing need that is required, and the second is the reporting. The reporting itself a not be in the format of Appendix A, ANS 3.5, although that's not necessarily bad idea. But it must cover those items that are called out in the Regulation con- in Section 55.45(a), specifically a description of the performance tests differs ducted, and the schedule -for future performance tests, if that schedule from one that was previously submitted with the certification.
The actual testing must include not only the Appendix A performancethat testing, as are called out in the standard, but the specific list of malfunctions per identified in Section 3.1.2 of the standard, both at the rate of 25 percent B of the standard year. Also, the operability testing that's shown in Appendix is to be performed annually. So, testing and reporting are separate issues.
Q. 217. When does the Commission project that their guidance for conducting simulation facility audits will be made public?
A. That guidance is available now in draft NUREG-1258, and we will accept your comments on that NUREG until-the 26th of May.
Q. 218. Will simulator certification audits be performed by NRC headquarters staff, regional NRC staff, or some combination?
com- A" In all'probabilityi the simulation facility inspection program will func- bine headquarters and regional staff, starting largely as a headquarters tion and over time becoming more region-based as we move into the inspection procedures.
Q. 219. NRC released a final draft of "Handbook for Software Quality'Assurance Techniques Applicable to the Nuclear Industry," dated February 1986. This handbook addresses the applicability of 10 CFR 50 Appendix B requirements associated with computer uses in the nuclear industry.
as- It specifies that training simulators require stringent software quality should surance. This requirement seems to imply that the simulator's software be treated as though it were safety related, with the appropriate programmatic area and procedural controls applied. What are the Commission's plans in this and what relationship, if any, will the draft handbook have to simulator certification? '
the A. 'The draft handbook to which you refer imposes no requirements on for industry. It is under consideration by the staff, but there is no intent quality control procedures as they us to review your software development or apply to Part 55 and to simulation facility certification.
NUREG-1262 61
You, of course, have to manage your own simulator software program in order to meet the regulations in Part 55 as required to certify that the simulation facility is suitable for conducting operating tests. And we will review the simulation facility's adequacy using the performance testing program, after you submit your Form 474.
We will take a look at the handbook to determine its status, but we think it is safe to consider it not applicable to these regulations.
The best way of determining whether the software is any good or not is to see whether it performs in accordance with the plant's design characteristics. We don't need a very prescriptive software control program protocol that is sub- ject to NRC review and evaluation.
We've described how we intend to inspect the simulation facilities and we have put that into the Simulation Facility Evaluation Procedure. The evaluations will be based upon running things like Licensee Event Report scenarios and seeing how the simulation facility compares with the plant.
But if you start modifying the software in one area, you may affect other areas. So you need to understand what impacts such changes will have to the overall performance tests. If a modification causes a performance test to fall outside of its acceptance values -- that is, the 2 percent and the 10 percent
-- you need to rerun that test to ensure that the simulation facility is still performing in accordance with the design specification. We're looking for a machine that will replicate what we expect to happen in the plant. We're not looking for developing a software control system which is appropriate to a reactor protection system where you cannot test by operation how effectively the performance of the reactor protection system works. Title 10 CFR 50 Ap- pendix B requirements would appear to be appropriate in such safety-related applications. That's the difference.
Q. 220. This question concerns a simulation facility consisting of other than a plant-referenced simulator, and the performance testing related to such a fa- cility. What performance tests are required and what standard is used to evaluate whether the tests are satisfactory or not?
A. We intend to follow the guidelines in the ANSI standard as applicable to the simulation facility which you have proposed.
Let's say that you want to use another plant's simulation facility for reactor startup and that you can effectively model the controls and indications that would be used for reactor startup. We would expect you to follow the ANSI
standard as it related to startup modeling., You may not be able to model it for controls and indications because you don't have that capability on the simulation facility. You would not have to follow ANS 3.5 guidelines in that instance because they are not applicable.
Q. 221. If the standard for performance tests is ANSI/ANS 3.5, as modified by Regulatory Guide 1.149, will it be possible to deviate from the standard in certain areas or must it be adhered to in its entirety?
NUREG-1262 62
A. We recognize that there will be a number of outstanding discrepancy re- ports on the simulation facility against its reference plant. We expect that, for certified simulation facilities, as well as for those that achieve approval after application, exceptions will have to be taken from the requirements of ANS 3.5. There is a block on Form 474 for certified simulation facilities to address the exceptions that you take at any given time'. The same would apply to noncertified simulation facilities where you would address those exceptions in your application.
Q. 222. Does a simulation-facility certification form, NRC 474, have to be sub- mitted prior to each operating examination?
A. No. Assuming that you maintain the acceptability of the simulation facil- ity, it is a one-time certification.
Q. 223. Will the guidance document be limited to auditing the provisions of ANSI/ANS 3.5-1985?
A. No. It will be limited to auditing certification against the requirements of Section 55.45(a) of the regulation, which delineates the 13 components of the operating test, and ANS 3.5-1985, as endorsed by Regulatory Guide 1.149.
Q. 224. Will the performance testing documentation maintained for NRC review be limited to those items addressed in ANSI 3.5?
A. No. The performance testing and its documentation will use Section 55.45(a)
of the regulation-as its criterion, and must employ the malfunction testing of Section 3.1.2 of ANS 3.5, as well as the standard's two appendices, and the endorsement by Regulatory Guide 1.149.
To amplify, the operability test identified as Appendix B in the standard is done annually. We have not taken exception to that. Performance testing, which appears in Appendix A, plus the repeat of the malfunction testing, which is described in Section 3 of the standard (that set of testing at approximately a rate of 25 percent per year over four years), will constitute the additional annual testing to be done.
So you have an annual operability test, and then 25 percent of the performance tests that are described in the first appendix, plus 25 percent of the mal- functions'that are listed. To the extent the operability test itself dupli- cates a portion of the performance test', that's sufficient. You don't need to do it twice, 'but that's the scope of the testing we are expecting to be done on an annual basis, and the term annual is used in its common meaning. We are interested in you doing the performance tests regularly over a period of four years, and not putting them off for the last year.
Of course, before you submit your certification or your application for ap- proval, you should have completed 100 percent of the operating tests and the performance tests. After that, the 25 percent per year cycle will begin.
Q. 225. It was indicated that when we submit the Form 474, we should have
100 percent of the performance tests completed. Can we count performance tests, specifically malfunction tests, that were performed as part of an acceptable NUREG-1262 63
test procedure, say, three years ago, towards having performed that part of the performance test one time, or do we have to redo it before we submit the form?
A. There is not necessarily any need to redo those performance tests. The concern, if any, is the difference in'time'from when they were done, and any changes to the plant configuration that would be required by the ANSI standard to bring the simulation facility up to date. If there have been no changes that would require you to repeat some performance tests to make them in com--
pliance with the standard, then those tests should be acceptable.
Q. 226. So if we conducted an acceptable test program, and since then have had a program in place to test all the modifications to the software, including malfunctions, if appropriate, then we've got a basis for starting, anyway?
A. Yes. We intentionally did not specify a time prior to certification by which you had to have them all completed.
But the situation you have is that once you do certify, then you start perform- ing those same performance tests over again on a 25-percent-per-year basis over the 4 years to ensure that configuration changes are, indeed, incorporated in the simulation facility. But the rule itself is silent on how long before certification these tests may have been performed.
There were some changes in the standard between the 1981 version and the
1985 version. You have to show that you have met the 1985 version, and that any design changes or software changes that you have made since then have not affected the validity of those earlier tests. It may be easier to repeat them than to repeat the entire process, but that's up to you.
Q. 227. Is there any intent to include remote shutdown panels in any of the simulation facility requirements?
A. No. However, if these panels are provided as part of the simulation facil- ity, they may be used in the NRC operating test.
Q. 228. What does the Commission consider an adequate schedule to correct per- formance test failures identified in the four-year anniversary certification?
A. Although the rule requires a report on every four-year anniversary of certification, or four-year anniversary of application, we intend to have a much closer working relationship with you so that we will know on an ongoing basis about any such performance test failures, and there are several mecha- nisms to do that. One is the 90-day letter prior to examinations, in which uncorrected performance test failures would be identified. Another would be simulation facility fidelity reports from our examiners, and the third would be the results of our periodic audit and inspections of simulation facilities.
The schedule to correct performance test failures is really based upon the seriousness and the magnitude of the failures that are discovered. It may range from purely an NRC recommendation that the failures be corrected, to a recommendation that a failure be corrected within the normal update cycle re- quired by ANS 3.5. The next level would require a correction on an accelerated schedule. The most serious failures require that the simulation facility essentially shut down until the failures are corrected.
NUREG-1262 64
.Q. 229. What detail of description is the Commission anticipating in the re- port? Should the report be revised if a schedule for conducting a performance test changes year-to-year during the four-year period?
A. If your schedule for performance testing changes between the time you submit a certification and any subsequent four-year report, you should advise us of that change on the Form 474.
There are three documents for certified simulation facilities that address the level of-detail.' The rule, specifically the operating test in 55.45(a), lists
13 items that make up'the content of the exam; ANS 3.5,-which sets out the requirements for the simulation facility's capabilities, as well as the per- formance testing requirements; and Form 474, which indicates that we want performance test abstracts and performance test schedules."
We don't want reams of material on the details of all your performance tests and all the results. If we need additional information in the course of conducting an off-site or an on-site simulation facility evaluation we will request it from you; we are really'looking for summaries and abstracts sub- mitted with that certification form.
Q. 230. Will an NRC certification team be sent'to the facility to conduct a simulator performance audit using'the new simulator certification criteria?
A. Essentially yes. The NRC staff will conduct the review and the inspection.
It will be a two-phase process, an offsite review, followed by an onsite in- spection, if necessary. Only'as a'result of onsite inspection might certifica- tion be removed, as a last resort. For further clarification, a certification is not removed as a result of an inspection. It's removed as a result of fail- ing performance tests which are required by the regulation. During the inspec- tion we conduct performance tests where we audit the ability of the simulation facility to perform as described in the performance tests that you submitted. .
So if the machine does not work during'an inspection, the criterion is still the failure-of a substantial number of 'performance tests, such that you cannot perform a meaningful operating test as described in the regulation.
The conclusion is based upon the requirements for the operating test, not just on failing some fraction of the performance tests. You have to fail perform- ance' tests, but it's got to be a substantial enough number of performance tests that it impacts on the simulation facility's ability to conduct an NRC
operating'examination. So one performance'test failure does.not necessarily mean that the simulation facility would be decertified. It has to'be'a gross enough set of failures that we can't conduct a test.
Q. 231. We presently have two years before a plant modification must be incorpor- ated into our simulator. Can we certify the simulator to the NRC without having incorporated all plant modifications?.'
A. We always anticipate'that even when you certify a simulation facility, there will be exceptions if you haven't been able to bring it up to date with plant modifications. The ANSI standard allows a two-year period from the date you identified the need for making modifications until those are fully incor- porated into the simulation facility. So the answer is yes, you can certify prior to the date you've incorporated the modifications.
NUREG-1262 - 65',
Q. 232. Where specifically would that be on Form 474?
A. There is a block near the top of the form that says "I hereby certify that the simulation facility meets 10 CFR 55 and ANSI 3.5."
It then says: "If there are any exceptions to the certification of item two above [that is, the ANSI standard], check here and describe on additional pages if necessary."
Q. 233. In earlier discussions mention was made about using controlled copies of procedures for simulators. What do you mean by the word control?
A. Controlled copies means those procedures identical to the ones that you use in the control room of the plant. The copies should be up to date, including references and revisions.
- Q. 234. When an examiner conducts an exam on. the simulator, are we going to be able to take a look at some of the fidelity questions that they have on a simu- lator prior to them leaving or prior to their exit interview?
A. Yes. The examiner will provide any comments that he or she has about the simulator's fidelity on a "Simulation Facility Fidelity Report," which has been added to Examiner Standard ES-104. Those thoughts will be shared with the facility licensee along with the rest of the examiner's comments, before he or she leaves the site.
Q. 235. Are licensees required to submit exemption requests per the ANSI Stand- ard or the Regulatory Guide, and they are to be issued per the requirements of
55.45?
A. If any one of the requirements of the operating tests in Section 55.45(a)
cannot be met with the simulation facility, you would require an exemption from the Regulation. A failure to meet all of the requirements of the ANSI standard does not require an exemption. It simply requires an identification of what it is that you cannot meet. And it must include a conclusion on your part that that difference would not preclude the conduct of an operating test as it's described in the Regulation.
That's why the certification on Form 474 is a certification to the Regulation with an identification that you follow the ANSI standard with some exceptions.
We recognize that there will be exceptions. There are exceptions on new licenses on the day they're issued and we issue a number of license conditions.
We don't expect that the number of discrepancy reports on a simulation facility is ever going to get to zero. It's anticipated that there will always be some feedback, some necessary correction. The standard itself provides a schedule for incorporating those corrections and revisions.
Q. 236. I'm unclear as to how much we have to put into our simulator with re- gard to back panels.
The simulator we have is what's called a main horseshoe. We have 50 to 60 back panels in the simulator which are used during surveillance testing, and NUREG-1262 66
I2 recently there have been a lot of bypass switches that we use during our emer- gency plan training. Must we have all those back panels in our simulator or can we substitute the plant for that part of the training? It's a very big main control room, and we put all our back panels in there instead of outside the main control room.
A. Our intent is not to have you model the entire plant, but if the evolu- tions you are citing are your operating and emergency procedures for the fa- cility, and it's an evolution which is conducted from within the control room by the regulation, we would expect that to be modeled or you would have to show us how that could be done without modelling and identify that as an exception.
But for facilities that have a large number of back panels or other equipment available in the control room, it's not the intent that you mock up all those panels. Generally, they are merged in the main control boards. For example, those that control the reactor, safety systems, electrical line-up, and balance of plant are the typical ones that we're looking for.
Q. 237. Would it be safe to assume that you have in mind the area that the operating shift typically does not leave during normal operation of the facility?
A. It's those portions of the facility where the individual is defined as being "at the controls," which is described in Regulatory Guide 1.114. Some facilities mark it off with a red line on the floor or with a fence or whatever.
It's that area where the individual is at the controls as defined in the Regu- latory Guide that we're interested in simulating.
NUREG-1262 67
LICENSES
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Special Senior Operator Licenses (Including Instructor Certification)
Q. 238. What is the impact of the new rule on instructor qualifications? Are the requirements of NUREG-0737 superseded?
A. The new rule supersedes the requirements for instructor qualifications in NUREG-0737. The responsiblity for ensuring that instructors are qualified now rests with the accreditation process. INPO has established the qualifications for technical instructors, which would be reviewed within accreditation. NRC's role is to monitor the accreditation program to ensure that it maintains the standards that have been endorsed by the Commission.
Q. 239. Instructors who have been certified or who have held a license pre- viously may instruct students in courses needed to prepare applicants for NRC
licensing examinations. Are these instructors required to participate in a requalification program?
A. If you have an accredited program or systems approach to training (SAT)
program, then that program will define the continuing qualification and re- training requirements for instructors. If you do not have an accredited pro- gram, then the instructors will have to meet the commitments of the approved program as defined under Part 55 and commitments contained in the FSAR. NRC
will no longer issue instructor certifications. If a licensee is using vendor- certified instructors in a requalification program that has not been completely converted to an SAT program (performance-based), it is conceivable that a 50.59 change could be made to support such an approach in the interim until such time as the requalification program is converted to an SAT-based program.
Q. 240. As I understand it, only people that hold a license for a facility may instruct license-type material to a hot license class. Would consultants who were previously licensed and certified by General Electric be able to teach such material?
A. If your program is accredited, then you determine subject matter expertise and instructor skills in accordance with the accredited program. If your pro- gram is not yet accredited and you were previously under the commitment in the Denton letter to assure subject matter expertise for instructors -- which was that those instructing integrated plant operations have a level of knowledge comparable to that of a senior reactor operator -- then the process we've allowed in the interim permits you to certify your instructors based upon their successful completion of your senior operator training program.
We have also allowed that those examined and certified by NRC in the past can continue, but they should receive additional training on plant or procedure changes, that portion of the requalification program which is applicable to what they're teaching.
Now, the practical aspect is that those people who are instructing have to learn that material to a depth greater than that which they instruct, and your program also has mechanisms for evaluating instructor performance.
NUREG-1262 68
We are trying to move out of the area of specifying training program content or qualifications for instructors. So depending upon your commitment in the pre- sently approved program, you may need to review that in accordance with 50.59.
NRC will not need to certify it; you may do that under your own program.
Q. 241. How would that apply to vendors such as Westinghouse? We cannot get accredited by INPO. Therefore, if we hold a staff of instructors, are they then going to have to go to the utility and the utility is going to have to either license or certify them?
A. For contractors that are providing instruction for facilities, it is the responsibility of the facility to ensure that the contractors have the appro- priate subject matter expertise and instructor skills to meet the requirements of their accredited program. The staff will not be certifying or approving instructors who are contractors, nor will'we be certifying or approving instruc- tors who are facility employees.
Q. 242. Did I understand correctly that you said that if you're not accredited, that you would have to license instructors?
A. Some facilities in their existing-training programs have committed in the FSAR to have either licensed senior reactor operators or individuals who were certified instructors. The-old instructor certification, which was comparable to a license (the eligibilty requirements'were relaxed), required that the instructor go through the same examination, although he was not authorized to manipulate the controls. We no longer issue such certificates, which would imply that you would be obligated to have licensed operators conduct your program.
We also indicated that you could perform a 50.59 type of review that-would meet the same intent.' Having your instructors complete and be examined by the stan- dards of a program comparable to your own senior reactor operator program, such as a vendor certification program, would be sufficient in the interim. When we get to the point where everyone has been accredited, that issue is superseded.
The accreditation process covers instructor qualification and training.
Q. 243. I do not have my programs accredited yet. I hope we will have them done by the end of the year. But I have people who are in a program right now, the same one we've been using all along, and they are being examined by us next week. And the Region is not going to come in and give them an NRC exam. My intention is to certify them as I have done in the past and put them right into a classroom. They will' also be in a requalification program. Do I understand that to be a correct procedure?
A. Yes. If you are getting ready for accreditation, you probably have com- pleted the self-evaluation report, and are getting ready for a team visit. As preparation for that, you look at how you train and certify instructors. We want that to be a part of the accreditation process, and not a part of the NRC
review.
Q. 244. Can trainees participating in a systems training program for instruc- tor certification manipulate controls on the facility under the appropriate supervision of licensed personnel?
NUREG-1262 69
A. If that training program can lead to a license if carried to completion trainers may manipulate controls under appropriate supervision if it occurs in the proper sequence within the training program. The trainee may also manipu- late controls (under proper supervision) without being involved in a course that leads to a license if the systems that are being manipulated do not affect power or reactivity (e.g., feedwater). However if the systems that the trainee will teach, and therefore the controls he would manuipulate, do affect power or ractivity, then he must be enrolled in a course that leads to a license.
Q. 245. As I understand it, in the accredited utilities, instructors will be considered to be certified to teach licensed operators after they complete the accredited training program. In the case of a utility that doesn't have their operations programs accredited yet, could you outline what the requirements will be?
A. The requirements are basically those which were in existence before the effective date of the Rule, and that is to either have an individual who has completed a training program comparable to that of an SRO, and been examined on it (we used to call that instructor certification), or be a licensed senior operator, who is currently enrolled in a requalification training program.
Because of the fact that we no longer are going to be giving instructor certi- fications, you then have only the option of using a licensed operator to teach those courses. We are not going to give any further instructor's certifications, that's not permitted under the Rule.
For NTOLs and facilities that are in the accreditation process, the Commission's Policy Statement in Training and Qualification of Power Plant Personnel of March 20, 1985 allowed facilities to make the transition from FSAR commitments to accredited programs. Therefore NRC instructor certifications which, as a policy, were discontinued in Mid 1985, relied on facility certification of instructors. We believe this policy will continue and eventually be reflected in Revisions to Section 13.2 of NUREG-0800, the Standard Review Plan.
Q. 246. So, training instructors must be licensed operators?
A. Yes, until such time as you get accredited, or have some other way of gett- ing subject matter expertise through your accredited program, including in- structor training. We are not going to specify that for an accredited program.
But you may have a program on record today, in which you have committed to the requirements to the Denton letter, which said you were going to do certain things to ensure subject matter expertise in instructors. And that was to either use a licensed senior reactor operator or an individual who has been examined by the NRC to the same level as a senior operator.
We are not going to examine without issuing a license.
Q. 247. Will people who are currently certified by virtue of the fact that they have previously passed a senior reactor operator examination somewhere, and thus demonstrated their competency, be considered as certified to teach?
A. Yes. But when they come to us after the effective date of the Rule request- ing to have their certification renewed, that's not going to happen, because there is no longer such certification.
NUREG-1262 70
Q. 248. So, then, is someone who has passed an SRO exam given by the NRC at some point in the past, considered certified or, not?.,-
A. For the purpose of meeting your training program commitment of having-an individual who has a knowledge level, comparable to that of a senior reactor operator, the answer is yes, provided'the individual is maintaining currency in the requalification program, with respect to any changes which would affect his knowledge base. That is consistent with what INPO is looking at in the instruc- tofrtraining and as identified in Technical Instructor Training and.Qualification Guideline, INPO 82-026 at 7.1.
Q. 249. Can you tell us how you expect to treat people under the-new rule who are currently SRO instructor certified? What kind of credit are they going to get because they 'are SRO instructor certified, if any? i A. The answer'is none. 'Obviously they have completed the same training program and taken the same'exam-as an SRO, but because of eligibility requirements or time on shift or some other requirement they did not;meet the SRO requirements.
In the past, there'have been individuals who successfully converted an instruc- tor's certification to an RO license.
Additionally, there is the provision for waiver of certain portions of the NRC
examination, based on operators having: (1) extensive actual operating experi- ence at a comparable facility within two years, (2) discharged his or her responsibilities competently and safely and is capable of continuing to do so, and (3) learned the'operating procedures and is qualified to competently operate the'facility designated in the' application.
If you want these individuals-to become licensed, you will-need to submit a complete application, and if applicable, request a waiver under the Regulation.
Thls application would then be reviewed by the Region as"to what portion, if any, of the examination would be waivered.
"Actively Performing the'Functions of an Operator or Senior Operator"
,Q.250. What guidance will the Commissfon provide to the facility licensees and the staff that Section IIF(2) is Commission policy?
A. Section IIF(2) is part of the Statement of Considerations that summarizes public comments and-describes the 'staff's final actions in response to them.
This Section.discusses'the definition of "actively performing the functions of an operator or senior operator," which is part of the regulation, contained in Sections 55.53(e) and 55.53(f).' -
- Q.251. The regulation for active participation states that "an individual has a position on the shift crew that requires the individual to be licensed asca-de- fined in the facility's Technical Specifications, and that the individual rries out and is responsible for the duties covered in that position." How does this rule accommodate plants with RO and SRO licenses on shift that exceed the Technical' Specification minimum staffing requirements?
NUREG-1262 71-
A. The rule does-not preclude having additional people on shift beyond the minimum staffing requirements. That is a utility decision. However, in order to take credit for the proficiency of such personnel standing watch above the Technical Specification' minimums, as a condition for maintaining a license under
10 CFR 55.53(e), the facility licensee must maintain administrative control over these designated watchstanders, and must be satisfied that these individuals are maintaining their proficiency by manipulating the controls of the facility in the case of an operator, or by manipulating the controls and directing the li-;
censed activities of licensed operators, in the case of a senior operator.
So that if you operate a single unit with three reactor operators on shift, two of those individuals are in positions required by the Technical Specifications.
One is usually the reactor operator and the other is the balance of plant opera- tor. The third person would need to rotate into one of those two positions over the course of a quarter to obtain the requisite number of shifts to maintain his license active, so he would need to sign the logs, on occasion, as the reactor operator or the balance of'plant operator. So it's clear that you.must be-in the position on shift-required by the Technical Specifications, and additional personnel on' shift to perform other duties do 'not meet the requirement for directing the activities of licensed operators or for manipulating the controls.
There are alternatives built into the regulation to provide ample flexibility in obtaining proficiency for licensed duties, e.g., 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch standing.
Q. 252. Our Technical Specifications do not address the individual's responsi- bilities for each position in order to satisfy the active participation re- quirement--it says you have to have an RO and twoSROs, one SRO as a shift supervisor and one that's another RO. Can you rotate that SRO position from a shift foreman position to another senior reactor operator position? It doesn't say who is required to fill those positions, so the complication is that if we have a senior control operator who has an SRO license and he's clearly direct- ing the operator's activities, can we give him the responsibility for the day and say the shift foreman no longer has the responsibility, because both of them hold'an SRO license?'
A. For the case that you've described, the individual who is on shift directing the activities is the one who's in the position required by the Technical Speci- fications. Whether he is the shift foreman for that shift because that's the title that you use to describe other responsibilities he may have, it is the senior operator in the control room who directs how the other two operators manipulate the controls and who is there fulfilling the requirements of.the Technical Specifications to be supervising the activities of the licensed operators. That'.s the position that qualifies for the eight hours on that shift, independent of title. Your administrative procedures should be clear as to who has authority to direct licensed operators so that if the shift foreman is relieved-there is another senior-operator in the control room carrying out.
those duties. The Technical Specifications don't refer to shift foreman; they say senior operator directing the activities of other licensed operators.
There is a related question that concerns the extra person on shift who may not be in the licensed role. It is possible for that individual to complete 40
hours of parallel watch standing; that is, he's not in the position required by NUREG-1262 72
the Technical Specifications, as long as he is being supervised and his activi- ties are being closely monitored by the person responsible. He could accrue a
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch standing for that quarter and not'be actually inat position required by the Technical Specifications to meet the seven shifts eight hours each, or thelfive shifts of twelve hours each.
facil- It would require in that case, that the authorizing representative of the it's ity certify that he has completed that duty. From a practical standpoint, easier to rotate the people through the watch to maintain their proficiency.
The active license status is intended as a way of maintaining the proficiency the of the people who are performing the functions. If you're dual licensed, or active status requirement can be met by standing watch on only one plant, on some combination of the plants.
Conditions of Licenses (Subpart F, Section 55.53)-
once a Q. 253. With regards to fuel handlers, in the case where you may refuel year, it's probable that the requirement won't be maintained. Subparagraph the
55.53(f)(2) suggests that one shift of supervised duty is required before fuel handling foreman with the license can assume his full duties. Is the SRO who intent that that supervision be performed by another fully qualified may not be a fuel handling specialist?
A. That is correct. -An actiVe SRO license includes the capability and re- sponsibilities associated with monitoring fuel-handling activities.
by Tech- Q. 254. The Operations Managerand Operations Supervisor are required in- nical Specifications to be licensed as Senior Reactor Operators. These the dividuals do not have a position on the shift crew.: They are involved in day-to-day direction of Licensed Operator activities. Are these positions considered as actively performing Licensed Duties?,
12-hour A. No, unless they stand the seven 8-hour shifts per quarter, or five Manager and the Ops shifts per quarter. That does not mean that the Ops are Supervisor cannot keep a license. The requirements to maintain a license that they continue in requalification.
in If the Operations Manager must hold a license, then he must participate directing requal, but he need not stand watch on shift in a position where he is or not, the activities of the Reactor Operators. A license, whether it's active may meet some Technical Specification requirement.,
the Q. 255. What if you~have an.SRO stand a shift assignment as an RO? Does SRO get credit for standing watch in that position for renewal purposes?
Unless A. The SRO is not performing Senior Reactor Operator license duties. license he is also standing SRO's duties during that quarter, then his SRO
would would not be active. Where an SRO is standing an RO watch, his license continue to be active insofar as-it deals with his operating or manipulating the controls as an RO.
In order for him to direct others, he would have to'stand a 40-hour Heparallel could, shift in order to be proficient and go back into an SRO's duties.
NUREG-1262 73
however, continue to maintain an SRO license if he's current in requal. If he wants to assume an SRO's capacity, he must go back to a 40-hour shift under instruction as an SRO.
Q. 256. When the operations-manager is licensed, should technical advisors or licensed instructors have to become members of a shift crew to maintain an active license?
A. Yes, to maintain an active license, they do. To maintain an inactive license, they don't.
Q. 257. Do personnel seeking to maintain an active license have to replace a member of a shift crew to meet the watch requirements of 10 CFR 55.53?
A. Yes, they do, with the understanding that there may be additional people on shift beyond the minimum technical specification requirements.
Q. 258. Although there is only one Technical Specification SRO position on shift (Shift Supervisor), our Technical Specification reflects the 10 CFR 50.54 requirement of a second SRO on shift. Would standing a watch as a designated second SRO meet the definition of actively performing the function of a Senior Operator?
A. If he is filling an SRO position under the Tech Specs then he would be maintaining his active SRO license. A number of people have asked, can we have two or three people come in to get their on-shift time? Our position is that those meeting the minimum staffing Technical Specification requirements for whatever operational mode get credit, although there can be other people on shift who are also eligible for credit.
For clarification, this question seems to imply that at this facility the Tech Specs do not conform to the Regulation for a single-unit site for having two Senior Operators on shift during operational modes. That's understandable because the Rule itself supersedes the Technical Specification requirement, and is a higher order requirement. That is, you must conform to the Rule even if your Tech Specs permit something less. We would suggest that the next time you have an administrative change to that section of the Technical Specifications, amend it to conform to the Rule.
Q. 259. If the Operations Manager does not hold an active license, what duties may he perform or not perform in that status? For instance, we all have Tech- nical Specifications that require licensed Senior Reactor Operators to approve changes to procedures. Would an inactive license allow him to do those admin- istrative functions?
A. Yes. He can do everything but direct a Reactor Operator in manipulation of controls, or himself manipulate the controls.
Q. 260. All stations have engineering expertise on shift in the form of a shift engineer, who is the STA. STAs hold a current SRO license. They direct activities and integrate schedules. Are they not actively performing the func- tions of an SRO license by those duties, or are they going to have to come back and perform as a shift supervisor, on shift?
NUREG-1262 74
by Technical Specifica- A. If they are one of the two individuals required is acceptable. If one tions to'staff the shift, then what you just described hold an SRO license, and is there as an engineer on shift who happens also to not responsible for directing is only fulfilling the-role of an STA, then he is cases of extra people on the activities of licensed operators. There are many tags, procedures, line- day shift,who' do support functions, such as reviewing to perform them., It ups, records, etc., and do-not require an active licenseof an operator or a is only when he is performing the functions and duties senior operator that an active license is required.
reactor operators and
- Q.261. Our Technical Specifications require two senior Typically, though, we'll two reactor operators for mode one and two operation. that only the two have others assigned to the shift. Is it NRC's intention reactor operator are and the people assigned as the balance of plant operator manipulating the con- receiving credit for being on shift? Or-are the others trols getting credit for being on shift?
necessary for safe oper- A. .,If utility management-has determined that they are is that of the the number of additional watchstanders Nation, the decision about for the proficiency of such facility licensee. Howeverin order to take credit as a condi- personnel standing watch above the Technical Specification'minimums,
55.53(e), the facility licensee must tion for maintaining a license under 10 CFR the controls, by manipulating be-satisfied that they maintain their proficiency and directing the in the' case of an operator, or by manipulating the controls of a senior operator.
licensed activities of licensed operators, in the case to-be upgraded to senior.
Q. 262. Do candidates with ah RO license in training while standing watch as operator lose their active license status per 55.53(e)
an extra operator for three months?
of an RO, he,-loses A. Yes'. If the operator does not maintain the requirements his active status.
a license. Could -
Q. 263. This question is related to actively maintainingto meet the active and then again in June someone stand 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in Januaryquarter.
license requirement by calendar maintaining a license, A. No. The 40-hour requirement does not pertain to Maintaining an active status.
but is part of the requirement for resuming active license means standing'the necessary shift watches.
dual-unit plant.
- Q.264. This question concerns active license statustheat-a activities of the The shift supervisor is the SRO who normally directs both of-the shift super- operators. We also have an-SRO on shift who is over of the operators, but-he visors. He does not normally direct the activities time?
may.- Would his supervisory time on shift count as active for a dual-unit site, you A. Yes. If you look in the Regulations on staffing those positions, that have three SROs for the two units. If he is in one of you may still take credit qualifies him. If he is not in one of those positions, that proficiency for his proficiency if you are satisfied that he is maintaining activities of licensed by'man'ipulating the controls and directing'the licensed operators.
NUREG-1262 75
Q. 265. If an operator gets sick in the middle of February, and has been ac- tively on watch in January and February and has this requirement met but is sick for three months before he goes back on the watch, does he have to stand a
40-hour watch? You don't have to demonstrate in the prior three months he has served 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />; isn't it by calendar quarter?
A. Correct. But during the remainder of that quarter he's going to have to complete the required number of shifts to be considered actively performing the functions.
Q. 266. What records will-the Commission require to ensure that a licensee has, maintained active status per 10 CFR 55.53(e)? What will be the record reten- tion period?
A. It's up to the facility to determine how it wants to be able to document the active status. Shift turnover logs would be appropriate documentation.
The key is that the documentation be retained and available for review.
