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Answers to Questions at Public Meetings Regarding Implementation of Title 10,CODE of Federal Regulations,Part 55 on Operators' Licenses
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Issue date:	11/30/1987
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	NUREG-1262, NUDOCS 8712230304
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NUREG-1262 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 panovy kh N m a r 11 :, 1262 R

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                     .    -..                                              ...F, NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

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Washington, DC 20555

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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, circulani, 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. , 1 1 i

NUREG-1262

Answers to Questions at l Public Meetings Regarding Implementation of itle 10, Code of Federal Regulations, ,

       .Part 55 on Operators' Licenses                                          j l

teIu hed ov ber Division of Licens.ae Performance and Quality Evaluation , Office of Nuclear Reactor Regulation f U.S. Nuclear Regulatory Commission Washington, DC 20666 i y"'%,,, 6

                                       ~ 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, i

1 1 l iii !

 .2 a

TABLE OF CONTENTS P,,,ag iii !

    . ABSTRACT .............................................................
    ' 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) ...........                      7 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) ................................................

Written Examinations and Operating Tests (Statement of 31 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, 1 Section 55.47) ................................................ 41 i SIMULATION FACILITIES ................................................ 42

          -Written Examinations and Operating Tests: Implementation 42
                       ~

(Subpart E, Section 55.45(b)) ................................. Regulatory Guide 1.149 ............................... .......... 50 ANSI /ANS 3.5, 1985 .............................................. 52

Simulation Facility Certification (Including Performance Testing, NRC Form 474, NUREG-1258) ............................ 55 v

1 TABLE OF CONTENTS (Continued) Page LICENSES ............................................................. i 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) ..................

i l 82 Requalification (Subpart H, Section 55.59) ...................... 88 -CONFORMING AMENDMENTS IN 10 CFR PART 50 .............................. 115 ! OPERATOR LICENSING EXAMINER STANDARDS (NUREG-1021) ................... 117 i REFERENCES ................... ....................................... APPENDICES 122 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 ........ 0-1 E Regulatory Guide 1.8 -- Qualification and Training for Personnel for Nuclear Power Plants . . . . . . . . . . . . . . . . . . . . . . . . . E-1 1 vi

3 I I PREFACE I On March 25, 1987, the U.S. Nuclear Regulatory Commission published in the j 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

l 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 manipulating 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- i strative controls which assure that functions and duties are divided and rotated in a manner which provides each watchstander meaningful and significant oppor-i tunity tor and/or senior operator as appropriate.toNormally, maintainmore proficiency than oneinadditional the performance of th! 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 l 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 i General Counsel under 10 CFR 55.6, the NRC staff may provide informal. guidance 'I as needed and as appropriate. This report does not impose any requirements on facility licensees nor does it replace or supersede any existing regulations. I l II INTRODUCTION i 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

l Utility Management and Resources Committee (NUMARC) and the Institute for Nu-clear Power Operations (INP0), 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. 1his 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. f l i INP0 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 In past, NRC has placed great importance in the INP0 accreditation process. its review of INP0 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 The and, when exercise of requested, further review was conducted at NRC headquarters. 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 dcys. 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. i 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 reapplyThe under the provisions of 10 CFR 55.12 until he has a final denial in hand. 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. The review process as outlined is currently under staff review for ways in which it can be expedited. 1 xi

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I ACROMYMS AND INITIALISMS ANS American Muc. lear Society i

  ~ ANSI      American National Standards Institute l

B0P Balance of Plant BWR Boiling Water Reactor CE Combustion Engineering CRD Control Rod Drive DLPQE Division of Licensee Performance and Quality Evaluation- ) E0P Emergency Operating Procedure ES Examiner Standard FSAR Final Safety Analysis Report GE ' General Emergency IE Office of Inspection and Enforcement (NRC)

 -INP0        Institute of Nuclear Power Operations K/A         Knowledge and Abilities-LER         Licensee Event Report NLO        Nonlicensed OperatorL 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 R0 Reactor Operator RWP Radiation Work Permit SAE Site Area Emergency SAT Systematic (or Systems) Approach to Training SFEP Simulation Facility Evaluation Procedure SR0 Senior Reactor Operator STA Shift Technical Advisor Tech Specs Technical Specifications TSD Training System Development UE Unusual Event xvi l

GENERAL ISSUES PERTAINING TO 10 CFR PART 55

i 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 Genton 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 and Denton's letter, and it's still in Regulatory Guide 1.8 and NUREG-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 shif ts that an STA must serve. So, nothing in this regulation affects these commitments even though there is i 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. NUREG-1262 1

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 R0 and the SR0 super-seded by this change? A. No. NUkEG-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.

                                                                                      ' s 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 INP0 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 INP0 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 t'olicy State-ment shall limit the authority or responsibility of the NRC to fo' low up on operational events or place any limit on NRC's enforcement authority when l , regulatory requirements are not met." NUREG-1262 2 r

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, wo~'d be considered satisfactory for multiple units or plants. If your operato s a o not dual-licensed, it is still possible to certify with exceptions, 61t% ogh 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?

NUREG-1262 3

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 tha't 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 INP0-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, cm 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 function because he understands what he is doing -- he has either had the systems training, or he's had the theory train-1 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 af ter 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

l l 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 INP0 accreditation process and criteria. If you look at the objectives in INP0 85-002 for on-the-job training, you will find that they intend that the person adequately understand the task before performing it. l Q. 23. Can trainees manipulate facility controls under the appropriate super-vision of licensed personnel? 1 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. NUREG-1262 5

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. l l NUREG-1262 6

I. l i APPLICATIONS l 1 i s am i s isa_,.. i

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 SR0 beyond meeting the requirements of an accredited SR0 training program?

A; He must submit completed Forms 398 and 396 and'be examined as an SR0. 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 INP0-accredited program with an acceptabie 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 INP0 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 i also adjusted the requirements for resuming an active license to six hours of parallel watch-standing. j Q. 34. I understand that the designation of the authorized representative for a facility is changing, gIs that true? A. We will accept, as the authorized representative, the senior individual on site responsible for operations. Some companies have a vice president on site, some have a site manager. Others may choose to designate someone at a higher NUREG-1262 7 l

l level, and send it off site to the corporate office. That is acceptable to us. 3 It is also acceptable for it to be done on site. It need not be the same y 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. I Please note a new requirement on Forms 396, 474, and 398. Above the signature k 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. L 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 R0 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 INP0-accredited program and a simulation f acility 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. NUREG-1262 8

I 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 requirements are in effect unless superseded by the rule, until the training program is accredited. l 1 Q. 40. Is accreditation by INP0'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, 1 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 you are 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 INP0 standards? A. It's both. The Commission has specifically endorsed the INP0 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. j 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 INP0 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 adequal.ely cover the material, and therefore, it need not be bac k-fi t. 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. NUREG-1262 9 ; i

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?                                                           j A.         No. For accredited programs,.the particular evaluation, feedback and modification of your program is part of the process. For those programs-that                                        i 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.                                                                                          j 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 INP0-accredited training programs be required to submit these programs to the NRC for approval? A. No. Programs that have been accredited by INP0 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 INP0-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 INP0 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 INP0-accredited 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 INP0-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 accredited programs 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 conments 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 eitner left to the utility to resolve with INP0 or, if they were of a more severe nature, we might ask for a performance-based inspection. Depending on the results of that in-spectior., 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

j. 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?

1 A. No. This will not be continued. The Form 398 will be revised to remove the words "or will have." NUREG-1262 11 ,

t 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 INP0 accreditation for NRC approval, while Mr. Denton's Generic letter 87-07 requires that the traini~ng 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 INP0 guidelines, and not upon the INP0 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 INP0-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 INP0-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. loclarify,ifautilityhasaprogramthathasbeenaccreditedbyINPO,weex-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 i now the standard of record with NRC. If you 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

1

l l 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 j NUREG-1220, or you could propose that you have done it in accordance with the i TSD process, which INP0 is using. If you show that it's comparable to that, we l would also consider it. That is a vehicle for getting a Commission approval of j a performance-based or SAT-based program on a case-by-case basis for a cold i i plant. We don't mean to exclude you from being able to do performance-based trair ing. 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 f 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 a.nd 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 l 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. Is there any difference between an " approved simulation facility" and a Q. 59. " 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? I NUREG-1262 14

I 1 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 f ar as the five significant control manipulations are concerned, what's going to constitute evidence? A. Documentation on the 0JT qualification cards consisting of a simple "per-formed" code next to the sianature 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. I ( A. This applies only to a hot license. If the individual has not had the opportunity to perform control manipulations on shift because of an extended shut 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 Y__-____-____-_ - -__

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 INP0-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 l chief examiner to determine which initial license candidates will be audited. l 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. l 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-j 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 INP0 guidelines 86-025 and 86-026. We are aware that INP0 guideline 83-022 "PWR Control Room Operator, Senior Control Room Operator and Shift Supervisor

 -Qualification" does contain the three months on shift training period.                                        l 1

NUREG-1262 16

Q. 73. Reg Guide 1.8 endorses ANSI /ANS 3.1 for R0s and SR0s. 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, j 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- I 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. I 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 INP0-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 INP0-accredited program and an NRC-approved program are the same. (1) Unfavorable NRC review may be due to a nunber 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. i NUREG-1262 17

l An unfavorable review would not have any direct effect on your program. NRC would work with INP0 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? i A. Refer to Reg Guide 1.8 Regulatory Position C.1.h for guidance on what the ! Commission considers to be acceptable. I 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 655.31(a)(4) and 655.59(c), the next annual FSAR update could delete training prcgram details. Please clarify what (event or achievement) is meant by " implementation" of 655.31(a)(4) and S55.59(c): what wculd 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 INP0 accredited the FSAR should retain revised program i 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 1.73. 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 nedical 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 l l

_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-cations 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, INP0 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?

The form has been revised to delete the felony blocks. A certification A. is now required that the individual meets the safeguards requirements of the facility. Q. 89. Will a standardized form be provided by the Commission for notification of disability or illness? A. The intent is that licensees keep the records. We don't need to be involved when someone breaks an arm or may be out for an extended illness. If it's a temporary condition, no notification is required. We ask the question, "can the operator perform licensed duties?" If the in-dividual is going on shift, and there is any question in your mind,We wemay would tell say submit a revised Form 396 to describe the condition / remedy. you it's not necessary to make a ruling on it. But you can have a problem if you don't notify us and some individual has a problem in performing licensed duties. If a person is to resume duties after a disabling condition, then we would need to be notified with a Form 396. Q. 90. What is the relationship between the facility licensee and the individ-ual with regard to responsibility for notification on medical issues? The Regu-lations indicate that we have a 30-day notification period upon learning the diagnosis. The question really is, what's the mechanism for the facility to 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. A. It is the operator's responsibility not to operate that plant in a disabled condition. The Regulation says that the facility licensee shall notify the Commission, but we believe that, logically, the operator should have enough re-sponsibility to tell you there's a problem. Facility procedures should be set up to ensure that that occurs. There is nothing in the Regulation that obligates the operator, or the senior operator, to let the f acility know. But there is an obligation for you, on the biennial medical examination, to identify and report disabling medical conditions. Q. 91. If the individual has a medical problem during the period of the h license, for instance a broken arm, does this need to be reported to NRC if the operator is not carrying on licensed duties? For example, if he is training l 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-ability. Usually, if he has a temporary disability that would preclude him from performing regular duties, he's not to perform those duties with that temporary disability We need not know if it's temporary. When you return him NUREG-1262 21

l' 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 l license to allow the operator to perform licensed duties with the medical con- -{ I 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 p returns to duty, and he must receive 40 hours of parallel watch standing. t~ 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. Arc 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 INP0, 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. bhen 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 upd&te, which is required pursuant to 2.0 CFR 50.71(e)(4). Simply send a letter saying that you were accredited, and the date of accredita-l 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 i s

Q. 96. For the FSAR update following accreditation, it would not be necessary to have the extent of detail in that update, as previously was the case, is that correct? A. That is correct. It can be blank, except for the information about the date of accreditation. It need not say anything, other than you were accredited, All records associated v:ith your and the date you achieved the accreditation. training program, following accreditation, are available tv the staff on site for review; they need not be submitted. Q. 97. If the facility dces not certify its training programs in accordance with Generic Letter 57-07, when must FSAR Chapter 13 be revised and how do I do it? A. The Rule becomes ef fective on May 26th,1987, and at that time, you must comply with the new provisions in the requalification program. So, there would need to be a change to the FSAR submitted in accordance with 10 CFR 50.54(i) and 55.59(c), to conform to the regulation, if you chose not to certify the training program. The Commission endorsed the INP0 Program for accreditation in the Policy State-ment. We said we would accept a program after it was accredited and certified to be based on a systems approach to training. A utility that perceives they get some advantage by leaving an old training program on the docket because that's all NRC is going to inspect is misguided. That is not consistent with the intent of improving training in the industry. We do not require that you tell us all the details about an accredited program, but we do expect you to implement them. We have heard rumors that some facilities intend to have one standard for NRC, and a different standard for INPO. That is not the Commission's intent in the Policy Statement and we would bring such a practice to the Commission's atten-tion promptly. We expect you to follow the accredited program when it is accredited. Failure to implement that program will be of concern both to INP0 and to NRC. Q. 98. Will NRC be prepared to approve or disapprove FSAR Chapter 13 changes within the 60 days allowed for implementing 10 CFR 55 requirements? A. The approval is effective automatically, if you have an accredited program and have certified that it is based on a systems approach in accordance with GL 87-07. You shouldn't expect to see any response from the Commission on changes that are implemented as a result of this rule, with the exception of [ any license amendments which are required because of something in your Technical Specifications. There are a number of facilities that have a more restrictive requirement in their Technical Specifications than that for which they would have to apply; amending their Technical Specifications to obtain relief is per-mitted under the rule. It would be an administrative change in order to con-form with the Regulation. But it would not have to be acted on within 60 days and would be processed as any routine change to the Technical Specifications. If you do not plan to certify that your program is based on a systems approach, we cannot act on it until we receive it in accordance with 10 CFR 50.54(i). NUREG-1262 23 ___ J

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- I 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, but you now must implement your commitment to the Accrediting Board. We have 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 INP0 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 r,eeds 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 INP0-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

and eliminate training in a systems. approach. If someone misses a portion of the training program because he has been ill or been away, you may use some-thing like a required reading program and a test to ensure that he has covered the material. But when the Rule says training on a continuing basis, it refers to whatever cycle you have designed that has been accepted by the accrediting board. NRC has separated itself from the training review. We would prefer, after you are accredited, that you certify you have a systems approach in place to us, and eliminate the details from your FSAR. Certification is all that we need because the periodic reviews through the accreditation process are the vehicle for keeping your training programs current. We think that the separation of training from examining is the most significant part of this rule-making. Q. 102. There are a lot of documents involved with the accreditation process, so if an IE inspector came in and said, "We think that your program is less than the scope," what is he basing that on? A. Regional inspectors are governed by inspection module IP 41701, which requires a performance-based inspection. If you make a change to your program through the accreditation process using the mechanisms for revising and updating your pro-gram, based upon feedback and need, and that's the reason that you're revising it, we don't see that that is an issue of lessening the scope. The lessening of a scope issue had to do with the old program when it was regulatory-based, where we required a certain number of hours in the classroom and certain types of content. The approach now is one of modeling the program based upon performance and need, and the process is one that has been endorsed by the Commission through the policy statement. To the extent that you need to change the program based upon feedback of your own performance, that's appropriate. If you have_an approved program today that calls for administering a comprehen-sive written exam annually and you want to change that to a comprehensive writ-ten exam every two years, the regulation is the basis for concluding that that is acceptable; that is not reducing the scope. That is simply conforming to the regulation. You can make changes to match the regulation either through the 50.59 review process or by amending your license. There are a few facili-ties which have commitments to operator training programs associated with a staf fing requirement section in Section 6 of the Technical Specifications. If you are in that category, you can submit an amendment request to the Commission for an administrative change to your Technical Specifications to conform to the requirements of the regulation, but you may not do less if it is, in fact, a requirement in your license now. You can't do less than what's currently in the license. If it's in your approved program, you can do a 50.59 review to conform to the regulation. Q. 103. Let's say that in my systematic approach to training, I have determined that it doesn't take three years of experience to meet the requirements. I com-plete the program with whatever experience we determine is appropriate, and we've got an accredited program. Do we still have to have the experience re-quirements in our program? Do we still have to meet them if we have an 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 icok 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 ao 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 INP0 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 accreditation program. That means that you control the review and waiver process, through your vehicle with INP0. Now, if you want to deviate significantly from the INP0 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 INP0 and NUMARC in order to provide both training and qualifications. Q. 104. Have the experience requirements to sit for an R0 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 l l 1

_ _ _ _ - _ _ _ = _ _ _ - _ _ - _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - year of experience as an R0 before entering the training program for an SRO?' ANSI /ANS 3.1-1981 requires a minimum of six months. A. Yes, there is a' change to the eligibility requirements except if a facility In that care, has an accredited program and an acceptable simulation facility. the requirement goes away because it becomes part of your accredited program. Q. 106. The way I understand the Examiner Standards presently, the experience requirement to take a reactor operator exam is two years of power plant experi-ence, one of which is nuclear. ANSI Standard 3.1-1981, specifies three years of power plant experience, one of which is nuclear. The two remaining years should be as a nonlicensed operator, and of that, six months should be as a nonlicensed operator at the facility for which you seek the license. So, that would be, in my interpretation, a three-year requirement now, whereas in the past it was a two year Is that correct? A. That is correct. The standard had not been imposed across the board in 1981. There are some facilities that have committed to that standard in their application, and were reviewed against that standard. A previous version of the Examiner Standards was based upon ANSI N18.1-1971, because we had not endorsed ANSI 3.1. This rule making process endorses ANSI 3.1.-1981. Q. 107. And the same applies for the senior o~perator. Examiner Standard 109 says four years, and ANSI 3.1 says three. So, you will be changing that one also? A. The Reg Guide takes exception to the ANSI Standard. Reg Guide 1.8 cites a four year requirement for experience for the SRO.

  *Q. 108. Reg Guide 1.8 endorses certain positions through ANSI 3.1-1981 for training and qualifications. The ANSI Standard has experience requirements For instance, for which are different from those in the Examiner Standards.

a reactor operator, ANSI 3.1 of 1981 requires three years power plant experi-ence, one of which is nuclear. And I believe it says two years as a non-licensed operator, with six months as a nonlicensed operator at the facility. Is the Reg Guide endorsing those eligibility requirements also, or just training? A. We have not taken exception to three years of experience for reactor operator. We have endorsed the ANSI Standard with respect to threeThat's years for the RO, but have taken exception by requiring the four years for SRO. same as the practice has been. We recognize the difference between the Exam-iner Standards and the Reg Guide in this area. The Examiner Standards will be changed to coincide with the implementation date of the Reg Guide, which is March 31, 1988. Q. 109. Are the experience requirements for operator licenses applicable also to research and training reactors? The requirements for test and research reactors have not changed. Whatever l A. I has been approved in the past, in terms of eligibility requirements, continues for test and research reactors. The eligibility requirements in Regulatory 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, INP0 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 INP0'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 exp.ect 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 SR0 candidate, and I was referring, primarily, to R0 candidates. In the past, particularly for those who weren't committed to the 1981 version of that ANSI Standard, there was no requirement for R0 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 aon'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- i 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 level into your training program. You can count time and training prior to that pro-gram, but we have not been giving credit for experience for the training which is required and has been approved by NRC as a part of the specitic 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? A. The requirements for radiation protection personnel in Reg Guide 1.8 are the same as those included in ANSI Standard 18.1 of 1971. Q. 115. About five years ago, we all wrote our response to the Denton letter and said that we would do specific punch list items to train our STAS. Now if we have an approved STA training program, per INPO, the old prescriptive hours that we committed to no longer apply. However, if that punch list item is in our FSAR, we need to remove it "per the INP0-accredited program." Is that correct? A. That is correct, as it relates to licensed operator programs and other programs for which you have made training commitments which are covered by the Commission's Policy Statement on training and qualifications. And in both cases, it is simply a 50.59 type review to amend or update your FSAR to indi-cate the date on which you received accreditation, for instance, for the STA position. The only exception relates to the Commission Policy Statement on engineering expertise on shift or the use of the dual role SR0/STA compared with a separate STA, as indicated in Reg Guide 1.8, Regulatory Position C.1.j. Q. 116. When an applied science degree is being considered, what constitutes an acceptable degree? How do we know what specific degree allows someone to be an instant SR0 or whether he must first be an R0? A. The staff reviews those and we use our best judgment, as do the people in the regions, in making a determination based on an application. If you feel that an application has been unfairly rejected, you can request reviews by re-gional and headquarter's management. If you want to bring it up through a re-view, we can certainly do that on a plant-specific basis. Q. 117. Is it true that in the future it won't be a problem, because you won't check up on us? If we send an application in saying someone's an SR0, will you l accept the application because you won't know what degree he has because it won't be listed? A. It's our understanding that the determination will be made in accordance with guidelines that have been established under your INPO-accredited program. NUREG-1262 29

The Commission has made a determination that we're going to trust the industry i 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- I 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 som'e 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 SR0 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 nowever, does not state that there are allowable training exceptions from following ANSI /ANS 3.1 for R0s and SR0s. Please explain why exceptions were not allowed for R0 and SR0 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

WRITTEN EXAMINATIONS AND OPERATING TESTS

General Issues (Including Learning Objectives and Examination Question Bank) Q. 121. Will the format of the written exams change? If so, how? A. At the present time the format of the examinations is not expected to change, although there are numerous initiatives under way which may lead to format changes in one way or another as we refine the process. Q. 122. The exam content states that Licensee Event Reports (LER) will be in- i cluded in the exam. How is the scope of LERs determined and communicated to i the individual taking the examination? A. We expect your training program to include relevant LERs. We would sample from your learning objectives, but we would not necessarily be limit'd to those. We would not take an LER from a significantly different plant and try to adapt it to your plant. But if there were LERs that reflect either training needs or operat.ional safety, we are going to include those in the exam process. It may be in the written exam or on the operating test. , Q. 123. Will there be any effort by NRC to ensure a consistent level of de-tail in the facility's learning objectives? A. Yes. We have a major effort under way to evaluate the quslity of learning i objectives that are submitted for an exam. This is a significant issue be-cause we have seen a large spectrum of differences in learning objectives. As a part of our examination development efforts, we have been reviewing the quality of the learning objectives submitted with materials for the 90-day letters. We're evaluating their quality and using that as a feedback mechanism into the evaluation process for how well accreditation is working. . Where we find that the learning objectives are not adequate, we'll use other materials. Where they are adequate, we will use them. We intend to evolve i over time to the point where we can construct an NRC exam solely using the i facility learning objectives. We have also opened our examination development training program to INP0 and others, providing information to them on how we construct examinations and on the training that we're providing to examiners. There are also activities underway within INP0 to improve development of testing objectives. Q. 124. How does the Commission intend to implement written examinations based upon the knowledge, skills, and abilities identified in the learning objectives derived from the systematic analysis of licensed operator duties? A. It's our intent, as expressed in the Statement of Considerations, to reach the point where the training program's learning objectives become the major source for our examination. We want to sample according to a scheme that looks at the most important job performance, knowledge, and abilities, and we have that area documented with our K/A Catalogs. In fact, there's a supplement to the PWR Catalog being published that has the same sections as the BWR Catalog. 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

There's a related issue. We issued Generic Letter 87-01, which announced the availability of the NRC Examination Question Bank, and indicated the mechanisms by which utilities could request the information on what's contained in the bank on their facility or similar facilities. It also indicated a mechanism for you to update questions on the bank, either where we have inaccurate ref-erences or the design of the facility has changed. Me purged the bank of questions that were more than two years old because some of the older questions did not meet today's quality standards. In some cases, we have only four or five examinations on the bank for a particular utility. We want to improve that and are interested in your comments and/or questions for the bank. We'll also provide the bank to you for creating your own ques-tions. To the extent you provide us information that's in a format which is compatible with loading into the bank, we can do that directly, either through hard copy or electronically. But for security reasons, we can't give you di-rect access to the bank. We have discussed with INP0 the need for an industry initiative to validate a set of plant-specific questions that could be a source for NRC exams. Q. 126. If the utility has established some internal guidelines of what they expect of the individual, will you accept those guidelines for the purposes of written examinations? A. Yes. We would have an issue that we would discuss with the utility, that we would want to revise the guidelines if they did not conform to our testing blueprint based on the job-related knowledge and ability statements with high safety significance. Q. 127. Can we submit that in advance of the written examination, and then come to an agreement somewhere up front? A. It can be part of the materials that you submit in accordance with the 90-day letter, and we would consider that in developing the exam. Q. 128. You mentioned a training program for the examiners on writing the learning objectives. How is that program being instructed; who's teaching that? A. We started several years back working on writing multiple choice questions, and have been doing one-week training sessions in all the regions, twice at headquarters, and once each for contractors. During the one-week training session, examiners converted learning objectives into testing objectives and practiced writing testing obj6ctives. We've shared that information with INPO and have had INP0 staff participate and take the materials back with them, so the information that we're using to develop examinations is available to you through INPO, or even through the staff if you want to request it. Written Examinations and Operating Tests (Statement of Considerations) Q. 129. In the Statement of Considerations, under Part D, Written Examinations and Operating Tests, it says: " Learning objectives derived from job-task l NUREG-1262 33

analyses should form the basis for licensing written examinations and operating i 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 R0 and SR0 positions. We'll sample more heavily in plant systems for R0s and more heavily in emergencies that have fewer normal and more integrated plant responses for SR0s. The final decision on that will be made based on the recommendation of a Panel made up cf 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 l 1

Q. 132. I've heard different people say that all NRC exams are now based 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 r mments 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.

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 the reactor operator? 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 Handling 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. l What is the reason for this difference? Is ES-202 correct in its application for Technical Specification knowledge? l NUREG-1262 35 i

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 SR0 in a timely manner. The same thing goes for the SRO. We don't expect SR0s 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 R0s and SR0s by virtue of SR0s directing the activities of others. The SR0 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 SR0 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 R0 doesn't have to know about approving surveillance, yet surveillance are covered in the Technical Specifications. An R0 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 INP0-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 allow 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 j objectives in terms of their explicit statement of conditions and standards, the i better the supporting material, and the better it's tied to our Catalog, the better the whole system works. NUREG-1262 36 r

1 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 INP0 Job Analysis in your own plant-specific analysis. And part of the reason that we tied our analysis at the generic level to the INP0 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 psychometrics 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 l 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 shape our 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 examineet! 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 SR0 level, as opposed to the R0 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 froa 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

l 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 be implemented 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 operatinr1 changes in the facility. What is the intent of this? Should the SR0 understand the process the licensee goes about in obtaining a design charge? A. There may be administrative procedures which would allow, for example, two SR0'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 SR0 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 maintenance activities are included in 55.43(b)(4)? A. Section (b)(4) talks about radiation hazards that may 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 he would be expected to have site- , specific knowledge in that area. l 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 SR0s must be able to address the " assessment of facility conditions and selection of appropriate procedures during normal, abnormal, and emergency conditions." However, neither R0s nor SR0s 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? j 1 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 SR0 typically checks such calculations, then we may ask the SR0 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 R0s are not expected to pass a test at the SR0 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 j scenarios for the Integrated Plant Operations portion of the test that would l 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

  -SR0 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 B0P to do? What reports do you expect to receive from the RO upon reactor trip? How would you verify a questionable report from.the B0P/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 and in such a way that the facility li-censee's procedures are adhered 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 requires that an applicant: (1) follow procedures, (2) observe and check instrumentation, (3) exhibit dexterity and a feel for console operations? Or, will this evaluation be addressed in a future revision of ES-302? A. This criterion is addressed in the operating test using the existing ES 302 with the new Form 157. Specifically, the form identifies, in competencies G and H (both with and without a simulator), the evaluation of communication / crew interaction and responsibility / supervision. , Waiver of Examination and Test Requirements (Subpart E, Section 55.47) Q. 154. In 10 CFR 55.47, what is a comparable facility? A. This question addresses the waiver of written examination and operating test requirements. We would look 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." l dh l I j NUREG-1262 41

SIMULATION FACILITIES f

Written Examinations and Operating Tests: Implementation (Subpart E, Section 55.45(b)) Q. 155. Will NRC continue to examine operators on plant-referenced simulation fai:ilities 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 hava 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 Faility 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, af ter it has been certified, an inspection proves that it is unable to meet NUREG-1262 42

l I the requirements of conducting an operating exam. And, if certification is pulled, then it needs to be decertified. Q. 160. For simulators that are not plant specific, when the regulation goes into effect in May, are 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. i 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 conduct exams on a walk-through basis. But if you do obtain a simulation facility between now and the date that you l 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 licensen 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 l I 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 i 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 ANS 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 4 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 (b)(2)(iii), which is 46 themonths, relationship (of the two and b)(3)(iii), timetables which provided in 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- j keted application. The 60-day requirement in (b)(3)(iii) refers only to what I we call facility applicants, which includes only those without docketed appli-cations. So you can ignore that 60-day requirement. j 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, an<i 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 I 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 i four year report at year eight, you can discard all the performance testing I 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

1 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 i 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 3 obtain approval to use that simulator? ! A. The answer assumes that the utility who wants to use it is treating it 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, thay 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 sinulation 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 g 4

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 l be submittal of a plan within a year, followed by application for NRC approval. i 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)(i) and (ii) state that within one year a plan shall j be submitted for a simulation facility (other than a plant-referenced simulator), j 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 oetermine 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 f acility 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 is identified, 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 components 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 facil'.ty 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 familiarization." NUREG-1262 59