There are two answers to the question of record retention. If the record is the control room log, it has its own record-retention requirement, which is essentially for the life of the plant. If you are using the control room log to determine whether the guy was signed in, that's adequate.
The certification for his returning to duties is based upon his standing 40
hours of parallel watch. On parallel watch, however, he need not sign the control room log. Under those conditions, the responsible official onsite could create a form which would go into your records onsite and be available for audit. That form would have a record retention requirement equal to that person's license; that is, six years.
Q. 267. The proposed rulemaking said nothing about the five 12-hour shifts or seven 8-hour shifts. What is the basis for this, and why weren't we given an opportunity to comment?
A. The previous practice has been for a minimum of one shift, essentially per month, three per quarter. That was deemed by the Commission to not be suffi- cient, as a part of their review and determination of the final Rule, and they increased it to the current requirements in the Rule.
Q. 268. Would it be possible for an operations superintendent to direct activi- ties from off his shift, and if so, then would that individual be required to maintain an active license by actual shift time for a calendar quarter?
A. Let me give you what I think is the most practical example: in an emergency, typically, the operations superintendent is the individual who goes back and forth between the Tech Support Center or provides assistance in an emergency. He gives directions to whoever it is, the Shift Superintendent or the other SROs; so he is not directing the manipulation of the controls;
he's providing guidance on how he wants the event to be handled.
Someone else in the decision process is actually deciding whether he agrees or doesn't and directs the activities of the licensed operators in manipulating controls.
NUREG-1262 76
So in that case he is not on shift in the position; he is off shift, responding in accordance with the emergency plan, which is covered by a different portion- of the regulations.
So the operations superintendent need not hold an active license-unless you intend him to go on shift as a shift superintendent.
Q. 269. That same logic would apply to day-to-day operations, then, if I under- stand you correctly?
A. There is no day-to-day operations issue. He's there fulfilling the posi- tion that's required by the Tech Specs as the operations superintendent;:that -
is, independent of proficiency in manipulating controls. We would not expect the operations superintendent to go in, for instance, and line up systems or manipulate controls on the board.
He needs to be proficient in order to be consistent with the requirements-of,- the regulations', so he would either have to stand 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel duty or maintain proficiency or keep his hands off the controls.-
In the process of examining him for requalification, we would examine him both at the RO and the SRO level. Your continuing training program should ensure that he doesn't lose those manipulative skills because he is not required to maintain an active license.-
Q. 270. If our Technical Specification defined the STA position as an SRO- Qn shift, would filling that-capacity satisfy the requirements?-
A. Yes.
- Q. 271. Consider a plant in cold shutdown with lowered minimum shift manning requirements. Are the licensed operators assigned to that crew who are in excess of the minimum cold shutdown staffing requirements actively performing licensed duties?
A. Yes, if you have determined that they are necessary for safe operations,.
you maintain administrative control over these positions, and if you are satis- fied that they are maintaining their proficiency in accordance with the regulation.
Q. 272. How, and to whomi is certification made under 55.53(f)?
A. This section has to do with returning the individual to an active status.
A certification must be made and available on file for inspection purposes; it need not be made to the NRC.
hours Q. 273. It would appear that once a quarter, an individual could spen¶d 40 could on shift under the direction of the licensed operators. And the facility certify that he-had done so, and that his status in the requal program was cur- rent. And by doing so, he could maintain an active license by spending essen- tially 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a quarter on shift, instead of the 56 to 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> specified in other-parts of the Regulations? Is-that true?
NUREG-1262 77
A. That is true, although thatis not what we intend. The issue is to make it easy for people to maintain a license. And that's a decision that the facility makes with respect to the commitment of time to the requalification program.
If the facility wants to commit an additional 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> for parallel watch standing in a control room in addition to the requalification program, so that he can be active, that's their choice. Our intent was to make the minimum seven watches at eight hours, or five watches at twelve hours, to maintain the proficiency of those who are actually directing the activities, or manipulating the controls. It's a proficiency issue, it's.not a license renewal issue.
Q. 274. Are any allowances made in 55.53(f) for off-shift licensed personnel who are involved in daily operation's supervision?
A. No. They are either in active status or they are not. If they are not, their just being a daily operations manager, or an operations superintendent, does not convert them to an active status.
Q. 275. Suppose someone completes 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> on shift under supervision; then his clock starts again for his seven 8-hour periods. If an individual goes through this in the last month of a quarter, does he have to complete those seven 8-hour shifts before that month is up, or does he start during the next calendar quarter?
A. If he's done 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch in a quarter, he's active in that quarter. For the next calendar quarter, he would need to stand either seven
8-hour watches, or five 12-hour watches. Regaining proficiency allows him to go back into an active status to stand watch. He does not have to do both in the same quarter. That is, he does not have to serve 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> under instruction, plus stand seven 8-hour watches, or five 12-hour shifts in that quarter; it goes to the next one.
Q. 276. Could you clarify what you.mean by "parallel watch standing?"
A. It's very similar to "being directly under the supervision of," as we use.
that phrase for a trainee; that is, the individual that has the watch still has the responsibility.
The person that's in the parallel situation, even though he's licensed, is not considered proficient. The regulation requires that he not manipulate the controls or direct activities except under the direct supervision of someone who has an active license.
Q. 277. Do those 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> have to be consecutive; i.e., eight hours a day?
A. No. It has to be 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. You can have four tens or ten fours or any other combination that adds up to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />; however, they must be in the same calendar quarter. -
The only explicit guidance in the regulation concerns the seven 8-hour or five
12-hour shifts where a full shift means from watch relief to watch relief.
NUREG-1262 78
'A
active status perform Q. 278. Can licensed Senior Operators who are not in refueling SRO duties?.
If they are not A. No. Only active SROs can supervise refueling activities. from licensed active active, they must stand one 8-hour shift under instruction SROs to perform Active SRO duties limited to fuel handling.
that an operator has Q. 279. What leeway do you give to the facility to know received a felony conv'iction?X
A. Convicted felons typically go to jail, so they're not going to be at work.
have background Also, all those granted clearance for unrestricted access for felonies. You will investigations that relate to such things as convictions have access to the information from that source, too.
days?
Q. 280. But the facility will not necessarily know within 30
in 30 days, as a condition A. It is the operator who is required to let us know of the license.
you within 30 days?
Q. 281. So, we don't assume any liability for not potifying to know, we're.
A. If you don't know, and you didn't have a reasonable'basis get a criminal history not going to hold you liable for that. However, if-you of a felony, we expect you check that shows that the person has been convicted to tell us. '
had a'felony 15 years Q. 282. If we submit an applicant for a license awho'has licensing exam and was ready ago, is that still reportable? If he had taken 30 days, assuming we to receive a license, would he have to notify'you within did not know that?
of a felony in the A. If the individual knew that he had been':cbrvicted his application past, and he did not report that on the initial application, the basis for be would be considered incomplete.' Such an omission could revoking his license, since he would have withheld information.
the'Form 396 certifying Q. 283. Why is the applicant no'longer required to sign that he or she has no felony convictions?
that individuals A. Because it is'a condition of a license, per Part 55.53(g)So, should someone get notify us within 30 days of a.conviction for a felony.
required to notify us of the prior a license who had a prior felony, he would be felony.
go inactive, would it also be Q. 284. If we were to let an individual's license lapse?
reasonabile'for us to let'his medical requiremerts He must be medically A. No, you cannot let-his medical requirements lapse.license, whether he main- examined each two 'years. That is a condition of his tains proficiency or not.
NUREG-1262 79
Q. 285. Is there is a purpose for that, if he is going to continue inactive?
He is not permitted go on shift, so there seems to be little point to maintain the medical status up to date?
A. The issue is whether he is medically fit to carry out the duties of a li- censed operator if you put him in a situation of watch standing to regain his proficiency. At that point, he would be permitted to manipulate the controls of the facility, and/or direct activities. The reason we extended the licensing period to six years was to make it coincide with the medical requirement, which comes up in two-year cycles.
Q. 286. Are licensees who maintain an inactive license required to participate in a requalification program to the same extent as licensees maintaining an active license?
A. Yes. A condition of their license under the new Part 55.53 (h), requires participation in the requalification program.
Q. 287. The problem is that standing the shift foreman's license does not pre- pare this person to go out and handle fuel, and I don't understand how doing one watch under instruction does that, how that can guarantee that he's going to be a safe person in charge of fuel handling?
A. We're talking about an SRO limited to fuel handling, not an SRO with an unlimited license here. So if a guy has an SRO license and he'.s an active SRO,
he 'can be used as an SRO with no other duties but to handle fuel, or be the- supervisor in charge of fuel handling, with no other duties. If he's a senior with a limited license, he's in a different category, because he can't be used as an SRO. So any active SRO could be a fuel handler senior, but if he is an active fuel handler and then he doesn't handle any fuel for awhile, or for some reason he doesn't use his license, then he has to only stand one watch, or one eight-hour shift with an SRO who is an active SRO, or an SRO with a limited fuel handler, and then he has met that certification again.
The only adjustments we've made in the rule for fuel handlers are that, in order to become active, they only have to stand one parallel shift, which would make it much quicker and easier than the 40 parallel shift, and that the requal program is limited only to those aspects of the plant operation to which their license is limited.
Q. 288. With respect to the requirements for maintaining operating proficiency, can a licensed STA (SRO License) who is standing the "STA Watch" get credit for SRO proficiency?
A. No.
Q. 289. We had a concern on restoration of an inactive license as a full-scope SRO license, and we wanted to use that individual for fuel handling during re- fueling. Would that individual as a full-scope license have to go through the
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of concurrent duties, or just eight hours of concurrent duties?
A. It would only take eight hours under parallel watch with a person whose license is active, whether that's another licensee limited to fuel handling only, or it's a senior reactor operator.
NUREG-1262 80
when the new rule is Q. 290. When will the quarter for shift standing start implemented?
quarter after the A. For accountability purposes the first complete calendar requirement.
rule is implemented must meet the seven shift/quarter position such as shift engi- Q. 291. Does completion of 7 days on shift in one position on shift for neer, allow the individual to perform duties in another which he is also qualified?
to hold a SRO license, A. If shift engineer is a Tech Spec position required would permit the then performing in the seven-8 hour shifts, per 55.53(e)
licensee to perform duties as either an SRO or RO.
require an active license, Q. 292. Do technical advisors or licensed instructors or FSAR?
if they must maintain a license for technical specifications FSAR etc., but it A. They may need a license per the Technical Specifications, the individual is re- does not have to be "active" per the Regulation unless Specifications identify quired to assume a position onshift that the Technical as a licensed shift manning requirement.
calendar quarter, how is he to Q. 293. If an operator gets his license during a meet the seven shifts per quarter requirement?
is issued, he is con- A. For the initial calendar quarter for which a license virtue of having passed the sidered to have met the proficiency requirements by will commence in the first exam. Thus, the "actively performing" requirement calendar quarter after he receives the license.
NUREG-1262 81
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Requalification and Renewal (Statement of Considerations)
Q. 294. The regulation says that sometime during that six-year period, a can- didate will get a test. That may be the first year through the sixth year, but the next time he is renewed, it may be as much as 11 years apart. Is that correct?
A. No. In the Statement of Considerations, II(H)(4), the last sentence says,
"The NRC will administer these requalification written examinations and operating tests on a random basis, so that no operator or senior operator will go longer than six years without being examined by the NRC once a six-year license is issued." That's a direction from the Commission to the staff. That's the same way we handle the clarification of the INPO status, in the Statement of Consid- erations that goes with the Rule, describing intent. Some operators will receive more than one NRC-administered exam during the term of their license in order to comply with the Commission's direction to the staff.
Renewal of Licenses (Subpart H, Section 55.57)
Q. 295. At what point will the six-year cycle start for present license holders?
A. It will start with the first license issuance after-May 26th. We do not intend to amend the present licenses. So on May 25th, someone will get a two- year license. On May 26th, that individual would receive a six-year license.
Q. 296. I have 107 licenses expiring over the next two years for which NRC
requal exams are not taken. Where do they stand?
A. The renewal of the two-year license is governed by the rules under which they were given their original license, so no NRC exam is required.
Q. 297. We've gone from a situation where at the end of the examination con- ducted by NRC, the results were discussed with the utility, to a situation presently where the results are not discussed until the license certificate is signed off and the results have been reviewed at the Region. In combining requalification exams administered by NRC with initial license exams admin- istered by NRC, will the examiners, upon an indication that a candidate for renewal was a potential failure as a result of the operating portion of the exam, discuss that information with the utility, or will you allow that person to go back on shift pending the complete review? And how do you expect this to affect the turn-around time when we're significantly increasing the number of exams to be evaluated?
A. We can't predict how it will affect the turn-around time. Hopefully we will have the resources to do it within the existing time frame. From the point of view of a licensing decision, no decision has been made until the paper is signed. In other words, it is only a recommendation until the point that either the license or the failure has been approved by the branch chief, by the licensing authority.
We're prohibited from discussing predecisional information. That's why we do not give preliminary results either on site or from the regional office.
NUREG-1262 82
Obviously, if the examiner believes that it's a safety Issue if an individual .
returns to shift, it's incumbent upon him to notify the licensee. We would not leave-the site with a safety issue pending. However, when we leave the site, we don't always know whether an individual has passed or failed all.portions of the examination (written, oral, and simulator).
Q. 298. What is written evidence of the applicant's experience and how is this supplied?
A. Written evidence will be the same as it is now; as it.is.reporteO on rele-.,
vant portions of*Form 398. . -
Q. 299. What is the evidence that the applicant has-discharged thelicense responsibilities competently and safely,.and howlis this information provided?
A. The utility certifies that the individual has performed in accordance with -
the terms and conditions of his license, and that he has performed satisfac- torily. It is for you to determine how that performance has been,,through whatever mechanisms you want to use; whether it be performance evaluations, or -
other information that you-have in your company files related-to that individual.
Q. 300. In reviewing pasttperformance under Section 55.57, you.said earlier that an NRC letter or a letter of reprimand might be part-of what you'd eval- ...
uate. Does this mean a letter of reprimand specifically from NRC, or one from the site -itself?
A. An NRC review would be based upon two things:, the certification from the company, and any official enforcement actions taken against the individual that are in his official docket file. .It does not include information that has-not been formally transmitted to the individual under his license, as it must be a- completed action. The fact that an individual is under investigation by-the NRC-may not result in 'something going into his file. It. only goes into his file when we complete an enforcementaction and he receives a letter-. _t's,.a...
formal notification, 'and there-is guidance.as to what is permitted in the doc-k ket file and what is 'not.- Essentially, anything in the NRC docket file has already been presented to that candidate, whether it be an examination-grading report result,v'or an enforcement action.
Q. 301. :'If someone never operates the controls, and he gets a license, that license is renewable. -Why do we then report the number of hours one operates the facility-on a renewal? . . . . .
A. Although we will renew a license of an individual who has not stood watch, that information may'be helpful-in making judgments on renewal applications in.
which the individuals did not fully meet all 55.57(b) requi-rements,.to the let-.
ter. For example,.an individual may have been unable to attend every requal.
class because' he was participating in-a management course. -The number of operational hours'for this person may influence our decision.regarding his renewal.
Q.'302. When -it's time to renew the license of our shift engineers, can.their- license be renewed in an inactive status, without another examination, if they, have maintained all of their requal requirements?
NUREG-1262 83
I
A. For anyone who holds a license, he must be kept current cation program; he must be medically fit, and he must have in the requalifi- time by NRC during the course of that six-year license. Thebeen examined at some requalification examination requirements are applicable independent of active/inactive status.
Q. 303. If a licensee is not maintaining an active license in accordance with
55.53(f) at the time of license expiration, what are the requirements renewal? for A. If he is not maintaining an active license, he still must requirements for renewal in 55.57(b). However, he does not meet all of the have to be active to get his license renewed. He must be, most importantly, current qualification program, but he does not have to be active to in the re- renewed. have his license Q. 304. In order to obtain license renewal you must be examined least once during the six-year life of the license. What is by the NRC at examination: written, operating, both, either?, the extent of this A. With respect to format, the requalification exam will parallel exam, i.e., it will include both a written and operating test. the initial requalification exams will be based on the facility's learning The content of vided that these objectives are satisfactory.. objectives pro- Q. 305. Section 55.57 states that license renewal is going to be based on having passed the comprehensive requal exam and operating test administered Commission during the term of a six-year license. I believe by the interpreted that to mean that an exam will be given-at least that you have years? once every six A. -Yes, that's what the Commission has stated. The Commission the staff to examine operators at least once each six years-, has directed know that some people may have an exam more than once in six and that's why we years.
Q. 306. What percentage of people will you examine at a time?
A. At least 16 percent per year, because we've got to examine six years. In fact, it will be greater than 16 percent because 100 percent in ness involved in ensuring that candidates don't have prior knowledgeof the random- are coming-in to examine them. of when we Q. 307. How far in advance will an individual licensee be notified by the Commission of his scheduled examination date?,
A. Ten days, minimum; 6 weeks, maximum.
Q. 308. Do you need to take examination to renew a two-year license?
A. No. The rule is very specific: You need an examination by the NRC only for the renewal of a six-year license.
Q. 309. I have some renewal submittals that will hive to the May 26th date, but the renewal is not until after. Do beI submitted before the existing rules for them to come back as a six-year license?submit them under NUREG-1262 84
___ __ ---
4.
one that's in A. The Form 398 that you use until.May 26, 1987 is the same form, if we.issue a.
effect today. Even though you submit that-version of theAny applications sub- license after the 26th, it will be a six-year license. the new Form 396.
mitted after May 26tLh should be on the new Form 398 with have to reapply .it Q. 310. Will the people presently holding two-year licenses extended to the the expiration of the two years or will they be automatically
-?
civ-va c rvr e- their current license.
A. They need to reapply prior'to the expiration date of accredited retraining Q. 311. Considering-that every utility has or will have an which would in- program, what is the justification for the random selection, period, versus clude the 'possibility of having more than one exam in a:six-year one exam in that the possibility of.doing an orderly schedule to include.only same six-year period?
maintain a A. It is NRC's mandate to ensure that all licensed operators the required exam is satisfactory level of proficiency at'all times. As such, that level of.proficiency is intended4to serve as a "spot-check" to verify that that operators can demon- in fact being maintained. Further, we want.to ensure outside of the strate this level of competence without special preparation believe that this is best normal required.training program.. The Commissioners the required exam.
to sit for accomplished by randomly selecting the operators with your regular To the exteht possible, we will coordinate the exam.schedule wrong with cycles. But'if we~have reason to believethat there is something we will conduct exami-,
the program,-or we have other indications of problems, cycle.
nations at times other-than during your requalification written exam once Q. 312. How can the Commission administer a comprehensive their written exam during the six-year cycle if the utility is administering spread out over a segmented period?.
a satisfactory level A. As stated above, the Commission's mandate is to ensure licenses's responsi- of operatorproficiency at all times. It is the facility maintains this bility to ensure that their required program, although segmented, level of proficiency-throughout the training cycle.
to ensure he has had Q. 313.. Who will schedule and track each licensed operator an NRC exam prior to renewal?
the Regions by tne A. That's NRC's responsibility. It will be trackedtheinlast NRC-administered docket files onteach individual which will conrtain requal exam.
an NRC exam?
Q. 314.' How soon can someone be re-examined after.failing If the individual A. 'We haveresources for two visits to a facility per year. evaluate on a fails and-is getting close to the point for renewal, we wquld and give another back case-by-ease basis whether our resources permit us to go examination-before the next regularly scheduled exam.
NUREG-1262' 85
If he's within, say, six months of renewal, and that's when he's targeted to come up for an exam, that's a pretty good indicator that he's going to be tak- ing an exam at that next cycle before his license renewal.
Q. 315. In the past, if an operator failed the requal exam, he would go into an accelerated requal program normally administered by the utility. Is that going to remain the same, and, once he completes the accelerated requal and the examination by the utility, would that be acceptable as far as meeting the requirement of passing the NRC-administered exam?
A. No. There are two different questions there, The first deals with the acceptability of the facility's accelerated retraining program to return that individual to licensed duties, and this depends upon the status of your requali- fication program. If your requalification program is deemed satisfactory, then you have the capabilities under your program of dealing with the failure of a requalification examination.
The second concerns satisfying the requirement .for a six-year reexamination.
The Commission has directed the staff to administer a requalification examina- tion to each licensee during the six-year term of the license. If he fails and you have a program that has been deemed satisfactory, you can retrain him and return him to shift duties; however, he must successfully pass an NRC-
administered requalification examination before renewal of his license.
Q. 316. Is the appeal process for the requal examination the same as the ini- tial exam? If so, there are two problems. One is the individual's own self- respect if he fails that exam and he feels he should not have. The other pro- blem is that our program is being judged against the results of that requal exam. If there's something that we feel was amiss during the exam, we should have a method of recourse in having that evaluated.
A. The answer is that the appeal process does apply as it relates to the administrative process. You are provided the opportunity to comment on the written examination through the normal process for any written examination.
However, the individual does not have the right to request a hearing because his license has not been taken away. He still has a license. He can request an administrative review by the Division Director in the Region and a review at NRC Headquarters if there is a potential for the exam results to preclude his license renewal.
If we were to deny the renewal of his license and he was contesting the failure of that exam administratively, he would have the right to a hearing because we had not granted the license renewal. So in that context, he would be eligible to request a hearing on the denial of his application for a license renewal.
Q. 317. Why weren't the utilities allowed to make public comments on 10 CFR
55.57(b)(2)(iv), license renewal requirements?
A. The Commission decided to add Section 55.57(b)(2)(iv) between the time of the proposed and final rules to allow it to examine licensees during a 6-year license period. This decision was an outgrowth of comments on the proposed rule and is consistent with the Commission's Policy Statement on Training and NUREG-1262 86
Qualifications, and with Section 306 of the Nuclear Waste Policy Act. Part of the reason for that decision is that we indicated in the policy statement on training and qualifications that we would use the requalification examination as a mechanism for judging the validity of the industry-accredited training program process. The Commission is continuing to do that.
We have moved out of the training review and are instead judging the ability of the individual to perform after training. We make that judgment through an examining process. That's the reason for it. The Commission has indicated their policy both through the policy statement, which was publicly noticed and available, and through a continuation of staff practice.
The Commission tied it to renewal to ensure that there was a clear understand- ing on the part of all-operators that this was required, and to eliminate the question of "Why me," because in the past, when the staff selected opera- tors for examination, there was always a question of, "How did I get chosen, why not someone else?" In this case, it's clear that it applies to all li- censed operators who hold a six-year license.
Q. 318. Will future NRC requalification exams given in conjunction with re- placement tests be modified replacement tests as in the past?
A. NRC requalification examinations are developed to evaluate the adequacy of the facility licensee's requalification program. Where replacement training program and requalification training program objectives overlap, duplication of questions is acceptable.
Q. 319. Since it is six years before any renewals will require the completion of an NRC exam, when will the process of "10-day notice exams" get started?
A. As of the effective date of the rule. We can notify select(?ee !S Up to six weeks in advance of the examination date, but in no case will li Wsi than 10 days notice be aiven. -
Q. 320. Does the six-year license apply to nonpower reactors? t their licensed DO
operators require an NRC exam prior to renewing a license?
A. Operators of nonpower reactors will receive six-year licenses upon satisfactory license renewal after their current licenses expire. License renewal will be in accordance with 55.57.
Q. 321. When will the requirement for an applicant' to be examined by the NRC
prior to renewal be implemented?
A. That requirement will become effective for all'six-year licenses granted after May 26, 1987.. -
Q. 322. What will the basis be for "continued need" under 55.67(b)(3)?
A. It is the facility licensee's-decision as to whether there is a continued need for an operator. We will not question the judgment of facility management.
Q. 323. Can the requirements of 55.57(a)(4),(5), and (6) be certified on the Form 398?
NUREG-1262 87
A. Part 55.57(a)(4), assurance that the applicant has satisfactorily completed the requalification program, and 55.57(a)(5), assurance that the applicant has discharged license responsibilities competently and safely, can both be certified in Form 398. For 55.57(a)(6), certification of medical condition, a Form 396 is needed.
Requalification (Subpart H, Section 55.59)
Q.324. What is required for Commission approval of a requalification program?
A. You simply certify to us that you have an accredited program that is based on a systems approach to training, and that's sufficient.
Q. 325. In Generic Letter 87-07, page 24, it states that "The specific cycle g7<Will be approved by the NRC as part of each facility's training program." What
'does this refer to?
A. It covers programs which are not approved through the accreditation process.
Q. 326. On the training program approval, if you have an accredited program and you certify that you're doing an SAT process, that's one method. You also listed implementation of INPO Guideline 86-025 as another approach. Can you explain this?
A. The accreditation process has a hierarchy of requirements, the top level of which are called objectives. You must meet the intent of the objective in order to be accredited, and those are contained in INPO 85-002. The Commission has reviewed and endorsed the INPO accreditation objectives and criteria as meeting the SAT or systems approach to training. I believe there are 12 objectives.
Each objective has a number of criteria; meet the criteria and you meet the objective, but the opposite is not always the case. That is, you may not meet one criterion, but you still may meet the intent of the objective through some other mechanism. You go through the criteria and objectives for your self- evaluation.
Subordinate to those are the guidelines for licensed operator training, for maintenance training, and for other areas. One guideline is for continuing training for licensed operators (INPO 86-025); it gives information about the content appropriate for a continuing training program. It also describes how you evaluate and feed information from plant operations and performance eval- uations back into the process.
You clearly do not have to cross all the t's and dot all the i's of everything that's in that guideline. That guideline, however, constitutes an acceptable method of implementing a performance-based, SAT-based continuing training pro- gram that the staff would find acceptable.
The next level below guidelines are good practices. Those are things which INPO has seen facilities do that worked particularly well for a facility, and they have provided guidance on those.
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We have concluded that if'you are accredited you understand what the objectives are, and how criteria are used, and what the process is for developing a systems approach to training. We think that understanding, along with recent INPO
training guidelines provide an adequate basis for you to review your own programs and certify to us that your program is based upon a systems approach to training.
We believe that there are two final parts to that. You need to look at the tasks that are relevant to the job, decide which ones are appropriate for training on a continuing basis, based upon such criteria as importance of the task to the safety function and frequency of performance. Clearly, emergency procedures would fall into that category. Shift relief and 'turnover would be outside of that category, such that your continuing training program would not address shift relief and turnover.
If you've operated continuously between outages, you would not necessarily have performed plant startups and shutdowns. In that case, you may want to fold the startup and shutdown into the continuing training program, and do that on a simulator.
It's that type of flexibility, and reviewing and determining the content of the program which we feel is the most important attribute of the change to the regulation. It gives you the flexibility to tailor your program to the needs of the job incumbents, and to bring them up to a comparable level with the initial training programs through the INPO accreditation. That's the process we think should be followed. It doesn't mean that everything has to be done in INPO 85-026 with respect to'simulator training, or INPO 85-025 with respect to continuing training. Those are guidelines, and you really need to address the issues as to how much of that should be followed or done with INPO, not with the staff. We are not in the position of reviewing and determining what constitutes INPO requirements. *We want to-move out of that.> We will provide our-comments to INPO should we see problem areas for INPO to address generically with the industry. We do not want to get into the mode of providing guidance to individual utilities on how much of an INPO document needs to be followed before the staff would accept a'certification. That's for you and INPO to work out.
Q. 327. While someone is in an SRO upgrade for (say) ten months, he is not of- ficially in the requalification program. How is that going to affect that inactive status?
A. - If your upgrade program meets the objectives of your requal program, you can take credit for that. However, if there is a differential there might be some areas that are not covered at all, but are covered in a requalification program. If that individual is no longer current in requalification, to resume active 'status,'he would have to receive the remedial training necessary to make him current with the requalification program. Simply being in the upgrade program does not, necessarily, compensate for the requalification program.
We hope that that's not an issue that we face very often, because we expect- that most candidates who go into an upgrade program would receive a license as a senior operator and remain cognizant of changes, LERs, and significant events.
And upon the date they receive a license, they can manipulate the controls and NUREG-1262 ':89
direct the activities of others. So, it's only when there's a period between the end of his training and the time he gets a license when you may want to use him as a reactor operator. He may have to stand some parallel watch with the reactor operator before resuming duties. And that's the point when you would have to certify that he had completed the necessary requirements of the reactor requalification program, if there are any aspects that were not covered in the SRO operating training.
Q. 328. Since Section 55.59(b) indicates that the Commission would accept additional training in lieu of a licensee's participation in the requalification program, is it acceptable for a utility to remove certain license holders from the requalification program, yet have them retain their licenses if this addi- tional training was provided to them?
A. No. Section 55.53(h) requires completion of a requalification program as a condition of a license. In general, a licensee who is permanently removed from the requalification program no longer satisfies this condition of their license, and thus has been determined to no longer need a license by the facility licensee under Section 55.55, Expiration. Only under extenuating circumstances (e.g., special temporary assignment, extended illness, removal from shift to enter a degree program, etc.) would the provisions of Section
55.59(b) be invoked. This will be handled on a case-by-case basis.
Q. 329. There is no requirement to modify the Requalification Program documen- tation. We just have to follow the new rule, correct?
A. That is correct. You must follow the new Rule, or your existing program, whichever is more restrictive. But you may perform a 50.59 review to bring your existing program in conformance, and simply submit that. Or, if you need an amendment to the license, you request the amendment, and you would have an administrative change approved to put your program in conformance with the Rule.
Q. 330. Most facilities have an NRC-approved requalification program in the FSAR. For utilities that cannot certify their requalification programs, either because their requalification program has not been approved by INPO, or it has been approved and does not meet the INPO 86-25 requirements for SAT, how will we implement 10 CFR 55?
A. You will continue to follow your approved program of record, as is documented in the FSAR, until you either modify it, bring it up to the INPO guidelines in
86-25, or take some other action to modify it. That's one way of doing it. You may be able to discuss with INPO other alternatives. But you follow the program of record, as modified by the Rule.
Q. 331. What is the difference between a requalification program 24 months long followed by successive requalification programs and a continuing training pro- gram administered throughout the term of the individual's license? Does the Commission mean to imply something by use of the word "requalification" versus
"continuing training?" If so, what is the distinction?
A. There is little difference between the two. We expect you on some basis to step back and take a look at the performance of your licensed operators and NUREG-1262 90
modify your program appropriately to reflect those areas that need continuing training. From that aspect, we chose 24 months, consistent with the previous program, to be a point at which you would take that formal look at your program.
There is no distinction except that the law used the term "requalification,"
and that's why we continued with that term.
Q. 332. The requalification program must be conducted for a continuous period not to exceed 24 months. What is the purpose of the 24-month limit?
A. Because it's consistent with defining a fixed-length program. Since the previous period was 24 months,-we retained it.
Q. 333. Is there an intent to look at a 24-month period as an isolated section and try to meet certain requirements within a 24-month period?
A. The intent is that at the end of that period we want you to do a comprehen- sive evaluation of the program and decide how you need to modify it for the next cycle. If you want to do it in 12-month or 18-month cycles, that's also acceptable. If you want to tie it to refueling schedules that's also acceptable.
The cycle cannot be longer than 24,months, however.
Q. 334. What is considered a "continuous period" with respect to the conduct of the requalification program?
A. It's 24 months, then you start over again for another 24 months, and then another 24 months, so that you'd have three 2-year requal cycles in the six-year license period.
Q. 335. Will the program that breaks for, say, a two-month refueling outage be considered a continuous program?
A. By "continuous" we mean that it's the same program for operators on shift as well as off shift, and it's the program as you've described it. There may be cases where you want to stop it for a period of time, where you are using segmented training and you want to teach one segment, and in the next segment you, in fact, may have some particular training in the outage that you want to cover prior to the outage.
That's the flexibility you have under the systems approach in defining-your needs are and sequencing accordingly. -
We want one program for all licensed operators. We don't want one schedule or program for people on shift and a different schedule or program for people who are not normal watch standers on shift.
Q. 336. Does NRC want to see a comprehensive evaluation of the program on a biennial basis?
A. Yes, at least on a biennial basis. That's the intent of the biennial qualification examination being comprehensive. Part 55 requires that the evaluation be used in determination of subsequent continuing training requirements.
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Q. 337. On Page 24 of the supplementary information provided to Generic Letter 87-07 is the following statement: "The frequency of the comprehensive re- qUalification written examination has been changed to a maximum of every two years." Where is this statement to be found in the text of 10 CFR 55?
A. The statement "maximum of two years" with regard to examination frequency can be derived from 10 CFR 55.59(a)(1) under "Requalification Requirements"
where it says "Each licensee shall successfully complete the requalification program developed by the facility licensee that has been approved by the Commission and that the program shall be conducted for a continuous period not to exceed 24 months in duration." The next paragraph says "pass a comprehensive requalification examination and an annual operating test." So, by inference, the written examination only has to be administered on a two-year basis, where the operating test is required on an annual basis.
Q. 338. Does this statement mean that written requalification exams can occur less often than every two years?
A. No. It must be conducted concurrent with the two-year program.
Q. 339. If a utility currently has an NRC requal examination scheduled for the first week of June 1987, what will be the impact of this rule on the examina- tion? Will the examination content be covered by the old rule, or will the content be upgraded to the requirements of the new rule? If the examination will be covering the content by the old rule, when can we expect examinations utilizing the content covered in the new rule?