This means that non-full-scope simulators would clearly be excluded from the Standard, and, hence, a simulation facility that does not consist solely of a full-scope simulator has no guidance or standard which a utility may use to obtain NRC approval. The previous statement leads us to the following conclu-sions: If Reg. Guide 1.149 and ANSI /ANS 3.5-1985 become the only standard for determining the acceptability of a simulation facility, the simulation facility must be a full-scope simulator, is that correct? A. No. Regulatory Guide 1.149, in regulatory position (c)(2), takes exception to those segments of the Standard that were just cited. The Reg Guide says that i simulation facilities, as defined in Section 55.4 of the Regulation (and that includes the plant, and potentially other simulation devices) should meet applicable requirements of the Standard. Also remember that Regulatory Guide 1.149 is only one acceptable means of meeting the requirements of the Regulation, and that facilitv licensees may pr ?ose other approaches to meet-ing the Regulation. We intend to evaluate those simulation facilities which are other than certified plant-referenced simulators on a case-by-case basis, once we get to the point of dealing only with the applicable portions of the Standard. Q. 185. If Regulatory Guide 1.149 and ANSI /ANS 3.5-1985 do not represent the only standard for determining the acceptability of a simulation facility, will NRC identify the minimum standards and criteria that are acceptable to them for non-full-scope simulators? Those two documents do describe the only standards. But Regulatory Guide A. 1.149 is a Guide, it is not a regulation. A facility licensee may propose alternative ways to comply with the regulations in Part 55, other than the submittal of the information in Regulatory Guide 1.149. Q. 186. Does NRC continue to endorse the requirement in ANSI /ANS 3.5-1985 to perform annual operability tests? If so, should this be part of the 25 percent testing, or should it be done annually? A. Yes. We endorse Appendix B on operability testing, and as the standard requires, this must be done annually. This is not a part of the 25 percent performance testing. Q. 187. Section C4 of Reg. Guide 1.149 specifies that reference plant modifica-tions be reviewed annually against the simulator and that the simulator update design data be revised as appropriate, and that the first such annual review and update should take place within one year following the facility licensee's certification. Does this mean we have until a year after certification to match the simulator update design database to the reference plant or 18 montns after simulator operational date, as specified in ANS 3.5, Section 5.2? A. No. According to W ction 5.2 of ANS 3.5, you start with a database which may, for nonoperating plants, be based on predicted data. Eighteen months after the simulator is ready for training, your simulator update design data must include available plant data, unless the simulator is on line before the plant, in which case you have 18 months from the date that the plant becomes operational. In accordance with the standard, it's whichever is operational 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 of plant modifications, follcwed 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 operationa'. But you must b~Ji u your cycle of annual plant review of reference plant modifications when you submit the certification. I Q. 188. Section D, " Implementation," of Regulatory Guide 1.149, outlines a i procedure to be followed for a facility licensee that wishes to utilize a simu- ' lation facility at more than one nuclear power olant. Does this guidance apply to facility licensees that wish to use another facility licensee's plant-referenced simulator? l i 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 plaM ' 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 j of the simulation facility to meet the regulations in 10 CFR Part 55.45(a), and i 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

A. Our operational definition is any change to the simulation facility, its models or software that might cause the results of performance tests to fall outside the acceptable performance criteria set within the standard. The standard does not define "significant," and for an official definition, or an of ficial clarification, you need to seek guidance from ANS itself. It's pos-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"? Do you understand that this causes confusion on the part of the simulator ven-dors in that if I was to go to a vendor and tell him that I want a reactor trip malfunction, he's going to wonder what I'm talking about? Do I want power to the CRD breakers? Do I want to lose all reactor coolant system flow? How do I want to do this to create the abnormal event that ANSI 3.5 is asking me to per-form? Isn't that really referring to a list of abnormal transients? A. Yes. Q. 192. ANSI /ANS 3.5 Section 3.1.1(7) requires that the simulator be capable of performing startup and power operations with less than full rated reactor cool-ent 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 Specifications, then the simulation facility need not possess that capability as it applies to routine operations. Q. 193. The Technical Specifications clearly bind the conditions under which the plant is allowed to operate. Am I correct that the simulator only needs to be bound by the same parameters? A. No. For normal startup and shutdown practical-factor evolutions, in accordance with your procedures, you need not model those to be outside the bounds of the Technical Specifications. The question came up in the context of "N-minus-1 loop operation"; for instance, continued operation with a recircula-tion pump out of service or continued operation with one reactor coolant pump out of service. You need not model the simulation facility for operation in that mode if you are not permitted normally to start up in that mode. It was with respect to the context for startup. Clearly, emergency procedures, for example, which go into function restoration guidelines and go beyond design basis accidents are not covered by Tech Specs, but we expect the simulation f acility to be able to reasonably model those ( events. The same holds true when you insert malfunctions. If you turn off power to a panel, you're clearly outside the bounds of the Technical Specifica-tions. You would not be operating with that panel de-energized. So in general, if you are conducting malfunctions, you may be in that mode. Q. 194. ANSI /ANS 3.5 Section 3.1.1(9) states that measurement of reactivity co-efficients and control rod worth using permanently installed instruments be performed. What is meant by " permanently installed instrumentation?" NUREG-1262 53

A. The question of the meaning of the term " permanently installed instruments-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 instruments-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 sy:; tem 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 surveillance that you can perform on those particular systems to show that those systems are operating within the bounds expected by the plant. Af ter 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: I interpret their relationship this way. Plant data represents the current plant 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

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. Simul uion Facility Certification (Including Performance Testing, NRC Form 474, NUREG-1258) Q. 198. When will the official simulation 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 l< that we did not test and certify, would those capabilities be utilized in l examining the operators? A. Possibly. eor 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 our examinations. On the other hand, if you are able to go into the area of, 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 iat'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 l-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 (E0P), we can quickly get outside the bounds of simulation. How do you propose that we address that issue on E0Ps? A. There are two ways: First, the standard irdicates 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-cirfe, 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- j 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

I I I i i 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? l A. Let's assume that it is a step in the procedure that's used in the control j room, but it directs an activity outside the control room. Say the reactor i operator tells the auxiliary operator to do something, and you have not modeled that capability in the simulation f acility. 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 look 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

I 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. i However, even today, with the present vintage of simulators, you still are experiencing feedback reports, althouqh 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 performanc.e 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 at NUREG-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 l 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 certificatic,n. 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 f acility 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 malft.nctions 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 yeview 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 l 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 to be sure that all of_the malfunctions that are listed in the standard can be performed. Q. 216. Section 55.45(b)(5)(vi) says a certification report need only include a description of performance testing completed, performance testing planned, and the schedule for conducting 25 percent of performance tests per year for the next four years. Is this sufficient, or must the document conform to ANS 3.5-1985 Appendix A?" A. This question addresses two different issues. The first is the testing that is required, and the second is the reporting. The reporting itself need not be in the format of Apperdix A, ANS 3.5, although that's not necessarily a bad idea. But it must cover those items that are called out in the Regulation in Section 55.45(a), specifically a description of the performance tests con-ducted, and the schedule for future performance tests, if that schedule differs from one that was previously submitted with the certification. The actual testing must include not only the Appendix A performance testing, as called out in the standard, but the specific list of malfunctions that are identified in Section 3.1.2 of the standard, both at the rate of 25 percent per i year. Also, the operability testing that's shown in Appendix B of the standard 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? A. In all probability, the simulation facility inspection program will com-bine headquarters and regional staff, starting largely as a headquarters func-tion and over time becoming more region-based as we move into the inspection procedures. Q. 219. NRC released a final draf t 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. It specifies that training simulators require stringent software quality as-surance. This requirement seems to imply that the simulator's sof tware should be treated as though it were safety related, with the appropriate programmatic and procedural controls applied. What are the Commission's plans in this area and what relationship, if any, will the draft handbook have to simulator certification? A. The draft handbook to which you refer imposes no requirements on the industry. It is under consideration by the staff, but there is no intent for us to review your software development or quality control procedures as they apply to Part 55 and to simulation facility certification. NUREG-1262 61 l l 1 d

You, of course, have to manage your own simulator software program in order to meet the regu'ations in Part 55 as required to certify that the simulation 1 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 sof tware 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-ref erenced 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 satisf actory 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? l NUREG-1262 62 l l l

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 mai-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 _ _ . __ l

l 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 me't 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 I 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 reenved, 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-ante 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. I l NUREG-1262 65 l 1

l L 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 contrni room of the plant. The copies should be up to date, including references brd 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- i 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. I 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

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 l l

Special Senior Operator Licenses (Incluaing 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 responsibility for ensuring that instructors are qualified now rests with the accreditation process. INP0 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 l change could be made to support such an approach in the interim until such tirre I 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 INP0. 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.1 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 1 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 toose 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 NT0Ls 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 mttter expertise in instructors. And that was to either use a licensed senh.c 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. HUREG-1262 70

Q. 248. So, then, is someone who has passed an SR0 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 INP0 is looking at in the instruc-tor training and as identified in Technical Instructor Training and Qualification Guideline, INP0 82-026 at 7.1. Q. 249. Can you tell us how you expect to treat people under the new rule who are currently SR0 instructor certified? What kind of credit are they going to get because they are SRO instructor certified, if any? A. The answer is none. Obviously they have completed the same training program and taken the same exam as an SR0, 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 R0 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. This 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 Commission 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 as de-fined in the facility's Technical Specifications, and that the individual ca-rries out and is responsible for the duties covered in that position." How does this rule accommodate plants with R0 and SRO licenses on shift that exceed the Technical Specification minimum staffing requirements?

NUREG-1262 71 j

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 hours of parallel watch standing. Q. 252. Our Technical Specifications do not address the individual's responsi-bilities for each position in order to satisfy a active participation re-quirement--it says you have to have an R0 and 6 i SR0s, one SR0 as a shift supervisor and one that's another R0. Can you rotate that SR0 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 sehior control operator who has an SR0 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 SR0 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 I 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 40 hours of parallel watch standing for that quarter and not be actually in a position required by the Technical Specifications to meet the seven shifts at eight hours each, or the five shifts of twelve hours each. It would require in that case, that the authorizing representative of the facil-ity certify that he has completed that duty. From a practical stanopolnt, it's 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 of the people who are performing the functions. If you're dual licensed, the active status requirement can be met by standing watch on only one plant, or on some combination of the plants. Conditions of Licenses (Subpart F, Section 55.53) Q. 253. With regards to fuel handlers, in the case where you may refuel once a year, it's probable that the requirement won't be maintained. Subparagraph 55.53(f)(2) suggests that one shift of supervised duty is required before the fuel handling foreman with the license can assume his full duties. Is the intent that that supervision be performed by another fully qualified SR0 who may not be a fuel handling specialist? l A. That is correct. An active SR0 license includes the capability and re-sponsibilities associated with monitoring fuel-handling activities. Q. 254. The Operations Manager and Operations Supervisor are required by Tech-nical Specifications to be licensed as Senior Reactor Operators. These in-dividuals do not have a position on the shift crew. They are involved in the day-to-day direction of Licensed Operator activities. Are these positions considered as actively performing Licensed Duties? A. No, unless they stand the seven 8-hour shifts per quarter, or five 12-hour shifts per quarter. That does not mean that the Ops Manager and the Ops Supervisor cannot keep a license. The requirements to maintain a license are that they continue in requalification. If the Operations Manager must hold a license, then he must participate in requal, but he need not stand watch on shift in a position where he is directing the activities of the Reactor Operators. A license, whether it's active or not, may meet some Technical Specification requirement. Q. 255. What if you have an SR0 stand a shift assignment as an R0? Does the SR0 get credit for standing watch in that position for renewal purposes? A. The SRO is not performing Senior Reactor Operator license duties. Unless he is also standing SR0's duties during that quarter, then his SRO license would not be active. Where an SR0 is standing an RO watch, his license would continue to be ar,ive insofar as it deals with his operating or manipulating the controls as an R0. i In order for him io direct others, he would have to stand a 40-hour parallel shift in order to bw proficient and go back into an SRO's duties. He could,

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however, continue to maintain an SR0 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. I 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 Techr.ical Specification SR0 position on shift (Shift Supervisor), our Techni;al Specification re' acts the 10 CFR 50.54 requirement of a second SR0 on shift. Would standing a wa;ch as a designated second SR0 meet the definition of actively performing the function of a Senior Operator?

        'A. if he is filling an SR0 position under the Tech Specs then he would be maintaining his active SR0 license. A number of people have asked, can we have two or'three people come in to get the9 on-shift time? Our position is that those n:eeting 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 si*.e 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 +.c procedures. Would an inactive license allow him to do those admin-istrative functions? A. Yr s. He can do everything but direct a Revtor Operator in manipulation of controis, or himself manipulate the controls. Q. 260. All stations have engit mering expertise on shif t in the form of a shift engineer, who is the STA. STAS hold a current SRO license. They direct l activities and integrate scheJuju tra they not actively performing the func-tions of an SRC license by those duties, or are they going to have to come back and pe'1orm as a shift supervisor, on shift?

         .N02EG-1262                                     74 e                 \                                                     _______       .        ___

A. If they are one of the two individuals required by Technical Specifica-tions to staff the shift, then what you just described is acceptable. If one is there as an engineer on shift who happens also to hold an SR0 license, and is only fulfilling the role of an STA, then he is not responsible for directing the activities of licensed operators. There are many cases of extra people on day shift, who do support functions, such as reviewing tags, procedures, line-ups, records, etc., and do not require an active license to perform them. It is only when he is performing the functions and duties of an operator or a senior operator that an active license is required.

  *Q. 261. Our Technical Specifications require two senior reactor operators and two reactor operators for mode one and two operation. Typically, though, we'll have others assigned to the shift. Is it NRC's intention that only the two people assigned as the balance of plant operator and the reactor operator are receiving credit for being on shift? Or are the others manipulating the con-trols getting credit for being on shift?

A. If utility management has determined that they are necessary for safe oper-

 'ation, the decision about the number of additional watchstanders is that of the facility licensee.       However, in order to take credit for the proficiency of such personnel standing watch above the Technical Specification minimums, as a condi-tion for maintaining a license under 10 CFR 55.53(e), the facility licensee must be satisfied that they maintain their proficiency by manipulating the controls, in the case of an operator, or by manipulating the controls and directing the licensed activities of licensed operators, in the case of a senior operator.

Q. 262. Do candidates with an R0 license in training to be upgraded to senior operator lose their active license status per 55.53(e) while standing watch as an extra operator for three months? A. Yes. If the operator does not maintain the requirements of an R0, he loses his active status. This question is related to actively maintaining a license. Could Q. 263. someone stand 40 hours in January and then again in June to meet the active i license requirement by calendar quarter. A. No. The 40-hour requirement does not pertain to maintaining a license, but is part of the requirement for resuming active status. Maintaining an i active license means standing the necessary shift watches. l *Q. 264. This question concerns active license status at a dual-unit plant. 1 The shift supervisor is the SR0 who normally directs the activities of the operators. We also have an SRO on shift who is over both of the shift super-visors. He does not normally direct the activities of the operators, but he may. Would his supervisory time on shift count as active time? A. Yes. If you look in the Regulations on staffing for a dual-unit site, you have three SR0s for the two units. If he is in one of those positions, that qualifies him. If he is not in one of those positions, you may still take credit for his proficiency if you are satisfied that he is maintaining that proficiency by manipulating the controls and directing the licensed activities of licensed operators. NUREG-1262 75 l

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 hours; 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 I 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- j 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 SR0s; 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 'oergency plan, which is covered by a different portion of the _ regulations. j l 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? ; 1 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 hours 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 R0 and the SR0 level. Your continuing training program should ensure that he doesn't lose those manipulative skills because he is not required to n,aintain an active license. Q. 270. If our Technical Specification defined the STA position as an SR0 on 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 whom, 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. Q. 273. It would appear that once a quarter, an individual could spend 40 hours I on shift under the direction of the licensed operators. And the facility could 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 hours a quarter on shift, instead of the 56 to 60 hours specified in other parts of the Regulations? Is that true? , NUREG-1262 77

1 l I A. That is true, although that is not what we intend. The issue is to make it easy for people to maintain a license. Aad 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 hours 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 i who are involved in daily operation's supervision? I A. No. They are either in active status or they are not. If they are not, l 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 hours 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 hours 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 came quarter. That is, he does not have to serve 40 hours 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. l Q. 277. Do those 40 hours have to be consecutive; i.e., eight hours a day? l A. No. It has to be 40 hours. You can have four tens or ten fours or any other combination that adds up to 40 hours; 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

Q. 278. Can licensed Senior Operators who are not in active status perform refueling SR0 duties? A. No. Only active SR0s can supervise refueling activities. If they are not active,.they must stand one 8-hour shift under instruction from licensed active SR0s to perform active SR0 duties limited to fuel handling. Q. 279. What leeway do you give to the facility to know that an operator has received a felony conviction? A. Convicted felons typically go to jail, so they're not going to be at work. Also, all those granted clearance for unrestricted access have background investigations that relate to such things as convictions for felonies. You will have access to the information from that source, too. Q. 280. But the facility will not necessarily know within 30 days? A. It is the operator who is required to let us know in 30 days, as a condition of the license. Q. 281. So, we don't assume any liability for not notifying you within 30 days? A. If you don't know, and you didn't have a reasonable' basis to know, we're not going to hold you liable for that. However, if you get a criminal history check that shows that the person has been convicted of a felony, we expect you to tell us. Q. 282. If we submit an applicant for a license who has had a felony 15 years ago, is that still reportable? If he had taken a licensing exam and was ready to receive a license, would he have to notify you within 30 days, assuming we did not know that? A. If the individual knew that he had been convicted of a felony in the past, and he did not report that on the initial application, his application would be considered incomplete. Such an omission could be the basis for revoking his license, since he would have withheld information. Q. 283. Why is the applicant no longer required to sign the Form 396 certifying that he or she has no felony convictions? A. Because it is a condition of a license, per Part 55.53(g) that individuals notify us within 30 days of a conviction for a felony. So, should someone get a license who had a prior felony, he would be required to notify us of the prior

.f el ony.

Q. 284. If we were to let an individual's license go inactive, would it also be reasonable for us to let his medical requirements lapse? A. No, you cannot let his medical requirements lapse. .He must be medically examined each two years. That is a condition of his license, whether he main-tains proficiency or not. NUREG-1262 79

l 1 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 1 comes up in two year cycles. ] 1 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 l 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 SR0 limited to fuel handling, not an SR0 with an unlimited license here. So if a guy has an SR0 license and he's an active SRO, he can be used as an SR0 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 SR0 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 SR0 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 (SR0 License) who is standing the "STA Watch" get credit for SR0 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 hours 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

Q. 290. When will the quarter for shift standing start when the new rule is implemented? A. For accountability purposes the first complete calendar quarter after the rule is implemented must meet the seven shift / quarter requirement. Q. 291. Does completion of 7 days on shift in one position such as shift engi-neer, allow the individual to perform duties in another position on shift for which he is also qualified? A. If shift engineer is a Tech Spec position required to hold a SR0 license, then performing in the seven-8 hour shifts, per 55.53(e) would permit the licensee to perform duties as either an SR0 or R0. Q. 292. Do technical advisors or licensed instructors require an active license, if they must maintain a license for technical specifications or FSAR? A. They may need a license per the Technical Specifications, FSAR etc., but it does not have to be " active" per the Regulation unless the individual is re-quired to assume a position onshift that the Techrical Specifications identify as a licensed shift manning requirement. Q. 293. If an operator gets his license during a calendar quarter, how is he to meet the seven shifts per quarter requirement? A. For the initial calendar quarter for which a license is i'ssued, he is con-sidered to have met the proficiency requirements by virtue of having passed the exam. Thus, the " actively performing" requirement will commence in the first calendar quarter after he receives the license. NUREG-1262 81 l

1 REQUALIFICATION AND RENEWAL l l

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 INP0 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 cf 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 j that either the license or the failure has been approved by the branch chief, l by the licensing authority, i 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 individe91 f 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). l 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 reported on rele-vant portions of Form 398. Q. 299. What is the evidence that the applicant has discharged the. license responsibilities competently and safely, and how is 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 past performance 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 enforcement action and he receives a letter. It's a formal notification, and there is guidance as to what is permitted in the doc-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, 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) requirements 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? 1 NUREG-1262 83 1

A. For anyone who holds a license, he must be kept current in the requalifi-cation program; he must be medically fit, and he must have been examined at some , time by NRC during the course of that six year license. The requalification , j examination requirements are applicable independent of active / inactive status. j 1 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 for renewal? A. If he is not maintaining an active license, he still must meet all of the requirements for renewal in 55.57(b). However, he does not have to be active to get his license renewed. He must be, most importantly, current in the re-qualification program, but he does not have to be active to have his license renewed. ]

Q. 304. In order to obtain license renewal you must be examined by the NRC at least once during the six year life of the license. What is the extent of this examination: written, operating, both, either? A. With respect to format, the requalification exam will parallel the initial exam, i.e., it will include both a written and operating test. The content of requalification exams will be based on the facility's learning objectives pro-vided that these objectives are satisfactory. 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 by the Commission during the term of a six year license. I believe that you have interpreted that to mean that an exam will be given at least once every six years? A. Yes, that's what the Commission has stated. The Commission has directed the staff to examine operators at least once each six years, and that's why we know that some people may have an exam more than once in six 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 100 percent in six years. In fact, it will be greater than 16 percent because of the random-ness involved in ensuring that candidates don't have prior knowledge of when we are coming in to examine them. 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 have to be submitted before the May 26th date, but the renewal is not until after. Do I submit them under the existing rules for them to come back as a six year license? NUREG-1262 84

l A. The Form 398 that you use until May 26, 1987 is the same one that's in effect today. Even though you submit that version of the form, if we issue a license after the 26th, it will be a six year license. Any applications sub-mitted after May 26th should be on the new Form 398 with the new Form 396. Q. 310. Will the people presently holding two year licenses have to reapply at the expiration of the 4wo years or will they be automatically extended to the six year cycle? A. They need to reapply prior to the expiration date of their current license. j l Q. 311. Considering that every utility has or will have an accredited retraining 1 program, what is the justification for the random selection, which would in-clude the possibility of having more than one exam in a six year period, versus the possibility of doing an orderly schedule to include only one exam in that same six year period? A. It is NRC's mandate to ensure that all licensed operators maintain a satisf actory level of proficiency at all times. As such, the required exam is intended to serve as a " spot-check" to verify that that level of proficiency is in fact being maintained. Further, we want to ensure that operators can demon-strate this level of competence without special preparation outside of the normal required training program. The Commissioners believe that this is best accomplished by randomly selecting the operators to sit for the required exam. To the extent possible, we will coordinate the exam schedule with your regular cycles. But if we have reason to believe that there.is something wrong with J the program, or we have other indications of problems, we will conduct exami-nations at times other than during your requalification cycle. Q. 312. How can the Commission administer a comprehensive written exam once during the six year cycle if the utility is administering their written exam spread out over a segmented period? A. As stated above, the Commission's mandate is to ensure a satisfactory level of operator proficiency at all times. It is the facility licenses's responsi-bility to ensure that their required program, although segmented, maintains this ' level of proficiency throughout the training cycle. Q. 313. Who will schedule and track each licensed operator to ensure he has had an NRC exam prior to renewal? A. That's NRC's responsibility. It will be tracked in the Regions by the docket files on each individual which will contain the last NRC-administered requal exam. Q. 314. How soon can someone be re-examined after failing an NRC exam? A. We have resources for two visits to a facility per year. If the individual fails and is getting close to the point for renewal, we would evaluate on a case-by-case basis whether our resources permit us to go back and give another examination before the next regularly scheduled exam. i 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 e pretty good indicator that he's going to be tak- l ing an exam at that next cyc'n before his license renewal. ! Q. 315. In the past, if an p rator 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 l 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- i 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

l 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-a9 credited 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 Comraission 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 selectees up to six weeks in advance of the examination date, but in no case will less than 10 days l notice be given. Q. 320. Does the six year license apply to nonpower reactors? Do their licensed 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 55.57(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? l 1 I 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
 ^ "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 INP0 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 oi the objective in order to be accredited, and those are' contained in INP0 85-002. The Commission has reviewed and endorsed the INP0 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 (INP0 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 INP0 has seen facilities do that worked particularly well for a f acility, and they have provided guidance on those. NUREG-1262 88

l l i 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 INP0 ' 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 i that are relevant to the job, decide which ones are appropriate for training on l a continuing basis, based upon such criteria as importance of the task to the i 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 INP0 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 INP0 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 INP0, 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 INP0 should we see problem areas for INP0 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 INP0 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 SR0 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 I

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 SR0 operating training. Q. 328. Since Section 55.59(b) indicates that the Commission would accept cdditional 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 1 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 INP0, 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 INP0 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. , I ! Q. 331. What is the difference between a requalification program 24 months long i 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 l

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 i not to exceed 24 months. What is the purpose of the 24-month limit? I 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. HUREG-1262 91 - __ _ __ _ _ _ l

I 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. 359. 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 operatir.g 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 l of the requal program, or the current licensing program at the facilities, but l there will be some change in forms and in the documentation process. The reason for that is that those examinatioro are already in preparation now, and you j 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 af ter 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 j over a period of time or is the intent to administer one complete examination l at one time? l A. If you currently have ?. 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 moving to 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 you've notified us that you're changing. Along those lines, with regard to the segmented exams, if you currently have in your program 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 l 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 it be NRC's goal to document those differences between the initial exams end 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. 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. NUREG-1262 93

We believe that to the extent you follow the INP0 guidelines in 86-025, you will { have done that. We believe that that's a fair representation of the type of i material that should be contained in continuing training and should be used for ) the basis of a requalification examination. l Q. 343. Where do we find the standards and criteria for administering the com-prehensive exams for the requals? I 1 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 I comprehensive written exam every two years, that the NRC exam would count for l 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 pol. icy 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 SR0 who i 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 SR0 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. I I These include operating tests on an annual basis. If an individual is licensed I 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 cnanges 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 op.erating 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. Af ter 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. 1 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 requests for renewal? Would that be the appropri-ate way to handle that? A. No, that would not be necessary. NUREG-1262 95

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. i We're using a more common sense approach, so if you submit an application for l } renewal for a candidate who has a two year license now, and you submit it in l four .?onths, 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. I 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 i practical part until successful, whether it takes one, two, or three tries. I 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 i 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 loo'K 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 plant and the simulator 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 I 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 l I i

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 I 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 j 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 INP0 accreditation would have a longer period between NRC visits. Q. 359. On the question of randomness, if in year two a candidate passes the cxam, 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

e l 1 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 , [ a 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 his 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 pending 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 shif t due to illness or vacation, etc., but most of the people, normally three out of the four, usually remain the same. potentially The potential to four peopleexists that don't for administering work togethera normally. simulator examination,hi- Have we cor deredthepotentialjeopardythere,thatwehavecreatedanenvircrmentcor{ , trary to the way we have been trying to teach the operators, in particular 'l going to the plant-referenced simulators? l A. The examiner standards indicate that when selecting people from shift, you select one crew. 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 sorrnally work. But when you consider all the other constraints, such as tnese who have !< six year licenses, those who have two years, the time frame for renawal, etc., /' Ei 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, i t. 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 nctice ty be 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 t,etween 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 test od or will the whole license complement be tested? , y l NUREG-1262 99 s

i 0ws

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 /                                             4. In keeping with the Commission directive #, it should bey a' random sople of license holders. All would be subject to exams. We vo0ld 'coordi.iate that with you if there were severe har;aships but that would have- p be handled                 ' '

ong case-by-case basis. Q.)}3. This concerns the random examinations of lisjnsed operators. How far iii d. fence will I know who will be examined? WhenwilfI.besuppliedwiththe lisy c/ names, saying that on this day, these people will be, examined? *

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A. You Nire,re notified of the e> lination 90 days in ai/ance in aWrdance ' with ES-601. r:ybically, ten days td six weeks, prior to the examfah.Ln, we will notify you of the individuals who have been randomly selected for the e requalification program evaluation, s, , f Q./364. WillNRCnotifythefacilityintimetofacilitateprepara?inol'the

                                              ,ligeose holders before taking the,requalification exam?                                                 i
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AhW will provide ten days to six weeks notice. It was explic\ W rection i . - y Aootie Commission to ensure that examining is done on a random ifa.,is for ,' '

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                        ,                       rfasem that are associated with evaluating the continuing training pngram,                                    .

's a'nd evaluating and ensuring that the candidate maintains profklency and an appropriate knowledge level over the duration of his license. ' , ,p

                                                                                                                                                                                   ,j We will coordinate the scheduling of /. yard         / ation visits with your Nguld . equal                                  ,4L
                                             / prograTfichry! ales and/or your replanW.ent ' examination schedulgs gn ine eient                                             pl 6e p;n. t But our resources are limitcts We are t,udgeted for tw4 A its per Ne: a[a facilitv.           And if you havd a need for more than bro to 'acco,t.modate somesj;:ivityt~lt*clikelynottooccur,withoutadeauatepovancedplanning.                                     ,

And e:will chotse candidates from among those who hav rotbeotexaminedbf theNRgbeformeselectsomeonewhoalreadyhasbeenso,e>imined. However, some people will h examined twice, so that those who act examined early in their cycle coyTM Make the assumptior that they're r;ut going to see the NRC again for U.e doration of that period. Q. 365. In theWA NRC tested requal every two years and the operators were drum-brpd ,t,ight until somebody was randomly selected. Then they relaxed for two or Whice years, dep e diffs upon whether everybody had gotten accredited.

And then the cycle was ?codated. , y f. t

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                    ,1                            I'munderthe,.fmpressionthatpeit@rNUMARC,northe$r.)erators,noranybody
                ' j, >                           else, had an us.n tunity to critigte. these particWar two paragraphs' ,4*r to having seem tlyi b re         It appears to me thal' H a minimuir,. NRC is gef/v to have to giW i t eml. '. test once a yvir, if I have requested a hot license test once a year.                                  f        (                                                                              l t                            -
                     \
                                            , in Ycur perception is quite accurate. The Statement of Considerattom is the                                                     '
                        'f ., Af.hicle                    that the Commhsion used to provide directions to the staff on how to                                                   .

j,'. Liplement the Regulation, which has always perditted the staff to administer i

                        /                     'jequalification examinations. The f act that the requalification examination
                               /              'las been made a condition of license renewal is new.

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There was some concern in the past, of "why me?" "Why not this other guy?" Cy putting it in the Regulation, and indicating what the intent is, it becomes (Hear that everyone will, at some time during that six year license, be examined by NRC in order to have his license renewed. ! ~ J We' ave accepting a certification by the facility for two written tests and five operating tents per six years, but the staff will continue to examine in some cues. That is, we will simply choose not to accept the facility's certifica-tic.r3 at that time, and we will examine the individual. There may be some cases whev a w indiviCual will be examined more frequently than once each six years. Q. 366. . If an operetor gets his license renewed, and is tested in the first year, my arithmstic safs trat he can't go but one year beyond his renewal. Then, clearly, the frequency tis going to be greater, by definition, than once every six years. A. Correct. That's why we use the term at least once during a six year license. i Q 367. . These questions ne related to the NRC-administered requal. Would it be possibie for an individual to be selected twice during the six year period before all other individual licensees were selected once? A. We intend to select people who have not been selected before selecting someone a secor.d time. But that does not preclude this from happening, if we got everybody else. If we've been through all of the people with six year licenses, and we are still sampling, it is possible for an individual to be ayimined twice.