A. There will be no change for the June exams because preparation of those exams has already begun. Only exams given after July 1st of this year will be able to conform to the new rule.
For clarification, there are clearly some changes in the rule that will change the examination. We don't expect that there will be changes in the content of the exam, based upon a requal program that's already been done under the current Examiner Standard, ES-601, where we are auditing individuals who have two-year.
licenses and auditing the company's program.
Clearly, however, the operating test portion will be documented on the new Form
157, and we will be addressing areas that are required by the regulation in constructing the examination. We aren't going to be testing on areas outside of the requal program, or the current licensing program at the facilities, but there will be some change in forms and in the documentation process. The reason for that is that those examinations are already in preparation now, and you can't do 90 days worth of work in the transition period, so we will be continuing to use the materials that were submitted prior to the effective date of the rule to construct the first few exams after the effective date of the rule, but there will be some changes in .forms and processing and how it's handled.
Q. 340. Can the written requalification examination be given in several sections over a period of time or is the intent to administer one complete examination at one time?
A. If you currently have a requalification program in which you've committed to an annual comprehensive written exam, you have to continue giving that annual NUREG-1262 92
comprehensive written exam until you have-sent in the appropriate documentation that you have an SAT-based program and that you're 'Movingto a continuous pro- gram that is going to be conducted over a period of 24 months. That's one way of doing it, sending us a letter telling us when you are accredited and that you have a requalification program that's SAT-based.
The other alternative is what we have done in the past, which is the 50.54 change, where you would notify us that you're changing your program. So if you're committed to an annual written exam'during this transition period, you have to continue to meet your commitments until youv'ye notified us that you're changing.
Along those lines, with regard to the segmented exams, if you currently have in your protgram an annual comprehensive examination, then we will expect you to continue that.;
If you have an accredited program and the segmented approach to evaluation is an acceptable methodology under that program, we will allow you to implement your program. -
But realizing that the NRC examination will be a comprehensive examination, we expect that the program evaluations-that you implement will be comprehensive in nature, also-.' For clarification, weekly quizzes that may be given following a week of instruction tallied together to form one exam probably would not meet the comprehensive intent of this evaluation process.
Q. 341. Written examinations for requalification will be based on initial li- cense material. Should the exam not be limited to the scope of the approved'
Requalification Program?
A. The requalification-exams are intended to be performance-based and opera- tionally oriented.' To the extent that they're made available to us in the submittal following the 90-day letter, we intend to use the facility licensee's learning objectives that pertain specifically to the continuing training program. ;
We. anticipate that when you have an SAT-based requal training program, it would be modified from time to time, depending on the needs of the job incumbents.
As your'needs change, you would'modify your program.
We anticipate that those learning objectives might be different from time to time. We would, of course, tailor our exams to those learning-objectives.
Q. 342. Would 'itbe NRC's -goal to document those differences between the initial exams and the requalification'exams?
A. We want you to certify that'you've'got a-requalification program that's based upon a systems approach to training; and you should document those differences. ii - ' -
That's why we say that when'you do the-initial'task analysis, you should identify that subset of tasks which are appropriate for' continuing training.
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We believe that to the extent you follow the INPO guidelines in 86-025, you will have done that. We believe that that's a fair representation of the type of material that should be contained in continuing training and should be used for the basis of a requalification examination.
Q. 343. Where do we find the standards and criteria for administering the com- prehensive exams for the requals?
A. The standards and criteria are identified in Section 55.59, and as far as our implementation, they will be clarified in ES-601.
Q. 344. You said previously, where there is an annual operating exam and then a comprehensive written exam every two years, that the NRC exam would count for the operating portion of the examination. 'Why would that not also be accept- able for the written portion, if individuals were scheduled to have their writ- ten exam during that year?
A. We intend for it to be both. If NRC administers a written exam, that will substitute for the facility written; if'NRC administers an operating test, that will substitute for the facility operating test for that year or for that program, whichever is appropriate.
Q. 345. Will section 55.59(a)(2) change the policy of using a licensed SRO to write/review the written requal examination? If the written examination is given every two years, would he still fulfill the requirements of this section since technically he is not taking the exam? Similarly, will the SRO who writes the performance exam, and is thus exempt from taking the exam for that year, comply with this requirement?
A. Section 55.59(a)(2) will not change the policy of using a licensed SRO to write or renew these examinations. However, it is the Commission's intent that all licensed operators be enrolled in the requalification program and take the requalification exams; further, an individual must take an exam that he did not write or review.
Q. 346. What will be the duration of the grace period for the implementation of the new 10 CFR 55?
A. The rule goes into effect on May 26, 1987. There are grace periods identi- fied within the rule for certain aspects of the rule, and those are stated in the rule.
These include operating tests on an annual basis. If an individual is licensed on May 26, 1987, and holds a license, he must have had an operating test by May 26, 1988, within one year. For an application which you submit in the middle of that period -- after, say, six months has expired -- he may or may not have had an operating test, because you would not have been required to complete an operating test for everyone until after one year. So if it says you've got to examine annually, then one year after the effective date of the rule, everyone should have had an operating test. Another example is the comprehensive written examination to be done at least each 24 months. After the rule has been in effect for 24 months, everyone who was licensed on the NUREG-1262 94
first day that the rule went into effect shall have had a comprehensive exami- nation, unless, of course, you are accredited, and then you may use a segmented exam.
Q. 347. It appears that comprehensive requalification written exams are required only every two years and operating tests are required once per year. Is this true?
A. It is true that the written examination will go to every two years unless your program commitments are more'stringent. If your current program requires an annual exam and it is not an accredited program then you will have to notify us if you intend to reduce that commitment. If it's an accredited program, then you can make the changes as appropriate.
Q. 348. Our past requal programs, for those facilities which don't have plant- referenced simulators, have not included an operating test. They have included some operating evaluations, but not a pure test in the context of the new regulation. Some of the currently licensed operators will be up for renewal immediately, as soon as the new 10 CFR 55 goes into effect. Will there be a transition period during which it would be possible to get a waiver for those operators because they will not have had an operating test? We do not have a simulator certified by NRC to conduct an operating test. And, in fact, I'm not even sure if, under the new regulation, we could use our current off-site -
simulator to conduct an operating test. So, how do we address'renewal of licenses for the period between now and when we get our plant-referenced simulator; or will there be some time after which we will have to do an operating test?
A. During the period between the effective date of the Rule and one year following, an individual may not have yet had an annual operating test, and you may put him up for license renewal. After'one year, everyone should have had an operating test. The issue of whether an operating test'is on a simula- tion facility, or conducted as a plant walk through is a different issue.
At least the plant walk-through portion will be required. The issue of doing it on a simulation facility, that would be required by May 26th, 1991. Prior to that time, if you have certified or approved simulation facility, you would also do it on the simulator. If you are currently using a simulator, and we are conducting examinations on it, we expect you to continue to do so, and within one year of the effective date of the rule, start examining candidates using your current simulator as a part of the operating test for the requalifi- cation program. Also, you have to make sure that the documentation that you provide for that annual operating test addresses all 13 items in the new Regulation. The Form 157 is the way that we are going to check that. You can use alternate ways, but you must make sure'you document all 13 items.
Q. 349. During this one-year period of transition, do we document, by exception, and ask for a waiver on our requestsfor renewal? Would that be'the appropri- ate way to handle that?
A. No, that would not be necessary.
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Q. 350. Must a facility administer annual operating tests to licensed operators before a certified plant referenced simulator is available?
A. Yes. Even though it may not be part of your requal program now, you have to start administering an operating exam, and if you don't have a simulator, then you would give an oral exam, a walk-through type like we do on the plant.
This is one aspect of the transition into the new rule where we are not going to look for everyone to have completed an operating test on May 26, 1987; but by May 26, 1988, everybody who's been licensed for that last year shall have completed an operating test on the facility.
We're using a more common sense approach, so if you. submit an application for renewal for a candidate who has a two-year license now, and you submit it in four months, that individual may not have had an operating test, as is described in the rule, because he has not been under that rule for a year. We would still renew the license and issue him a six-year license.
After everyone has been under the rule for,one year, we would not find that he had met the terms-and conditions of his license if he had not had an operating test, because the operating test is to be conducted each year.
Q. 351. If an SRO directs the proper action, does that satisfy the ability to perform the actions necessary?
A. Yes.
Q. 352. We've talked about an annual operating exam to be administered by the utility. What constitutes an "operating exam?"
A. If you currently have a simulator on which you or we are conducting exam- inations, then you must include an oral and a simulator examination. It is not performance of practical factors in a training environment. We've had, for instance, the requirement of the Denton letter to perform certain practical factors on an annual basis. People take simulator training and perform the practical part until successful, whether it takes one, two, or three tries.
We are interested in a structured examination. We are not interested in train- ing on the simulator. The structured examination must meet the requirements of the regulation as it relates to sampling those areas that are specified under the regulation. It is a combination on the simulator, if you have one, and in the plant. If you don't have a simulator, it must be done in the plant.
Q. 353. What constitutes by definition, an annual operating exam? In our NRC-
approved requal programs we administer what is called an accident assessment exam. It's an operational type exam, documented by written examination, which tests operator knowledge and on how they can operate the plant, implement procedures, diagnose a situation, a transient, an accident, or whatever. Does this meet the annual operating exam criteria?
A. Look at what is specified in the Regulation by way of observed behavior for the operating test, and assure yourself that the way you are implementing the exams covers those 12 items for an operating test for requal. The start up NUREG-1262 96
shut down is the only portion that's dropped out. But control board familiarity, those kinds of things are still being assessed. You need to look at your -
program, and judge whether you have met those 12 items for the operating test for requal.
Q. 354. Must the annual operating exam for requalification be given in one time frame or can that also be broken up into various pieces throughout the year? -It's very difficult to get everybody done in one year by the training staff.
A. For a candidate, it needs to be done at one time, but if what you are asking is that you have 30 people that need to have an operating test, and you want to spread out the 30 tests over the period of a year,. the-answer is yes.
But you can't take an individual and give him a walk-through today and some simulator evaluation tomorrow and then some six months from now add those three pieces up. That would not meet the intent of an annual operating test.
Q. 355.. Not even if you broke up the in-plantzand thelsimulator between the dif- ferent weeks in requal, and catch them one cycle a week, get a crew in on the simulator and maybe the next time they come up, five weeks from then, get that same crew up on the plant?-
A. Although we have explicitly approved such an approach for the written examination where you are using segmented tests, provided you show that the sum of the parts equals the whole in the comprehensive exam, we have not con- cluded that such an approach is acceptable for an operating test. Our posi- tion is that an operating test, to be effective, must be administered at one time, and must cover the 12 items' in the rule as a minimum.
Q. 356'. Section 55.59(a)(2) implies that the requalification program includes observations and evaluations of performance and competency by supervisors or staff members during actual abnormal and emergency procedures at the plant. Is this required?
A. This goes to part 5, evaluation, of the definition of systematic approach to training. The intent is that when the casualties are practiced on the simula- tor, performance would be evaluated by staff members as part of that systematic approach to training. It's not intended to have those evaluations done on the actual plant.
Q. 357. The criteria for the NRC comprehensive requalification examinations are similar to the standard criteria for an initial examination listed in 55.41 and
55.43. What is the perceived difference-between the two exams?
A. The-requalification exam requires a sampling of criteria. If your requal- ification program is based upon a systems approach to training, you will have reviewed the tasks from the initial program which are appropriate for continuing training. You-will have chosen those on some criteria, such as frequency of performance, safety-significance or other criteria. That's one way of deter- mining the content of your continuing training program.
Another way is the feedback from 'performance in the plant: licensee event re- ports, and the like. Another area would include facility design changes and/or NUREG-1262 97
changes in procedures. Those are the subject areas that we would tend to focus on for a requalification examination.
When you move to learning objectives for your requalification program that have conditions and standards, we would use that as the basis for sampling the content of the examination.
In the meantime, because that's not fully in place yet, we are using such things as the K/A catalogs, which identify the importance of job tasks and are based upon the industry generic job task analysis. We are also using a sampling plan
-- it was referred to as the "examiner handbook" -- where we sample from that catalog to ensure that we get a representative sample of the knowledge, skills and abilities -- the skills being done on the simulator--that are appropriate for an NRC examination.
We intend the initial examination to be different from the requalification examination. We will look at the two, even though we developed them in paral- lel; and questions which are not appropriate for a job incumbent -- questions, for instance, on watch relief and turnover or other things which he does on- a repetitive basis -- would be excluded from the requalification examination.
We believe that through the informal review process of appeals, and the facility review of the written examinations, there are sufficient safeguards in place during the transition period to ensure that there was a content-valid examina- tion that was indeed related to job performance.
From our review of examination reports from all the regions, the weaknesses concern knowledge of events that have occurred at their own plant, significant events at other similar plants, changes to design, changes to procedures, and selection of those tasks from the initial program which are relevant to training on a continuing basis. We do not help the operators if we simply repeat the initial program for continuing training. That's not the intent.
Q. 358. How are the current guidelines, which allow requalification examination site visits to be extended to every three years based on good SALP ratings or accreditation, going to interface with 100-percent requalification every six years?
A. Basically these are two different programs. One is a programmatic evalua- tion looking at the adequacy of the requalification program. The other deals with the Commission-directed re-examination of each licensed operator on a six-year basis. In the next couple of years, though, we don't expect it to change very much. It's going to take some time to build up a pool of six-year licenses so that we would be conducting the examinations in accordance with this regulation. So in the near term, those facilities which have better performance and have achieved INPO accreditation would have a longer period between NRC visits.
Q. 359. On the question of randomness, if in year two a candidate passes the exam, and in year four he fails, the rule says he has to pass it once during the six years. Will that stop the renewal of his license?
A. No. If he had passed one exam and failed a second one, but was re-examined by the facility after appropriate remedial training and returned to watch, he NUREG-1262 98
would have passed an exam and that would be the basis for the license renewal.
The rule does not say the last examination administered by the NRC. It says an examination during the six-year term of the license. And we recognize that some people may have more than one.
Q.-360. What process will be used to schedule the NRC-administered written examination and operating tests during the term of a six-year license?
A. It is our intent that this-will be a random test, performed on a random basis. We would try not to have double jeopardy, where an individual takes more than one NRC exam during hi's six-year term. But he may. We will have to coordinate with the facility. We would, in our 90-day letter, ask for lists of people who would be eligible to take the NRC exam.. This would include all licensed individuals at the site. If there were individuals who had a vacation scheduled during that time,'or if there were some personal hardship, we would want to know about it. We want to work with your people's needs as much as we can.
Q. 361. This question addresses the random requalification examination and the pe9ding notification. A lot of emphasis is placed on team work and communi- cations, even though the license is granted to an individual. Admittedly, periodically we may rotate a person within a shift due to'illness or vacation, etc., but most of the people, normally three out of the four, usually remain the same. The potential exists for administering a simulator examination, potentially to four people that don't work together normally. Have we consi- dered the potential jeopardy there, that we have created an environment con- trary to the way we have been trying to teach the operators, in particular going to the plant-referenced simulators?
A. The examiner standards indicate that when selecting people from shift, you select one cr'ew. That is the mechanism we use. And one crew is approxi- mately 20 percent of those people on shift, unless you have a six-shift rotation instead of five. And then we look at approximately 20 percent of the operators who are not on shift, the day-shift workers.,.
To the extent we can, we would put them into the crews where they normally work. But when you consider all the other constraints, such as those who have six-year licenses, those who have two years, the time frame for renewal, etc.,
that will not always be possible. To the extent we can, we want to accommodate your personnel. We would try to coordinate the examination visits with the requalification cycles that you are'already using.' In fact, in the past we have allowed the facility to identify how they wanted to combine the crews.
We just say these are the guys'we are going to see on this schedule, and you tell us how you want to group them.-
But at the same time, there is not going to be a lot of advance notice to the individual as to when he is going to be examined. It will-be on the order of ten days to six weeks. Although there may be some comfort in being examined in the team environment in which training takes place, transfer between teams is a practical reality with which each operator must be equipped to deal, both in the plant and in the NRC exam.
Q. 362. Will a representative sample group of license holders be tested or will the whole license complement be tested?
NUREG-1262 99
A. In keeping with the'Commission directive, it should be a random sample of license holders. All would be subject to exams-. We would coordinate that with you if there were severe hardships but that would have to be handled on..a case- by-case basis.
Q. 363. This concerns the random examinations of licensed operators. How far in advance will I know who will be examined? When will I be supplied with the list of names, saying that on this day, these people will be examined?
A. You will be notified of the examination 90 days in advance in accordance with ES-601. Typically, ten days to six weeks, prior to the examination, we will notify you of the individuals who have been randomly selected for the requalification program evaluation. '
Q. 364. Will NRC notify'-the facility in time to facilitate preparation of the license holders before taking the requalification exam?
A. We will provide ten days to six weeks notice. It was explicit direction from the Commission to ensure that examining is done on a random basis -for reasons- that are associated with evaluating the continuing training program, and evaluating and ensuring that the candidate maintains proficiency and an appropriate knowledge level over the duration of his license.
We will coordinate the scheduling of examination visits with your regular requal program schedules and/or your replacement examination schedules to the extent we can. But our resources are limited. We are budgeted for two visits per year to a facility. And if you have a need for more than two to accommodate some activity, it's likely not to occur without adequate advanced planning.
And we will choose candidates from among those who have not 6een examined by the-NRC before we select someone-who'already has been so-examined. However, some people will be examined twice, so that those who got examined early in their cycle shouldn't make the assumption that they're not going to see the NRC again for the duration of that period.
Q. 365. In the past NRC tested requal every two years and the operators were drum-head tight-until somebody was randomly selected. Then they relaxed for two or three years, depending upon whether everybody had gotten accredited.
And then the cycle was repeated. .
I'm under the impression that neither NUMARC, nor the operators, nor. anybody else, had an opportunity to critique these particular two paragraphs prior to having seem them here. It appears to me that as a minimum, NRC is going to have to give a requal test once a year, if I have requested a hot license test once a year.
A. Your perception is quite accurate. The Statement of Considerations is the vehicle that the Commission used to provide directions to the staff on how to implement the Regulation, which has always permitted the staff to administer requalification examinations. The fact that the-requalification examination has been made a condition of license~renewal is new. '
NUREG-1262 100
this other guy?"
There was some concern in the past, of "why me?" "Why notintent is, it becomes By putting it in the Regulation, and indicating what the license, be examined clear that everyone will, at some time during that six-year by NRC in order to have his license renewed.
tests and five We are accepting a certification by the facility for two written to examine in some operating tests per six years, but the staff will continue the facility's certifica- cases. That is, we will simply choose not to accept may be some cases tion at that time, and we will examine the individual. There once each six years.
where an individual will be examined more frequently than in the first year, Q. 366. If an operator gets his license renewed, and is-tested renewal. Then, my arithmetic says that he can't go but one year beyond his by definition, than once every clearly, the frequency is going to be greater, six years.
a six year A. Correct. That's why we use the term at least once during license.
requal. Would it Q. 367., These questions are related to the NRC-administered the six year period be possible for an individual to be selected twice during before all other individual licensees were selected once?-
before selecting A. -We intend to select people who have not been selectedfrom happening, if we someone a second time. But that does not preclude this all of the people with six-year got everybody else. If we've been through individual to be is possible for an licenses, and we are still sampling, it examined twice.-
selections are made Q. 368. So, it's random, but the pool from which the random gets smaller asopeople are selected?
being issued. At A. It could get larger, based upon more six-year licenses six-year license.
a some point it will reach equilibrium, where everybody has or is it testing Q. 369. Is this a testing of the requalification program, a step backwards in human beings every six years? I feel that it may have been are going to be up raising the anxiety level of the population of operators who of Considera- tight every year. That's why I don't understand the Statement tions, because I'm just concerned about those people.
more than six years A. It says that we're going to test so that nobody goesget examined more than without being tested, and means that some are going to is going through once in six years. It's our view that if a licensed operator be any concern an effective, continuing training program, then there shouldn't designed to confirm with that person getting an NRC exam because our exams are If he is that the individual has maintained a minimum acceptable capability. is that he is way going through a continuing training program, our expectation above the minimum that's acceptable.-
and our supervisors on Q. 370. I feel perfectly comfortable that our operators, using to measure the shift can safely operate our units. The vehicle you are those results. If we requalification program is improperly aimed at obtaining
.NUREG-1262 101
focus the requalification program on problem areas, design changes, and events in the industry, it's fairly narrowly focused. But the exam looks at a target area beyond that, that has not been covered, for memory/recall type things, and it's unrealistic to see the operator be able to pass that, or the senior operator, or anyone else.
But if the exam were focused on what the requal program had focused on, then the focus is on target. 'You ought to be able to pluck an operator off shift, have him evaluated, and expect that he'll do fine. But when it's not aimed at, the same material, very little probability exists of him doing well on the exam.
A. We understand your comment, and we recognize that both groups are trying to move'to the point where we are using content-valid examinations to measure performance. We have a ways to go, and we are working on that. And we think you all-have ways to go in describing adequately the content of the continuing:
training program. Eventually, we will get to the point where we have closure on the scope and content validity of a requalification examination.
Until then, there is going to be anxiety. We believe that with the administra- tive review process for examinations, there are-adequate safeguards to ensure that improper questions can be challenged, and that the questions are appropri- ate to the job. We have provided some tools to do that, and they need to be used. And until we get conservative feedback both ways, and recognize that the objective is to measure that individual's performance, the imperfect tools that we are using now aren't going to get much better.
And that is a challenge to the industry, to really take a hard look at the INPO
guidelines in continuing training programs, and to consider how your program is modified to meet those objectives.
We've had problems with exams in the past, and we probably will in the future.
We have found problems with requal programs in the past, and we'll probably find problems with those programs in the future. But we have not taken action against individuals by way of revoking licenses, or other activities. We do expect that 'until remediation is provided, those who fail are removed from shift-standing duties until they are brought back up to speed.
And if they feel-that the examination is unfair, they can request a review of- the examination by the Regional Division Director, and they can subsequently request a review by the Director of DLPQE. We are serious about improving the quality of exams and getting them content validated.
Q. 371. What would happen if, by chance, an individual wasn't selected during the six year period?
A. The NRC intends to administer a comprehensive written exam and operating test to 'every licensed operator at least once during the six-year term of the license. In the unlikely event that an individual did not receive such an exam, we would take immediate steps to initiate one. However, we would have to con- sider that he had made a timely application for renewal, and as a result, his existing license would remain in effect. But we would not issue a new license until we had examined the individual.-
NUREG-1262 102
Q. 372. What occurs when an individual fails the NRC-administered requalifica- tion exam?
ac- A. First, the individual is removed from licensed duties and placed in an celerated training program. Once he has successfully completed all remedial training, he must pass a facility-administered examination to ensure that all weaknesses have been corrected. If that facility's training program received an NRC rating of marginal or unsatisfactory, this examination may be overseen by the NRC, in keeping with the alternate approach to requalification evalua- tions which was recently adopted by NRC.
In addition, it should be noted that in accordance with Section 55.57, all of operators must pass an NRC-administered requalification exam during the term the six-year license.: Therefore, if this individual failed the NRC-administered exam requalification examination and has not passed anotherNRC-admifnistered renewed during the term of his current six-year license, his license will not be until he has passed such an examination.
Q. 373. Is there any minimum period before a person gets into the requalifica- tion pool, after getting an initial license?
a A. The clock starts the day'he gets his six-year license. But if we give requalification program audit, and there are individuals on site with two year licenses in effect, they are also in the pool to be randomly selected for an evaluation of the requalification program, in accordance with Examiner's Standard 601. So, don't assume that only six-year people may be chosen.
fa- Q. 374. 'Part 55.59 states'that in lieu of accepting certification by the cility'licensee'that the'licensee has passed written examinations and operating tests'administered by the facility licensee, the Commission may administer;
comprehensive requalification written examinations and an annual operating test. Will this'testing take the same form and frequency as the previously established 20 percent testing at 50 percent of the utilities in the Region?
A. Yes. It will have essentially the same form except it will now be about For'
16 percent of theoperators at all facilities in the region every year. the clarification, you can anticipate that the operating test will resemble one that would be given for an initial candidate, but the written exam would to be geared directly 'to'job performance. The written exam is going to have be operationally oriented.
Q. 375. Will requalification exams be administered to non-approved requalifica- tion programs?
A. As we see it, there are no such programs. You are operating under present you NRC approval under old Appendix A, new 55.59(c), the requal program, or out- have an INPO-accredited SAT-based requal program. There can't be anything side of those.
pro- Q. 376. Prior to the issuance of this rule, people developed their requal the other, gram with two taskmasters: one, the INPO accreditation process, and the relatively non-task based aspects'of Appendix A., Now that the utilities NUREG-1262 103
have got the flexibility to withdraw or to remove the non-task based part of the old programs, which may take some time, what is the approved program in the interim? Is it the old program?
A. Yes, you must follow the NRC-approved program, which was based previously in Appendix A to Part 55, until such time as you send to us a letter which certifies that you are accredited and that your program has been based upon an SAT approach. We don't believe, however, that that is such a big task. Some of the material we required in the past falls into the kinds of things that can be used in an SAT-based program.
Whether that set constitutes 80 percent coverage or 70 percent coverage, we're not sure; but the real issue is the flexibility to design your program based upon program evaluation and feedback from on-the-job performance to factor in changes in procedure, changes in design, licensee events, industry events, and if you look at the programs that have been approved by the NRC, those have been required.
In some cases, because of the need to cover so many hours in the classroom, you've had a competition for time available to conduct training, so important items have been covered in the discretionary time left.
So we think that's a major advantage, and it's one that we would encourage to look at carefully and to implement as quickly as you can. you You have to follow your approved program, but by May 26, 1987, that approved program has to be brought up to at least meet the requirements under the new rule. If you have an Appendix A approved program in place currently, then on May 26th, you can submit a certification that you have SAT program which now meets the requirements of the new rule, but if you do that on May 26th, to upgrade to the SAT program, the program you have in place has to comply. No matter what it is, it has to comply with the new rule on May 26, 1987.
If you do not intend to upgrade to an SAT program, you can continue to follow the format of your old program, but that old program has to meet the require- ments of the new rule on May 26, 1987.
Q. 377. What is the intent of the Commission to approve specific cycles as a part of each facility's training program?
A. Once the programs are certified as SAT programs, it's not our intention to recertify these programs on any particular basis. Item No. 5 brings in the continuing process of change that should reflect the feedback from the perform- ance evaluation of your program. The Commission will not be requesting periodic certification. You certify once and update to indicate when subsequent accredi- tation was achieved.
In the first round of accreditation, you have a specific date that you were accredited. Through that process you have a requirement to submit a report at two years and to be re-accredited at four years. You would simply send in another letter that says, "My programs have been again accredited," and that would be all that's required based upon the Commission's endorsement in the policy statement as it exists today.
NUREG-1262 104
Commission that their Q. 378. By what means.is a utility to certify to the upon.a systems approach to requalification program is both accredited and based training? The interpretation for implementing what a systems approach to training By specific standards-is our is somewhat different by the NRC and INPO. i. e., the NRC's certification for using a systems :approach to training.based;
evaluation, or criteria'utilized in conducting pre/post accreditation'site using the INPO 85-002 criteria?
essentially a series of A. The two are equivalent; that is, NUREG-1220.is a systems approach to training questions related to each of the five elements-of same policy statement, the as it's described in the policy statement. In that and criteria as being.
Commission has endorsed the.INPO accreditation objectives a systems approach to training.
and about-60 subor- The.difference comes about.in that INPO has 12 objectives identified five dinate criteria.. The Commission in the policy statement that we'use for information- elements, and the Staff has a number of questions that you use theINPO
gathering in our reviews. However, we would prefer supporting documents;,in particular, accreditation objectives and criteria and for your requalification program.
the INPO program. Objectives There is clearly a hierarchy-of documents within you can still meet the ob- be met if need to be met. Criteria may or may.not an acceptable way of jectives. Guidelines are just that--they are guidelines, doing business as INPO would review'it.
our postaccreditation.
That is very similar to the.staff's approach in doing the five elements that the audits. We have questions that relate to each of imply criteria. They are Commission has endorsed. Those questions do not simple answer to the question simply areas where we gather information. So the is follow INPO.
program was not based upon We have seen several cases where the requalification upon a training program a systems approach to training; rather, it was basedIt was very prescriptive. -
docketed.with the NRC, that the NRC had approved.training, perform certain prac- It was, "Conduct X number of hours of classroom the Denton letter," etc.
tical factors on the simulator in accordance with to change commitments that Because of a reluctance onthe part of.the utilitymany of those programs were are required by license condition or regulation, not changed to a systems approach.
by simply sending a Effective May 26th, you can remedy that prior restriction and that you have.-
letter to NRC which indicates that you are accredited basis.
developed your requalification program on a systems-approach-to-training gives you the flexibility to That's.the most important aspect of this rule. It upon the needs of the individ- control the content of continuing training based which are, described.
uals who-have been trained, and the feedback mechanisms training; program re- Most important is Element 5 of the systems approach to job. That's where we see vision based upon evaluation of performance on the you the .flexibility that the major payoff, and we think that we are giving through training andL
you need to fully implement the industry commitments accreditation.
NUREG-1262 105
K>
Q. 379. What criteria is the Commission going to use to veloped using a system approach to training? approve programs de- A. If you are asking the NRC to approve a requalification on a systems approach to training, we don't look forward program that's based kind of reviews. We'd rather see a submittal indicating to trying to do those that you have an INPO-accredited program, which has both initial and requalification based on an SAT. training If you were to ask NRC to review a training program that was not INPO-accredited, that you claimed was based on a systems approach to training, use the document that we now have to evaluate that, NUREG-1220.we would try to For clarification, if your program is accredited, and you're licensee, then prior to receiving an operating license we not a cold plant will use the INPO accreditation process and the guidelines fully expect that you been issued by INPO in their continuing training guidelines that have recently operators to develop your requalification continuing training for licensed program.
We will accept a simple statement to the effect that this accept as fact that you have been accredited, and thereforehas been done. We stand the process of developing performance-based training. that you under- to review such programs. I don't think INPO would like We do not expect against their criteria and to put them into that context. us to review programs We are this rulemaking, clearly differentiate between training programs, trying to, in being handled by the industry initiatives through NUMARC which are ing requirements and the NRC examination. We don't want and INPO, and licens- would probably have discussions with facilities that proposeto mix those two, and to do otherwise.
Q. 380. As far as the INPO document,86-025, is concerned, long as you are following the guidelines." Do you expect you just say "as with the guidelines, or just general compliance? verbatim compliance A. There is a hierarchy of criteria within the INPO program, objectives. Then you have criteria guidelines. You must starting with the objective. That's a "shall." When you get down to meet the intent of the not meet all of them verbatim. For some you may have alternate criteria, you may Guidelines indicates what INPO believes would be acceptable methods.
of the criteria and the objectives. to meet the intent Your program has mechanisms for reviewing and deciding how you put that process in place. The fact that you are accredited is evidence stand how to use that process and those guidelines. We to us that you under- details, based upon the fact that you have been through don't need to see the accreditation.
The principal goal for revising the requal programs is to operating problems, particularly licensee events, plant allow feedback from design dure changes, and other aspects of training for which there changes, proce- need, and not to be constrained to X number of hours in is a demonstrated what's been required in the past. a class, because that's Q. 381. What if I put in 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of simulator time, but we're doing okay with 80? although INPO says 120,
NUREG-1262 106
which utilizes A. That's between you and INPO and your needs under a program on our evaluation-of the SAT process. We have confidence in the process based training programs if we see per- a number of facilities. We may get back into our inspection an event or through formance deficiencies on the job, through program.
as to how We have developed guidance, the series of questions in NUREG-1220, know what you consider we're going to go about evaluating programs. So that you not in the mode of telling INPO
to be fair game for us to look at. But we are the facilities to -
what to do. That's for the Accrediting Board, INPO, and determine.
in accordance with the'
Q. 382. Will your evaluation of the training program be guidelines in NUREG-1220?
on-it, and we have been A. Yes. We have had a number of discussions with INPO
using that for our post-accreditation review.
10 CFR 55 requirements)
Q. 383. Will a change to FSAR Chapter 13 (to satisfy new requalification be considered a decrease in the scope of an approved operator in accordance with 10 CFR 50.54(i)?
program requiring prior NRC approval, where it A. No. That issue is addressed in the Statement of Considerations, Even '
indicates that this Rule supersedes all other previous requirements.
of your requal. program though the Rule may have caused a decrease in the scope approval of this Rule,.
it has already been sanctioned by the Commission in its then you must follow d;
provided your program is INPO accredited. If it's not, scope..
50.54(i); so you must determine if it has decreased in.
of Federal Regulations Q. 384. Applicable portions of Title 10, Chapter 1, Code Can you be more are one of the lecture topics for a requalification program. or is that "up to the specific as to which portions of Title 10 are applicable, plants to determine?
includes such things as A. You just cited the NRC Rules and Regulations, which that. So, there are l;
Tech Specs and amendments to licenses, and things like standards in part 20.
many Title 10 issues, including the radiation protection by the plants to The subject matter of those lectures should be determined satisfy the training needs of their operators.
manipulations to be Q. 385. Paragraph-(c)(3)(i) of Part 55.59 requires certain the list in the
.from performed annually. 'This list of manipulations differs program is based Harold Denton letter of March 28, 1980. Our requalification requalification on the Denton letter. -Howlong do we have to modify our program to be in compliance with the new 55.59 requirements?"
of the Harold A. The rule supersedes and should include the requirements in your program that Denton letter of March 28, 1980. If there are commitments then you will go beyond those identified within the March 28, 1980, letter, your program to that have to entertain an amendment to your Tech Specs to bring we expect you to have a minimum level specified within the rule. Otherwise, May 26, 1987.
by program that is modified and in compliance with rule NUREG-1262 107
Q. 386. Section 55.59(c)(3)(v) states: "A simulator may be used in meeting the requirements of paragraphs (c)(3)(i) and (3)(ii) of this section, if it repro- duces the general operating characteristics of the facility involved and.
the arrangement of the instrumentation and the controls of the simulator is similar to that of the facility involved." Fort Calhoun will continue to use the Combustion Engineering (CE) simulator in Windsor until the plant-referenced simulator is available for training. Is the CE simulator approved for meeting the applicable requirements until such time as a referenced simulator is avail-*
able? The same question applies to the discussion in Section 55.59(c)(4)(iv).
A. Yes, until May 26, 1991. This is now a part of your requalification pro- gram and will continue to be a part of your requalification program until you either have a certified or an approved simulation facility.
Q. 387. Does NRC agree with the utility interpretation that they may use the nonplant-referenced simulator as the preferred device when it comes to the requalification training program's on-the-job training control manipulations?
A. The word "preferred," we would think of as "equal." There is a nuance for the control manipulations -- the on-the-job training in items (a) through (f).
In the Rule, under on-the job trainings it says, "A simulator may be used in meeting the requirements of paragraps (c)(3)(i), and (c)(3)(ii) of this section, if it reproduces the general operating characteristics of the facility involved, and the arrangement of the instrumentation and controls of the simulator is similar to that -of the facility involved."
This difference permits the use of the nonplant-referenced simulator for-start up, shut down, and other things which are not related to casualty control, even after you have certified or received approval of your simulation facility. It specifies that you must use the certified or approved simulation facility for the operating test, and for Subparagraphs (g) through (aa) of the Section, which are the casualties.
So, you may use a simulator other than an acceptable simulation facility for control manipulations for requals. But you must use the acceptable simulation facility for casualties after May 26, 1991,- or after you have been certified or received approval. It provides you some flexibility during periods when your simulation facility may not be available for routine control manipulations.
Q. 388. May a utility use a certified simulation facility for requalification training programs, such as on-the-job training in control manipulations, or must some control manipulations be performed using the plant controls?
A. If you look at the list, it just says you can't do casualties on plant controls. Items A through F in 55.59 are eligible to be performed-either on the plant or with an approved or certified simulator.
These relate to start-ups and shutdowns and changes of power of more than 10
percent, manipulations which you can perform on the facility without putting it in danger. It is your option. You may either do those on the plant or on the simulator.
For the remaining items that are required annually or for the operating test, those must be done on a simulation facility. They may not be done on the plant.
NUREG-1262 108
operator requalification train- Q. 389. With respect to licensed operator/senior they can take credit for the ing, is it appropriate that utilities assumemanipulations completed on a required annual and biennial plant control if their programs have been approved simulation facility (nonplant referenced)
by the National Nuclear Accrediting Board?
A. Yes.
have not been accredited by the Q. 390. Can a utility whose training programs which does not have a plant referenced National Nuclear Accrediting Board and manipulations that are performed on a simulator take credit for plant control nonpiant referenced simulator?
is now, then there will be no change A. If that's what your approved program your own simulator, or until May 26, to that approved program until you get that the training portion be done
1991 at which time the regulation requiresfacility. There's an exception, in on a certified or approved simulation you may substitute your accredited pro- Section 3, "On-the-Job Training," that are able to talk INPO into accepting a gram for those requirements. So if you simulator, that's between you simulation facility other than a plant-referenced staff's review, we would expect you to26, and INPO, but for the purposes of the if you do that before the May use the simulator after it has-been certified to do with the first six on-the-job
1991, with one minor exception, which has case, you need not have a certified items listed under 55.59(c)(3). In that The words permit you to use simulation facility or an approved facility. permits the use of a simu- another simulation device. Section 55.59(c)(3)(v) characteristics of the facility lator which reproduces the general operating and controls of the simulator involved, if the arrangement of instrumentation involved.- It only requires the fidelity are similar to those of the facility the casualties.
of a plant referenced simulator for in Paragraph (55.59)(c)(3)(i) be Q. 39L Must all six manipulations listed the six?
performed biennially, or just one of annually.. All therest are performed A. Items A through L must be performed must be performed, either on the plant biennially. All of the first six items that must be performed on a or the simulator. The rest are casualties, simulator.
has now added fuel manipulations to Q. 392.- Is it correct that Section 55.59 They are more than what's in the the required items to be done annually? coming up during the summer of 1987, Harold Denton letter. We have renewals for the last year. There may be some and the training program has been ongoing accomplished on the simulator on an manipulations that, in fact, have not been now says should have been done on an annual basis by July of 1987 that 55.59 annual basis.
First, the requirements in Sec- A. There are two parts to this answer. the sequence, are identical to those in tion 55.59(c)(3), with the exeption of are required. Second, although the the Denton letter; no fuel manipulations don't have to be completed for new requirement exists, the annual manipulations in effect for one year.
everybody until the regulationfhas been
109 NUREG-1262
Q. 393. In 55.59, "ON-THE-JOB-TRAINING," loss of manipulations that needs to be performed. Is that electrical power is one of the degraded power sources, such as the loss of half of loss of off-site power or a total blackout? your emergency bus or is it A. It may be both. That is, it could be a total loss it could be loss of power, particularly involving buses of electrical power, or or consoles.
Q. 394. If we want to run those scenarios, either one would meet that?
A. That is correct. But remember that, according do casualties on the plant. The break-out in the to that Section, you may not Regulation specifies that everything below a loss of coolant event is an accident.
and faults are done on a simulator. But the permissive The malfunctions manipulations, the control manipulations, that may part is for the other be done on the plant or on a simulator.
Q. 395. Must plant control manipulations during the documented on Form 398? requalification period be A. The documentation hasn't changed for that particular You still have to certify that the control manipulations item of the 398 Form.
there would be exceptions to the guidance in Regulatory were done. Only where need to be some amplifying comments made. For example, Guide 1.8 would there manipulations, evaluated them and concluded they were if you did five similar want to point that out in the comments section on the acceptable, you might Form 398.
Q. 396. If a license holder fails the written requalification test administered by the Commission during the six-year exam or operating sequently participates in the approved accelerated license term and sub- requalification Section 55.59(c)(4)(v); will certification of successful program per program be acceptable for renewal, or will a second participation in this during the six-year term be required? NRC-administered exam A. 'A second NRC examination will be required. That individual can go back on shift after failing the NRC requal exam, after participating training and passing the facility's own evaluation. in upgrade However, the Regulation are that for renewal he must pass an NRC-administered terms of the exam.
Q. 397. Must licensed Operator training records be retained plant? for the life of the A. Those that deal with the six-year license, per six years. However, some facilities have committed se, only need to be kept for ments in their Technical Specifications which are more to record retention require- regulation. In order to get the relief that the regulation restrictive than this submit an administrative change request to amend your permits, you must to make the record retention requirements equal to Technical Specifications individual's license. six years or the term of the This Rule supersedes all previous requirements for training, unless you currently have a more restrictiveoperator licensing and case, there are two vehicles you can use. One is an requirement. In that amendment to the license, NUREG-1262 110
J-
other is a 50.59 review, which you if a formal amendment is necessary. The us that it has been completed when you can do administratively and then notify of the year. In any event, you must indicate your other changes at'the:end particularly those that are conform to the requirements of the regulation, more restrictive than your current program.
Most people today have an annual written Two examples immediately come to mind. to go to a two-year examination. The examination. The Rule would permit youprocessed under 50.59 and it does not change to go to a two-year exam.can be change is for the purpose of conforming constitute a reduction in scope if the to the regulation.
of reviewing the regulation, concluded That is, the Commission, in the process for changing from a one-year written exam that there were compensatory measures case the compensatory measure is the annual to a two-year written exam. In this a reduction of scope and it does not operating test. So it does not fall into to be involved in an amendment to require prior NRC approval unless it happens the license or the Tech Specs.
of exams given at the plant.
Q. 398. This is a question about documentation we must keep the student's answers for Under the requal program, it says that that we must keep those exams as the period of the license. Does this mean of the plant, or are you saying'
quality records and keep them for the lifetime that we keep it for the term of the license?
license. And in this case, for example, A. It's for the term of the operator's test examination forms, and three com- his records would include six operating individual file, until such time as his prehensive written examinations in his over again. Now, if you use a segmented license is renewed, andthen you start exam for each requal program, and you examination in lieu of a comprehensive that's a function of how you structure have more than three written exams, then term of that individual license.
your program. You keep them only for the exams that we administer, once we Q. 399. So, are you saying for any operator those as long as we have quality are past the renewal stage,.-we could destroy exam -- in other words, the grades, records to back up the fact that he had the and so forth?
program before, and you A. Given the fact that he was in a requalification could put them in other quality records.
certified that, the answer is yes, you we required to keep the exam itself, or Q. 400. On initial operator exams, are the operator's history file -- a sum- can we just keep a summary that goes in We currently keep the master exams mary of his grades, and things like this? required to keep the individual and a copy of the answer key, but are we student exams and his answers?
copies of the actual exam, be A. Our requirement is that the actual exam,ior license. When you get that license maintained for the-duration of-the currentfrom the files and start over.
renewed, you may eliminate that material gets a license, we could do that on Q. 401. So are you saying once an operator the initial files, too?;
NUREG-1262 111
A. That is correct. The requirement demonstrates that you've met the require- ment of the Regulation to conduct operating tests and comprehensive examinations during the term of that particular license. written Q. 402. How are microfilm records authenticated to meet 55.59(c)(5)(ii)?
A. They are authenticated by an authorized representative of the facility.
Q. 403. Could you comment on the use of video tape as far as exam You mentioned keeping a deck log where you would recover strip documentation.
charts. Would you give us some comment on the use of video tape?
A. We do not intend to use video tape or the equivalent of instant an examination. The records that we are looking for are the same replay during records would be used for a post-trip review, essentially the same documentation. that extent that the simulator has the ability to retain the scenario, To the down load that to a computer tape, you could retain and use that and you can tape.
Q. 404. I'd just like to make one comment on that. That's fine, the scenario includes a trip. If you're starting in mode four I think, if it's more difficult to recover those kind of parameters that youwith a scenario, recreate the scenario. would need to A. The problem with a TV tape is that it is incomplete. You may discussions between the candidate and the examiner because of how not hear are placed. We generally stand back, but at times we are at the microphones elbow. operator's We have been asked on numerous occasions whether the facility would to video tape for either record purposes or training purposes. be allowed intrusive, both on the candidate and the examiner, and incomplete.We consider it Q. 405. Most of the manipulations that are listed in the Regulation applicable to test and research reactors. Are we still operating are not manipulations in a two-year period, as we have been in the past? under the ten A. If that was in your approved requalification program, it would-remain approved.
Q. 406. Is it possible for requalification examinations administered to be "split", such that the written and operational exams are by the NRC
different site visits? given during A. This is Regional prerogative, on a case-by-case basis, with to the licensee. advance notice Q. 407. A licensed RO is enrolled in the facility's SRO upgrade gram. NRC chooses this individual, randomly, to participate training pro- in their program evaluation examination. He fails the NRC administered exam, requal passing or has passed all portions of the upgrade program to yet he is this point.
Does he have to be withdrawn from the upgrade program, go through requal for RO requal exam failure, and be reexamined, or can he accelerated qualification and pursue an SRO license? just drop RO
NUREG-1262 112
of the facility's requali- A. A licensed operator must meet the requirements training and/or reexami- fication program which generally requires accelerated training programs is the preroga- nation. His status in other facility managed elects to "drop RO qualification"
tive of facility management. If the facilityindividual could make application for the individual under 10 CFR 55.5(a) the the individual would not be an for an SRO license under 10WCFR 55.31. However, a active RO license.
SRO upgrade candidate as that status assumes Q. 408. Will written exams administered by NRC for requalification be totally objective, totally subjective, or some combination?;
examination questions are writ- A. They will be a combination of both. Some of an objective question. An ten with the intent of meeting the definition (1) there is only one correct objective question is defined as one in which:agree on the amount of credit al-
-answer; and (2) all qualified graders would lowed for any given candidate's answer.
be included in NRC requal Q. 409. Will persons holding a two year license exams during the transition?
in NRC'exams. However, re- A. Persons with valid licenses may be includedfacility licensee to indicate a newals will be under 55.57 which requires the need for renewal of the license.
is being asked for?
Q.-410. Please clarify paragraph 55.59(c)(4)(iii). What system for evaluating the A. The regulation requires a formalized, documented and senior operators. The performance and competency of licensed operators performance and evaluation of system must include observation of on-the-job the use of an operating test.
the operator's performance and competency through of actions taken during actual or The operating test must include evaluation and emergency procedures.
simulated events which require the use of abnormal what does "on a regularly Q. 411. Concerning paragraph 55.59(c)(3)(iv),
scheduled basis" mean?-
review schedule that will provide A. The facility licensee must establish a and senior operator is know- reasonable assurance that each licensed operator At a minimum, the schedule ledgeable of all abnormal and emergency procedures.
emergency procedures at least once must require the review of all abnormal and every two years.
of the requal program, is it neces- Q. 412. Where preplanned lectures are part of these lectures, notwithstanding sary that the licensees participate in all following these lectures, in successful completion of the written examinations met the requal program require- order to be able to say that the licensee has ments on the NRC-398 application?
of lectures is provided.
A. Under revised 55.59 no provisions for exemption provisions for licensed in- If currently approved programs contain exemption the programs are accredited.
structors the programs should continue until NUREG-1262 113
INPO guideline 82-026 contains exemption provisions for instructors specific subjects; however, they must attend lectures in who teach subjects they do not teach.
Q. 413. Paragraph 55.59(b) implies that the NRC is notified fails a comprehensive written examination or operating test. when an individual requirement? Is this a A. The NRC does not expect to be notified if a licensed operator fails an examination. Requalification programs operator or senior accelerated training. We expect facility management will have provisions for retraining and reexaminations before returning to active provide the necessary license status an operator or senior operator who has failed a requalification examination.
Q. 414. How will individuals who are in non-compliance qualification training programs (i.e. extended illness, with accreditated re- jury duty, etc.) be requalified?
A. Operators will be required to make-up missed portions tion program and to submit evidence to the Commission of of the requalifica- of the training. successful completion Q. 415. We have a program where we have licensed maintenance reactor operators limited to fuel handling. To what extent people as senior apply to us, since in the comments preceding the rule there's will this new rule is not being covered, that it's going to be covered as it mention that this done. is currently being For the past 14 years, as long as we've had SROs limited have not been required to give operating exams. Our annual to fuel handling, we exam is a written exam only. requalification A. For a license which is conditioned to fuel handling only, the testing and requalification program should be appropriate to the license tioned. The licensee is not permitted to operate the facility. as it's condi- therefore not be required to give him an operating test, You would as described in the regulation.
NUREG-1262 114
. l . . f iI
- r I-. ~-
CONFORMING AMENDMENTS TO 10 CFR PART-50 r ,
.11
. .p I . . . ,.
i . ,
. . . . .1 . .7 1I. . 1,
you of any change in Q. 416. The new 10 CFR 50.54(i-1) requires us to notify for you what our program the scope of our program. Since we are not defining is now, what is it that you are looking for?
program today, and you make a A. Let's say that you are using an NRC-approvedRegulation. Say you go from an modification to that program to conform to the examination each two years. You annual written examination to a comprehensive your FSAR at the next update.
may do that pursuant to 50.59, and simply amend your review of your Or, preferably, you would be accredited, have completed approach to training.
requalification program, and confirmed it as.a systems do not require amendments to Both methods may be done pursuant to 50.59. They something that's a part of the licenses. It is only when you have committed to have the Denton letter incor- licensing document. For instance, some facilities with staffing on shift.
porated in their Technical Specifications, associated basis for your utility.
You need to look at your commitments on a case-specificunder 50.59. They would Our intent is that you be able to do most of those advance of your implementing not'require review and approval by the staff in the change.
decrease in scope, frequency, Q. 417. Previously Part 50.54(i) referred to a Is that correct?
or duration. Now all you are saying is scope.
that you'shall have A. Yes. The reason for that is that the Rule specifies be followed. The program a duration of no longer than two years, and it must that you use through INPO describes content.
Q. 418. What about frequency of the parts?
where you look at the A. That's covered by the systems approach to training, And that's why we excluded is.
task that is performed, and you decide what it requalification given that you the classroom, OJTi, ad examination portion of with the systems approach to certify that your program is done in accordance be giving segmented exams in'
training. For clarification, although youbemay aware that if NRC conducts a re-.,
your requalification program, you should a comprehensive written exam qualification exam At your facility, it will be and will include an operating test.
is subjected to revisions Q. 419. The systems approach to training in itself may be considered, at least by to the training program. Some of these changes in 50.54 is still there, the utility, as a reduction in scope. The statementfor a reduction in scope in where it says that Commission approval is required comply with 55.59?
a training program. How do we meet 50.54 and still by the Commission."
A. The key words are "except as specifically authorized on Training and Qualification of The Commission-itself, in the Policy Statement particularly Element 5, indi- Nuclear Power Plant Personnel, op March 20, 1985, and revised as necessary, cates that it expects the program to be evaluated based upon job performance needs.
subtracted, you would eventually We recognize that if you only added and never time into training and never get to the point where you're putting all the NUREG-1262 115
doing anything on the job. We expect the evaluation to be reasonable based upon what you're doing. If you want to substitute something tant, the fact that you've dropped something does not that's more impor- in scope for a systems approach to training. constitute a reduction We believe that's a major improvement in the whole training not locked into doing something for the next six, seven, process. You are you committed to it in 1980. You now review it and, if or eight years because perform it -- you control that evaluation process. it's meaningful, you Q. 420. With respect to that area of 50.54 changes, which that we will have a requalification program and that basically states what documents would be looked at as base documents to we cannot lessen the scope, did not reduce the scope? see whether we did or A. We will look at your approved requalification training program.
Q. 421. In the 50.74 requirement, you have set up some all correspondence for Part 55 to the Region. However, direction as to sending
50 requirement, should we be sending that to the documentbecause this is a Part cordance with Part 50.4, which became effective in January control desk in ac- respondence required under Part 50 was supposed to go of 1987? All cor- desk, with a copy to the Regional Administrator. Please to the document control clarify.
A. Communications under each part of the regulation communications requirements of that part. have to conform to the Q. 422. Is the licensee definition under 50.74 the same nition in 10 CFR 55? as the licensee defi- A. Yes.
Q. 423. If a licensee is out of conformance with the program, is that reportable pursuant to 10 CFR 50.72 andINPO-accredited training
50.73?
A. It's not reportable to NRC, but you may need to report with what you're doing to get back into conformance. it to INPO, along NRC if you have certified that someone is a graduate of It may be reportable to and that he has completed the program, then you find that an accredited program the program adequately. In that instance, you may have you have not implemented to NRC. a reporting requirement NUREG-1262 116
OPERATOR LICENSING EXAMINER STANDARDS (NUREG-1021)
Q. 424. What weight does NUREG-1021 carry?.
is to ensure uniformity A. The purpose of the Examiner Standards, NUREG-1021, the examination process.
and consistency among the'regions in the conduct of expect them to conduct the -
It provides direction to the regions on how we against that Standard. It operator licensing function. We audit the regions are addressed does not impose new requirements. That is, the-requirements'that whether it be a in the Examiner Standards flow.from other documents Regulatory Guide, or Regulation, *or other guideline.
described result from That's why many of the changes-to Examiner Standards The standard contains the change to the Rule,,the moye.authoritative document.
policy on how to carry out-.the.Rule.
would be filling out a Q. 425. It was mentioned that theiMcense examiners we request that those re- simulation facility fidelity feedback report ,Could packages when they are re- ports be included in our copy of-the examination turned to us?
4 to the Examiner Stan-
-A. They will be. That has been incorporated into'Rev. report Is contained in Exami- dards. The simulation facility fidelity feedback Activities," as section C(3),
ner Standard ES-104 "Procedures for Postexamination be prepared for each which requires that a Simulation Facility Fidelity.report The Standard also examination including simulator evaluations of candidates..-
Report sent,-to the facility.
requires this report to be part of the-Examination Report be used to'deter- Q. 426. Will the SimulationtFacility. fidelity Feedback mine the status of'current simulators?
be applicable A. The guidance to the examiners is that this information-will have applied for only to simulation facilities' that have been certified'or vintage ofssimulators, you approval. However, even-today, with .thepresent review process. And that'
still receive informal feedback reportslin. the exam the operating test will continue. If the'Examiners have' a problem conducting it won't be as formal at your simulator; you can expect'.some feedback, although
.as would occur after certification or approval.
is submitted, the simulation Q. 427. It was stated earlier that once Form 474 3.5, and that there are three facility is certified in accordance with ANSI/ANS of further evaluation:
different mechanisms that may trigger the process
(2) random visits to the
(1) questions regardingtheForm 474'submittal, activities associated with facility for evaluation, and (3) the post-examination the examination at the facility.
evaluatioh feedback due by May Would the procedures for the simulation facility standards and criteria and
-- specifically, ES-104.-- be specific as to the evaluation of a mechanisms by which. the examiners will make a post-examrifiation procedure?
facility that would .then trigger'the evaluation a-simple comment sheet A. No. The mechanism is intended to be' essentially
"During Scenario X,' the simula- that might contain a comment.to the effect that flow coast down tion facility failed to.perform as expected.' 'There-wasno loss of.power."
associated with reactor coolant pumps on a NUREG-1262 . 117 '
This type of comment would be collected and evaluated.
determine whether it raised a question in our mind that Someone would then going back and looking at the simulation facility. would be the basis for It's not significantly different from comments on the simulator in the examina- tion report -- the inspection report that's issued following are a number of random failures, that's the kind of information an exam. If there collecting. we're There is no acceptance criteria threshold. It's the examiner's he felt there was a problem, we're giving him a vehicle judgment. If communicate it back so that knowledgeable people can to write it down and whether that would trigger an inspection or evaluation.look at it and decide Q. 428. Typically after that type of evaluation, there's nificant amount of data by which someone away from the not going to be a sig- was not there at the time of the examination, could make facility, someone who accurate determination as to whether there is a problem a very objective or with facility or not; and I understand that there are a significant the simulation If, during an overpressure incident, pressure continues number of freezes.
then obviously there's a problem with the simulation to rise to 3,500 pounds, amples may not be so clear-cut. Therefore, there's a facility, but other ex- potential where, perhaps it was not warranted because of an evaluation for NRC followup was not there when the event occurred., made by someone who A. That's why we're getting the feedback from the examiner the time it occurred. The facility will also receive who was there at the inspection report, and I'm sure it will be a subjecta copy of the writeup with with the chief examiner at the end of the exam week. in the exit briefing We think there are adequatemechanisms in place to alert what the potential concern is, but most importantly, we the facility as to on how well the simulation facility is working during want to get feedback an examination based upon an examiner's observation of that simulation facility.
Further, we have been increasingly requesting that facilities simulator exams to the greatest extent possible so that record data during for review on a more objective scale. information is available Q. 429. We are required to complete training and experience because we don't yet have an acceptable simulation facility, blocks on Form 398 have an INPO-accredited program. Will we still be evaluated even though we current ES-109 requirements? in accordance with A. Yes.
Q. 430. Under eligibility, you previously cited Examiner the future an accredited program with an acceptable simulation Standard 109. In substituted for eligibility. Examiner Standard 109 says facility may be plant experience is required. Does that requirement two years of power remain?
A. A facility with an INPO-accredited training program fied or approved simulation facility need not meet other that utilizes a certi- experience requirements.
NUREG-1262 118
to conform with the Revision 4 to the-examiner standards' revises ES 109 Regulation..
requirements for licensed Q. 431. Examiner Standard 109 lists the eligibility ts. One of these requirements operators and senior licensed operatoreapplica shift'aS an extra man under the is that'each individual spend three months'on Is this requirement supervision of a licensed or senior licensed operator. from, given that it is not still in effect? Where does this requirement come previous requirements?
addressed in 10 CFR 55, and the new revision supersedes our past practice, and A. Although not a requirement, this is consistent'With It will be it's consistent withoReg Guide 1.-8, which endorses"ANSI13.1-1981. a'waiver, and their re- continued in ES-109. Facility litensees 'can ask for quests will be considered.
Q. 432. Examiner Standard 109 'says that training conducted as part of a license
'ButANSI/ANS 3. 1-1981, which is what the program cannot count for experience. tethnical training to count Commissioners have'toldius to use, allows'relatedwith'3.1?
- T
4 n
-r.lO
I WI
enmnlianre X~ll
- h_
Tor experience~. . 5 J-.U
refers to the training A. The training time that doesn't count as experience individual is partici- required by the approved license'program in which/the he may-have received in pating. Related technical-trainlngrefers to" training time may be counted, up to another position, such as auxiliary operator. This a certain percentage.
1987, page 42, that says Q. 433. There was an-article in Nuclear News,'January exams administered by, the average pass rate for the industry on requalification says that in order for the NRC is 78 percent nationwide. 'Examiner'Standard'601 80 percent or more a requalification program to be evaluated as satisfactory, has less than a have to pass. This indicates that the industry, nation-wide, satisfactory requal program. Co you agree?
A. No, because the statistics that Nuclear News used'are somewhat question-
17 facilities, and 5 of them fell in the marginal able. Last year we evaluated higher failure rates.
or unsatisfactory'category because they had substantially be different. It was similar So, a few are causing the national statistics to were ithe marginal or un- the year before, when we had five facilities" that satisfactory category. ! .
more pass. It's not The programevaluation is based upon whether'SO percent-or exam. In other based upon the average scores of the candidates taking'the have 80 percent passing words, if you examine 10 candidates, and 2 fail, you average-score on that exam and we determine that-program is satisfactory. The scored in the 60s, while may be 78 per cent because the 2 people that failed everybody else scored above 80.
requalification exams, Q. 434. Assume that NRC comes in to give-the utility rated marginal.' After the are and the scores are between 60 and'80 percent and failures, 'and comes out with a utility modifies their 'program, reexamines those to acceptable program?
satisfactory grade, does NRC change that from a marginal given, in accordance A. The marginal rating would be based on'the examination individuals with weak- with ES-601. We evaluated the program and identified given. Their training will nesses. They require remedial training, which is NUREG-1262 119
not cause us to revise our evaluation. Two years hence, when we come back and do another evaluation, hopefully 80 percent will pass at that time, and you will be evaluated as satisfactory. The original evaluation and conclusion stands until we come back and re-evaluate, either by inspection or re-examination.
Q. 435. Is that true, even if our program was modified to cover those weak- nesses that you discovered?
A. Yes. Your program may, indeed, no longer be marginal. But until we come back and independently evaluate, that remains our conclusion of record.
Q. 436. So, the only way we can get that changed, is for you to come back to give another exam, is that true?
A. Yes, we come back and inspect that area, and reach a conclusion based on our inspection at that time.
Q. 437. Can we ask for such a re-evaluation?
A. Sure.
Q. 438. What limits on materials requested from the facility licensee exist, if any?
A. We will be reasonable, but there are no specific limits. Typically, we go through the list with the facility, and indicate what items we' need. We are not going to ask for the whole library or every print on the facility. However, we may need more material at times than you issue to the student to learn the plant, because we have to get familiar with different plants that have slight differences from one type'vendor to another. So, we may-need more in-depth material.
Q. 439. We receive a copy of the written exam after it has been administered, and as part of the documentation, we are provided with the learning objectives of the source documents from which these questions were derived. For simulator examinations, could we be provided with that same documentation, since we go to the effort to develop scenarios that are based on industry events, LERs, and learning objectives that we've derived from our program so that when you design your simulator exams, they would also be based upon these same precepts?
A. We currently fill out Attachments 3 and 5 to Examiner Standard 302, which delineates the objectives that the exam events are trying to accomplish. Those have been provided to all the individuals who have failed the examination. For individuals who passed, we have provided only Attachment 3, the delineation of the overall exercise itself, malfunction by malfunction, or over-ride by over- ride. We have not been providing Attachment 5 to individuals who pass. If request, we can provide you a copy of Attachment 5, which contains our objec-you tives for that examination.
Q. 440. With regard to IE Information Notice (IEIN) No.85-101 "Applicability of 10 CFR 21 to Consulting Firms Providing Training," is training material that is found deficient reportable under 10 CFR 21?
NUREG-1262 120
A. The answer is yes under certain conditions. IEIN85-101 provides guidance to licensees and consultants concerning applicability of 10 CFR 21 to certain training activities provided by consultants. Further information regarding reporting requirements can be found in NUREG-0302 Rev. 1, "Remarks Presented (Questions/Answers'Discussed at Public Regional Meetings to Discuss Regulations
(10 CFR Part 21) for Reporting of Defects and Noncompliance."
Q. 441. Would the review of the exam to make our comments within the five, working days also apply to the simulator exam?
A. The comment procedure has been limited to the written examination by the Examiner's Standards. You can comment, obviously, on our simulator exam, and we are more than willing to listen to what you have to say. But we have not been going through a formal comment procedure for the simulator exam. One of the reasons is that the simulator examination is on-going during the course of the week. And the written examination is given typically in the first day.
And, usually, by the end of the week, you provide us with your written exam comments, and that expedites the grading process.
Our present practice does not solicit written comments on the simulator exam for grading purposes. Normally the dialogue established with the simulator operators (training staff) is adequate to resolve any weaknesses in the simu- lator scenarios prior to their execution. Otherwise, written comments are accepted during an appeal process for an individual candidate.
NUREG-1262 121
Appendix A
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555 MAR 1987 TO ALL FACILITY LICENSEES
SUBJECT: INFORMATION TRANSMITTAL OF FINAL RULEMAKING
FOR REVISIONS TO OPERATOR LICENSING -
10 CFR 55 AND CONFORMING AMENDMENTS
(Generic Letter No. 87-07)
To provide information about the final revisions to 10 CFR 55, 'Operators'
Licenses," and their implementation, the Commission Is holding a series of public meetings. These meetings will be held as follows:
A. April 9, 1987 for Region II
Richard'B. Russell Federal Building.
Strom Auditorium, Lower Level'
75 Spring Street, SW
Atlanta, Georgia Point of Contact:' Mr.Kenneth E. Brockman US Nuclear Regulatory Commission, Region II
101 Marietta Street, Suite'3100
Atlanta, GA 30323
(404) 331-5594 X
B. April 14,`1987 for'Regions IV and V
Stouffer Concourse Hotel
3801 Quebec Street Denver, Colorado (Across from Stapleton Airport)
Points of Contact: Mr. Ralph Cooley US Nuclear Regulatory Commission, Region IV
Parkway Central Plaza Building
611 Ryan Plaza Drive, Suite 1000
Arlington, TX 76011
(817) 860-8147 Mr. Phillip Morrill US Nuclear Regulatory Commission, Region V
1450 Maria Lane, Suite 210
Walnut Creek, CA 94596
(415) 943-3740
C. April 16, 1987 for Region III
Ramada Hotel O'Hare
6600 N. Mannheim Road (corner of Higgins)
Rosemont, Illinois (One mile from O'Hare Airport)
Phone: (312) 827-5131 Point of Contact: Mr. Thomas Burdick US Nuclear Regulatory Commission, Region III
799 Roosevelt Road Glen Ellyn, IL 60137
(312) 790-5566
.7
8703190287 A-i.
- 2 -
D. April 20, 1987 for Region I
Hilton Hotel Valley Forge
251 West DeKalb Pike King of Prussia, Pennsylvania Phone: (215) 337-1200
Point of Contact: Mr. Noel F. Dudley US Nuclear Regulatory Commission, Region I
631 Park Avenue King of Prussia, PA 19406
(215) 337-5211 Enclosed with this letter is a double-spaced copy of the regulations supporting information for your review prior to the public meeting. and You are encouraged to. forward questions to the appropriate point-of-contact, prior to the date of the meeting which you plan to attend. The staff one week intends to answer these questions and others during the meetings and will consolidate all questions and answers into a NUREG report after the meeting.