              'Q. 368.      So, it's random, but the pool from which the random selections are made

, gets smaller as people are selected? A. R could get larger, based upon more six year licenses being issued. At some point it will reach equilibrium, where everybody has a six year license. Q. 369. Is this a testing of the requalification program, or is it testing

               . human beings every six years? I feel that it may have been a step backwards in raising the anxiety level of the population of operators who are going to be up s;              tight every ye r. That's why I don't understand the Statement of Considera-tions, becauss I'm just concerned about those people.

A. It safs;that we're going to test so that nobody goes more than six years without being tested, and means that some are going to get examined more than once in six years. It's our. view that if a licensed operator is going through an effettive, continuing training program, then there shouldn't be any concern with that person getting an hE exam because nur exams are designed to confirm that the individual has maintained a minimum acceptable capability. If he is going through a continuing training program, our expectation is that he is way above the minimum that's acceptable. Q. 370. I feel perfectly comfortable that our operators, and our supervisors on shift can safely operate our units. The vehicle you are using to measure the requalification progcam is improperly aimed at obtaining those results. If we 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 cperator, 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. j l A. We understand your comment, and we recognize that both groups are trying j to move to the point where we are using content-valid examinations to measure j performance. We have a ways to go, and we are working on that. And we think l you all have ways to go in describing adequately the content of the continuing l l training program. Eventually, we will get to the point where we have closure on the scope and content validity of a requalification examination. l 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 perfo.rmance, the imperfect tools that l 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 INP0 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 i quality of exams and getting them content validated. l 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 en nt 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? A. First, the individual is removed from licensed duties and placed in an ac-celerated training program. Once he has successfully com*pleted 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 operators must pass an NRC-administered requalification exam during the term of the six year license. Therefore, if this individual failed the NRC-administered requalification examination and has not passed another NRC-administered exam during the term of his current six year license, his license will not be renewed 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. The clock starts the day he gets his six year license. But if we give a 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. Q. 374. Part 55.59 states that in lieu of accepting certification by the fa-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 ar.d 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 16 percent of the operators at all facilities in the region every year. For clarification, you can anticipate that the operating test will resemble the one that would be given for an initial candidate, but the written exam would be geared directly to job performance. The written exam is going to have to 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 NRC approval under old Appendix A, new 55.59(c), the requal program, or you have an INPO-accredited SAT-based requal program. There can't be anything out-side of those. Q. 376. Prior to the issuance of this rule, people developed their requal pro-gram with two taskmasters: one, the INPO accreditation process, and the other, the relatively non-task based aspects of Appendix A. Now that the utilities NUREG-1262 103 l

have got the flexibility to withdraw or to remove the non-task based part of the old programs, which may tuke some time, what is the approved program in the interim? Is it the old program? I 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 i SAT approach. We don't believe, however, that that is such a big task. Some I of the material we required in the past falls into the kinds of things that can I be used in an SAT-based program. I 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 i if you look at the programs that have been approved by the NRC, those have been I 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 you to look at carefully and to implement as quickly as you can. 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

Q. 378. By what means is a utility to certify to the Commission that their requalification program is both accredited and based upon a systems approach to training? The interpretation for implementing a systems approach to training is somewhat different by the NRC and INPO. By what specific standards is our certification for using a systems approach to training based; i. e., the NRC's criteria utilized in conducting pre / post accreditation site evaluation, or using the INP0 85-002 criteria? A. The two are equivalent; that is, NUREG-1220 is essentially a series of questions related to each of the five elements of a systems approach to training as it's described in the policy statement. In that same policy statement, the Commission has endorsed the INP0 accreditation objectives and criteria as being a systems approach to training. The difference comes about in that INP0 has 12 objectives and about 60 subor-dinate criteria. The Commission in the policy statement identified five elements, and the Staff has a number of questions that we use for information-gathering in our reviews. However, we would prefer that you use the INP0 accreditation objectives and criteria and supporting documents; in particular, for your requalification program. There is clearly a hierarchy of documents within the INP0 program. Objectives need to be met. Criteria may or may not be met if you can still meet the ob-jectives. Guidelines are just that--they are guidelines, an acceptable way of doing business as INP0 would review it. That is very similar to the staff's approach in doing our postaccreditation dudits. We have questions that relate to each of the five elements that the Commission has endorsed. Those questions do not imply criteria. They are simply areas where we gather information. So the simple answer to the question is follow INP0. We have seen several cases where the requalification program was not based upon a systems approach to training; rather, it was based upon a training program docketed with the NRC, that the NRC had approved. It was very prescriptive. It was, " Conduct X number of hours of classroom training, perform certain prac-tical factors on the simulator in accordance with the Denton letter," etc. Because of a reluctance on the part of the utility to change commitments that are required by license condition or regulation, many of those programs were not changed to a systems approach. Effective May 26th, you can remedy that prior restriction by simply sending a letter to NRC which indicates that you are accredited and that you have developed your requalification program on a systems-approach-to-training basis. That's the most important aspect of this rule. It gives you the flexibility to control the content of continuing training based upon the needs of the individ-uals who have been trained, and the feedback mechanisms which are described. Most important is Element 5 of the systems approach to training: program re-vision based upon evaluation of performance on the job. That's where we see the major payoff, and we think that we are giving you the flexibility that you need to fully implement the industry commitments through training and accreditation. NUREG-1262 105

Q. 379. What criteria is the Commission going to use to approve programs de-veloped using a system approach to training? A. If you are asking the NRC to approve a requalification program that's based on a systems approach to training, we don't look forward to trying to do those kind of reviews. We'd rather see a submittal indicating that you have an INP0-accredited program, which has both initial and requalification training based on an SAT. If you were to ask NRC to review a training program that was not INP0-accredited, that you claimed was based on a systems approach to training, we would try to use the document that we now have to evaluate that, NUREG-1220. For clarification, if your program is accredited, and you're not a cold plant licensee, then prior to receiving an operating license we fully expect that you will use the INP0 accreditation process and the guidelines that have recently been issued by INP0 in their continuing training guidelines for licensed operators to develop your requalification continuing training program. We will accept a simple statement to the effect that this has been done. We accept as fact that you have been accredited, and therefore that you under-stand the process of developing performance-based training. We do not expect to review such programs. I don't think INP0 would like us to review programs against their criteria and to put them into that context. We are trying to, in this rulemaking, clearly differentiate between training programs, which are being handled by the industry initiatives through NUMARC and INP0, and licens-ing requirements and the NRC examination. We don't want to mix those two, and would probably have discussions with facilities that propose to do otherwise. Q. 380. As far as the INP0 document, 86-025, is concerned, you just say "as long as you are following the guidelines." Do you expect verbatim compliance with the guidelines, or just general compliance? A. There is a hierarchy of criteria within the INP0 program, starting with objectives. Then you have criteria guidelines. You must meet the intent of the objective. That's a "shall." When you get down to the criteria, you may not meet all of them verbatim. For some you may have alternate methods. Guidelines indicates what INP0 believes would be acceptable to meet the intent of the criteria and the objectives. Your program has mechanisms for reviewing and deciding how you put that process in place. The fact that you are accredited is evidence to us that you under-stand how to use that process and thore guidelines. We don't need to see the details, based upon the fact that you have been through accreditation. The principal goal for revising the requal programs is to allow feedback from operating problems, particularly licensee events, plant design changes, proce-dure changes, and other aspects of training for which there is a demonstrated need, and not to be constrained to X number of hours in a class, because that's what's been required in the past. Q. 381. What if I put in 80 hours of simulator time, although INP0 says 120, but we're doing okay with 807 NUREG-1262 106 l

A. That's between you and INP0 and your needs under a program which utilizes the SAT process. We have confidence in the process based on our evaluation of a number of facilities. We may get back into training programs if we see per-formance deficiencies on the job, through an event or through our inspection program. We have developed guidance, the series of questions in NUREG-1220, as to how i we're going to go about evaluating programs. So that you know what you consider to be fair game for us to look at. But we are not in the mode of telling INP0 what to do. That's for the Accrediting Board, INPO, and the facilities to determine.

Q. 382. Will your evaluation of the training program be in accordance with the guidelines in NUREG-1229?

A. Yes. We have had a number of discussions with INP0 on it, and we have been I using that for our post-accreditation review. Q. 383. Will a change to FSAR Chapter 13 (to satisfy new 10 CFR 55 requirements) be considered a decrease in the scope of an approved operator requalification program requiring prior NRC approval, in accordance with 10 CFR 50.54(i)? A. No. That issue is addressed in the Statement of Considerations, where it indicates that this Rule supersedes all other previous requirements. Even though the Rule may have caused a decrease in the scope of your requal program it has already been sanctioned by the Commission in its approval of this Rule, provided your program is INP0 accredited. If it's not, then you must follow 50.54(i); so you must determine if it has decreased in scope. Q. 384. Applicable portions of Title 10, Chapter 1, Code of Federal Regulations are one of the lecture topics for a requalification program. Can you be more specific as to which portions of Title 10 are applicable, or is that up to the I plants to determine? A. You just cited the NRC Rules and Regulations, which includes such things as Tech Specs and amendments to licenses, and things like that. So, there are many Title 10 issues, including the radiation protection standards in Part 20. The subject matter of those lectures should be determined by the plants to satisfy the training needs of their operators. Q. 385. Paragraph (c)(3)(i) of Part 55.59 requires certain manipulations to be performed annually. This list of manipulations differs from the list in the Harold Denton letter of March 28, 1980. Our requalification program is based on the Denton letter. How long do we have to modify our requalification program to be in compliance with the new 55.59 requirements?" A. The rule supersedes and should include the requirements of the Harold Denton letter of March 28, 1980. If there are commitments in your program that go beyond those identified within the March 28, 1980, letter, then you will have to entertain an amendment to your Tech Specs to bring your program to that minimum level specified within the rule. Otherwise, we expect you to have a program that is modified and in compliance with rule by May 26, 1987. l i l l l NUREG-1262 107 l j

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 C61houn 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 Mcy 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 training, 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. i i 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

Q. 389. With respect to licensed operator / senior operator requalification train-ing, is it-appropriate that utilities assume they can take credit for the required annual and biennial plant control manipulations completed on a . simulation facility (nonplant referenced) if their programs have been approved ( 1 by the National Nuclear Accrediting Board? k A. Yes. Q. 390. Can a utility whose training programs have not been accredited by the National Nuclear Accrediting Board and which does not have a plant referenced simulator take credit for plant control manipulations that are performed on a nonplant referenced simulator? A. If that's what your approved program is now, then there will be no change to that approved program until you get your own simulator, or until May 26, 1991 at which time the regulation requires that the training portion be done on a. certified or approved simulation facility. There's an exception, in ' t Section 3, "On-the-Job Training," that you may substitute your accredited pro-gram for those requirements. So if you are able to talk INP0 into accepting a simulation facility other than a plant-referenced simulator, that's between you and INP0, but for the purposes of the staff's review, we would expect you to use the simulator after it has been certified if you do that before the May 26, 1991, with one minor exception, which has to do with the first six on-the-job items listed under 55.59(c)(3). In t hat case,The you need not have a certified words permit you to use simulation facility or an approved facility. another simulation device. Section 55.59(c)(3)(v) permits the use of a simu-lator which reproduces the general operating characteristics of the facility involved, if the arrangement of instrumentation and controls of the simulator are similar to those of the facility involved. It only requires the fidelity of a plant referenced simulator for the casualties. Q. 391. Must all six manipulations listed in Paragraph (55.59)(c)(3)(i) be performed biennially, or just one of the six? A. Items A through L must be performed annually. All the rest are performed biennially. All of the first six items must be performed, either on the plant i or the simulator. The rest are casualties, that must be performed on a simulator. Q. 392. Is it correct that Section 55.59 has now added fuel manipulations to i the required items to be done annually? They are more than what's in the Harold Denton letter. We have renewals coming up during the summer of 1987, and the training program has been ongoing for the last year. There may be some manipulations that, in fact, have not been accomplished on the simulator on an annual basis by July of 1987 that 55.59 now says should have been done on an annual basis. A. There are two parts to this answer. First, the requirements in Sec-tion 55.59(c)(3), with the exeption of the sequence, are identical to those in the Denton letter; no fuel manipulations are required. Second, although the new requirement exists, the annual manipulations don't have to be completed for everybody until the regulation has been in effect for one year. NUREG-1262 109

Q. 393. In 55.59, "0N-THE-J08-TRAINING," loss of electrical power is one of the manipulations that needs to be performed. Is that loss of off-site power or degraded power sources, such as the loss of half of your emergency bus or is it a total blackout? A. It may be both. That is, it could be a total loss of electrical power, or it could be loss of power, particularly involving buses or consoles. Q. 394. If we want to run those scenarios, either one would meet that? A. That is correct. But remember that, according to that Section, you may not do casualties on the plant. The break-out in the Regulation specifies that everything below a loss of coolant event is an accident. The malfunctions and faults are done on a simulator. But the permissive part is for the other manipulations, the control manipulations, that may be done on the plant or on a simulator. Q. 395. Must plant control manipulations during the requalification period be documented on Form 398? A. The documentation hasn't changed for that particular item of the 398 Form. You still have to certify that the control manipulations were done. Only where there would be exceptions to the guidance in Regulatory Guide 1.8 would there need to be some amplifying comments made. For example, if you did five similar manipulations, evaluated them and concluded they were acceptable, you might want to point that out in the comments section on the Form 398. Q. 396. If a license holder fails the written requalification exam or operating test administered by the Commission during the six year license term and sub-sequently participates in the approved accelerated requalification program per Section 55.59(c)(4)(v), will certification of successful participation in this program be acceptable for renewal, or will a second NRC-administered exam during the six year term be required? A. A second NRC examination will be required. That individual can go back on shift after failing the NRC requal exam, after participating in upgrade training and passing the facility's own evaluation. However, the terms of the Regulation are that for renewal he must pass an NRC-administered exam. Q. 397. Must licensed Operator training records be retained for the life of the plant? j A. Those that deal with the six year license, per se, only need to be kept for six years. However, some facilities have committed to record retention require-ments in their Technical Specifications which are more restrictive than this regulation. In order to get the relief that the regulation permits, you must submit an administrative change request to amend your Technical Specifications to make the record retention requirements equal to six years or the term of the individual's license. This Rule supersedes all previous requirements for operator licensing and training, unless you currently have a more restrictive requirement. In that case, there are two vehicles you can use. One is an amendment to the license, NUREG-1262 110