In preparation for these meetings, alll1censees should pay special attention to the requirements of Sections 55.31(a) and 55.59(c) regarding both initial and requalification training and the option of substituting an accredited training program for initial and requalification training programs previously approved by NRC. This option may be implemented upon written notification the NRC and does not require any staff review. However, because of conflicts to between previous 1OCFR55 Appendix A requirements and a systems approach requalification training, it is necessary to certify that the substitute to training program is both accredited and based upon a systems approach training. The superseded training program description contained in to need not be revised until the next update required by 50.71(e). the FSAR
Sincerely, arold R. Denton, Director ffice of Nuclear Reactor Regulation Enclosure:
As stated A-2
1 0 CF'at 0ad5 LieseanCofrigA
erator~~~~~~~- ndnt P.;
Federal Register / Vol. ~~No. 57 / Wednesday, -Marchv 25; 1987 k esand, Regtzlationd 95 gm known brucellosis in cattle for the not a "major rule" Based on Information respect to this interim rule are period of 12 months preceding compiled by the Department. we have Impracticable and contrary to the public classification as Class Free. The Class C determined that this rule will have an Interest, and good cause Is found for classification Is for States or areas with effect on the economy of less than 6100 making this interim rule effective less the highest rate of brucellosis. with miilion: will not cause a major increase than 30 days after the publication of this Class A and Class B in between. in costs or prices for consumers. document in the Federal Register.
Restrictions on the movement of cattle individual Industries, Federal. State. or Comments are being solicited for 60
are more stringent for movements from local government agencies, or days after publication of this document.
Class AStates or areas compared with geographic regions; and will not cause a and a final document discussing movements from ree States or areas, significant adverse effect on comments received and any and are more stringent for movements competition. employment Investment amendments required will be published from Cass B States or areas compared productivity, innovation. or on the in the Federal Reiaster as soon as with movements frosm Class A States or ability of United States-based possible.
areas, andso on. enterprises to compete with foreign- List of Subjects In 9 CFM Part 78 The basic standards for the different based enterprises In domestic or export classifications of States or areas markets. Animal diseases. Brucelloss. Cattle.
concern maintenance of: (1)A cattle For this action, the Office of Hogs Quarantine, Transportation.
herd Infection rate, based on the number Management and Budget has waived its PART 7-BRUCELLOSIS
of herds found to have brucellosis review process required by Executive reactors, not to exceed a stated level Order 12291. Accordingly. 9 CFR Part781I
during 12 consecutive months: (2)a rate Cattle moved interstate are moved for amended as follows:
of infection Inthe cattle population. slaughter. for use as breeding stock, or 1.The authority citation for Part 78 based on the percentage of brucellosis for feeding. Changing the status of continues to read as follows:
reactors found in Market Cattle Alabama reduces certain testing and Authority. 21 USC. l1l-114a-l. 114g. 115.
Identification (MCI)-testing at other requirements on the interstate 117,120.121.123-125. 134b. 1s4E 7 CFR 2.17, stocky ads and slaughtering. movement of these cattle. However. 2.51. and 371.2(d).
establishments-not lo exceed a stated cattle from certified brucellosis-free leveh (3)a surveillance system that herds moving interstate are not affected 178.41 lAnmnddI
requires testing of dairy herds, by these changes In status. We have 2.Section 78.41, paragraph (b) is participation of all slaughtering determined that the changes In amended by adding "Alabama"
establishments in the MCI program. brucellosis status made by this immediately before "Arizona".
Identification and monitoring of herds at document will not affect market patterns 7841. paragraph (c) Is
3. Section high risk of infection. including herds and will not have a significant economic amended by removing "Alabama".
adjacent to infected herds and herds Impact on those persons affected by this document. Done in Washingon. DC. this a0h day of from which infected animals have been March. 1987.
sold or received. and (4)minimum Under these circumstances. the Administrator of the Animal and Plant B. G.Jhnson .,
procedural standards for administering DeputyAdministrotor. VeterinaryServices.
the program. Health Inspection Service has Prior to the effective date of this determined that this action will not have AnimalandPlantHeolth Inspection Service.
document, Alabama was classified as a a significant economic impact on a (FR Doc.87-421 Filed 3-24-87:8:45 am)
Class B State because of the herd substantial number of small entities. BUWO COOM 344 infection rate and the MCI reactor Executive Order 12372 prevalence rate. However, a review of the brucellosis program establishes that This program/activity Is listed In the NUCLEAR REGULATORY
Alabama should be changed to Class A Catalog of Federal Domestic Assistance COMMISSION
status. under No. 10.025 and Is subject to the In order to attain and maintain Class provisions of Executive Order 12372. 10 CFR Parts 60 and 55 A status, a State or area must (1)not which requires Intergovernmental exceed a cattle berd infection rate, due consultation with State and local Operators' Licenses and ConformIng to field Strain Brucela abortusof 025 officials. (See 7 CFR Part 3015, Subpart Amendments percent or 2.5 herds per 1.0W based on V.) AOENCv: Nuclear Regulatory the number of reactors found within the Emergency Action Commission.
State or area during any 12 consecutive months, except in States with 10.000 or Dr. John K.Atwell. Deputy AcTxs: Final rule.
fewer herds; (2)maintain a 12 Administrator of the Animal and Plant consecutive months MCI reactor Health Inspection Service for Veterinary euwUAnr The Nuclear Regulatory Services. has determined that an Commission is amending its regulations prevalence rate not to exceed one to (1)clarify the regulations for issuing reactor perl.OOOcattle tested (0.10 emergency situation exists. which percent); and (3)have an approved warrants publication of this interim rule licenses to operators and senior without prior opportunity for public operators; (2)revise the requirements individual herd plan in-effect within 15 and scope of written examinations and days of locating the source herd or comment. Immnediate action Is warranted in order to delete operating tests for operators and senior recipient herd. Alabama now meets the operators. including a requirement for a criteria for classification as Class A. unnecessary restrictionston the interstate movement of certain cattle simulation facility; (3)codify procedures Executive Order 12291 and Regulatory fr6m Alabama. for administering requalification Flexibility Act Further, pursuant to administrative examinations; and (4)describe the form We are issuing this rule In procedure provisions in 5 U.S.C. 33. it IIi u and content for operator license conformance with Executive Order found upon good cause that prior notice applications. The rule is necessary to
12291. and we have determined that it is and other public procedures with meet NRC responsibilities under Section
13-l
9454 Federal Register / 4t N52,o. 57 / Wednesday. March 25, 19r Rules and Regulations
306 of the Nuclear Waste Policy Act of Branch, Office of Nuclear Reactor "Medical Requirements." A 90-day
1982. Regulation. U.S. Nuclear Regulatory comment period expired on February 25, DATES: Effective Date: May 28. 1987. Commission. Washington, DC 20555. 1985. Comments were received from 88 Publicmeeting dotes: April 9, 14t . and Telephone: 301-49Z-4888 respondents. An additional 47 -:
20. 1987. FOR FURTHER INFORMATION
CONTACT
. respondents commented on the three ADDRESSES: Public meeting locations: Chief, Operator Licensing Branch, Office associated regulatory guides, also Issued Public meetings will be held to discuss of Nuclear Reactor Regulation, U.S. for public comment. Reports that contain implementation of the requirements of Nuclear Regulatory Commission, a detailed analysis of these comments this rule. The meetings will be held as Washington, DC 20555, Telephone: (301) and their resolution are available as follows: 492-486& indicated under "ADDRESSES:.-
A. April 9. 1987 for Region iH.Richard SUPPLEMENTARY INFORMATION: These proposed revisions to 10 CFR
B.Russell Federal Building, Strom Part 55 were to improve the operator Auditorium. Lower Level, 75 Spring 1 Background Street. SW., Atlanta. Georgia. licensing process and to achieve the Section 107 of the Atomic Energy Act following objectives.t Point of Contact Mr. Kenneth E. of 1954, as amended (42 U.S.C. 2137).
Brockman. U.S. Nuclear Regulatory requires the Nuclear Regulatory (1)Improve the safety of nuclear Commission. Region IL101 Marietta Commission to prescribe uniform power plant operations by Improving the Street, Suite 3100. Altanta, GA 30323. conditions for licensing individuals as operator licensing process and
(404) 331-5594. operators of production and utilization examination content, B. April 14,1987 for Regions IV and V. facilities and to determine the (2)Provide the NRC with an improved Stouffer Concourse Hotel. 3801 Quebec qualifications of these individuals and to basis for administering operator Street, Denver, Colorado (Across from issue licenses to such individuals. The licensing examinations and conducting Stapleton Airport). regulations implementing these operating tests, and Points of Contact. Mr. Ralph Colley. requirements are set out In Part 55 of (3)Respond to the specific direction U.S. Nuclear Regulatory Commission. Title 10, Chapter 1, of the Code of Region IV. Parkway Central Plaza Federal Regulations. To assist licensees given by Congress In Section 306.
Building. 811 Ryan Plaza Drive. Suite Nuclear Waste Policy Act of 1982. Pub.
and others, the Commission also has L 97-425. to promulgate regulations and
1000. Arlington. TX 7601, (817) 860- issued regulatory guides and generic
8147. guidance In the area of examinations.
letters that provide guidance on Mr. Phillip Morrill. U.S. Nuclear acceptable methods of meeting these On March 20. 1985, the Commission Regulatory Commission. Region V.1450 regulatory requirements. published a Final Policy Statement on Maria Lane. Suite 210. Walnut Creek, The Commission has become Training and Qualification of Nuclear CA 94590. (415) 943-3740. increasingly aware of the need to update Power Plant Personnel (50 FR 11147) that C.April 18, 1987 for Region IlL Its operator licensing regulations and describes the Commission's current Ramada Hotel O'Hare, 6800 N. related regulatory guides. These policy regarding training of operators. In Mannheim Road (comer of Higgins) revisions are needed to clarify the addition to this policy statement, the Rosemont. Illinois (One mile from extent to which simulators should be Commission is publishing the new rules O'Hare Airport). Phone: (312) 827-5131. used in licensing examinations and to described in this notice; these rules Point of Contact: Mr. Thomas Burdick. reflect upgraded requirements for supercede all current regulations for U.S. Nuclear Regulatory Commission. licensed operator selection, training, and operator licenses. Those facility Region HI1. 799 Roosevelt Road. Glen requalification programs resulting from licensees that have made a commitment Ellyn. IL 80137. (312) 790-5586 the accident at TMI-2 Although the that is less than that required by these D. April 20. 1987 for Region I, Hilton Commission has been actively engaged new rules must conform to the new rules Hotel Valley Forge. 251 West DeKalb in Investigating these matters, the automatically. Those facility licensees Pike. King of Prussia. Pennsylvania. schedule for completing these activities that have made a commitment different Phone: (215) 337-1200. was further accelerated by the from or more than that required by these Point of Contact: Mr. Noel P. Dudley. enactment of January?, 1983, of the new rules for license amendments and U.S. Nuclear Regulatory Commission, Nuclear Waste Policy Act of 1982, Pub. technical specification changes, may Region 1 831 Park Avenue. King of L 97-425. Section 306 of that act (42 Prussia, PA 19400.(215) 337-5211. apply to the Commission so that they U.S.C. 10228.96 Stat. 2201 at 2282-2283) can conform to these new rules. Other- Background information for the rule directs the NRC to establish (1)
includes a copy of the regulatory simulator training requirements for changes should be made in accordance analysis, the supporting statement for applicants for operator licenses and for with 10 CFR 50.59 the Office of Management and Budget operator requalification programs, (2) Production facilities previously clearance of the information collection requirements governing NRC included in Part 55 are not referenced in requirements. Regulatory Guides, ANSI/ administration of requalification the revisions since there are no ANS standards, NUREG-series examinations, and (3)requirements for operators at production facilities documents. other documents discussed operating tests at civilian nuclear power currently licensed by the Commission.
in this notice. and reports that contain a plant simulators Although special consideration has been detailed analysis of the public On November 2A.1984 thei given to the smaller size and scope of comments received during the public Commission published proposed test and research reactors the comment period and their resolution amendments to 10 CFR Part 55, requirements In this notice apply to all may be examined at the NRC Public "Operators' Licenses' In the Federal utilization facilities licensed under 10
Document Room, 1717 H Street NW, Register (49 FR 46428), These CFR Part 50, Including test and research Washington. DC. amendments proposed granting. In part. reactors. Consequently, except where A single copy of the reports a petition for rulemaking (PRM-55-1) specific wording has been used to note concerning public comments may be that was filed by KMC. Inc. PRM-55-1 is different requirements, these rules apply obtained from Chief, Operator Licensing discussed more fully under Section nLIL to test and researchreactors B-2
Federal Register / Vol. 5,_jo. 57 / Wednesday. March 25. 1987 I_;pI and Regulations 945 IL Summary of Public Comments and requested clarification about the Plants." IThe intent is to prevent the Final ActIons limitation of the conditions under which manipulation of the controls by an the plant could be used. operator whose medical condition and The proposed amendments to improve general health would cause operational the operator licensing process have been It Is not the
Intent
of NRC to permit or encourage the Initiation of translents on errors endangering public health and modified in response to the comnunn safety. The medical requirements rely received. A summary of the public the plant when and if the plant is used as a simulation facility. The use of the on examination of the applicant or cqmments and, where appropriate. a operator by a licensed physician who description of the changes that resulted plant Is envisioned as a possible evaluates the medical conditon of the fromiem follows approach that a facility licensee might operator. based on the criteria of ANSI/
I(A) GeneralCommentu-(1) General. propose to use Inconjunction with ANS 3.-83 that Is endorsed by purposeofthese amendments. Several another simulation device or devices, in Regulatory Guide 1.134, "Medical commenters provided general support lieu of a plant-referenced simulator. This Evaluation of Licensed Personnel for for the proposed rule. Other commenters approach might be suitable, for example, Nuclear Power Plants," and makes suggested changes to clarify the purpose for older plants without access to plant- recommendations to the facility's and exemptions sections. These sections referenced simulators, where management The facility's management were reworded as a result of the manipulations of the plant, to the extent is responsible for certifying the evaluation of these comments. In consistent with plant conditions. might suitability of the applicant for a license.
particular, the purpose of the nrle. be used to demonstrate familiarity with The NRC has the responsibility for indicates that terms end conditions of the plant for which the candidate would making an assessment of the applicant operators' licenses and renewal are be licensed. for a license, Including the applicant's covered. Exemption for trainees at a Several commenters suggested that medical fitness. Neither the facility nor facility Is clafried to indicate that a the definition of "reference plant" the NRC staff will make medical trainee is only exempted while should not be specific to a plant and Its judgments. When a conditional license participating in an NRC-approved unit. The word "unit" has been deleted training program to qualify for an Is requested, the NRC will use a operator license. In addition, employees from this definition, although it remains qualified medical expert to review the involved In fuel handling are exempt If the NRC's
Intent
that a reference plant medical evidence submitted by the they are supervised by a licensed senior refer to a specific docket number. For facility to make a determination. For operator. those situations in which a multiunit minor conditions, such as the need to
(2) Definitions.Many commenters plant is composed of units from the wear corrective lenses or a hearing aid.
were concerned with the specific same vendor and vintage, It is likely that the Form NRC 396 Is modified to definitions In the rule. A namber of only one simulation facility would be simplify the process for obtaining a commenters addressed the definitions ol required. For others. Regulatory Guide medically conditioned license.
"simulation facility" and "Plant- 1.149 provides specific guidance for Moreover, while the biennial medical referenced simulator." and requested those facility licensees that want to examination required under 1 55.21 is clarification of the NRC's
Intent
for the consider the use of one simulation intended to detect alcoholism or drug use of such devices in the Oartial facility for use at more than one nuclear dependency or both, no reference is conduct of operating tests. Several power plant. This guidance I based made In the rule to alcohol or drug commenters believed that only plant- upon existing NRC policy on the problems. These issues are covered in a referenced simulators would be granting of multimnit operator's licenses. Policy Statement on Fitness for Duty of permitted. (B) Medicolrequirements-1)- Nuclear Power Plant Personnel (51 FR
The definition of a "plant-referenced Criteriafor medical requirements.Most 27921). published on August 4.1988, by simulator" Is Intended to mean a commenters agreed with the revisions to the Commission. In addition, the license simulator that meets an of the the medical certification process, which renewal period Is changed to 6 years to requirements of ANSI/ANS 5.5985. as would require, for the usual case, a brief be compatible with the biennial medical endorsed by Regulatory Guide 1.149. certification by the facility licensee on examination requirements.
"Nuclear Power Plant Simulation Form NRC-39, as revised. Some In jult 1983. KMC. Inc.. petitioned the Facilities for Use in Operator License commenters questioned the relationship Commission (PRM-55-1) "to simplify the Examinations." (see Section V. of these requirements to drug and procedure for the review of the medical Regulatory Guides. of this alcohol problems and programs. Other status of applicants for operator- Supplementary Information). commenters were confused about who ... licenses." KMC stated that the The definition of a !,simulation would have responsibility for current procedures require that a facility- Isintended to provide for the medical condition of an detailed medical history and results of flexibility in the conduct of the simulate determining ir operator or applicant for an operator's the applicant's medical examination by (non-plant-walkthrough) portion of the license. Some comments were made a licensed physician be sent to the operating test. The
Intent
Is to permit. about the specific language in the Commission. The petitioner requested under circumstances specified In 10 CFI that the Commission amend its
55.45(b), the use of the plant Itself, and/ medical requirements regarding regulations to permit designated medical andlor disqualifying conditions and or a plantieferenced simulator, examiners. as defined in ANSI N546- some other type of simulation device commenters requested changes or 1976, "Medical Certification and such as a part-task or basic-principles clarification. Many commenters noted Monitoring of Personnel Requiring simulator, for the conduct of the the need to adjust the medical Operator Licenses for Nuclear Power simulator portion of the operating test. requirements to the renewal cycle. Plants," to certify that the applicant has A number of commenters expressed The medical requirements reflect the concern that a plant, when used as a industry standard articulated In ANSI/ i Standards discussed in this rule are available simulator, could not safely perform the ANS 3.-1983. "Medical Certification for purchase from American Nuclear Society. 555 full range of functions that a simulator and Monitoring of Personnel Requiring North Kensington Avenue. La Grange Park, Illinois could perform. and some commenters Operating Licenses for Nuclear Power B-3
. 52.N Rul
9456' Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations been examined (using the guidance licensee to certify that there is a need issue a document that specifically contained in ANSI N548-1975 as for the applicant to perform assigned delineates what an operator Is endorsed by Regulatory Guide 1.134) duties. Several commenters were responsible for on NRC examinations and that the applicant's general health concerned that the "need" was not and operating tests.
and physical condition is not such as clearly defined. The requirements are Systematic analysis of job may cause operational errors. Under the Intended to simply have the facility performance requirements is an petitioner's request the use of the licensee's management internally review accepted methodology for deriving current NRC Form 396 would be the need for the license before the licensing examination content; The job- discontinued for utility operators and application is made. Another concern of task analyses are being performed as detailed medical records would be many commenters was the relationship part of the performance-based programs retained by the licensee's designated between industry-accredited training that are being implemented by facility medical examiner. Subpart C to Part 55 programs and the details regarding licensees as part of the Industry responds to the KMC, Inc. petition NRC training and experience needed to apply supported-accreditation program. The grants its request, in part, by eliminating to the NRC on Form NRC-39aL In learning objectives derived from these the requirement to submit, In usual addition, some commenters were job-task analyses should form the basis cases, medical information for an concerned with the definition of the for licensing written examinations and applicant for an operatlor's license phrase "learned to operate." This phrase operating tests at a facility. Ultimately.
directly to the NRC. Instead, as has been deleted from 5 55.31 and the NRC testing objectives will reflect described above, a certification to NRC replaced by wording which indicates facility licensee-developed learning about compliance with the health that if a candidate successfully objectives. In the interim while these requirements in I 55.33(a](1) would be completes the training and experience programs are being developed and made by the facility licensee. requirements to be licensed as an reviewed for accreditation. the NRC has
(2)Notification of incapacitation operator, the NRC will conduct the activities underway to improve the because of disabilityor illness. Some appropriate examination and operating content validity of NRC examinations confusion was noted by several test Section 55.31(a)(5) has been added and operating tests.
commenters regarding the process to to specify the minimum number of (2) Specific wording of cotegories.
notify the Commission when an operator control manipulations to be conducted Many commenters made specific was incapacitated because of disability by an applicant. Details regarding other wording recommendations for the or illness. The final rule is changed to training and qualification will not be categories listed under content of the reflect more clearly the Commission's written examinations and operating test.
intent. That is, if. during the term of the required to be supplied on Form NRC-
398, if these requirements are contained These suggestions were reviewed by license, an operator's medical condition subject-matter experts and changes changes and does not meet the in an NRC-approved training program that uses a simulation facility were made to clarify or improve the requirements set forth in ANSI/ANS content categories. No major changes
3.4-1983, notification of the Commission acceptable to the NRC under I 55.45(b).
Subject to continued Commission resulted except to two categories under by the facility licensee Isrequired. At the operating test. Under 5 55.45.
the same time, if the examining endorsement of the Industry's accreditation process under the Final categories (12) and (13) were reworded physician Indicates that the condition as follows:
can be accommodated as noted in 5.1 Policy Statement on Training and of the ANSI/ANS 3.4-1983, a conditional Qualification of Nuclear Power Plant (121 Demonstrate the knowledge and ability Personnel (50 FR 11147; March 20. 1985), as appropriate to the assigned position to license may be requested by an assume that responsibilities associated with authorized representative of the facility a facility licensee's training program the safe operation of the facility.
licensee. Form NRC 395 must be used would be approved by being accredited and supporting medical evidence must by the National Nuclear Accrediting (13) Demonstrate the applicant's ability to be supplied. However, the facility Board. function within the control room team as licensee does not have to wait for appropriate to the assigned position, in such a (D) Written examinationsand way that the facility licensee's procedures are permission from the Commission before operatingtests-(1) Content. Most adhered to and that the limitations In its returning an operator to licensed duties, commenters recommended that the license and amendments are not violated.
if the operator has been examined by a principal means of determining the physician. who. using ANSI/ANS 34- knowledge, skills, and abilities to be (3) Waivers. Several commenters
1983 as a basis, has recommended to the included in operator licensing written suggested that examinations and tests facility's management that the operator examinations and operating tests should be automatically waived under specific can return. be the learning objectives derived from circumstances. As the agency
(3)Test andresearchreactors.Many a systematic analysis of the Job responsible for public health and safety test and research reactor operators were with regard to nuclear facilities. the performance requirements. These Commission cannot waive Its concerned that the requirements In the commenters recommended that these independent assessment of operators.
rule changed the medical requirements learning objectives form the basis and Waivers are based on operators for them. The rule changes only the scope of examinations and tests and previously passing all or part of a requirements for test and research that other sources of information should licensing examination. Details regarding reactor facility licensees. It does not only be used until the learning the processing of waivers are addressed change the status quo for reactor objectives are available for a facility. in NUREG-1021. "Operator Licensing operators, for whom ANSI/ANS-15.4- Conversely. some commenters Examiner Standards." 2
1977(N 380), "Selection and Training of questioned as premature the Personnel for Research Reactors.' endorsement by NRC of a systematic requirements continue. analysis from which to draw the content 'NUREG-sertes documents am available for public Inspection and copyinS for a le In the (C) Applications. Applications for an for licensing examinations and tests. Commlslton's Public Document Room at 1717 H
operator license require the facility One commenter recommended that NRC Contlwed B-4
Federal Register / Vof'..vd No. 57 / Wednesday, March 25, 1987\1....dules and Regulations 95
945
(4)integrityand examinations and periodic "subsequent" application has event that simulator design changes tests. Although many commenters been eliminated. In support of its result in significant simulator supported the addition of t 55.49, certification or its application, as configuration or performance variations.
"Integrity of Examinations and Tests," appropriate, each facility licensee will In addition, the standard is silent on they felt that the penalties In 1 55.71 be required to conduct periodic the subject of periodic testing of were excessive. Other commenters were performance tests on its simulation malfunctions. The NRC endorsement of afraid that any action might be facility, and maintain records pertaining the standard in the R.G. takes exception interpreted as cheating and that the role to the conduct of these tests and the to the deletion of periodic performance of facility licensees In enforcement was results obtained. testing. The regulations will require unclear. The NRC always has It Is the Commission's intent that performance testing to be conducted prosecutorial discretion not to take those facility licensees that submit a throughout the life of a simulation enforcement action in unclear cases. certification for a simulation facility facility, on a four-year cycle, at the rate The language in 1 55.71 on criminal may Immediately begin use of the of approximately 25 percent per year.
violations only covers persons who certified simulation facility for the The protection of public health and
"willfully violate" the Atomic Energy conduct of operating tests at the safety requires that licensed operators Act or the NRC's regulations and does reference plant. not only be proficient in general no aply to situations such as (2)Performancetesting. Many operations but be able to safely cope iscussions after an examination Is comments addressed the requirement with plant transients and malfunctions.
administered or when a previously for the conduct of a series of Thus a reactor operator license administered examination Is used as a performance tests, in which an candidate's response to malfunctions practice examination. extensive range of tests would be during an operating test is an important I(E) Simulation focilities-(1) conducted over a 4-year cycle, 25 factor in the examiner's assessment of Applicationprocess. Many commenters percent per year. The industry standard that candidate's performance. It Is also were concerned with what they termed which was in effect at the time of the necessary to avoid misleading or the burdensome procedure requiring proposed rulemaking. ANSI/ANS 3.- negative training, which could result initial and subsequent application for 1981 required complete simulator from the use of a simulation facility approval to use a simulation facility. performance testing every four years, which does not correctly portray plant Most of these commenters felt that and R.G. 1.149 endorsed that response to malfunctions. Therefore the certification by the facility licensee to requirement. In addition, the R.G. ability of a simulation facility to theNRC that the simulation facility met specified that all malfunctions which a faithfully portray plant malfunctions as Industry standards should suffice, when simulation facility was capable of well as general operability is to be combined with the NRC's ability to performing should be tested to the verified by periodic performance testing.
audit the simulation facility and review extent that such malfunctions could be Such testing provides assurance that the the supporting documentation. used in the conduct of operating tests. simulation facility remains acceptable The Commission has amended the The majority of commenters felt that the over time and continues to meet the final rule to reflect the position taken in burden of conducting these tests would Commission's regulations. A definition these comments. Any facility licensee demand an excessive amount of time on of performance testing has been added that proposes to use a simulation facility the part of the simulation facility as well to I 55.4. and the requirements for that meets the definition of a plant- as the facility licensee's staff. Numerous performance testing have been clarified referenced simulator (essentially a suggestions were made proposing lists in the applicable paragraphs of simulator that meets the requirements of of performance tests thought to be
- 55.45(b), as they apply to all ANS-3.5. 1985, "Nuclear Power Plant appropriate, suggesting alternative simulation facilities, whether certified or Simulators for Use In Operator formulas for the cycle of performance approved.
Training," as modified by Regulatory testing. or offering suggestions that the (3)Schedule. A number of comments Guide 1.149) will be required only to rule merely endorse a new version of the included criticism of the time schedules certify this to the Commission, and to industry standard which was in specified as being unreasonably short maintain records pertaining to preparation at the time. for submitting a simulation facility plan performance testing results for and for having a simulation facility in Commission review or audit. Any A new version of the standard, identified as ANSI/ANS 3.5-1985, was full compliance with the regulation.
facility licensee that proposes to use a The regulation has been changed to simulation facility that is other than a published after the expiration of the public comment period. In response to allow 1 year (versus 120 days) for a plan-referenced simulator will be facility licensee to submit a plan required to submit a plan detailing how the comments received and to the newly the requirements of 1 55.45 will be met Issued industry standard, R.G. 1.149 has detailing its approach to the simulation
,on the alternative device or devices. been changed to endorse the new facility requirement; and to allow 4 followed by an application for NRC standard, with exceptions, and to years (versus 3) for its simulation approval for use of the simulation Include in its endorsement the specific, facility to be in full compliance with the facility. However, in response to the limited list of malfunction performance regulation. Those facility licensees that numerous comments received, this tests contained In the standard. certify the use of a plant-referenced application process has been greatly However, although the new standard simulator will not have to submit a plan.
simplified. and the requirement for a continues to require the conduct of (4)Penaltyfor unavailabilityof simulator performance tests, it has simulation facility. Several comments deleted the requirement that these tests expressed concern that the penalty was Street NW.. Washington. DC These documents may too harsh for the unavailability of a be purchased from the U.S. Government Printing be conducted on a four-year cycle for Office (GPO) by calling 202-27-20W0 or by writing the life of the simulator. Instead it has simulation facility acceptable to the the GPO. P.O. Box 37062 Washington. DC 2013- substituted an annual operability test, Commission.
706Z. They may also be purchased rrom the National and now.required that performance tests It is the Commission's intent that Technical Information Service, U.S. Department of every facility licensee have available a Commerce. 5255 Port Royal Road. Springfield. VA be conducted only upon completion of
22161. initial simulator construction and Inthe simulation facility that meets the B-5
9450 Federal Register / V!,,2. No. 57 / Wednesday, March 25. 1981jRules and Regulations _
Commission's requirements within a senior operator licenses from the final months or longer. Therefore, thes -
reasonable period of time after the rule. This action Isin recognition of the following requirements have been effective date of the rule, and that, once industry accreditation of training added;
available, the simulation facility be programs, which Includes instructor If an operator has not performed licensed maintained and upgraded, as needed, to training, qualification and evaluation, duties on aminimum of seven 8-hour shifts 6r continue its acceptability for the and is in keeping with the intent of the five 12-hour shifts per quarter, before conduct of operating tests. The Commission Policy Statement on resumption of activities authorized by a Commission recognizes that unique Training and Qualifications of Nuclear license issued under these regulations. an -
circumstances may arise on a plant- Power Plant Personnel. Industry efforts authorized representative of the facility- specific basis that cause some deviation in implementing instructor training. licensee shall certify that the qualifications from the time requirements established qualification and evaluation programs and status of the licensee are current and in the rule and that, from time-to-time, a will be monitored as described by the valid. and that the licensee has completed a previously certified or approved Policy Statement. Moreover, senior minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under simulation facility may become operator licenses limited to fuel the direction of the operator or senior temporarily unacceptable for the operator, as appropriate, and Inthe position handling will continue to be issued as to which the Individual licenses will be conduct of operating tests. It is the they are currently. However. since assigned. Por licenses limited to fuel Commission's intent to address any such industry accreditation includes handling, one supervised shift issumclent:
situations on a case-by-case basis. instructor evaluation, current NRC Certification shall be maintained at the
(5)Lack of guidancefor assessment. instructor certification will not continue facility.
A number of comments expressed at facilities with industry accreditation. The revision In the wording of the rule concern that the guidance to be used by A great number of commenters had was made so that it is no longeer the Commission in Its assessment of specific suggestions regarding the necessary to Include the wording simulation facility adequacy was not yet requirements for special senior available. It is the Commission's
Intent
operators. These comments are no "activelyand extensively engaged that no simulation facility audits will be longer applicable since the Commission under requaliflcatibn. A licensee can conducted until this guidance has been has deleted these licenses from the final now maintian licensed status by fully developed and made publicly rule. successfully completing the facilty- available for a minimum of 8 months. (2) "Actively performing thefunctions licensees NRC-approved requalification
(6) Applicability to futurefacility of on operatoror senioroperator." program and passing the requalificaton licensees. Several commenters Although only one commenter examinations and operating tests.
questioned whether the Commission's specifically questioned the definition of However to return to active regulations regarding simulation "actively performing the [functions] of," performance after a period ofmnot facilities were intended to apply to a great many commenters questioned participating on shift, the conditions of a future facility licensees. this phrase in regard to R.G. 1.8 license in 55 53(be must be met In this It is the Commission's intent that Personnel Qualifications and Training manner, a licensee without currente.
these regulations apply to future facility for Nuclear Power Plants," as It was knowledge of the facility would not be licensees as well as current facility published for public comment in able to perform shift cuties.
licensees. conjunction with the proposed rule. For test and research reactor the
(7)Test and researchreactor From the comments made in response to requirement for "actively perfdoming operators.Several test and research the regulatory guide and other the functions of an operator or senior reactor operators were concerned that comments made regarding the provision operator" would be met with a mniimuom the requirements in the rule changed the in the rule under "Requalificaton. of four hours per calender quarter.
licensing process for them. As stated which required that an operator or Similarly under i 55.53(I a minimum oIfn above, the rule does not change the senior operator be 'actively and sih hours parallel workd would be status quo for this category of operator. extensively engaged" as an operator or required to return to active status.
The definition of 'simulation facility" in senior operator, It is clear that many (3)Notificationafthe Commission.
1 5S4 allows the plant to be used to commenters were confused about the Some comnmenters noted that the meet the requirements of I 55.45(b). In degree of participation in plant Commission had no need to know about addition, specific wording in I 55.45(b) operations that is required as a the criminal conviction of a licensee.
permits test and research reactor facility condition to maintain an operatoris or However. 155.53(g) is Intended to cover licensees to be exempted from senior operator's license. To prevent criminal behavior. NRC Ii interested in submitting a plan for the use of a further confusion, the rule has been felonious criminal convictions of a simulation facility that is other than a modified In I 554, "Definitlons," to licenses. The NRC considers that there plant-referenced simulator. provide the following definition may be a relationship between (F) Licenses-(I)Special senior Actively performing the functions of aa conviction for a felony and job -
operatorlicenses Many commenters operator or senior operator means that an: perfornance.
questioned the Issuance of special Individual has a position on the shift crew (G) &piradtion. Currently, licenses senior licenses. Several argued that that requires the individual to be licensed as expire after two years To lessen the, current instructor certification defined in the facility's technical paperwork burdens of facility licensees requirements were sufficient, others specifications, and that the Individual carries and the NRC. a five year expiration was Indicated that industry-accredited out and is responsible for the duties covered proposed. Many commentes suggested programs include Instructor evaluation. by that position Nthat the proposed five year expiration and others cited the Commission's In addition. several commenters were and renewal of licenses be adjusted to Policy Statement on Training and concerned that the requirements were meet the biennial medical examination Qualifications of Nuclear Power Plant unclear regarding the return to."actve" requirements. The renewal cycle has Personnel as conflictfig with these status following a period du whicha been changed and licenses will now.
licenses. licensee has not been "activelc expire after a years The Commission has deleted the performing the functions of an operator (H) JRequaification andrenewoall)
provision for the issuance of special or senior operator" for a period of 4 RequalificationpMgram and B-6
Federal Rtegister l Vol. 62, No. r7 / Wednesday, March 25, 1987 / Rules and Regulations 8459 examination content A great many successfully maintaining the proficiency licensed will be a much more effective commenters were unclear about the and knowledge of licensed personnel. training tool than one which Is not.
relationship of the NRC requalification To this end, the rule requires in 1 55.57 The Commission decided, however, requirements and performance-based that each applicant for renewal of a six- that because there might be special training programs. Moreover, many year license pass an NRC administered circumstances In some cases which commenters urged more flexibility in the comprehensive requalification written would weigh against requiring that a requalification cycle and more clarity in examination and operating test at least particular utility purchase a simulator the-program content requirements. once during each six-year license. The the Commission would not make Ita Although the requirement for NRC NRC will administer these requirement. This kind of case-specific approval of requalification programs requalification written examinations special circumstances is precisely what will reain the list of content areas and operating tests on a random basis our exemption procedures are intended under i 155A1, 55.43 and 55.45 will be so that no operator or senior operator to handle. If a licensee had appropriate referenced in 1 55.59 to clarify the issue will go longer than six years without justification, the Commission could of examination and operating test being examined by the NRC once a six- always consider whether to grant an content In addition. I 55.59(c) content year license Is Issued. exemption to the regulation. Instead. the requirements (formerly Appendix A to (1)Modificationand revocation of Commission chose to water down the
10 CFR Part 55) can be met with a licenses. Some comments were received regulation and require less.
performance-based program-for a about the Commission's authority to facility as Approved by the NRC. In its modify and revoke licenses. The Separate Views of Commissioner Final Policy Statement on Training and Commission has the authority to modify. Bernthal Qualification of Nuclear Power Plant suspend or revoke a license under the I fully support the Commission's PTersonniL the Commission endorsed Atomic Energy Act. Moreover, Inherent broad objective that operators be industry-accredited programs as in'the Commission's authority to modify. reexamined on a regular basis. But I
performance based. The frequency of suspend, or revoke a license is its ability believe the final rule is too inflexible for the comprehensive requalification to place a licensed operator or senior good regulatory and administrative written examination has been changed operator under probation. If warranted. practice. NRC may indeed need to to a rbaximum of every Zyears and of (Jl Editorial.Many commenters had examine operators every six years; in the requalification operating test to once non-substantive editorial changes to some cases, perhaps more often. But if a a year. The requalification program must suggest. These comments were reviewed licensee satisfactorily demonstrates its be conducted for a continuous period by an NRC technical editor and ability to conduct high quality.
not to exceed 24 months. The specific incorporated as appropriate. performance-based examinations in cycle ill be approved by the NRC as (K)Conforming amendments. A accordance with I 55.57(b)(2)(iii), such feach: faclitytraining program. conforming amendment 10 CFR 50.74. licensee performance may well justify
-(2) zActively andextensively requires the facility licensee to notify extension or relaxation of this ueWged."A explained above, many the Commission of a change in operator requirement. This approach would have
-comnenters where concerned with the status This amendment complements been consistent with the Commission's Implementation of the provision for policy of rewarding good licensee
"actively and extensively engaged as an I 5.535(g). performance and focusing attention and operator or senior operator" as It related (L)Revision to 10 CFR 50.54 and 1o CFR 50.34(b)(8J. Revisions have been resources on deficient performers. The to renewaal.This provision Is deleted in Commission thus could have provided the final ule. This action complements made to s0 CFR 5O.34(b)(8) and 50.54 to the additions J 55.53 (e)and () to. reflect the changes made to 10 CFR Part Incentive to licensees and flexibility to
'Conditions of Ucenses." 65. the NRC examiner staff, and should have thereby focused NRC's limited
(3)Test and researchreactors. Separate Views of Commissioner regulatory resources where they are Severalcommenters were concerned Asselstine that the requalification requirements for most urgently needed.
operators at this class of reactor were Tiis rule Isa good Idea, but it does I also continue to believe that the time changed. The requirements in not go far enough. The Commission has come (given the decreased cost and I 55.59(c)(7) continue the requirements should have required all licensees to increased sophistication of the of former Appendix A to 10 CFR Part 55 obtain plant referenced simulators. technology) for all but a few small for test and research reactors. No change There are two reasons for this. First, I powerplants to be required to have plant In requirements is intended. - believe that section 308 of the Nuclear reference simulators for operator
(4)NRC administrationof Waste Policy Act of 1982 (Pub. L 97- training. While there may be some requolificotion examinotions. Some 425) requires it. Second, plant referenced special cases that would qualify for commenters questioned the NRC simulators are an excellent way for exemption from such a requirement, on
-administratlon of requalification reactor operators to practice control the basis of geography and/or plant examinations. The Commission believes manipulations for the plant and to similarity, licensees could in those that an NRC administered examination actually see how the plant would circumstances apply for and receive an for license renewal provides assurance respond. This Is especially Important in exemption.
that an operator or senior operator can training the operators to deal with 111. Regulatory Analysis operate the controls In a safe and emergency or other situations when the competent manner and that a senior plant is not in its normal state. It is a The regulatory analysis describes the operator can direct the activities of much more effective teaching tool for values (benefits) and impacts (costs) of other licensed operators In a safe and the operators to actually manipulate implementing the proposed regulations competent manner. The Commission controls and watch the "plant" respond and guidance for operator licensing. The also believes that NRC administered than to have them merely memorize accuracy of these estimates in the examinations provide assurance that emergency procedures. Further, a regulatory analysis is limited by the lack
-facility licensee administered simulator which Is referenced to the of extensive data on human requarification programs are plant on which the operator will be performance improvement associated B-7
l
9460 Federal Register / v - 52, No. 57 / Wednesday, March 25. 19R , Rules and Reizulations nomml- with an Improved licensing process. by the Office of Management and Subpart 5-Exemptons Where possible, quantitative measures Budget approval number 3150-018 55.11 Specific exemptions.
were qualitatively compared to related 55 1l General exemptions.
information from other sources for VIII. Regulatory Flexibility Certification verification. The full text of the Subpart C-Medical Requirements As required by the Regulatory regulatory analysis on these Flexibility Act of 1980,5 U.S.C. 0b). 5521 Medical examination.
amendments is available for inspection the Commission hereby certifies that 55.23 Certification.
55.25 Incapacitation because of disability or in the NRC Public Document Room, 1717 this rule will not have a significant illness.
H Street NW., Washington. DC. Single economic impact on a substantial 55.27 Documentation.
copies of the analysis may be obtained number of small entities. The from Chief. Operator Licensing Branch. conforming amendment to 10 CFR Part Subpart D-Appflcations telephone: (301) 492-488& 50 and the revision of 10 CFR Part 55 5531 How to apply.
affect primarily the companies that own s5533 Disposition of an initial application IV. Backfit Analysis 55.35 Re-applcatons and operate light-water nuclear power The Commission has determined that reactors and the vendors of those Subpart E-WrItten Examinadons and these rules are in response to section reactors. They also affect individuals Operatn Test
306 of the Nuclear Waste Policy Act of licensed as operators at these 55.41 Written examinationu Operators.
1982 and, therefore, are exempt from the companies. Neither the companies that 55.43 Written examination Senior operators backfit rule 10 CFR 50.109 (50 FR 38097). own and operate reactors nor these 55.45 Operating tests.
individuals fail within the scope of the 55.47 Waiver of examination and test V. Regulatory Guides requirements definition of "small entity" set forth in Three regulatory guides were section 501(b) of the Regulatory 55.49 Integrity of examinations and tests.
published in draft form for public Flexibility Act. NRC's Size Standards Subpart P-LJCens comment in conjunction with the adopted December 9, 1985 (50 FR 50241). 55.51 Issuance of licenses.
proposed rule. These guides were or the Small Business Size Standards set 55.53 Conditions of licenses.
intended to provide guidance on out in regulations issued by the Sinall 55.55 Expiration.
acceptable methods of implementing the Business Administration in 13 CFR Part 55.57 Renewal of licenses.
revisions to the regulations. As a result 121. 55s Requalification.
of public comment and additional staff Subpart 0a-odification and Revocation of review, these three guides are being Uist of Subjects Ucenses issued in final form: 10 CFA Pait50 55.81 Modification and revocation of licenses.
(1) R.G. 1.134. Revision 2. "Medical Evaluation of Licensed Personnel for Antitrust, Classified information, Fire Subpart H-Eforcement Nuclear Power Plants." prevention, Incorporation by reference. 55.7T1 Violations.
(2) R.G. 1.149, Revision Z. "Nuclear Intergovernmental relations. Nuclear Authorityr Secs. 107. 181 182. 8 Stat. 939.
Power Plant Simulation Facilities for power plants and reactors, Penalty, 948 953 as amended. soc. 234.83 Stat. 444, as Use in Operator License Examinations." Radiation protection. Reactor siting.. amended (42 USC. 2137. Z1. 2232. 2282)
criteria. Reporting and recordkeeping secs. 201. as amended. 202 88 Stat. 1242. as
13) R.G. 1.8 Revision 2,"Qualification requirements.
and Training of Personnel for Nuclear amended 12441(4 USC. 5841. S842).
Power Plants." 10 CFA Part55 Sections 55.41. 543. 55.45 and 5559 also Issued under sec. 308 Pub. L 97-425 .9 StaL
Copies of these guides may be Manpower training programs, Nuclear 2282(42 U.SC 20228). Section 55.81 also purchased from the Government Printing power plants and reactors. Penalty, issued under secs. 188.187, 88 Stat. 955(42 Office at the current GPO price. Reporting andtrecordkeeping U.S.C. 2238 2237).
Information on current GPO prices may requirements. For the purposes of sec. 223.88 Stat. 958. as be obtained by contacting the, amended (42 U.C. 2273) I555.3 55.21.55.49 Superintendent of Documents, U.S For the reasons set out In the and 55.53 are Issued under sec. 161i .8 Stat.
Government Printing Office. Post Offic.-_ preamble and under the authority of the 949. as amended (42 U.S.C. 220(l)k and Box 37082. Washington. DC 20013-7082f Atomic Energy Act of 1954., as amended. 115523. 55.25 and 55.53(f) are Issued under telephone (202) 275-2060 or (202) 275- the Energy Reorganization Act of 1974; sec. l~o. 88 Stat 954 as amended (42 USC
as amended, the Nuclear Waste Policy 2201(o)).
2171.
Act of 1982. and 5 U.SC. 553. the NRC Is VL Environmental Impact Categorical adopting the following amendments to Subpart A-General Provisitons Exclusion 10 CFR Part 55 and 10 CFR Part 50. 155.1
Purpose
.
The NRC has determined that this 1. 10 CFR Part 55 Is revised to read as The regulations In this part regulation is the type of action described follows: (a) Establish procedures and criteria in categorical exclusion 10 CFR for the issuance of licenses to operators
51.22(c)(1). Therefore, neither an PART 55-OPERATORS UCENSES and senior operators of utilization environmental impact statement nor an facilities licensed pursuant to the environmental assessment has been Subpart A-General Provisions Atomic Energy Act of 1954. as amended.
prepared for this regulation. se& or section 202 of the Energy
55.1
Purpose
. Reorganization Act of 1974. as amended, VIL Paperwork Reduction Act 55.2 Scope.
Statement and Part 50 of this chapter.
55.3 License requirements. (b) Provide for the terms and This final rule amends Information 55.4 Definitions
55.5 Communications. conditions upon which the Commission collection requirements that are subject 53.8 Interpretations. will issue or modify these licenses, and to the Paperwork Reduction Act of 1980 55.7 Additional requirements. (c) Provide for the terms and.
(44 U.S.C. 3501 et seq.). These 55.5 Information collection requirements conditions to maintain and renew these paperwork requirements were approved oMB approval licenses.
B-8
9 - =
Register J Vol iAo. 57 / Wednesday, March 25. 1987 k..Ies and Regulations wFederal 9461 flu6 p demonstrates expected plant response for operators and senior operators of The regulations In this part apply to- to operator input, and to normal, nuclear reactors licensed under 10 CFR
(a)Any individual who manipulates the transient and accident conditions to Part 50 and located In these regions.
controls of any utilization facility which the simulator has been designed (2)Any application for a license or licensed pursuant to Part S0 of this to respond. license renewal filed under the chapter, and "Reference plant" means the specific regulations In this part involving a Ib) Any Individual designated by e nuclear power plant from which a nuclear reactor licensed under 10 CFR
facility licensee to be responsible for simulation facility's control room Part t0 and any related Inquiry.
directing any licensed activity of. configuration. system control communication. Information, or report licensed operator. arrangement. and design data are must be submitted by mail ar in person derived. to the Regional Administrator. The I 65.3 Lens rqulremnerft 'Senior operator" means atiy Regional Administrator or the -
A person must be authorized by a individual licensed under this part to. Administrator's designee will transmit license issued by the Commission to manipulate the controls of a facility and to the Director of Nuclear Reactor perform the function of an operator or a to direct the licensed activities of Regulation any matter that Isnot within senior operator asdefined In this par licensed operators.
the scope of the Regional
"Simulation facility" means one or Administrator's delegated authority.
more of the following components. alone As used In this part or In combination, used for the partial (i)If the nuclear reactor Is located In
'Act' means the Atomic Energy Act conduct of operating tests for operators Region 1.submission must be made to of M.54. Including any amendments to senior operators. and candidates: the Regional Administrator, Region I
the Act. (1)The plant. US. Nuclear Regulatory Commission,
"Actively performing the functions of (2)A plant-referenced simulator, 631 Park Avenue, King of Prussia.
an operator or senior operator" means (3)Another simulation device. Pennsylvania 19406.
that an Individual has a position on the "Systems approach to training" means (ii) If the nuclear reactor Is located In shift crew that requires the Individual to a training program that includes the Region II. submission must be made to be licensed as defined In the facility's following five elements: the Regional Administrator, Region II,
technical specifications. and that the (1)Systematic analysis of the Jobs to U.S. Nuclear Regulatory Commission.
Individual carries out and is responsible be performed. 101 Marietta Street. Suite 2900. Atlanta.
for the duties covered by that position. 12) Learning objectives derived from Georgia 30303.
"Commisslon" means the Nuclear the analysis which describe desired (iii) If the nuclear reactor Is located in Regulatory Commission or Its duly performance after training. Region Ill. submission must be made to authorized representatives. (3)Training design and the Regional Administrator, Region Ill,
"Controls" when used with respect to implementation based on the learning a nuclear reactor means apparatus and objectives. U.S. Nuclear Regulatory Commission, mechanisms the manipulation of which (4)Evaluation of trainee mastery of 799 Roosevelt Road. Glen Ellyn. Illinois directly affects the reactivity or power the objectives during training. 50137.
level of the reactor. ,(5) Evaluation and revision of the (iv) If the nuclear reactor is located In
"Facility" means any utilization training based on the performance of Region IV.submission must be made to facility as defined In Part 50 of this trained personnel In the job setting. the Regional Administrator, Region IV.
chapter. In cases for which a license Is "United States," when used In a U.S. Nuclear Regulatory Commission, Issued for operation of two or more geographical sense, Includes Puerto Rico 611 Ryan Plaza Drive, Suite 1000.
facilities. 'facility" means all facilities and all territories and possessions of the Arlington. Texas 76011.
Identified In the license. United States. (v)If the nucear reactor is located in Facility licensee" means an applicant Region V,submission must be made to for or holder of a license for a facility. I 5.5. Communications. the Regional Administrator. Region V.
"Licensee" means an Individual (a) Except as provided under a U.S. Nuclear Regulatory Commission.
licensed operator or senior operator. regional licensing program Identified In 1450 Maria Lane, Suite 210. Walnut
"Operator' means any Individual paragraph (b) of this section. an. Creek. California 94596.
licensed under this part to manipulate a applicant or licensee or facility licensee control of . facility. shall submit any communication or I55.6 Interpretations.
'Performance testing" means testing report concerning the regulations In this Except as specifically authorized by conducted to verify a simulation part and shall submit any application the Commission Inwriting, no facility's performance as compared to filed under these regulations to the Interpretation of the meaning of the actual or predicted reference plant Commission as follows: regulations In this part by any officer or performance. (1)By mail addressed to-Director of employee of the Commission other than
"Physician" means an Individual Nuclear Reactor Regulation. U.S. a written interpretation by the General licensed by a State or territory of the Nuclear Regulatory Commission, Counsel will be recognized to be binding United States, the District of Columbia Washington. DC 20555. or or the Commonwealth of Puerto Rico to (2)By delivery in person to the upon the Commission.
dispense drugs In the practice of Commission offices at-(i) 1717 H Street I 65.7 Addtitonal requirements.
medicine. NW.. Washington. DC or (ii)7920 ;.
"Plant-referenced simulator" means a Norfolk Avenue. Bethesda. Maryland. The Commission may. by rule.
simulator modeling the systems of the (b)l() The Director of Nuclear Reactor regulation, or order, impose upon any reference plant with which the operator Regulation has delegated to the Regional licensee such requirements. Inaddition interfaces Inthe control room. including Administrators of Regions l. II11 ll, IV. to those established in the regulations in operating consoles. and which permits and V authority and responsibility this part, as It deems appropriate or use of the reference plant's procedures. pursuant to the regulations In this part necessary to protect health and to A plant-referenced simulator for the Issuance and renewal of licenses minimize danger to life or properly.
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9462 Federal Register / ~o52, No. 57 / Wednesday. March 25, 19 Rulei and Regulations
1 55.8 Information coitection Subpart C-Medlcal Requirements requirements: oMB approvaL Licensee," available from Publication
1 55.21 Medical examination. Services Section. Document (a) The Nuclear Regulatory Management Branch, Division of Commission has submitted the An applicant for a license shall have a Technical Information and Document Information collection requirements medical examination by a physician. A Control. U.S. Nuclear Regulatory contained in this part to the Office of licensee shall have a medical Commission, Washington. DC 20555;
Management and Budget (OMB) for examination by a physician every two (2)File an original and two copies of approval as required by the Paperwork years. The physician shall determine Form NRC-g39a, together with the Reduction Act of 1980 (44 U.S.C. 3501 et that the applicant or licensee meets the information required In paragraphs seq.). OMB has approved the requirements of I 55.33(a)(1). (a)(3). (4). (5)and (6)of this section. with information collection requirements 155.23 Certification. the appropriate Regional Administrator, contained in this part under control (3)Submit a written request from an number 3150-OM& To certify the medical fitness of the authorized representative of the facility (b) The approved information applicant, an authorized representative licensee by which the applicant will be collection requirements contained in this of the facility licensee shall complete employed that the written examination part appear in J1 55.45, 55.53 and and sign Form NRC-390, "Certification and operating test be administered to
155.59. of Medical Examination by Facility the applicant;
Licensee," available from Publication (c) This part contains information Services Section, Document (4)Provide evidence that the applicant collection requirements in addition to Management Branch, Division of has successfully completed the facility those approved under the control Technical Information and Document licensee's requirements to be licensed as number specified in paragraph (a) of this Control. U.S. Nuclear Regulatory an operator or senior operator and of the section. These information collection Commission. Washington. DC 20555. facility licensee's need for an operator requirements and the control numbers (a) Form NRC-398 must certify that a or a senior operator to perform assigned under which they are approved are as physician has conducted the medical duties. An authorized representative of follows: examination of the applicant as required the facility licensee shall certify this
(1)In 11 55.23. 55.25, 55.27, 55.31. Form in 1 55.21. evidence on Form NRC-398. This NRC-393 Is approved under control (b) When the certification requests a certification must include details of the number 3150-0024. conditional license based on medical applicant's qualifications, and details on
(2)In HI 55.31. 55.35. 55.47, and 55.57, evidence, the medical evidence must be courses of Instruction administered by Form NRC-398 is approved under submitted on NRC Form 398 to the the facility licensee, and describe the control number 31504-090. Commission and the Commission then nature of the training received at the
(3)In 1 55.45. Form NRC-474 is makes a determination in accordance facility, and the startup and shutdown oauproved under control number 3150- with I 55W experience received. In lieu of these
0138 details, the Commission may accept I SS25 Incapacitation because of certification that the applicant has Subpart B-Exemptions disability or Iness successfully completed a Commission.
If.during the term of the license, the approved training program that Is based
155.11 Specifl exemptions. licensee develops a physical or mental on a systems approach to training and The Commission may. upon condition that causes the licensee to fail that uses a simulation facility application by an interested person, or to meet the requirements of 1 5521 of acceptable to the Commission under upon its own initiative, grant such this part, the facility licensee shall notify I 55.45(b) of this part;
exemptions from the requirements of the the Commission within 30 days of (5)Provide evidence that the regulations in this part as it determines learning of the diagnosis. For conditions applicant, as a trainee, has successfully are authorized by law and will not for which a conditional license (as manipulated the controls of the facility endanger life or property and are describing in I 55.33(b) of this part) Is for which a license Is sought. At a otherwise in the public Interest. requested, the facility licensee shall minimum five significant control provide medical certification on Form manipulations must be performed which
155.13 General exemptions NRC 396 to the Commission (as affect reactivity or power leveL For a The regulations in this part do not described in i 55.23 of this part). facility that has not completed require a license for an Individual 155.27 Documentation.
preoperational testing and initial startup who- test program as described in its Final The facility licensee shall document Safety Analysis Report as amended and (a) Under the direction and in the and maintain the results of medical presence of a licensed operator or senior approved by the Commission, the operator, manipulates the controls of- qualifications data, test results, and Commission may accept evidence of each operator's or senior operator's satisfactory performance of simulated
(1)A research or training reactor as medical history for the current license control manipulations as part of a part of the individual's training as a period and provide the documentation Commission-approved training program student, or to the Commission upon request. The by a trainee on a simulation facility
(2)A facility as a part of the facility licensee shall retain this acceptable to the Commission under individuals training In a facility documentation while an individual I 55.45(b) of this part For a facility licensee's training program as approved performs the functions of an operator or which his (I)completed preoperational by the Commission to qualify for an senior operator. testing as described in its Final Safety operator license under this part. Subpart D-ApplIcations Analysis Report, as amended and (b) Under the direction and In the approved by the Commission, and Iii) is presence of a licensed senior operator. 15S.31 How to apply. in an extended shutdown which.
manipulates the controls of a facility to (a) The applicant shalk precludes manipulation of the control of load or unload the fuel into, out of, or (1)Complete Form NRC-398, the facility in the control room, the within the reactor vessel. "Personal Qualification Statement- Commission may process the B- 10
9463
-
-
Federal Register Vollsa, No. 57 / Wednesday, March 25: 1987'Fules and Regulations under I 55.33(a)(1) of this part the (b) The written examination for an application and may administer the operator for a facility will Include a written examination and operating test CCommission may approve the eapplication and include conditions in representative sample from among the required by 1 55.41 or 55.43 and 55.45 following 14 Items, to the extent of this part. but may not issue the the license to accommodate the medical license until the required evidence of ddefect. The Commission will consider applicable to the facility.
control manipulations Is supplied. For the recommendations and supporting (1) Fundamentals of reactor theory, licensed operators applying for a senior ievidence of the facility licensee and of including fission process. neutron operator license, certification that the Ithe examining physician (provided on multiplication, source effects, control operator has successfully operated the IForm NRC-M) in arriving at its rod effects, criticality indications.
controls of the facility as a licensed i decision. reactivity coefficients, and poison effects.
operator shall be accepted; and 16555 Re-applIcations.
(6) Provide certification by the facility (2) General design features of the licensee of medical condition and (a) An applicant whose application for core, including core structure, fuel general health on Form NRC-M, to a license has been denied because of elements, control rods, core comply with I s5521.55. and failure to pass the written examination instrumentation, and coolant flow.
55.33(a~lI or operating test, or both, may file a new (3)Mechanical components and (b) The Commission may at any time application two months after the date of design features of the reactor primary after the application has been filed, and denial. The application must be - system.
before the license has expiredL require submitted on Form NRC-398 and include (4)Seondary coolant and auxiliary futher Information under oath or a statement signed by an authorized systems that affect the facility.
affirmation in order to enable It to representative of the facility licensee by -(5) Facility operating characteristics determine whether to grant or deny the. whom the applicant will be employed during steady state and transient application or whether to revoke, that states in detail the extent of the conditions, including coolant chemistry, modify. or suspend the license.J applicant's additional training since the causes and effects of temperature.
(c) An applicant whose application denial and certifies that the applicant Is pressure and reactivity changes. effects has been denied because of a medica I ready for re-examination. An applicant of load changes, and operating condition or general health may submit may filed a third application six months limitations and reasons for these a further medical report at any time as a after the date of denial of the second operating characteristics.
supplement to the application. application, and may file further (6)Design, components. and functions (d)Each application and statemnt successive applications two years after of reactivity control mechanisms and must contain complete and accurate the date of denial of each prior instrumentation.
disclosure as to all matters required to application. The applicant shall submit (7)Design, components, and functions be disclosed. The applicant shall sign each successive application on Form of control and safety systems. including statements required by paragraphs (a)(1) NRC-398 and Include a statement of instrumentation, signals, interlocks, and (2)of this section. additional training. failure modes. and automatic and (b) An applicant who has passed manual features.
155.33 Disposition of an Ual either the written examination or (8gComponents. capacity. and appication. operating test and failed the other may functions of emergency systems.
(a) Requirements for the apprvi'alof request In a new application on Form (9)Shielding, isolation, and on initialapplication.The Commission NRC-398 to be excused from re- containment design features. including will approve an Initial application for a examination on the portions of the access limitations.
license pursuant to the regulations In examination or test which the applicant (10) Administrative, normal.
this part, if It finds that- has passed. The Commission may In its abnormal. and emergency operating
(1)Health. The applicants medical discretion grant the request. if it procedures for the facility.
condition and general health will not determines that sufficient justification is (11)
Purpose
and operation of adversely affect the performance of presented. radiation monitoring systems, including assigned operator job duties or cause alarms and survey equipment- operational errors endangering public Subpart E-Written Examinations and health and safety. The Commission will Operating Tests (12) Radiological safety principles and base its finding upon the certification by procedures.,
the facility licensee as detailed in 55541 Written examInatlon Operators. (13) Procedures and equipment
£ 55.23. (a) Content. The written examination available for handling and disposal of
(2) Witten examination and for an operator will contain a radioactive materials and effluents.
operatingtesL The applicant has passed representative selection of questions on (14) Principles of heat transfer the requisite written examination and the knowledge, skills, and abilities thermodynamics and fluid mechanics.
operating test in accordance with needed to perform licensed operator duties. The knowledge, skills, and 55.43 Written examination Senlor, Ii 55I41 and 55.45 or 55.43 and 5545. operators.
These examinations and tests determine abilities will be Identified, in part, from whether the applicant for an operator's learning objectives derived from a (a) Content. The written examination systematic analysis of licensed operator for a senior operator will contain a license has learned to operate d facility representative selection of questions on competently and safely. and* duties performed by each facility licensee and contained in its training the knowledge. skills. and abilities additionally. in the case of a senior needed to perform licensed senior operator. whether the applicant has program and from information In the learned to direct the licensed activities Final Safety Analysis Report, system operator duties. The knowledge. skills.
description manuals and operating and abilities will be identified. Inpart, of licensed operators competently and from learning objectives'derived from a safely. procedures, facility license and license amendments, Licensee Event Reports, systematic analysis of licensed senior (b) Conditionallicense. If an operator duties performed by each applicant's general medical condition and other materials requested from the does not meet the minimum standards facility licensee by the Commission. facility licensee and contained in Its B-1l
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9464. Federal Register / Vol. 52, No. 57 / Wednesday. March 25 1987 / Rules and-RegulatlionsI
training program and from information (2) Manipulate the console controls as In the Final Safety Analysis Report. (i) A simulation facility which the required to operate the facility between Commission has approved for use after sylem description manuals and shutdown and designated power levels.
operating procedures, facility license application has been made by the and license amendments. Licensee (3) Identify annunciators and facility licensee, or condition-indicating signals and perform (ii) A simulation facility consisting Event Reports, and other materials appropriate remedial actions where requested from the facility licensee by solely of a plant-referenced simultator appropriate. which has been certified to the the Commission. (4) Identify the instrumentation Commission by the facility licensee.
(b) The written examination for a systems and the significance of facility (2) Schedule forfacility licensees. (i)
senior operator for a facility will include instrument readings. Within one year after the effective date a representative sample from among the (5) Observe and safely control the of this part, each facility licensee which following seven items and the 14 items operating behavior characteristics of the proposes to use a simulation facility specified in £ 55.41 of this part, to the facility. pursuant to paragraph (bXl)(i) of this extent applicable to the facility: (6) Perform control manipulations section, except test and research
(1) Conditions and limitations in the required to obtain desired operating reactors, shall submit a plan by which facility license. results during normal, abnormal, and Its simulation facility will be developed
(2) Facility operating limitations in the emergency situations. and by which an application will be technical specifications and their bases. (7) Safely operate the facility's head submitted for its use.
(3) Facility licensee procedures removal systems, including primary (ii) Those facility licensees which required to obtain authority for design coolant, emergency coolant, and decay propose to conform with paragraph and operating changes in the facility. heat removal systems. and identify the (b)(1)(i) of this section, not later than 42
(4) Radiation hazards that may arise relations of the proper operation of months after the effective date of this during normal and abnormal situations, these systems to the operation of the rule, shall submit an application for use including maintenance activities and facility. of this simulation facility to the various contamination conditions. (8) Safely operate the facility's Commission. in accordance with
(5) Assessment of facility conditions auxiliary and emergency systems. paragraph (b)(4)(i) of this section.
and selection of appropriate procedures including operation of those controls (ill) Those facility licensees which during nornaL abnormal, and associated with plant equipment that propose to conform with paragraph emergency situations. could affect reactivity or the release of (b)(1)(ii) of this section, not later than 4B
radioactive materials to the months after the effective date of this
(8) Procedures and limitations environment involved in initial core loading. rule, shall submit a certification for use alterations In core configuration, control (9) Demonstrate or describe the use of this simulation facility to the rod programming, and determination of and function of the facility's radiation Commission on Form NRC-474.
various internal and external effects on monitoring systems. InIcuding fixed "Simulation Facility Certification,"
radiation monitors and alarms, portable available from Publication Services core reactivity. survey instruments, and personnel
(7) Fuel handling facilities and Section. Document Management Branch, monitoring equipment. Division of Technical Information and procedures. (10) Demonstrate knowledge of Document ControL U.S Nuclear
1 S54S OperatIng teds. significant radiation hazards, including Regulatory Commission. Washington.
permissible levels in excess of those DC 2055, in accordance with paragraph (a) Content The operating tests authorized, and ability to perform other administered to applicants for operator (b)(5)(1) of this section.
procedures to reduce excessive levels of (iv) The simulation facility portion of and senior operator licenses in radiation and to guard against personnel accordance with paragraph (b)(1) of this the operating test will not be exposure. administered on other than a certified or section are generally similar in scope. (11) Demonstrate knowledge of the The content will be identified. in part. an approved simulation facility after emergency plan for the facility, May 28 1991.
from learning objectives derived from a including. as appropriate, the operator's systematic analysis of licensed operator (3) Scheduleforfacilityapplicants.(I)
or senior operator duties performed by or senior operator's responsibility to For facility licensee applications after decide whether the plan should be the effective date of this rule, except test each facility licensee and contained in executed end the duties under the plan its training program and from and research reactors, the applicant assigned. shall submit a plan which Identifies information in the Final Safety Analysis (12) Demonstrate the knowledge and Report system description manuals and whether Its simulation facility will ability as appropriate to the assigned conform with paragraph (b~l)(1) or operating procedures, facility license position to assume the responsibilities and license amendments, Licensee (b)(1)(iI) of this section at the time of associated with the safe operation of the application.
Event Reports. and other materials facility, requested from the facility licensee by *(ii) Those applicants which propose to
(13) Demonstrate the applicant's conform with paragraph (b(1)(1) of this the Commission. The operating test, to ability to function within th6 control the extent applicable. requires the section, not later than 180 days before room team as appropriate to the the date when the applicant proposes applicant to demonstrate an understanding of and the ability to assigned position. In such c way that the that the Commission conduct operating facility licensee's procedures are tests. shall submit an application for use perform the actions necessary to adhered to and that the limitations in lts accomplish a representative sample of its simulation facility to the NRC In license and amendments are not accordance with paragraph (b)(4)(i) of from among the following 13 items. violated. this section.