if a formal amendment is necessary. The other is a 50.59 review, which you can do administratively and then notify us that it has been completed when you indicate your other changes at the end of the year. In any event, you must conform to the requirements of the regulation, particularly those that are more restrictive than your current program. Two examples immediately come to mind. Most people today have an annual written The examination. The Rule would permit you to go to a two year examination. change to go to a two year exam can be processed under 50.59 and it does not constitute a reduction in scope if the change is for the purpose of conforming to the regulation. That is, the Commission, in the process of reviewing the regulation, concluded that there were compensatory measures for changing from a one year written exam to a two year written exam. In this case the compensatory measure is the annual operating test. So it does not fall into a reduction of scope and it does not require prior NRC approval unless it happens to be involved in an amendment to the license or the Tech Specs. Q. 398. This is a question about documentation of exams given at the plant. Under the requal program, it says that we must keep the student's answers for the period of the license. Does this mean that we must keep those exams as quality records and keep them for the lifetime of the plant, or are you saying that we keep it for the term of the license? A. It's for the term of the operator's license. And in this case, for example, his records would include six operating test examination forms, and three com-prehensive written examinations in his individual file, until such time as his license is renewed, and then you start over again. Now, if you use a segmented { examination in lieu of a comprehensive exam for each requal program, and you have more than three written exams, then that's a function of how you structure your program. You keep them only for the term of that individual license. Q. 399. So, are you saying for any operator exams that we administer, once we are past the renewal stage, we could destroy those as long as we have quality records to back up the fact that he had the exam -- in other words, the grades, and so forth? A. Given the fact that he was in a requalification program before, and you certified that, the answer is yes, you could put them in other quality records. Q. 400. On initial operator exams, are we required to keep the exam itself, or can we just keep a summary that goes in the operator's history file -- a sum-mary of his grades, and things like this? We currently keep the master exams l' and a copy of the answer key, but are we required to keep the individual student exams and his answers? A. Our requirement is that the actual exam, or copies of the actual exam, be maintained for the duration of the current license. When you get that license renewed, you may eliminate that material from the files and start over. Q. 401. So are you saying once an operator gets a license, we could do that on 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 written ex'aminations during the term of that particular license. 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 documentation. You mentioned keeping a deck log where you would recover strip 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 replay during an examination. The records that we are looking for are the same records that would be used for a post-trip review, essentially the same documentation. To the extent that the simulator has the ability to retain the scenario, and you can down load that to a computer tape, you could retain and use that tape. Q. 404. I'd just like to make one comment on that. That's fine, I think, if the scenario includes a trip. If you're starting in mode four with a scenario, it's more difficult to recover those kind of parameters that you would need to recreate the scenario. A. The problem with a TV tape is that it is incomplete. You may not hear discussions between the candidate and the examiner because of how microphones are placed. We generally stand back, but at times we are at the operator's elbow. We have been asked on numerous occasions whether the facility would be allowed to video tape for either record purposes or training purposes. We consider it intrusive, both on the candidate and the examiner, and incomplete. Q. 405. Most of the manipulations that are listed in the Regulation are not applicable to test and research reactors. Are we still operating under the ten manipulations in a two year period, as we have been in the past? A. If that was in your approved requalification program, it would remain approved. Q. 406.- Is it possible for requalification examinations administered by the NRC to be " split", such that the written and operational exams are given during different site visits? A. This is Regional prerogative, on a case-by case basis, with advance notice to the licensee. Q. 407. A licensed R0 is enrolled in the facility's SR0 upgrade training pro-gram. NRC chooses this individual, randomly, to participate in their requal program evaluation examination. He fails the NRC administered exam, yet he is passing or has passed all portions of the upgrade program to this point. Does he have to be withdrawn from the upgrade program, go through accelerated requal for R0 requal exam failure, and be reexamined, or can he just drop R0 qualification and pursue an SR0 license? NUREG-1262 112

A. A license 6 operator must meet the requirements of the facility's requali-fication program which generally requires accelerated training and/or reexami-nation. His status in other facility managed training programs is the preroga-tive of facility management. If the facility elects to " drop R0 qualification" for the individual under 10 CFR 55.5(a) the individual could make application for an SR0 license under 10 CFR 55.31. However, the individual would not be an SR0 upgrade candidate as that status assumes a active R0 license. Q. 408. Will written exams administered by NRC for requalification be totally objective, totally subjective, or some combination? A. They will be a combination of both. Some examination questions are writ-ten with the intent of meeting the definition of an objective question. An objective question is defined as one in which: (1) there is only one correct answer; and (2) all qualified graders would agree on the amount of credit al-lowed for any given candidate's answer. l Q. 409. Will persons holding a two year license be included in NRC requal exams during the transition? A. Persons with valid licenses may be included in NRC exams. However, re-newals will be under 55.57 which requires the facility licensee to indicate a need for renewal of the license. Please clarify paragraph 55.59(c)(4)(iii). What is being asked for? Q. 410. A. The regulation requires a formalized, documented system for evaluating the performance and competency of licensed operators and senior operators. The system must include observation of on-the-job performance and evaluation of the operator's performance and competency through the use of an operating test. The operating test must include evaluation of actions taken during actual or simulated events which require the use of abnormal and emergency procedures. Q. 411. Concerning parag'aph 55.59(c)(3)(iv), what does "on a regularly scheduled basis" mean? A. The facility licensee must establish a review schedule that will provide reasonable assurance that each licensed operator and senior operator is know-ledgeable of all abnormal and emergency procedures. At a minimum, the schedule must require the review of all abnormal and emergency procedures at least once every two years. Q. 412. Where preplanned lectures are part of the requal program, is it neces-sary that the licensees participate in all of these lectures, notwithstanding successful completion of the written examinations following these lectures, in order to be able to say that the licensee has met the requal program require-ments on the NRC-398 application? A. Under revised 55.59 no provisions for exemption of lectures is provided. If currently approved programs contain exemption provisions for licensed in-structors the programs should continue until the programs are accredited. NUREG-1262 113

INP0 guideline 82-026 contains exemption provisions for instructors who teach specific subjects; however, they must attend lectures in subjects they do not teach. Q. 413. Paragraph 55.59(b) implies that the NRC is notified when an individual fails a comprehensive written examination or operating test. Is this a requirement? A. The NRC does not expect to be notified if a licensed operator or senior operator fails an examination. Requalification programs have provisions for accelerated training. We expect facility management will provide the necessary retraining and reexaminations before returning to active license status an S l operator or senior operator who has failed a requalification examination. ' Q. 414. How will individuals who are in non-compliance with accreditated re-qualification training programs (i.e. extended illness, jury duty, etc.) be requalified? i A. Operators will be required to make-up missed portions of the requalifica-tion program and to submit evidence to the Commission of successful completion ! of the training. Q. 415. We have a program where we have licensed maintenance people as senior reactor operators limited to fuel handling. To what extent will this new rule apply to us, since in the comments preceding the rule there's mention that this is not being covered, that it's going to be covered as it is currently being done. For the past 14 years, as long as we've had SR0s limited to fuel handling, we have not been required to give operating exams. Our annual requalification exam is a written exam only. A. For a license which is conditioned to fuel handling only, the testing and requalification program should be appropriate to the license as it's condi-tiened. The licensee is not permitted to cperate the facility. You would therefore not be required to give him an operating test, as described in the regulation. l NUREG-1262 114

i i CONFORMING AMENDMENTS TO 10 CFR PART 50 l i l

Q. 416. The new 10 CFR 50.54(1-1) requires us to notify you of any change in the scope of our program. Since we are not defining for you what our program is now, what is it that you are looking for? . a A. Let's say thet you are using an NRC-approved program today, and you make a modification to that program to conform to the Regulation. Say you go from an-annual written examination to a comprehensive examination each .two years. You may do that pursuant to 50.59, and simply amend your FSAR at the next update. Or, preferably, you would be accredited, have completed your review of your requalification program, and confirmed it as.a systems approach to training. Both methods may be done pursuant to 50.59. They do not require amendments to licenses. It is only when you have committed to something that's a part of the licensing document. For instance, some facilities have the Denton letter incor-porated in their Technical Specifications, associated with staffing on shift. You need to look at your commitments on a case-specific basis for your utility. Our intent is that you be able to do most of those under 50.59. They would not require review and approval by the staff in advance of your implementing the change. Q. 417. Previously Part 50.54(i) referred to a decrease in scope, frequency, or duration. Now all you are saying is scope. Is that correct? A. Yes. The reason for that is that the Rule specifies that you shall have a duration 6f no longer than two years, end it must be followed. The program that you use through INPO describes content. Q. 418. What about frequency of the parts? A. That's covered by the systems approach to training, where you look at the task that is performed, and you decide what it is. And that's why we excluded the classroom, OJT, and examination portion of_requalification given that you certify that your program is done in accordance with the systems approach to training. For clarification, although you may be giving segmented exams in your requalification program, you should be aware that if NRC conducts a re-qualification exam at your facility, it will be a comprehensive written exam and will include an operating test. Q. 419. The systems approach to training in itself is subjected to revisions to the training program. Some of these changes may be considered, at least by the utility, as a reduction in scope. The statement in 50.54 is still there, where it says that Commission approval is required for a reduction in scope in a training program. How do we meet 50.54 and still comply with 55.59? A. The key words are "except as specifically authorized by the Commission." The Commission itself, in the Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, on March 20, 1985, particularly Element 5, indi-cates that it expects the program to be evaluated and revised as necessary, based upon job performance needs. We recognize that if you only added and never subtracted, you would eventually get to the point where you're putting all the time into training and never 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 that's more impor-tant, the fact that you've dropped something does not constitute a reduction i in scope for a systems approach to training. We believe that's a major improvement in the whole training process. You are not locked into doing something for the next six, seven, or eight years because you committed to it in 1980. You now review it and, if it's meaningful, you { perform it - you control that evaluation process. i I Q. 420. With respect to that area of 50.54 changes, which basically states that we will have a requalification program and that we cannot lessen the scope, what documents would be looked at as base documents to see whether we did or did not reduce the scope? A. We will look at your approved requalification training. program. l Q. 421. In the 50.74 requirement, you have set up some direction as to sending all correspondence for Part 55 to the Region. However, because this is a Part ' 50 requirement,- should we be sending that to the document control desk in ac-cordance with Part 50.4, which became effective in January of 1987? All cor-despondence required under Part 50 was supposed to go to the document control desk, with a copy to the Regional Administrator. Please clarify. A. Communications under each part of the regulation have to conform to the communications requirements of that part. Q. 422. Is the licensee definition under 50.74 the same as the licensee defi-nition in 10 CFR 55? A. Yes. Q. 423. If a licensee is out of conformance with the INP0-accredited training program, is that reportable pursuant to 10 CFR 50.72 and 50.73? A. It's not reportable to NRC, but you may need to report it to INPO, along with what you're doing to get back into conformance. It may be reportable to NRC if you have certified that someone is a graduate of an accredited program and that he has completed the program, then you find that you have not implemented 1 the program adequately. In that instance, you may have a reporting requireme.nt l to NRC. I NUREG-1262 116 I

OPERATOR LICENSING EXAMINER STANDARDS (NUREG-1021)

1 Q. 424. What weight does NUREG-1021 carry? A. The purpose of the Examiner Standards, NUREG-1021, is' to ensure uniformity and consistency among the regions in the conduct of the examination process. It provides direction to the regions on how we expect them to conduct the operator licensing function. We audit the regions against that Standard. It does not impose new requirements. That is, the requirements that are addressed in the Examiner Standards flow from other documents, whether it be a Regulatory Guide, or Regulation, or other guideline. That's why many of the changes to Examiner Standards described result from the change to the Rule, the more authoritative document. The standard contains ) policy on how to carry out the Rule. , 1 Q. 425. It was mentioned that the license examiners would be filling out a simulation facility fidelity feedback report. Could we request that those re-ports be included in our copy of the examination packages when they are re-turned to us? A. They will be. That has been incorporated into Rev. 4 to the Examiner Stan-dards. The simulation facility fidelity feedback report is contained in Exami-ner Standard ES-104 " Procedures for Postexamination Activities," as section C(3), which requires that a Simulation Facility Fidelity report be prepared for each examination including simulator evaluations of candidates. The Standard also requires this report to be part of the Examination Report sent to the facility. Q. 426. Will the Simulation Facility Fidelity Feedback Report be used to deter-mine the status of current simulators? A. The guidance to the examiners is that this information 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 receive informal feedback reports in the exam review process. And that will continue. If the Examiners have a problem conducting the operating test l at your simulator, you can expect some feedback, although it won't be as formal as would occur after certification or approval. Q. 427. It was stated earlier that once Form 474 is submitted, the simulation facility is certified in accordance with ANSI /ANS 3.5, and that there are three different mechanisms that may trigger the process of further evaluation: (1) questions regarding the Form 474 submittal, (2) random visits to the facility for evaluation, and (3) the post-examination activities associated with the examination at the facility. Would the procedures for the simulation facility evaluation feedback due by May

 -- specifically, ES-104 -- be specific as to the standards and criteria and mechanisms by which the examiners will make a post-examination evaluation of a facility that would then trigger the evaluation procedure?

A. No. The mechanism is intended to be essentially a simple comment sheet a that might contain a comment to the effect that "During Scenario X, the simula-tion facility failed to perform as expected. There was no flow coast down associated with reactor coolant pumps on a loss of power." i NUREG-1262 117 i

This type of comment would be collected and evaluated. Someone would then determine whether it raised a question in our mind that would be the basis for going back and looking at the simulation facility. It's not significantly different from comments on the simulator in the examina-tion report -- the inspection report that's issued following an exam. If there are a number of random failures, that's the kind of.information we're collecting. There is_no acceptance criteria threshold. It's the examiner's judgment. If he felt there was a problem, we're giving him a vehicle to write it down and communicate it back so that knowledgeable people can look at it and decide whether that would trigger an inspection or evaluation. Q. 428. Typically after that type of evaluation, there's not going to be a sig-nificant amount of data by which someone away from the facility, someone who was not there at the time of the examination, could make a very objective or accurate determination as to whether there is a problem with the simulation facility or not; and I understand that there are a significant number of freezes. If, during an overpressure incident, pressure continues to rise to 3,500 pounds, then obviously there's a problem with the simulation facility, but other ex-amples may not be so clear-cut. Therefore, there's a potential for NRC followup where, perhaps it was not warranted because of an evaluation made by someone who was not there when the event occurred. A. That's why we're getting the feedback from the examiner who was there at the time it occurred. The facility will also receive a copy of the writeup with the inspection report, and I'm sure it will be a subject in the exit briefing with the chief examiner at the end of the exam week. We think there are adequate mechanisms in place to alert the facility as to ) what the potential concern is, but most importantly, we want to get feedback on how well the simulation facility is working during an examination based upon an examiner's observation of that simulation facility. Further, we have been increasingly requesting that facilities record data during simulator exams to the greatest extent possible so that information is available for review on a more objective scale. Q. 429. We are required to complete training and experience blocks on Form 398 because we don't yet have an acceptable simulation facility, even though we have an INP0-accredited program. Will we still be evaluated in accordance with current ES-109 requirements? A. Yes. Q. 430. Under eligibility, you previously cited Examiner Standard 109. In the future an accredited program with an acceptable simulation facility may be substituted for eligibility. Examiner Standard 109 says two years of power plant experience is required. Does that requirement remain? A. A facility with an INP0-accredited training program that utilizes a certi-fied or approved simulation facility need not meet other experience requirements. NUREG-1262 118