(1) Perform pre-startup procedures for (b) Implementation-(1)
the facility, including operating of those piii) Those applicants which propose Administration. The operating test will to conform with paragraph (b)(l)(ii) of controls associated with plant be administered in a plant walkthrough this section. not later than 60 days equipment that could affect reactivity. and in either- before the date when the applicant B- 12
F/1) 9465 Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 r4ules and Regulations proposes that NRC conduct operating including results of completed performance tests, if different, to be tests, shall submit a certification for use performance testing as required for conducted on the simulation facility of its simulation facility to the approval; during the subsequent four-year period.
Commission on Form NRC-474. in (vi) Any application or report and a schedule for the conduct of accordance with paragraph (b)(5)(i) of submitted pursuant to paragraphs approximately 25 percent of the this section. (b)(4)(i) (b)(4)(iii) and (b)(4)(vi) of this performance tests per year for the
(4)Application for and approval of section must include a description of the subsequent four years.
simulotionfacilities.Those facility performance testing completed for the 1 55.47 Walver ofexamInation and test.
licensees which propose, In accordance simulation facility, and must include a requirements.
with paragraph (b)(1)(i) of this section, description of performance tests, If (a) On application, the Commission to use a simulation facility that is other different, to be conducted on the a plant-referenced simulator simulation facility during the subsequent may waive any or all of the than solely requirements for a written examination as defined in I 55.4 shall- four-year period, and a schedule for the (i In accordance with the plan. conduct of approximately 25 percent of and operating test, if it finds'that the submitted pursuant to paragraph the performance tests per year for the applicant- (b)(2)(i) or [b)(3)(i) of this section, aS subsequent four years. (1)Has had extensive actual operating applicable submit an application for - (5)Certificationof simulation experience at a comparable facility, as determined by the Commission. within approval of the simulation facility to the facififies-Those facility licensees two years before the date of application;
Commission, in accordance with the which propose, in accordance with schedule in paragraph (b)(2)(Ki) or paragraph (b)(1)(l) of this section. to use (2)Has discharged his or her (b)(3)(11) of this section. as appropriate. a simulation facility consisting solely of responsibilities competently and safely This application must include :. a plant-referenced simulator as defined and is capable of continuing to do so;
(A) A statement that the simulation in 1 55.4. shall- and facility meets the plan submitted to the (I)Submit a certification to the (3)Has learned the operating Commission pursuant to paragraph Commission that the simulation facility procedures for and is qualified to (b)(2)(i) or (b)(3)(i) of this section, as meets the Commission's regulations. The operate competently and safely the applicable, facility licensee shall provide this facility designated in the application.
(B)A description of the components of certification on Form NRC-474 in (b) The Commission may accept as the simulation facility which are accordance with the schedule in proof of the applicant's past intended to be used for each part of the paragraph (b)(2)(iil) or (b)(3)(fii) of this performance a certification of an operating test; and section. as applicable. authorized representative of the facility (C) A description of the performance (ii) Submit, every four years on the licensee or of a holder of an tests as part of the application. and the anniversary of the certification, a report authorization by which the applicant results of such tests. to the Commission which Identifies any was previously employed. The (ii)The Commission will approve a uncorrected performance test failures. certification must contain a description simulation facility if it finds that the and submit a schedule for correction of of the applicant's operating experience.
simulation facility and Its proposed use such performance test failures, if any. including an approximate number of are suitable for the conduct of operating - (iii) Retain the results of the hours the applicant operated the tests for the facility licensee's reference performance test conducted until four controls of the facility, the duties plant, in accordance with paragraph (a) years after the submittal of certification performed, and the extent of the of this section. under paragraph (b)(5)(i), each report applicant's responsibility.
(iii) Submit. every four years on the pursuant to paragraph (b)(5)(ii). or (c)The Commission may accept as anniversary of the application. a report recertification under paragraph (b)(5)(v) proof of the applicant's current to the Commission which Identifies any of this section, as applicable. qualifications a certification of an'-
uncorrected performance test failures, (iv) If the Commission determines. authorized representative of the facility and submit a schedule for correction of based upon the results of performance licensee or of a holder of an these performance test failures, if any. testing, that a certified simulation authoriiation where the applicant's (iv) Retain the results of the facility does not meet the requirements services will be utilized.:
performance test conducted until four of this part, the simulation facility may years after the submittal of the not be used to conduct operating tests. *55.49 IntegrIty of examinations and application under paragraph (b)(4)(1); (v)If the Commission determines, tests.
each report pursuant to paragraph pursuant to paragraph (b)(5)(iv) of this Applicants: licensees, and facility (b)(4)(iii). or any reapplication under section. that a certified simulation licensees shall not engage in any paragraph (b)(4)(iv) of this section. as facility does not meet the requirements activity that compromises the integrity appropriate. of this part, the facility licensee may of any application, test, or examination (v) If the Commission determines. submit a recertification to the required by this part.
based upon the results of performance Commission on Form NRC-474. This testing, that an approved simulation recertification must Include a Subpart F-Ucenses facility does not meet the requirements description of corrective actions taken, I 55.51 Issuance of licenses.
of this part, the simulation facility may' including results of completed not be used to conduct operating tests. performance testing as required for Operatorand senior operator (vi) If the Commlission determines. recertification. licenses. If the Commission determines pursuant to paragraph (b)(4)(v) of this (vi) Any certification report. or that an applicant for an operator license section. that an approved simulation recertification submitted pursuant to or a senior operator license meets the facility does not meet the requirements paragraph (b)(5)(1). (b)(5)(ii) or (b)(5)(v) requirements of the Act and its of this part, the facility licensee may of this section must include a regulations. it will Issue a license in the again submit an application for description of performance testing form and containing any conditions and approval. This application must include completed for the simulation facility.: limitations it considers appropriate and a description of corrective actions taker A and must include a description of the necessary.
B- 13
9468 Federal Register / Vc No. 57 / Wednesday, March 25, 198&.vRules and Regulations
5553 CondItions oflenses. I 555. Expiration. (I)Is capable of continuing to Each license contains and Is subject to (a) Each operator license and senior competently and safely assume licensed the following conditions whether stated operator license expires six years after duties;
in the license or not: the date of issuance, upon termination (ii)Has successfully completed a (a) Neither the license nor any right of employment with the facility licensee, requalification program that has been under the license may be assigned or or upon determination by the facility approved by the Commission as otherwise transferred. licensee that the licensed individual no required by I 55.59; and (b) The license is limited to the facility longer needs to maintain a license. (iii) Has passed the requalification for which Itis issued. (b) If a licensee files an application for examinations and annual operating tests (c) The license is limited to those renewal or an upgrade of an existing as required by 1 55.59.
controls of the facility specified in the license on Form NRC-398 at least 30 (Iv)Has passed a comprehensive license. days before the expiration of the requalification written examination and (d) The license is subject to. and the existing license, It does not expire until operating test administered by the licensee shall observe. all applicable disposition of the application for Commission during the term of a six- rules. regulations, and orders of the renewal or for an upgraded license has year license.
Commission. been finally determined by the (3)There Is a continued need for a (e) If a licensee has not been actively Commission. Filing by mail or telegram licensee to operate or for a senior performing the functions of an operator will be deemed to be complete at the operator to direct operators at the or senior operator, the licensee may not time the application Isdeposited Inthe facility designated in the application.
resume activities authorized by a license mail or with a telegraph company. (4)The past performance of the Issued under this part except as licensee has been satisfactory to the permitted by paragraph (f) Of this 1 55.7 Renewal of licenses. Commission. In making its finding, the section. To maintain active status, the (a) The applicant for renewal of a Commission will Include Inits licensee shall actively perform the license shall- evaluation information such as notices functions of an operator or senior (1)Complete and sign Form NRC-398 of violations or letters of reprimand In operator on a minimum of seven 8-hour and include the number of the license the licensee's docket.
or five 12-hour shifts per calendar for which renewal is sought.
quarter. For test and research reactors, (2)File an original and two copies of I55.9 Requaliflcation.
the licensee shall actively perform the Form NRC-3 with the appropriate (a) Aequolification requirements functions of an operator or senior Regional Administrator specified in Each licensee shall- operator for a minimum of four hours I 55.5(b). (1)Successfully complete a per calendar quarter. (3)Provide written evidence of the requalification program developed by (f) If paragraph (e)of this section Is applicant's experience under the the facility licensee that has been not met before resumption of functions existing license and the approximate approved by the Commission. This authorized by a license issued under this number of hours that the licensee has program shall be conducted for a part, an authorized representative of the operated the facility. continuous period not to exceed 24 facility licensee shall certify the (4)Provide a statement by an months in duration.
following authorized representative of the facility (2)Pas a comprehensive
(1)That the qualifications and status licensee that during the effective term of requalification written examination and of the licensee are current and valid; the current license the applicant has an annual operating test.
and satisfactorily completed the (I)the written examination will
(2)That the licensee has completed a requalification program for the facility sample the Items specified in 1 55.42 minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions for which operator or senior operator and 5543 of this part, to the extent under the direction of an operator or license renewal is sought. applicable to the facility, the licensee, senior operator as appropriate and in (5)Provide evidence that the applicant and any limitation of the license under the position to which the individual will has discharged the license 15553(c) of this part.
be assigned. The 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> must have responsibilities competently and safely. (11)The operating test will require the included a complete tour of the plant The Commission may accept as operator or senior operator to and all required shift turnover evidence of the applicant's having met demonstrate an understanding of and procedures For senior operators limited this requirement a certificate of an the ability to perform the actions to fuel handling under paragraph (c) of authorized representative of the facility necessary to accomplish.a this section, one shift must have been licensee or holder of an authorization by comprehensive sample of Items completed. For test and research which the licensee has been employed. specified In 15545(a) (2)through (23)
reactors a minimum of six hours must (B)Provide certification by the facility inclusive to the extent applicable to the have been completed. licensee of medical condition and facility.
(g)The licensee shall notify the general health on Form NRC-39g8 to (III) In lieu of the Commission Commission within 30 days about a comply with 11 55.21. 55.2 and 55. accepting a certification by the facility conviction for a felony. licensee that the licensee has passed (b) The license will be renewed if the written examinations and operating (h) The licensee shall complete a Commission finds that- requalification program as described by tests administered by the facility
(1)The medical condition and the licensee within its Commission.
1fi55.59. general health of the licensee continue (I)The licensee shall have a biennial approved program developed by using a to be such as not to cause operational systems approach to training under medical examination. errors that endanger public health and (j) The licensee shall comply with any paragraph (c) of this section, the safety. The Commission will base this Commission may administer a other conditions that the Commission finding upon the certification by the comprehensive requalllfcation written may impose to protect health or-to facility licensee as described In 1 55.23. examination and an annual operating minimize danger to life or property. (2)The licensee- tesn B- 14
tNo.
N 67 /Wednesday, March 25. 198Rules and Regulations -9467
-. -Federal Register eiformed annually; all other items must (V)Turbine or generator trip.
(b) Additional training. ifthe on a two-year cycle. (W) Malfunction of an automatic requirements of paragraphs (a) (1)and be performed met, the However, the requalification programs control
< system that affects reactivity.
(2)of this section arenot contain a commitment that each (X) Malfunction of reactor coolant Commission may require the licensee to must additional training and to individual shall perform or participate in pressure/volume control system.
complete (Y)Reactor trip.
submit evidence to the Commission of a combination of reactivity control successful completion of this training manipulations based on the availability (Z) Main steam line break (inside or of plant equipment and systems. Those outside containment).
before returning to licensed duties. (AA) A nuclear instrumentation (c) Requalification program control manipulations which are not requirements.A facility licensee shall performed at the plant may be failure. l have a requalification program reviewed performed on *
simulator. The use of the (ii) Each licensed operator and senior Technilcal Specifications should be operator has demonstrated satisfactory and approved by the Commission. The maximized during the simulator control understanding of the operationof the requalification program must meet the requirementsof paragraphs (c) t1) manipulations. Senior operator licensees apparatus and mechanisms associated section. In lieu of are credited with these activities If they with the control manipulations in through(7) of this as they are paragraph (c)(3)(i) of this section. and- paragraphs (c)(2).(3), and (4)of this direct control manipulations performed. knows the operating procedures Ineach section. the Commission may approvea (A) Plant or reactor startups toinclude area for which the operator or senior program developed byusing a systems approach to training. arange that reactivity feedback from operator is licensed.
(l) Schedule. The requalification nuclear heat addition is noticeable and (iii) Each licensed operator and senior heatup rate isestablished. operator is cognizant of facility design program mus be conducted for a shutdown. changes, procedure changes, and facility continuous period not to exceed two (B)Plant must be (C) Manual control of steam license changes.
years. and upon conclusion (iv) Each licensed operator and senior promptly followed, pursuant to a generators or feedwater or both during continuous schedule, by successive startup and shutdown. operator reviews the contents of all -
(D) Boration or dilution during power abnormal and emergency procedures on requalification programs. a regularly scheduled basis.
(2)Lectures. The requalification operation.
preplanned (E) Significant (>10 percent) power (v) A simulator may be used in program must include changes in manual rod control or meeting the requirements of paragraphs lectures on a regular and continuing recirculation flow. and (3)(ii)of this section, if it basis throughout the license period in (c) (3)(i)
. (F) Reactor power change of 10 reproduces the general operating i -
those areas where operator and senior percent or greater where load change is characteristics of the facility involved operator written examinations and performed with load limit control or and the arrangement of the* - -
facility operating experience Indicate where flux. temperature. or speed and controls the of that emphasis in scope and depth of instrumentation coverage isneeded in the following control ison manual (for HTGR). simulator issimilar to that of the facility (G) Loss of coolant. including- involved. Ifthe simulator or simulation subjects: Significant PWR steam generator principles of operation. (1) device is used to administer operating (I) Theory and leaks tests for a facility, as provided in 1 55.45 (ii) General and specific plant (2) Inside and outside primary (b)(1), the device approved to meet the operating characteristics. containment requirements of I 55.45(b)(l)must be (iii) Plant instrumentation and control (3) Large and small, including lead-rate used for credit to be given for meeting systems. determination the requirements of paragraphs (c)(3)(i)
(iv) Plant protection systems. (4) Saturated reactor coolant response (G through AA) of this section.
(v) Engineered safety systems. (PWR). (4) Evaluation.The requalification (vi) Normal. abnormal. and emergency (H) Loss of instrument air (if program must include- operating procedures. simulated plant specific). Comprehensive requalification (vii) Radiation control and safety. (i)
Lossof electrical power (or (I) written examinations and annual (viii) Technical specifications. degraded power sources). flow/natural operating tests which determine areas in (ix) Applicable portions of Title 10. U)Loss of core coolant which retraining is needed to upgrade Chapter LCode of Federal circulation. licensed operator and senior operator Regulations. (K)Lossof feedwater (normal and knowledge.
(3) On-the-job training.The emergency). (ii)Written examinations which requalification program must include on- (L)Loss of service water. If required licensed operators' and senior determine the-pb training so that-. for safety. operators' knowledge of subjects i) Each licensed operator of a -M)Loss of shutdown cooling. covered Inthe requalification program utilization facility manipulates the plant (N) Loss of component cooling system and provide a basis for evaluating their controls and each licensed senior or cooling to an individual component. knowledge of abnormal and emergency operator either manipulates the controls (0) Loss of normal feedwater or procedures. r or directs the activities of individuals 'normal feedwater system failure. (iii) Systematic observation and during plant control manipulations (P) Loss of condenser vacuum. evaluation of the performance and during the term of the licensed (Q) Loss of protective system channel.
(R)Mispositioned control rod or rods competency of licensed operators and operator's or senior operator's license. senior operators by supervisors and/or For reactor operators and senior (or rod drops). training staff members. including .
operators. these manipulations must (S) Inability to drive control rods.
consist of the following control (T)Conditions requiring use of evaluation of actions taken or to be emergency boration orstandby liquid taken during actual or simulated manipulations and plant evolutions if system.--- abnormal and emergency procedures.
they areapplicable to the plant design. control (U)Fuel cladding failure or high (iv) Simulation of emergency or Itemsdescribed in paragraphs (c)(3)(i) abnormal conditions that may be (A) through (L)of this section must be activity inreactor coolant or offgas.
B- 15
9468 Federal Register / Vol_ i, No. 57 1 Wednesday, March 25. 1987Kules and Regulations accomplished by using the control panel from this record retention requirement of the facility involved or by using a violation of any provision of:
(B)Alternative trainingprograms The (1)The Atomic Energy Act of 1954, as simulator. Where the control panel of requirements of this section may be met the facility is used for simulation. the ambnded;
by requalification programs conducted (2)Title 1 of the Energy actions taken or to be taken for the by persons other than the facility emergency or abnormal condition shall Reorganization Act of 1974. as amended;
licensee if the requalification programs or be discussed; actual manipulation of the are similar to the program described in plant controls Is not required. If a (3)Any regulation or order issued simulator is used in meeting the paragraphs (c)(1)through (5)of this under these Acts.
requirements of paragraph (c)f4)tii) of section and the alternative program has (b) A court order may be obtained for this section. it shall accurately been approved by the Commission. the payment of a civil penalty imposed reproduce the operating characteristics (7) Applicability to researchand test under section 234 of the Aomic Energy of the facility involved and the reactorfacilities. To accommodate Act for violation oh arrangement of the instrumentation and specialized modes of operation and (1)Sections 53,57. M 83 81 82 101, controls of the simulator shall closely differences in control, equipment and 103,104,107, or 109 of the Atomic parallel that of the facility involved. operator skills and knowledge, the Energy Act;
After the provisions of I 55.45(b) have requalification program for each (2)Section 200 of the Energy been implemented at a facility, the licensed operator and senior operator of Reorganization Act of 1974;
certified or approved simulation facility a research reactor or test reactor facility (3)Any rule, regulation. or order must be used to comply with this must conform generally but need not be issued under these Acts;
paragraph. Identical to the requalification program (4)Any term. condition. or limitation (v) Provisions for each licensed outlined in paragraphs (c) (1)through (6) of any license issued under these Acts;
operator and senior operator to of this section. Significant deviations or participate in an accelerated from the requirements of paragraphs (c) (5)For any violation for which a requalification program where (1)through (a) of this section will be license may be revoked under section performance evaluations conducted permitted only if supported by written 188 of the Atomic Energy Act pursuant to paragraphs (c)(4) (I)through Justifiaton and approved by the * (c) Any person who willfully violates (iv) of this section clearly indicated the Commission. any provision of the Atomic Energy Adt need. or any regulation issued under the Act
(5) Records. The requalification Subpart G-Modfitcatlon and including the regulations in this part, program documentation must include Revocation of Licenses may be guilty of a crime and, upon the following conviction. may be punished by fine or
(1)The facility licensee shall maintain I S5.61 Modificaton and revocation of imprisonment, or both, as provided by records documenting the participation of licensee. law.
each licensed operator and senior.. (a) The terms and conditions of all operator in the requalification program. licenses are subject to amendment, C records must contain copies of written examinations administered, the revision. or modification by reason of PART 60-DMESTIC LICENSING OF
PRODUCTION AND UTILIZATION
rules, regulations. or orders Issued in FACULTIES
answers given by the licensees and the accordance with the Act or any results of evaluations and amendments thereto. '1The authority citation for Part 50
documentation of operating tests and of (b) Any license may be revoked, continues to read as follows.
any additional training administered in suspended, or modified, In whole or in Authority: Sec. 103, lo4. lt.1, 18Z5.188.
areas in which an operator or senior part: 189, 6 Stat 93937. 94, 3035. WA5958A as operator has exhibited deficiencies The facility Ifcensee shall retain these (1)For any material false statement In amended, sec. 234 83 Stat 1244. as amended the application or in any statement of (42 11S.C 2133 2134. 2201. 27 23, 2238.
records until the operators or senior 239. 282 secs 201,02208,88 Stat. 1242, operator's license is renewed. fact required under section 182 of the 1244.14 as amended (42 U.SC. 541584 pi) Each record required by this part Act, 588) unless other noted.
must be legible throughout the retention (2)Because of conditions rivealed by Section 50.7 also Issued under Pub. L 95- period specified by each Commission the application or statement of fact or 01, sOc 10, 2 Stat. 2951 (42 U.SC 58.fl regulation. The record may be the any report, record, inspection or other Sections 558.5MM, and 50.92 also Issued original or a reproduced copy or a means that would warrant the under Pub. L 97-415 96 StaL M0n. 2073 (42 Commission to refuse to grant a license U.SC. 2133,2239 SectIou 5076 also Issued microform provided that the copy or under sen. 1 8 Stat. 9 (42 U.SC 2152)
microform is authenticated by on an original application Sections 50.R-8 also itud under e.
authorized personnel and that the (3)For willful violation of or failure to 18 68 Stat. 954 as amended (42 U.SC. 2Z3)
microform is capable of producing a observe any of the terms and conditions Sections 50.100-5102 also Issued under sem clear copy throughout the required of the Act. or the licene orof any ivje h1860Stat 95( 42 U.S. 2236)
retention period. regulation, o order of the Commission, For the pu s of sec. 23 StaL 95,as (iii) If there is a conflict between the or amended (42 U..C. 2273, i1 50.10 (at (b).
Commission's regulations in this part and (), 544.50AS.0A, 50.M4, and Won)
(4)For any conduct determined by the are ied under se. isib. 68 Stat. 94 u and any license condition. or other Commission to be a hazard to safe written Commission approval or amended (42 U.C Z20(bfNl §15 o(b) and operation of the facility. (c) and 50.4 are Issued under sea. as11,66 authorization pertaining to the retention Stat. 949, as amended (42 USC 220(p1); and period for the same type of record, the Subpart H-Enforcement II S155(eel 50.59(6 50.705.715.
retention period specified for these 5.73, and 50.78 are Issued under sec. 81. a68 Stat records by the regulations in this part 5.71 Vsoations. 950. as amended (42 U.SC 22CM(o)).
apply unless the Commission. pursuant (a) An iniunction or other court order 3. In I 50M34 paragraph (b)(8) is to 55.11. grants a specific exemption may be obtained prohibiting any revised as follows:
B- 16
. Rules and Regulations 9469 sNo. 57 Wednesday, Mc itrse esn nopruiyt i
i 60.34 Contents of appUt;ation5 tchnical DEPARTMENT OF TRANSPORTATION pparticipate in the mnaking of this hitormatlWn. Federal Aviation Adminisltration asmendracuat Due consideration has been
- * * * 0
given to the comments received.
14 CFR Part 39 i (b) * The Air Transport Association (ATA)
(8)A description and plans for (Docket No. 3NM-21 -AD. Armdt. 31- ofAmerica representing operators of implementation of an operator 15" EN Boeing Model 747 and 757 airplanes requalification program. The operator Bo" s tated that the proposed rule requiring requalification program must as a AirworthiresDirecUvos; of all 747 and 757 airplanes Is Model 747 and 757 Series Akrplunm nspection minimum. meet the requirements for Lot tustified for those operators whose those programs contained In 1 5.59 of AGExcT: Federal Aviation nrecords list the serial numbers and Part 55 of this chapter. AdminIstratIon FAAM) DOT, ipplicabte aircraft of the subject
- * * 0
ACTION: Final rule. zeservo3Uir Italled The ATA. therefore.
4. In I 50.K paragraphs (I) and (I-1L) equested that paragrph A.of the summARr. This amendment adopts a proposed rule be deleted and that the are revised to read as follows: new airworthiness directive (AD), effectivity be revised to read "Boeing:
110.54 Canduomnooloens applicable to Boeing Models 747 and 757 Applies to all Model 747 and 757 series
- * * 0 series airplanes, which requires sirplanes equipped with emergency
Inspection of the passenger door power reservoirs listed In H.R. Textron (I)Except as provided in 5 65.13 of emergency power reservoir for integrity Service Bulletin No. 81103300-52-." The this chapter. the licensee may not permit of the pressure relief rupture disk, FAA agrees that It Is unnecessary to the manipulation of the controls of any repair, If necessary, and replacement of inspect the airplanes If records are facility by anyone who Is not a licensed defective disk retainers. This available to determine the serial operator or senior operator as provided amendment is prompted by numerous numbers of the reservoirs Installed, and in Part 55 of this chapter. reports of emergency power reservoirs the AD has been revised accordingly.
(i-i) Within three months after found to be prematurely discharged. however. In absence of such records, Issuance of an operating license. the This condition, If not corrected, would operators must inspect for serial licensee shall have In effect an operator render the emergency power reservoir numbers In accordance with the requalification program which must as i incapable of pr9viding power to assist in applicable service bulletin.
minimums meet the requirements of opening the door quickly when required The ATA also commented that the I 55.59(c) of this chapter. for emergency evacuation. "NOTE in the proposed rule which Notwithstanding the provisions of DATES: Effective May 1.1987. advises readers that the affected I 50.59, the licensee may not, except as ADDRESSES: The applicable Boeing reservoirs may be installed on other specifically authorized by the service Information may be obtained airplanes should be deleted because, If Commission decrease the scope of an from the Boeing Commercial Airplane adopted; will create confusion In the approved operator requalification Company, PD. Box 3707, Seattle. field since the effectivity of the program. Washington 98124; the applicable H.R. proposed rule is clearly only against
- * * * 0 Textron service Information may be Boeing aircraft. The FAA concurs that obtained from HR. Textron. 25200 West the effectivity is only Boeing aircraft and S. Immediately following 1 50.73. Rye Canyon Road, Valencia. California specifically Models 747 and 757;
"Licensee Event Report System." a nev 91355. This information may be however. the "NOTE" should not be
5 50.74 Is added as a conforming examined at the FAA, Northwest deleted because, while some Boeing 747 amendment to read as follows: Mountain Region. 17900 Pacific Highway and 757 aircraft may have been Seattle, Washington. or the delivered without defective reservoirs, a I 0.74 Notification of Change Inopnrtc C South. Seattle Aircraft Certification Office. defective reservoir could have been or senior operator status. Way-South. Seattle, Installed In the field since delivery. The
9010 East Marginal Each licensee shall notify the Washingon 98168 note has been revised to reflect "Boeing Commission in accordance with 1 50.4 rd FOR FURTHER INFORMATION
CONTACT
- Model 747 and 757 series airplanes."-
within 30 days of the following In rega: Mr. Pliny Brestel, Airframe Branch. The ATA also requested that the to a licensed operator or senior ANM-120S; telephone (20W) 431-1931. initial compliance period in paragraph operator Mailing address: FAA. Northwest A.of the proposed rule be changed from (a) Permanent reassignment from thl Mountain Region. 17900 Pacific Highway 60 to 90 days to afford those operators.
position for which the licensee has br South. C-68988, Seattle. Washington who may not have records listing serial certified the need for a licensed opera tDr 98i68. numbers of reservoirs, additional time to or senior operator under I 55.31ta)M3) i SUPPLEMENTARY INFORMATION A complete the fleet inspection to this chapter. proposal to amend Part 39 of the Federal determine if they are affected by the (b) Termination of any operator or Aviation Regulations to include an rule. The ATA stated that. in some senior operator. airworthiness directive which requires instances (likely 509), the installed of the passenger door reservoirs would require removal to (c) Disability or illness as descrldedI In Inspection read the serial number. Further, some
1 55.25 of this chapter. emergency power reservoir on Boeing Of Models 747 and 757 series airplanes for operators check the reservoirs every*
Dated at Washington. DC. this 2oth day Integrity of the pressure relief rupture four days and. therefore, need time to March 1987. disk. repair, if necessary. and change their maintenance program to For the Nuclear Regulatory Commission replacement of defective disk retainers comply with the daily check requirement lohn C. Hoyle, was published in the Federal Register on of paragraph B.The FAA does not December 24.1986 (51 FR 46687). The concur with an extension of the initial Acting SecreforylortheCommission. which compliance period from 60 to 90 days in JFR Doc. 87-6476 Filed 3-24-87; 8:45 aml comment period for the NPRM,
ended February 15, 1987, afforded that air safety and public interest
1LLN4 C00 16l041- B-17
Appendix C
Regulatory Guide.1.134 Medical Evaluation of Licensed Personnel for Nuclear Power Plants
C-I Revision 2 U.S. NUCLEAR REGULATORY COMMISSION April 1087 REGULATORY GUIDE
OFFICE OF NUCLEAR REGULATORY RESEARCH
REGULATORY GUIDE 1.134 (Task OL 401-5)
MEDICAL EVALUATION OF LICENSED PERSONNEL FOR NUCLEAR POWER PLANTS
A. INTRODUCTION The Advisory Committee on Reactor Safeguards has been consulted concerning this guide and has concurred in Sections 55.31, "How To Apply," and 55.57, "Renewal the regulatory position.
of Licenses," of 10 CFR Part 55, "Operators' Licenses,"
require that each initial or renewal application for an Any Information collection activities mentioned in this operator or senior operator license contain a medical regulatory guide are contained as requirements in 10 CFR
examination certification following the form prescribed Part 55, which provides the regulatory basis for this guide.
in Subpart C of Part 55, "Medical Requirements." Sec- The information collection requirements in 10 CFR Part 55 tions 55.33, "Disposition of Initial Application," and have been cleared under OMB Clearance No. 3150-0018.
55.57 state that the initial or renewal applications for these licenses will be approved if, among other things, B. DISCUSSION
the applicant has no medical or general health condition that might cause operational errors endangering public Section 55.23, "Certification," of Subpart C, "Medical health and safety. Paragraph (i) of § S5.S3, "Conditions Requirements," of 10 CFR Part 55 requires that a physician of Licenses," requires that an examination be conducted examine the applicant in accordance with NRC's regulatory every 2 years. guidance and determine that the examinee's medical condi- tion and general health meet the requirements for granting Section 55.25, "Incapacitation Because of Disability or renewing an operator license. The physician must send a Or Illness," deals with an operator or senior operator full medical examination report to the facility licensee, Vho becomes incapacitated because of a mental or which will then transmit a completed Form 396 to the physical condition that might cause impaired judgment NRC. The intent of these requirements is to have the facility or-motor coordination. licensee certify the health of its operators. However, the facility licensee is expected to maintain those records that Section 55.27, "Documentation," requires that the may be reviewed by the NRC. Therefore, § 55.27 requires facility licensee document and maintain the medical quali- the facility licensee to document and maintain the full fications data, current test results, and each operator's medical examination report, including the results of medical medical history and provide these to the NRC upon its qualifications data, test results, and each operator's medical request. history. In addition, § 55.27 requires the facility licensee to retain the most recent medical information as a result of This guide describes a method acceptable to the NRC the biennial physical examination and provide that informa- staff for providing the information needed by the staff tion to the NRC on request. The certification form would for its evaluation of the medical qualifications of applicants be sent by the facility licensee to the NRC.
for initial or renewal operator or senior operator licenses for nuclear power plants and for providing notification to There are two instances in which medical information the NRC of an incapacitating disability or illness. must be sent to the NRC. One is when a conditional license based on medical evidence is requested under the provisions The substantial number of changes in this revision has made it of paragraph 55.33(b). The second instance is when a licensed impractical to indicate the changes with lines in the margin. individual has become mentally or physically unable to USNRC REGULATORY GUIDES The guides are Issued In the following ten broad divisions:
Regulatory Guides are issued to describe and make available to the public methods acceptable to the NRC staff of Implementing 1. Power Reactors 6. Products specific parts of the Commission's regulations, to delineate tech- 2. Research and Test Reactors 7. Transportation niques used by the staff In evaluating specific problems or postu- 3. Fuels and Materials Facilities B. Occupational Health iated ccIdents or to provide guidance to applicants. Regulatory 4. Environmental and Siting 9. Antitrust and Financial Review Guides are noi substitutes for regulations, and compliance with 5. Materials and Plant Protection 10. General them is not required. Methods and solutlons different from those set out In the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or Copies of Issued guides may be purchased from the Government license by the Commission. Printing Office at the current GPO pric Information on current GPO prices may be obtained by contacting the Superintendent of This guide was issued after consideration of comments received from Documents, U.5 Government Printing Office, Post Office Box the public. Comments and suggestions for Improvements In these 37082, Washington, DC 20013-7082, telephone (202)275-2060 or guides are encouraged at all times, and guides will be revised, as (202)275-2171.
appropriate, to accommodate comments and to reflect new Informa- tion or experience.
Issued guides may also be purchased from the National Technical Written comments may be submitted to the Rules and Procedures Information ServIce on a standing order basis Details on this iBranch, ORR AOM, U.S. Nuclear Regulatory Commission, service may be obtained by writing NTIS, 5285 Port Royal Road, Washinfton, DC 20555. Springfield, VA 22161.
C-2 perform job duties. In this case, the facility licensee must notify the NRC within 30 days after learning Nothing in ANSI/ANS-3.4-1983 or this guide should the diagnosis has been made. The facility licensee that be construed to mean that such matters as an forward to the NRC Form 396 and medical records must vidual's reading habits, political or religious beliefs,indi- or describing the disability. This related information attitudes on social, economic, or political issues is should required by § 55.27 to be documented and maintained be investigated or judged.
by the facility.
C. REGULATORY PQSITION
An American National Standard developed by the The requirements contained in ANSI/ANS-3.4-1983, American Nuclear Society, ANSI/ANS-3.4-1983, "Medical Certification and Monitoring of Personnel Requiring "Medical Certification and Monitoring of Personnel Operator Licenses for Nuclear Power Plants,"I prescribes Requiring Operator Licenses for Nuclear Power Plants,"I
minimum requirements necessary to determine that provide a method acceptable to the NRC staff medical condition and general health of nuclear reactor the determining the medical qualifications of applicants for initial or renewal operator or senior operator licenses. for operators will not cause operational errors. The criteria presented in this standard provide an examining physician a basis for determining whether a potentially disqualify- D. IMPLEMENTATION
ing abnormal health condition exists. Establishing mum health requirements should aid in more uniform mini- The purpose of this section is to provide information medical evaluations. However, it is necessary to recognize to applicants and licensees about the staff's plans using this regulatory guide. for that, although it is the physician's responsibility identify and evaluate any potentially disqualifying to medical conditions, NRC makes the final determination Except in those cases in which the licensee proposes of the applicant's medical fitness. an acceptable alternative method for complying specified portions of the Commission's regulations, with methods described in the guide will be used in the evaluat-
1 ing the part of an application for initial or renewal Coples may be obtained from the American Nuclear Society, opera-
555 North Xensington Avenue, La Grange tor or senior operator licenses on NRC Form 396, "Certifi- Park, Mlinois 60525. cate of Medical Examination by Facility Licensee."
1.134-2
C-3 VALUE/IMPACT ANALYSIS
A separate value/impact analysis has not been pre- Room at that time. This analysis is also appropriate pared for this regulatory guide. A value/impact analysis to Revision 2 of Regulatory Guide 1.134. A copy of was included in the regulatory analysis for the amend- the regulatory analysis is available for inspection and copying for a fee at the NRC Public Document Room, ments to 10 CFR Part 55 published on March 25, 1987, . *
1717 H Street NW., Washington, DC.
a copy of which was placed in the Public Document
1.134-3
Appendix D
Regulatory Guide 1.149 Nuclear Power Plant Simulation Facilities for Use in Operator License Examinations
D-1 Revision 1.
April 1987 U.S. NUCLEAR REGULATORY COMMISSION
REGULATORY GUIDE
OFFICE OF NUCLEAR REGULATORY RESEARCH
REGULATORY GUIDE 1.149 (Task OL 402-5)
USE
NUCLEAR POWER PLANT SIMULATION FACILITIES FOR
IN OPERATOR LICENSE EXAMINATIONS
A. INTRODUCTION B. DISCUSSION
Paragraph 55.45(a) of 10 CFR Part 55, "Operators' Although ensuring that individuals who receive opera- tor or senior operator licenses possess the knowledge, Licenses," requires that an applicant for an operator or skills, and abilities necessary to operate the facility in a senior operator license demonstrate both an pnderstand- safe manner is the responsibility of facility licensees, the ing of and the ability to perform certain essential job Nuclear Regulatory Commission must perform an inde- tasks. Paragraph 55.45(b) specifies that these operating pendent audit of this process through its operator tests will be administered, in part, either in a simulation licensing examinations. Section 55.45, "Operating Tests,"
facility consisting solely of a plant-referenced simulator of 10 CFR Part 55 requires the candidate for a license that has been certified to the Commission by the to demonstrate (1) an understanding of and the ability facility licensee or in a simulation facility approved by to perform the actions necessary during normal, abnor- the Commission 1 after application has been made by the facility licensee. mal, and emergency situations; (2) the operation of systems that affect heat removal or reactivity changes;
This regulatory guide describes a method acceptable and (3) behaviors that show the individual's ability to function within the control room team in such a way to the NRC staff for complying with those portions of that the facility licensee's procedures are adhered to and the Commission's regulations regarding (1) certification of a simulation facility consisting solely of a plant- that the limitations in its license and amendments are not violated.
referenced simulator and (2) application for prior ap- proval of a simulation facility.
The use of a plant-referenced simulator for testing enables the examiner to evaluate a candidate's perfor- The Advisory Committee on Reactor Safeguards has mance in an environment closely correlated with condi- been consulted concerning this guide and has concurred in the regulatory position. tions in the specific plant for which that candidate has applied for a license. With major facility differences minimized between the testing and operating environ- Any information collection activities mentioned in ments, examiners have been able. to make pass-fail this regulatory guide are contained as requirements in judgments with confidence.
those sections of 10 CFR Part 55 that provide the regulatory basis for this guide. The information collec- Although the increased use of plant-referenced simu- tion requirements in 10 CFR Part 55 have been cleared lators has provided to examiners the capability for under Clearance No. 31504018 and No. 3150-0138. better discrimination between success and failure in a The substantial number of changes In this revision has made It candidate than could be achieved with non-plant- impractical to indicate the changes with lines in the margin.
referenced simulators, the staff recognizes the existence
'A simulation facility is defined in § s55A as usedone or more of the for the partial of several factors that could suggest the use of alterna- following components, alone or in combination,senior operators and candi- tive systems or devices for conducting the non- conduct of operating tests for operators, dates (i)the lant, (H) a pIant-eferenced simulator,(il) another walkthrough portions of operating tests. These factors simulauion duice USNRC REGULATORY GUIDES The guides are Issued In the following ten broad divislOns:
Regulatory Guides are issued to describe and make available to the 1 Power Reactors 6. Products NRC staff of implementing public methods acceptable to the regulations, 2. Research and Test Reactors 7. Transportation specific parts of the Commlssion's, to delineate tech- 3 Fuels end Materials Facilities aS. Occupational Health niques used by the staf In evaluating specific probiems or postu- 4. Environmental and Siting g, Antitrust and Financial Review ated acidents or to rovide guidance to appicants Regulatory and compliance with 5. Materiasand Plant Protection 10. GeneraI
Guids are noX substitutes for regulations,different from those set them is not requird. Methods and solutions they provide a basis for the from the Government out In the guides will be acceptableorIf continuance of a permit or Copies of Issued guides may be purchased on current findings rquisite to the issuance current GPO price. Information Printing Office atbetheobtained GPO prices may by contacting the Superintendent of Government Printing Office. Post Office Box comments received from Documents, U.S. or This guide was issued after consideration of for improvements In these 37082. Washington, DC 20013-7082, telephone (202)275.2060
the public. Comments andallsuggestions times. and guides will be revised, as (202)275-2171.
guides are encouraged at Informs- apropriate. to accommodate comments and to reflect new from the National Technical Issued guides may also be purchased norexperericlonaetadiceode Information ServiMce on a sanding Order b sis Details on this Written comments may be submitted to the Rules and Procedures Royal Road, Commission, service may be obtained by writing NTIS. 5285 Rort Branch. OARR ADM, U.S. Nuclear Regulatory Springtbild, VA 22161.
Washington. 0C 20555.
D-2 include the cost and lead time associated with procure- ment or upgrading of a plant-referenced simulator. Morem to ensure the continued acceptability of the simulation over, rapidly changing technology in the simulation indus- facility. These malfunctions, if applicable to the facility, try is resulting in previously unavailable options should be tested in their entirety not less than could lead a facility licensee to seek alternative waysthat every to four years, approximately 25% per year. When meet the requirements of §55.45. ANSI/ANS-3.5-1985, con- ducted in addition to the tests required by Section
5.4
"Nuclear Power Plant Simulators for Use in Operator and when subjected to the performance criteria Training" 2 (the standard), in conjunction transient operations specified in Section 4.2, "Transient for with this regulatory guide, provides guidance in these areas. Operation," these malfunction tests provide an accept- able means of demonstrating the performance and C. REGULATORY POSITION operability of the simulation facility.
Requirements are set forth in ANSI/ANS-3.5-1985 for 6. Appendix A to the standard, "Guide for Document- specifying minimum performance and configuration cri- ing Simulator Performance," and Appendix B to the teria for a simulator, for comparing a simulator to standard, "Simulator Operability Tests," should be its con- reference plant, and for upgrading simulators to reflect sidered integral parts of the standard.
changes to reference plant response or control room configuration. These requirements provide a method D. IMPLEMENTATION
acceptable to the NRC staff for a facility licensee (1)
to certify a simulation facility consisting solely of a plant- The purpose of this section is to provide information referenced simulator or (2) to obtain approval of to facility licensees about the NRC staff's plans for a using simulation facility for use in portions of reactor opera- this regulatory guide.
tor and senior operator license examinations subject to the following: In accordance with the requirements in §55.45
10 CFR Part 55, the simulation facility portion of of
1. The references to operator training in Section 1, operating test will not be administered on other than the an
"Scope," of the standard should be taken to apply approved or a certified simulation facility after:
to operating tests for operators; senior operators, and candidates.
1. The facility licensee has submitted a certification
2. Simulation facilities as defined in §55.4 of 10 CFR in accordance with paragraph 55.45(bX5)(i), or Part 5S, to the extent that the facility licensee applies for approval under the requirements of paragraph 55.45(b), 2. The staff has approved an application submitted should meet the applicable requirements of the standard. by the facility licensee in accordance with paragraph
55.45(bX4), or
3. The standard identifies in Section 1.1, "Background,"
other documents to be included as part of the standard. 3. May 28, 1991, whichever occurs sooner.
The applicability of one of these documents, ANSI/
ANS-3.1,2 should be determined by referring to Revi- Until that time, the NRC will continue to give exami- sion 2 to Regulatory Guide 1.8, "Qualification and nations for a facility licensee's reference plant in accord- Training of Personnel for Nuclear Power Plants." ance with Generic Letter 82-18, "Reactor Operator and Senior Reactor Operator Requalification Examinations," 3
4. Section 5.2, "Simulator Update Design Data," re- October 12, 1982.
quires that reference plant modifications be reviewed annually against the simulator and that the simulator Licensees and applicants may propose means other update design data be revised as appropriate. This than those specified in Section C of this guide for meeting should be taken to mean that the first such annual applicable regulations. Except in those cases in which a
review and update should take place within one year facility licensee submits a certification for its simulation following the facility licensee's certification as specified facility or proposes an acceptable alternative method for in paragraph 55.45(b)(5Xi) or within 18 months follow- complying with specified portions of the Commission's ing the submittal of the application for approval regulations, the NRC will use the method described as in specified in paragraph 55.45(b)(4)(i). this guide in the evaluation of the application approval submitted by the facility licensee for its simula- for
5. Section 5A, "Simulator Testing," requires the con- tion facility. The guidance provided in Section C has duct of specific tests to establish simulator performance been approved for use by the staff in the evaluation of and verify its operability. IJn addition to these proce- all submittals as an acceptable means of complying with dures, applicable malfunctions, identified in Section the Commission's regulations specified in Section A.
3.1.2, "Plant Malfunctions," should be periodically tested If a facility licensee wishes to utilize a simulation facility for more than one nuclear power plant, it
2 must Copies may be obtained from the
555 North Kensington Avenue, La GrangeAmerican Nuclear Society, Park, IL 60525.
3 Avaflable for copying for a Publc Document Room, 1717 H fee or inspection at the NRC
Street NW., Washington, DC.
1.149-2
D-3 its 2. Technical specifcations;
demonstrate to the NRC in its certification or in between the plants are application that the differences the not so significant that they have an impact on 3. Procedures, primarily abnormal and emergency ability of the simulation facility to meet the require- operating procedures;
ments and guidance of ANSI/ANS-3.5-1985 as qualified in this regulatory guide for each of the plants. This demonstration should include an analysis and summary 4. Control room design and instrument/control loca- of the differences between each plant and the simula- tion; and tion facility, including:
1. Facility design and systems relevant to control S. Operational characteristics.
room personnel;
1.149-3
D-4 '-I
VALUE/IMPACT ANALYSIS
A separate value/impact analysis has not pared for this regulatory guide. A value/impactbeen pre- Room at that time. This analysis is also appropriate to analysis Revision I of Regulatory Guide 1.149. A
was included in the regulatory analysis for copy of the the amend- regulatory analysis is available for inspection ments to 10 CFR Part 55 published on March and a copy of which was placed in the Public
25, 1987, ing for a fee at the NRC Public Document copy- Document 1717 H Street NW., Washington, DC. Room,
1.149-4
Appendix E
Regulatory Guide 1.8 Qualification and Training of Personnel for Nuclear Power Plants
l- ~E-1 Revision 21 U.S. NUCLEAR REGULATORY COMMISSION April 1987 REGULATORY GUIDE
OFFICE OF NUCLEAR REGULATORY RESEARCH
REGULATORY GUIDE 1.8
-Task OL 403.6)
QUALIFICATION AND TRAINING OF PERSONNELFOR NUCLEAR POWER PLANTS
A. INTRODUCTION training of nuclear power plant personnel. This standard was approved by the American National Standards Paragraph S0.34(bX6Xi) of 10 CFR Part 50, "Domestic Institute (ANSI) Committee N18, Design Criteria for licensing of Production and Utilization Facilities," requires Nuclear Power Plants, and--designated ANSI N18.1-1971, that an application for a license to operate a nuclear "Selection and Training of Nuclear Power Plant Person- power plant include information concerning organizational neL." Regulatory Guide 1.8, "Personnel Selection and structure, personnel qualifications, and related matters. Training," endorsing ANSI N18.l-1971, was issued in Subpart D, "Applications:' of 10 CFR Part 55, "Operators' March 1971, and Revision I was issued in September Licenses," requires that operator license applications 1975. A revision of ANSI N18.1-1971 was subsequently include information concerning an individual's education approved by the ANSI Board of Standards Review and and experience and related matters. This regulatory guide designated ANSIWANS-3.1-1978, "Selection and Training describes a method acceptable to the NRC staff for of Nuclear Power Plant PersonneL"
complying with those portions of the Commission's regulations with regard to the training and qualifications A first proposed Revision 2 to Regulatory Guide 1.8 of nuclear power plant personnel. Personnel of test, endorsing ANSI/ANS-3. 11978 was issued for public training, research, and mobile reactors are pot covered comment in February 1979. As a result of experience by this regulatory guide. gained from the accident, at Three Mile Island Unit 2 (TMI-2), additional public comments in the area of The Advisory Committee on Reactor Safeguards has personnel ,qualifications were requested. on proposed been consulted concerning this guide and has concurred Revision 2 to Regulatory Guide 1.8 in May 1979. All in the regulatory position. of the comments from both, requests were forwarded to the ANS-3 Subcommittee for Its use during the develop- Any information collection activities mentioned in ment of a revision to ANSI/ANS-3.1-1978. Subsequent- this regulatory guide are contained as requirements in ly, Draft Standard ANS 3.1, dated December 6, 1979,
10 CFR Parts 50 and 55, which provide the regulatory incorporating the upgraded requirements was issued. In basis for this guide. The information collection require- September 1980, public comments were requested on a ments in 10 CFR Part 50 have been approved under second proposed Revision 2 to Regulatory Guide 1.8 OMB Clearance No. 3150il, those in 10 CFR Part that endorsed Draft Standard ANS 3.1. The public comments received were held in abeyance pending
55, under OMB Clearance No. 3150-0018.
Commission action on proposed rules on operator B. DISCUSSION qualifications and licensing in SECY 81-84, "Qualifica-
~
mittee Reco ~ ; .N3 tion of 'Reactor Operators,"l February 2, 1981, and Subcommittee ANS-3, Reactor Operations, American SECY 8li-84A, '"Discussion of Revisions to Reactor Nuclear Society Standards Committee, 'developed a Operator Qualifications," 1 June 15, 1981. The Commis- standard containing criteria for 'the qualification and sion did not approve either of these 'proposals and directed the staff to continue to study the 'issue.
1 The substantial number of changes In this revision has made It Coples are available for inspection or copying oratee In the Impractical to indicate the changes with lines In the margin. NRC Public Document Room, 1717 H Street NW., Washington, DC.
USNRC REGULATORY GUIDES The guides are Issued In the following ten broad divisions:
Regulatory Guides are Issued to describe and make available to the 6. Products pubic methods acceptable to the NRC staff of Implementing 1. Power Reactors pecific Parts of the CommIssion's regulations, to delineate tech- 2 Research and Test Reactors 7 Transportation nkaues used by the staff In evaluating specific problems or postu- 3 Fuels and Materials Facilities 6C Occupational Health ated accidents or to provide guidance to applkcants "Regulatory 4. Environmental and Siting 9 Antitrust and Financial Review Guides ar no substitutes for regulations, and compliance with S. Materials and Plant Protection 10. General them Is not required. Methods and solutions different from those set out In the guides will be acceptable It they provide a basis for the Copies of Issued guIdes may be urchased from the Government findings requisite to the issuance or continuance of a permIt or PrInting Office at the current GIO price. Information on current license by the CommissIon. GPO Prices may te obtained by contacting the Superintendent of Documents. US Goverment Printing O ce. Post Office Box This guide was issued after consideration of comments received from 37082, sington DC 20013 702 telephone (202)275-2060 or the public. Comments and suggestions for Improvements In these (22)7-11
guides are encouraged at all times, and guides will be revised, as
- ppropriate, to accommodate comments and to reflect new Informa- tion or experience. Issued guides may also be purchased from the National Technical Written comments may be submitted to the Rules and Procedures information Service on a standing order basis Details on this Branch, DRR ADM U.S. Nuclear Regulatory Commission. servIce may be obtained by writing NTIS. 5265 Rort Royal Road, Washington. Do 20555. Springfield, VA 22161.
E-2 During 1981, Draft Standard ANS 3.1 was updated to 10 CFR Part 50) and the requirement to have a shift factor in additional lessons learned from the TMI-2 technical advisor (STA) available to the shift (NUREG-
accident and changing regulatory requirements. The 0737, LA.1.1). One option in the Policy Statement, standard was approved by the American Nuclear Society's which is preferred by the Commission, allows combining Nuclear Power Plant Standards Committee (NUPPSCO) the functions of the STA with one of the required senior and the ANSI Board of Standards Review and was operators as long as specific training and education reissued as ANSI/ANS-3.1-1981, "Selection, Qualification requirements are met. The other option allows for con- and Training of Personnel for Nuclear Power Plants." 2 A tinuation of an approved independent STA program.
third proposed Revision 2 of Regulatory Guide 1.8 was Regulatory Position C.j reflects the guidance provided developed to endorse ANSI/ANS-3.1-1981 with certain in this Policy Statement.
additions and exceptions and was issued for public com- ment in January 1985. As a result of the public com- C. REGULATORY POSITION
ments and Commission actions concerning training and qualifications, this Revision 2 of Regulatory Guide 1.8 1. Positions in ANSI/ANS-3.1-1981 that Are Endorsed now endorses Sections 4.3.1.1, "Shift Supervisor," 4.3.1.2, by this Regulatory Guide
"Senior Operator," 4.5.1.2, "Licensed- Operators," 4.4.8,
"Shift Technical Advisor," and 4.4.4, "Radiation Protec- For the positions listed in ANSI/ANS-3.1-1981, tion," of ANSI/ANS-3.1-1981. Endorsement for all other "Selection, Qualification and Training of Personnel for positions will remain with ANSI N18.1-1971, "Selection Nuclear Power Plants," as shift supervisor, senior opera- and Training of Nuclear Power Plant PersonneL" The tor, licensed operator, and shift technical advisor, the bases for the additions and exceptions to ANSI/ANS-3.1- requirements contained in the standard provide an
1981 are contained in NUREG-0737, "Clarification of approach acceptable to the NRC staff for complying with TMI Action Plan Requirements," 3 which includes the the qualifications and training requirements of 10 CFR
March 28, 1980 letter to all power reactor applicants Parts SO and 55 subject to the guidance regarding the and licensees regarding qualification of reactor operators, STA function provided in the Commission's "Policy and NUREG-0094, "Guide for the Licensing of Facility Statement on Engineering Expertise on Shift" and the Operators, Including Senior Operators,'4 and the Commis- clarifications, additions, and exceptions in paragraphs a sion's "Policy Statement on Engineering Expertise on through k below. For radiation protection supervisory Shift" (50 FR 43621) The regulatory position related personnel, Section 4.4.4 of the standard contains an to the radiation protection manager is revised from what approach acceptable for the position of radiation protec- was included in Revision I of Regulatory Guide 1.8 (1975). tion manager (RPM) subject to the following:
The industry has adopted the requisite qualifications in ANSI/ANS 3.1-1981, and the current change endorses a. In lieu of the description in Section 5.1 of ANSI/
that industry position. ANS-3.1-1981, cold license examinations should be defined as those that are administered before the unit has com- On March 20, 1985, the Commission issued a "Policy pleted preoperational testing and initial operations as Statement on Training and Qualification of Nuclear described in its Final Safety Analysis Report as amended Power Plant Personnel" (50 FR 11147) that recog- and approved by the Commission. Hot examinations are nizes industry commitment to accredit training pro. those administered after this condition is attained.
grams. In the policy statement, the NRC endorsed the training accreditation program managed by the Institute b. Hot license applicants must meet the training of Nuclear Power Operations (INPO) because it encom- elements in Sections 4.3.I.l.c, 4.3.1.2.c, and 4.5.1.2.c of passes the elements of performance-based training and the standard and the experience elements in Sections will provide the basis to ensure that personnel have 4.3.1.1.b, 4.3.1.2.b, and 4.5.1.2.b of the standard. Cold qualifications commensurate with the performance re- license applicants are subject to the training elements quirements of their jobs. The Commission has decided identified above, but they are exempt from the expe- to withhold action on promulgating new training and rience elements.
qualifications regulations during an evaluation period.
During that period, NRC will- continue to evaluate the c. Paragraph 2 of Section 4.3.1.1.a of ANSI/ANS-3.1- results of the accreditation program to determine if the 1981 is not applicable. An individual who meets the voluntary industry efforts ensure qualifications that meet Commission's "Policy Statement on Engineering Expertise or exceed the minimum standards included in this guide. on Shift" is required on all shifts to provide engineering expertise (see Regulatory Position C.Ij).
The Commission's "Policy Statement on Engineering Expertise on Shift" issued on October 28, 1985 (50 FR d. The minimum educational requirement for shift
43621) provides two options for meeting nuclear power supervisors, Section 4.3.1.1.a, and for senior operators, plant staffing requirements (paragraph 50.54(mX2Xi) of Section 4.3.1.2.a, is a high school diploma or equivalent.
2 Coples may be obtained from the American Nuclear Society, e. An applicant for a senior operator (SO) license
555 North Kensington Avenue, LaGrange Park, IL 60525. should have 4 years of responsible power plant exper- Post e may be obtained from the Government Printing Office, ience. Responsible power plant experience for an SO is Post Offlo Box 37082, Washington, DC 20013-7082. defined as having actively performed as a designated
1.8-2
E-3 control room operator (fossil or nuclear) or as a power STA has not actively performed, the STA should receive plant staff engineer involved in the day-to-day activities training sufficient to. ensure that the STA is cognizant of of the facility during or after the final year of construc- facility and procedure changes that occurred during the tion. A maximum of 2 years of responsible power plant absence.
experience may be fulfilled by academic or related tech- nical training on a one-for-one time basis. Two years should Combining the functions of a senior operator and the be nuclear power plant experience. At least 6 months of STA is acceptable if the provisions of the Commission's the nuclear power plant experience should be at the "Policy Statement on Engineering Expertise on Shift"
plant for which an applicant seeks a license. In addition, are met. In addition to the requirements specified in applicants for an SO position not holding a bachelor's Section 4.4.8.c of ANSI/ANS-3.1-1981, the STA should degree in engineering or equivalent should have held an have specific training in the response to and analysis of operator's license and should have been actively involved plant transients and accidents and training in the rela- in the performance of licensed duties for at least 1 year. tionship of accident conditions to offsite consequences and protective action strategies.
f. In addition to the requirements stated in Section
5.2.1.2.1 of ANSI/ANS-3.1-1981, classroom instruction k. The radiation protection manager should have the for all license applicants should include training in the qualifications described in Section 4.4.4 of ANSI/ANS-
use of installed plant systems for the control and mitiga- 3.1-1981 with the clarification that 3 of the 4 years of tion of an accident in which the core is severely damaged. experience in applied radiation protection should be professional-level experience.
g. In addition to the requirements in Section 5.2.1.3.1 of ANSI/ANS-3.1-1981, each applicant for an operator or 2. Positions in ANSI/ANS N18.1-1971 that Are Endorsed senior operator license should serve 3 months as an extra by this Regulatory Guide person on shift in training for that position. These 3 months as an extra person on shift in training should For positions listed in the standard other than those include all phases of day-to-day operations under the under Regulatory Position I above, the requirements con- supervision of licensed personnel. tained in ANSI N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel," provide an approach h. Control room operating experience for hot license acceptable to the NRC staff for complying with the quali- applicants, described in Section 5.2.1.3.1 of ANSI/ANS- fications and training requirements of 10 CFR Parts 50
3.1-1981, should include manipulation of controls of the and 55.
facility during a minimum of five reactivity changes. Every effort should be made to have a diversity of reactivity D. IMPLEMENTATION
changes for each applicant. Startups, shutdowns, large load changes, and changes in rod programming are some exam- The purpose of this section is to provide information ples and could be accomplished by manually using such to applicants and licensees regarding the NRC staff's systems as rod control, chemical shim control, or recircu- plans for using this regulatory guide.
lation flow.
Applicants and licensees may propose means other i. All cold license applicants should participate in than those specified in Section C of this guide for meet- practical work assignments as described in Section 5.2.1.4 ing applicable regulations.
of ANSI(ANS-3.1-1981 for a minimum of 6 months.
j. In addition to the responsibilities described in Sec- Except in those cases in which the applicant or licensee tion 4.4.8 of ANSI/ANS-3.1-1981, the STA should assume proposes an acceptable alternative means of complying an active role in shift activities. For example, the STA with the Commission's regulations specified in Section A,
should review plant logs, participate in shift turnover, the guidance provided in Section C has been approved and maintain awareness of plant configuration and status. for use by the staff after March 31, 1988, in the evalua- The educational requirements for the STA specified in tion of the qualifications and training requirements for Section 4.4.8.a of ANSI/ANS-3.1-1981 are not appli- (1) nuclear power plant personnel as described in appli- cable. An independent STA should have, a bachelor's cations for .an operating license, (2) applicants for opera- degree or equivalent in a scientific or engineering discipline. tor and senior operator licenses, and (3) replacement personnel in those positions in operating nuclear power
"Actively performing STA functions" means perform- plants whose training programs have not yet been accred- ing at least three shifts per quarter as the STA. If an ited by an accreditation program endorsed by the NRC.
1.8-3
E-4 VALUE/IMPACT ANALYSIS
A separate value/impact analysis has not been prepared that time. This analysis is also appropriate to Revision 2 for this regulatory guide. A value/impact analysis was of Regulatory Guide 1.8. A copy of the regulatory anal- included in the regulatory analysis for the amendments to ysis is available for inspection and copying for a fee at
10 CFR Part 55 published on March 25, 1987, a copy the NRC Public Document Room, 1717 H Street NW.,
of which was placed in the Public Document Room at Washington, DC.
1.8-4
. A~- - --- - - ---
NRC FORM U.S. NUCLEAR REGULATORY COMMISSION NUMBER AssigwdbVTIOC. ad rVioN.. If" t -,7 NRCM 1102. BI BLIOGRAPHIC DATA SHEET
3202 N201 O E .
SEEINSTRUtCTIONS ON THE REVERSE. NUREG-1262
2 TITLE AND SUBTITLE 3. LEAVE BLANK --
Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code of Federal Regulations, Part 55-on Operatorst Licenses '4 DATE REPORT COMPLETED
MONTH - YEAR
S.AUTHORtS) -November 1987
.6DATEREPORTISSUED .
MONTH 197 YEAR,
November @ 1987
7. PERFORMING ORGANIZATION NAME AND MAILING ADDRESS Ulwci Zro Cd) S. PROJECTITASK/WORK UNIT NUMBER
Division of Licensee Performance and Quality Evaluation _
Office of Nuclear Reactor Regulation 9. FIN OR GRANT NUMBER
U. S. Nuclear Regulatory Commission Washington, DC 20555
10.SPONSORING ORGANIZATION NAME AND MAILING ADDRESS IInOWch ZS Codru 11. TYPE OF REPORT
Division of Licensee Performance and Quality Evaluation Question and Answer Office of Nuclear Reactor Regulation rPnd Answe U. S. Nuclear Regulatory Commission bPERIODCOVERED ,lnuui4ru Washington, DC 20555
12 SUPPLEMENTARY NOTES
13. ABSTRACT (2W P01* or ftu This document presents questions and answers based on the transcripts of four public meetings (and from written questions submitted after the meetings) conducted from April 9 to April 20, 1987 by the staff of the U. S. Nuclear Regulatory Commission. The meetings discussed implementation of the Commission's final rule governing Operators'
Licenses and Conforming Amendments (10 CFR Parts 55 and 50), The rule became effective May 26, 1987 and is intended to clarify the regulations for issuing licenses to operators and senior operators; revise the requirements and scope of written examinations and operating tests for operators and senior operators, including a requirement for a simulation facility; clarify procedures for administering requalification examinations:
and describe the form and content for operator license applications.
IS. AVAILABILITY
14. DOCUMENT ANALYSIS - a.KEYWORDSIDESCRIPTORS STATEMENT
Nuclear Power Unlimited IS. SECURITYCLASSIFICATION
(This pope)
b. IDENTIFIERSIOPEN-ENDED TERMS
Operator Licenses (Ta, We'Q,)
10 CFR Parts 50 and 55 __?.U _BE _OF _AGE
Simulation Facilities Requalification Examinations 18 PRICE
- U.S.GGVERNMENT PRINTING WrVcEI1987-2O2-292i60299
4.
LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of Letter No. Subject Issuance Issued To GL B7-16 NUREG-1262, "ANSWERS TO 11/12/87 ALL POWER AND
QUESTIONS AT PUBLIC MEETINGS NONPOWER
RE IMPLEMENTATION OF 10 CFR55 REACTOR
ON OPERATORS LICENSEES AND
LICENSES APPLICANTS FOR
LICENSES
GL 87-15 POLICY STATEMENT ON DEFERRED 11/04/87 ALL HOLDERS OF
PLANTS CONSTRUCTION
PERMITS FOR A
NUCLEAR POWER
PLANT
GL 87-14 REQUEST FOR OPERATOR LICENSE 08/04/87 ALL POWER
SCHEDULES REACTOR
LICENSEES
GL 87-13 INTEGRITY OF REQUALIFICATION 07/10/87 ALL NON-POWER
EXAMINATIONS AT NON-POWER REACTOR
REACTORS LICENSEES
GL 87-12 50.54(f) LETTER RE. LOSS OF 07/09/87 ALL LICENSEES
RESIDUAL HEAT REMOVAL (RHR) OF OPERATING
DURING MID-LOOP OPERATION PWRS AND
HOLDERS OF
CONSTRUCTION
PERMITS FOR
PWRS
GL 87-11 RELAXATION IN ARBITRARY 06/23/87 ALL OPERATING
INTERMEDIATE PIPE RUPTURE LICENSEES,
REQUIREMENTS CONSTRUCTION
PERMIT
HOLDERS, AND
APPLICANTS FOR
CONSTRUCTION
PERMITS
GL 87-10 IMPLEMENTATION OF 10 CFR 06/12/87 ALL POWER
73.57, REQUIREMENTS FOR FBI REACTOR
CRIMINAL HISTORY CHECKS LICENSEES
GL 87-09 SECTIONS 3.0 AND 4.0 OF THE 06/04/87 ALL LIGHT
STANDARD TECHNICAL WATER REACTOR
SPECIFICATIONS ON THE LICENSEES AND
APPLICABILITY OF LCO AND APPLICANTS
SURVEILLANCE REQUIREMENTS
GL 87-08 IMPLEMENTATION OF 10 CFR 73.55 05/11/87 ALL POWER
MISCELLANEOUS AMENDMENTS AND REACTOR
SEARCH REQUIREMENTS LICENSEES
- 2 -
In addition to the above changes from the original answers desc e n NUREG-1262, as of the date of this letter NRC involvement in qualification examinations is under review, and changes to the guidance sented at the public meetings is being considered. Therefore, answers iven in the section titled "Requalifica ion and Renewal" should be conside d subject to change.
If you have any quest s, you should contact the NK Project Manager for your facility.
Sincerely, Enclosure: NUREG 1262 rank 3 Miraglia A soc te Director for Projects DISTRIBUTION: Of i of Nuclear Reactor Regulation Central Files JAWachtel LAWiens JNHannon JWRoe FJMiraglia RStarostecki DW/nereg 1262/ RRY3
0u'1
&B:D PQ OLB:DLPQ OLB:DLPQ DIRW-LrQ ADITA:NRR ADP: lR
JAWachtel:kw LAWiens JNHannon JWRoe RStarostecki FJMirabia
9 @ /87 9/ef/87 9/7,1/87 /0/7/87 9/ /87 9/ /87 \
q OFFICIAL RECORD COPY