Revision 4 to the examiner standards revises ES 109 to conform with the Regulation. Q. 431. Examiner Standard 109 lists the eligibility requirements for licensed operators and senior licensed operator applicants. One of these requirements is that each individual spend three months on shift as an extra man under the supervision of a licensed or senior licensed operator. Is this requirement still in effect? Where does this requirement come from, given that it is not addressed in 10 CFR 55, and the new revision supersedes previous requirements? A. Although not a requirement, this is consistent with our past practice, and it's consistent with Reg Guide'1.8, which endorses ANSI 3.1-1981. It will be continued in ES-109. Facility licensees can ask for a waiver, and their re-quests will be considered. Q. 432. Examiner Standard 109 says that training conducted as part of a license program cannot count for experience. But ANSI /ANS 3.1-1981, which is what the Commissioners have told us to use, allows related' technical training to count for experience. Is ES-109 in compliance with 3.1? l A. The training time that doesn't count as experience refers to the training ! required by the approved license program in which the individual is partici-pating. Related technical training refers to training he may have received in another position, such as auxiliary operator. This time may be counted, up to a certain percentage. Q. 433. There was an article in Nuclear News, January 1987, page 42, that says the average pass rate for the industry on requalification exams administered by the NRC is 78 percent nationwide. Examiner Standard 601 says that in order for a requalification program to be evaluated as satisfactory, 80 percent or more have to pass. This indicates that the industry, nation-wide, has less than a satisfactory requal program. Do you agree? A. No, because the statistics that Nuclear News used are somewhat question-able. Last year we evaluated 17 facilities, and 5 of them fell in the marginal or unsatisfactory category because they had substantially higher failure rates. So, a few are causing the national statistics to be different. It was similar the year before, when we had five facilities that were in the marginal or un-satisfactory category. The program evaluation is based upon whether 80 percent or more pass. It's not based upon the average scores of the candidates taking the exam. In other words, if you examine 10 candidates, and 2 fail, you have 80 percent passing and we determine that program is satisfactory. The average score on that exam may be 78 per cent because the 2 people that failed scored in the 60s, while everybody else scored above 80. Q. 434. Assume that NRC comes in to give the utility requalification exams, and the scores are between 60 and 80 percent and are rated marginal. After the utility modifies their program, reexamines those failures, and comes out with a satisfactory grade, does NRC change that from a marginal to acceptable program? A. The marginal rating would be based on the examination given, in accordance with ES-601. We evaluated the program and identified individuals with weak-nesses. They require remedial training, which is given. Their training will 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 j 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 you request, we can provide you a copy of Attachment 5, which contains our objec-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 Generic Letter 87-07

           "%g
    +              Jg                                UNITED STATES

[ p, NUCLEAR REGULATORY COMMISSION 5 ;j WASHINGTON, D. C. 20555

   %,...../

MAR 19 ;gg7 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 Comission, Region II 101 Marietta Street, Suite 3100 Atlanta, GA 30323 (404) 331-5594 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 Comission, Region IV Parkway Central Plaza Building 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 (817) 860-8147' Mr. Phillip Morrill US Nuclev Regulatory Comission, 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 Comission, Region III 799 Roosevelt Road Glen Ellyn, IL 60137 (312) 790-5566 8703190287 A-1

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 1 631 Park Avenue 19406 King)ofPrussia,PA (215 337-5211 Enclosed with this letter is a double-spaced copy of the regulations and supporting information for your review prior to the public meeting. You are encouraged to forward questions to the appropriate point-of-contact, one week prior to the date of the meeting which you plan to attend. The staff 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, all licensees 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 f training program for initial and requalification training programs previously approved by NRC. This option may.be implemented upon written notification to the NRC and does not require any staff review. However, because of conflicts between previous 10CFR55 Appendix A requirements and a systems approach to requalification training, it is necessary to certify that the substitute training program is both accredited and based upon a systems approach to training. The superseded training program description contained in the FSAR need not be revised until the next update required by 50.71(e). Sincerely, Q .v u s. h A us - 3% \

                                                                                       /arold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

i As stated A-2

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                                                                                                                                                   .                      l 8

10 CFR Parts 50 and 55 r Operators' Licenses and Conforming Amendments - a

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Federal Register / Vol. 52. No. 57 / Wednesday, March 25, 1987 / Rules andpgulations 9453 r a, c.

1;/ not a " major rule" Based on :nfowtfra respect tchhis interin. rule are

                       /knevu S'ucellosis in cattle for the                                                                                                                     '

pt-iod i (12 months preceding conciled by the Departmeat we have bpractice:le and contrart to the public i interest. and good cause is found for i cler.si1Wion as Class Free.ne Class C dere rmined that this rule will hve an effect on the economy of less than 'I.00 making this interim rule effecti v iess s vlassifH dor is for States or arehr with

            /            Be highes: ras d Sicellov. . with                mi' lion; will not causu w jor increase       than 30 dcys after the publicatLn of tb
                         .: lass A sp%!ssiB in between.                   O costs or prices iv. censumers,              document in the Federal Registar.

indivuual indnetrict NLral. State. or Corunents are being solicited for 60 ) Restrictiu s on the rnovement of catt!ri fI are ree stingent for moveir.ents frou local govervaev eger.;ies, or days after publication of this document. ' Clau A States or areas cer ;ared eith gwgraphic regionx ar.i will not cann a and a final do::ument discussing movet tats from Free Stato or areas, signiNrW ad. e .a effect on comments received and any and art. inore stringent for movements compeNon, employne,'nvestment, . amendments required will be published

      )                  from Clo..s B States or aitw cor npared          productivity, innovation, or on de             ir the Fadoral Regist.ar a9 sory. is u"                                                                         abil& of UnM Statu. bawd                       pon.ble.

with movemente from Class A ! Mates or t areas. and en em. enter; rises 6 2,af.Ce with foreip Ust of Subjects in 9 CFR Part 78 The basic standards for the d&ent baseu enterpaus in domestic on exprt r.lassifirrice,of States or arena. markets. /bimal daeases. Bmcellosis. Cattle.

            ,            og cc:.1 reintenance of:(1) A cmtle                   For this acticn. the Office of            Hop. Quarantine. Transportation W infect on rate, based oc the number Management and Budget has wiived it.s review process required by brutive            Pes JC 78-BRtJCEU.OSIS
                           >f he-ds focnd to have bruceshh -

reactors, not to exceed a . tad hvtJ Order 17291. dW KFR W8 is during 12 consecutr/ ! moi. he: 2) e ime Ca'tle moved interstate are mwed for amended se fdlows: of infection in the en fle ;when. slaughter. for use as breeding stock, or l 1.ne oathaty citation for Part 78 based on the percere. sO.uediosic for feeding. Changing the sta:as of Alabama reducce cMW testing and continues to reed a fo tows: roctors found b Mamt ".;: ttle othe? requiremen.s e n tha i.iterstate Authertty: 21 U.S C. n1 14s-1.1146 115. Ides fication (M;I)-test ng at 117.120,121.1W26, th 134f. 7 CFR 2.1% e att 9 ards and slavshtcring moveme. it of tme 4,atik 15 isver. 2.51. and 371.2(di M w[ Ahments.--not to exceed a stated catth fnm eMited bru&&fte ', Wh il) a surveillance system that hese moWnt Mterstate are not a&cted g .w g,w.ng ' m uirs testmg of dairy herds, b tAese chivs in sti tus. We have 2. Section 78.41, Pare 6raph (b) i participation of all slaughtering , de%.ined that the chcages in arm nded by adding .. Alabama, s estabhshments in de MCI program. b.ui.clk sis s ma made by this immediately before "Antons . identification awl o nnitoring of herds at docuant wui not affect market patterne 3. ScRn 7m. paragraph (c) is high risk ofinfem i. neluding herde ud v.I not hee a signif:camt economic rnen4i by removmg Alabama ,. adjacent to infected herds and herds impaa on the.M persons '.ffected by this document. cone in Washingtrm v o. : 20th 4,y of from which infectedL nimals have been March.1987. sold or received, ac ;(4, mirumum Under these rsrcumstances. the procedural strnderds for u ' ministering AdmirEstrator c loe Animal and Plant B. G. Joinson. the prcgrara Health luspectio's krc ice has Depu'y Admmistmtor. veterinary Sevices

                                                                                                                           .A pjpg / ggg p/gp( ypg/gh fppppg(ggp $pryjgy, Pnor Q 6.c dfective date oiMhis              determined that tl.is action will not b .ve docump.T. Alabama was clessifiet: as a           a signifkeni enonoraic irr. pact ort 9         [FR Doc. 87-6421 Filed 124-6L 8 45 am]

ClM f tate because of the herd substantial nwnber of sm@ #. ties. araneo coos um.u-u in ectim rett anJ tha MCI reactor NMive Order 12372

               ' -         pe..r.Jace iate.However a review of

ne i rum /e er program utablishese M This pruram/actiuty te'isted in 6e NUCLEAR REGULATORY Alnan 6 etnuld be riarmid te C1Jss A CWalos at Federal Domestic Assistance COMMISSION ater No.10.025 and is subject to tb y , s h tus.

la order u .%.. and maintain Class provisions of Executive Order 12372. 10 CFR Parts 50 and a5 A sinux a State or area must (1) not which requires intergovernmen%1 exreed a cattle hwi miection tr.te, due consultation with 9 ate and iN Operators' Ucenaea and Confeeming to field stra;n Bmeeaa ubortus of 0.25 officials. (Se 7 CFR Part 3015. Subpsrt Amendmente I I percent cr 2.5 herda ses

Or i based on V.)

ActNcy: Nuclear Regula t.ny. the numk of reactors .ound within th? Emergency Am.. State or area dunng any 12 consecutive Commission. i months, except in htes with 10.00u or sDr. John K. Atw# Deputy AcTeose. Fma! rrle. - fewer herds;(2) maintain a 12 Administrator of the Ammal and Plant consecutive months MCI reactor W alth inspection Service for Vetra rinary sussetAsty:The Nucir.ar Regulatory Servicce. t se determined that an Commission is amendmg its regulations prevalence rate not to exceed one to (1) clanfy the regulations for boutrig reactor per 1.000 cadlr tetted (0.10 einemoc,. situation exists, which warrents pbbcation of this intenm rule beenses to operators and seruor percent); at@,3) havt sti opproved individual J erd pha ;;i effect withh 15 without priot opporter.ity for public operatore; (2) revise the requirements comment. Irrac# i action is and scope of written examination.a and days of locating the source herd or wctranted m orche 'o delt;te operating tests for operators and senior recipient herd Alaoame now meets the unnecessary restrictions on the operators. including a requirement for a criteria for classification as Class A. "

                                                                             *          '*****          ' * " " U           ** * " "'                  '    #E Executive Order 12291 and R'8ulato'I            from Alabama.                                  for administering requahfication
    >     .                  Flexibility Act further, pursuant to administrative        exerninations; and (41 desenbe the form Weerr asuing this rule in                     procedure provisions in 5 USC.533. it is and content for operator hcense confor nar e w th Executive Order               fr; nd upor. good cause the. prior notice     4.p >hcationa. The rule ie necessary to 12291. and we have determmed that it is         un d other ribbe procedures with              meet NRC respcalbihfie. ur. der Seuicn el pw                       ,

q.

I 54 rederal Regist:r /_ Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 306 of the Nuclear Weste Policy Act of Brsnch, Office of Nuclear Reactor " Medical Requirements." A 90-day 19B? Regulation, U.S. Nuclear Regulatory comment period expired on February 25. DANtS: Effective Date Mr.y 26.1w87. Commission, Washington. DC 20555. 1985. Comments were received from 88 Public meeting detes: April 9,14.18. and Telephone: 301-493-4868. respondents. An additional 47 20.1907. FOR FURTllER INFORMATION CONTACT: respondents commented on the three ADDnFssES: Public meeting locations: Chief. Opera tor 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 i implementation of the rt:,wewnte.of Nuclear Regulatory Commission. a detailed analysis of these comments this rule. The meetings vus held as Washi.ngton DC 20555, Telephone: (301) and their resolution are available as follows: ,

                                      .       492-4868-                                    indicated under " ADDRESSES:",                                         I A. April 9.1987 for Region If,Wdard     SUPPLEMENTARY INFORM ATION:                      These proposed revisions to 10 CFR J

B. Russell Federal Building. Sem Part 55 were to improve the operator Auditorium, Lower Level. 75 Spring I*BackNd licenairy; process and to achieve the Street, SW., Atlanta. CerW4. Section 107 of (b Atomic Energy Act following objectives: i Point of Contact. Mr. L.x etn E. of 1954, as amended (42 U.S.C. 2137), B_rockman. U.S. Nuclear Regulatory requires the Nuclen F.egula'ory I*{,]*

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                                                                                                           ,,  , , by imp Y

ov ng the enission. Region 11.101 Marietta Commission to pres enbe unifw:n r Stret. Suite 3100. Altanta, GA 30323, conditions for licensing individuals as operator licensing process and examination content, (404) 331-5594. operators of pro;rction and utilization R April 14,1987 for Regions IV and V, facilities and to 6termine the (2) Provide the NRC with an improved Sioufler Concntse Hotel,3801 Quebec qt.alifications ohhese individ>tals and to basis for administering operator Street. Denver. Colorado ( Across from issue licenses to such individcab. The licensing examinations and conducting Stanleton Airport). regulations implementirt h operating tests, and I f )mts of

Contact:

Mr. Ralph Colley, requirements are set out in Part 55 af (3) Respond to the specific direction U.S. Nuclear Regulatory Commission, Title 13, Chapter 1. of the Ccde of given by Congress in Section 306, Region IV. Parkway Central Plaza Federal Regulations. To assist licer's ces Nuclear Waste Policy Act of1982, Pub. Building. 611 Ryon Plaza Drive, Suite and others, the Commission riso has L. 97-425. to promulgate regulations and i 1000. Arlington. TX 76011, (817) 860- issued regulatcry guides and generic guidance in the area of examinations. 1 8147. letters that provide guidance en Ort March 20,1985, the Comrrission Mr. Phillip Morn 11. U.S. Nuclear acceptable methods of meetN these published a Final Policy Statement on Pegulatcry Commission. Rep.m V.1450 regulatory requirements. Maria Lane, Suite 210. W sinui Creek. Training and Qualification of Nuclear The Commission has become CA 94596. (415) 94h3M. increasingly aware of the need to up; fate Power Plant Personnel (50 FR 11147) that C. April 16,1987 for Regson Ill itn operator licensing regulations and describes the Comm.ission's current Ramada Hotel O'Han . 6000 N. related regulatory guides.These policy regarding training of operators. In Mannheim Road (corner of Higpns), revisions are needed to clarify the addition to this policy statement, the Rosemont. Illinois (One mde in.*tu extent to which simulators should be Commission is publishing the new rules O' Hare Airport). Phone: (312) P.2b5131. used in licensing examinations and to ciescribed in this notice; these rules Point of

Contact:

Mr. Thomas lhttdick, reflect upgraded requirements for supercede all current regulations for U.S. Nuclear Regulatory Cormuksion, licensed operator selectiori, training, and operator licenses. Those facility Region !!!,799 Roosevdl Roa 1, Clzn r4 qualification programs resulting from licensees that have made a commitment Ellyn. IL 00137,(312) 7K 55fd the accident at TMl-2. Although tise that is less than that required by these D. Apnl t*t.1987 for Region I, Hilton Commicsion has been acth ely engaged new rules must conform to the new rules Hotel Valley Forge,251 West DeKalb in inver.tigating these matters, the automatically. Those facility licensees Pike, King of Prussia. Pennsylvania, schedule for comp!= ting these activities that have made a commitment different { Phone: l7151337-1200. was further accelm ted by the from or more than that required by these Point 4 '.ontact: Mr. Noel F. Dudley, enactment of January 7.1983. of the new rules for licensa amendments and U.S. Nuclear i e gulatory Commissis , Nuclear Waste Policy Act of 1982, Pub. technical specification changes, may Region L 631 Park Avenue. King of L. 97-475. Secon 300 of that act (42 apply to the Commission so that they Prussia, PA 19406. (21M A17-5211. U.S.C.10226.W Stet. 2201 at 2262-2263) can conform to these n-w rules. Other Background information for the rule directs the NRC 80 establish (1) chanpa should be made in accordance includes a copy of the regulatory simulator traids requirements for with 10 CFR 50.59. analysis, the supporting statement for applicants for operator licenses and for the Office of Management and B+4: Production fa":llities previously operator requalification programs, (2) clearance of the information crXection requirements governing NRC incluoed in Part 55 are not referenced in r tquirements. Regulatory Guid. s. ANS!/ admir,latration of requalification the revisions since there are no ANS standards, NUREC-series exammeians, and (3) requirements for operators at production facilities documents, other documents Er.mri operethg tests at civilian nu dear power currently licensed by the Commission. in this notice and reports that ccrab a plant ulmalators. Although special consideration has been detailed analysis of the public Or zum ember 26.1984, the given to the smaller size and scope of comments receiwd during the pulfic Cammission published pro;>osed ter,t and research reactors the comment period end their resobtion amendments to 10 CFR Part 55. req:drements in this notice apply to all may be em%ed at the NRC lutlic " Operators Licent.es"in the Federal u!D; ration facilities licensed under to Document hm.1717 H Street NW., Register (49 FR 46428). These CFR Part 50, including test and research Wa shington. DC. amendments proposed granting, in part, rebetars. Consequently, except where A single copy of the reports a petition for rulemaking (PR.M-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. Opciator Liccarng discussed more fully under Section II.B. to test and research reactors. D-2

Faderal Register / Vcl. 52. No. 67 / Wednesday. M:rch 25, 1987 / Rules and Regulations 9455 ) II. Summary of Public Comments and requeeted clarification about the Plants." 8 De intent is to prevent the Final Actions limitation of the conditions under which manipulation of the controls by an operator whose medical condition and The proposed amendments to improve the plant could be used. the operator licensing process have been it is not the intent of NRC to permit or general health would cause operational encourage the initiation of transients on enors endangenng pubhc health and I modified in response to the conunents received. A summary of the public the plant when and if the plant is used safety.ne medical requirements rely j as a simulation facility. The use of the on exarnination of the applicant or 1 c;mments and, where appropriate, a plant is envisioned se a possible operator by a Incensed physician who description of the changes that resulted approach that a facility licensee might evaluates the medicsi conditon of the from them follows. operator, based on the cnteria of ANSI / (A) Cenero/ Comments-{1) Geneml propose to use in conjunction with another simulation device or devices, in ANS 3.4-1983 that is endorsed by parpose of these omendments. Several commenters provided general support lieu of a plant-referenced simuistor.%is Regulatory Guide 1.134. " Medical f r the proposed rule.Other commenters approach might be suitable, for example. Evaluation of Licensed Personnel for suggested changes to clarify the purpose for older plants without access to plant- Nuclear Power Plants." and makes ) tod axemptions sections.These sections referenced simulators, where recommendations to the facility's 1 were reworded as a result of the management. The facility's management manipulations of the plant, to the extent evilcation of these comments. In is resp nelble for certifying the consistent with plant conditions might su tability of the applicant for a license. p:rticular, the purpose of the rule be used to demonstrate familiarity with Indicates that terms and conditions of %e NRC has the responsibility for the plant for which the candidate would makmg an assessment of the applicant operators licenses and renewal are be licensed' covered. Exemption for trainees at a for a license, including the applicant's Several commenters suggested that medical fitness. Neither the facility not f cility is clarified to indicate that a the definition of" reference plant" trainee is only exempted while the NRC staff will make medical should not be specific to a plant and its judgments. When a conditionallicense p2rticipating in an NRC-approved training program to qualify for an unit.The word " unit" has been deleted is requested, the NRC will use a i 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 tnedical evidence submitted by the !' they are supervised by a licensed senior refer to a specific docket number. For facility to make o determination. For operator. those situations in which a multi-unit minor conditions, such as the need to (2) Definitions. Many commenters Pl ant 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 modtfied to definitions in the rule. A trumber of only one simulation facility would be simplify the process for obtaining a commenters addressed the definitions of required. For others. Regulatory Cuite medically conditioned beense.

simulation facility" and " Plant- 1.149 provides specific guidance for Moreover, while the biennial medical rzftrenced simuletor " and requested those facility licensees that want to examination required under 155.21 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 partial facility for use at more than one nuclear dependency or both, no reference is conduct of operating tests. Several power plant.nis guidance is 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 ref:renced simulators would be granting of multiunit operator's licenses. Policy Statement on Fitness for Duty of permitted. (B) Medicolequirements-{1) Nuclear Power Plant Personnel (51 FR The definition of a " plant. referenced Criterio for medicof requimments. Most 27921), published on August 4,1986, by simulator is intended to mean a commenters agreed with the revisions to the Commission. In addition, the license simulator that meets all of the the medical certification process, which renewal period is changed to 6 years to requirements of ANSI /ANS 3.5-1985, 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.

Form NRC-396, as revised. Some, in July 1983. KMC Inc., petitioned the F cilit es or Use i p a r cease commenters questioned the relationsh,ip Commission (PRM-55-1) , to simplify the Examinations." (see Section V. f 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). licenses., KMC stated that the c mmenters were confused about who The definition of a " simulation would have responsibility for current procedures require that a facility"is intended to provide for detailed medical history and results of flexibility in the conduct of the simulator determining the medical condition of an the applicant a rnedical examination by operator or applicant for an operator's (non-plant-walkthrough) portion of the a licensed physician be sent to the operating test.The intent is to permit. license. Some comments were made Commission. The petitioner requested under circumstances specified in to CFR about the specific language in the that the Commission amend its 55.45(b), the use of the plant itself, and/ medical requirements regarding disqualifying conditions and regulations to permit designated medical or a plant-referenced simulator, and/or commenters requested changes or examjners as defined in ANSI N546-some other type of simulation device 1976. ' Medical Certification and such as a part. task or basic-principles clarification. Many commenters noted the need to adjust the medical Monitoring of Personnel Regumng simulator, for the conduct of the Operator 1.icenses for Nuclear Power simulator portion of the operating test. requirements to the renewal cycle. ) Plants, t certify that the applicant has i A number of commenters expressed The medical requimments reflect the concern that a plant, when used as a industry standard articulated in ANS!/ ANS 3.4-1983, " Medical Certification

8"dd' d"d * 'h's rule are a vadable simulator, could not safely perform the full range of functions that a simulator and Monitoring of Personnel Requiring 's$,C N AT M M M M, '

l rould perform, and some commenters Operating Licenses for Nuclear Power eas:s. B-3

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 N546-1976 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 operstmg 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 utihty 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, m part, by chmmating to the NRC on Furm NRC-398. 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 operator a license phrase " learned to operate." This phrase operating tests at a facility. Ultimately, directly to the NRC. Inrtead as has been deleted from i 55.31 and the NRC testing objectives will reflect described above, a certification to NRC facility licensee developed learning replaced by wording which indicates about compliance with the health that if a candidate successfully objectives. In the interim, while these requirements m 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 # incapacitation operator, the NRC will conduct the activities underway to improve the because of disabshty or illness. Some appropriate examination and operating content validity of NRC examinations confusion was noted by several and operating tests. commenters regarding the process t test. Section 55.31(a)(5) has been added to specify the n.inimum number of (2) Specific wording of categories. notify the Commission when an operator control manipulations to be conducted Many commenters made specific was incapacitated because of disability wording recommendations for the by an applicant. Details regarding other or illness. The final rule is changed t categories listed under content of the training and qualification will not be reflect more clearly the Commission a written examinations and operating test. requ red to be supplied on Form NRC-mtent. That is,if du, ring the term of the 398,if these requirements are contained These suggestions were reviewed by license, an operator e medical condition subject-matter experts and changes changes and does not meet the n an NRC-approved training program that t:ses a simulation facility were made to clarify or improve the requirements set forth in ANSI /ANS g 3 4-1983, notification of the Commission acceptable to the NRC under i 55 45(b). resulted except to two categories under by the facility licensee is required. At Subject to contimled Commission the operating test. Under i 55.45, the same time,if the examining endorsement of the industry a categories (12) and (13) were reworded physician indicates that the condition accreditation process under the Final , gggi, , - can be accommodated as noted in i 5.1 Policy Statement on Training and (12) Demonstrate the knowledge and ability of the ANSI /ANS 3.4-1983, a conditional Qualification of Nuclear Power Plant as appm a gned on ' license may be requested by an Personnel (50 FR 11147; March 20,1985),

                                                                                                 ,                                                       ,          d authorized representative of the facility                             a facility licensee a tratnmg program               the safe operation of the facihty.

licensee. Form NRC 390 must be used would be approved by being accredited by the National Nuclear Accrediting (13) Demonstrate the applicant's ability to and supporting medical evidence must function within the control room team as be supplied. However, the f acility Board' appropriate to the assigned position. in such a licensee does not have to wait for (D) Written examinations and way that the facility licenset's procedures are permission from the Commission before operating tests--(1) Content. Most adhered to and that the hmitations in its returning an operator to licensed duties, commenters recommended that the hcense and amendments are not violated. principal means of determining the ' If the operator has been examined by a (3) Waivers. Several commenters physician. who, using ANSI /ANS 3.4- knowledge, skills, and abilities to be suggested that examinations and tests 1983 as a basis, has recommended to the included in operator licensing written be automatically waived under specific facility,a management that the operator examinations and operating tests should circumstances. As the agency can return. be the learning objectives derived from responsible for public health and safety (3) Test andresearch reactors. Many a systematic analysts of the job with regard to nuclear facilities, the test and research reactor operators were performance requirements.There 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 exammations 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 facihty. in NUREG-1021. " Operator Licensing operators. for whom ANS!/ANS-15.4- Conversely, some commenters Examiner Standards." 8 1977(N 380)," Selection and Training of questioned as premature the Personnel for Research Reactors." endorsement by NRC of a systematic , gg,Rr.c- enes document er, eveilable for requirements continue. analysis from which to draw the content pm m.p cuen end copyms roe a fee m ihe (C) Applications. Applications for an for licensing examinations and tests. - commission a Pubhc Document Room et 1717 H operator hcense rtquire the facility One commenter recommended that NRC caanand B-4

Fedtral R:gistrr / Vol. 52, No. 57 / Wednesday March 25, 1987 / Rules and Regulations H57 (4) Integrity and examinations and periodic " subsequent" application has event that simulator design changes fests. Althot gh many cummentars .been eliminated. In support of its result in significant simulator supported the addition of 5 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 i 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.C. 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 i 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 not apply to situations such as.        .

(2) Performance testing. Many operations but be able to safely cope discussions after an examination is comments addressed the requirement with plant transients and malfunctions. admmistered 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 (E) Simulation facilities-(1) conducted over a 4. year cycle. 25 factor in the examiner's assessment of Application process. 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 proposed rulemaking. ANSI /ANS 3.5- negative training. which could result tia and a se uent apphcat for "9 * *N N* "' ' * * " * * * * "* Y approval to use a simulation facihtv. 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 facdity to the NRC that the simulation facility met specified that all malfunctions which a faithfully portray plant malfunctions as industry standards should suffice, when simulati n facility was capable of well as heneral operability is to be combined with the NRC's ability to peri rming 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 fmal rule to reflect the position taken in Commission,s regulations. A definition burden of conducting these tests would these comments. Any facility licensee of performance testing has been added demand an excessive amount of time on 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 in the applicable paragraphs of simulator that meets the requiremeals of suggestions were made proposing lists i 55.45(b), as they apply to all ANS-3.5,1985.

Nuclear Power Plant f performance tests thought to be appropriate, suggesting alternative simulation facilities, whether certified or Simulators for Use in Operator approved.

Training." as modified by Regulatory f rmulas for the cycle of performance Guide 1.149) wdl be required only to testing or offering suggestions that the (3) Schedule. A number of comments rule merely endorse a new version of the included criticism of the time schedules certify this to the Commission. and to specified as being unreasonably short maintain records pertaining to mdustry standard which was in preparation at the time. for submitting a simulation facihty 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 published after the expiration of the The regulation has been changed to simulation facility that is other than a public comment period. In response to allow 1 ) ear (versus 120 days) for a plan referenced simulator wdl be required to submit a plan detaihng how the comments received and to the newly facility licensee to submit a plan issued industry standard. R G.1.149 has detailing its approach to the simulation the requirements of I 55 45 will be met 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, facihty to be in full compliance with the facihty. 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 However, although the new standard simulator will not bas e to sul.mit a plan. application process has been greatly simphfied. and the requirement for a continues to require the conduct of (4) T'eno/tyfor unavailability of simulator performance teats. it haa simulation focdity. Several comments deleted the requirement that these tests expressed concern that the penalty was Streci NW..weshmston DC Three documnts may too harsh for the unasailabthly of a ter purchased from ihe U S Gmemment Prmimg be conducted on a four year cycle for omce icPoi t, unms zo:-zwo or in mma the life of the simulator. Instead it has simulation facihty acceptable to the the cro. P o non nmz w..hmp'on tr imib substituted an annual operabdity test. Commission.

and now required that performance tests It is the Commission's intent that Nn).'IifUmYa eNei[sY 0me*n$ be conducted only upon completion of esery facility bcensee have available a commme. szas Pori Roy.i so.a sprmgf<eid v A

let initial simulator construction and in the simulation facility that meets the B-5

9458 Federal Register / Vol. 52. No. 57 / Wednesday. March 25. 1987 / Rules and Regulations

 ' Commission's requirements within a           senior operator licenses from the final                                                      months or longer. Therefore, the reasonable period of time after the          rule. This action is in 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 a minimum of seven 8-hour shifts or continue its acceptabihty 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 recogmzes 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 bcensee are current and the in the rule and that. from time to time, a   will be monitored as described by the                                                          ['jk*j,'g                 ho    SU$NSP eted       9d r i previously certified or approved             Policy Statement. Moreover, senior                                                             the direction of the operator or senior                I simulation facility may become               operator licenses limited to fuel                                                              operator, as appropnate. and in the position temporarily unacceptable for the             handling will continue to be issued as                                                          to which the individual licensee will be conduct of operating tests. It is the        they are currentl 3. However, cince                                                             assigned. For licenses limited to fuel Commission's intent to address any such industry accreditation includes                                                                     handling. one supervised shift is sufficient.

situations on a case-by-case basis, instructor evaluation, current NRC Certif cation shall be maintained at the (5) Lock ofguidancefor ossessment. 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 longer the Commission m its assessment of specific suggestions regarding the ecessary to include the wording simulation facility adequacy was not yet requirements for special senior n.. actively and extensively engaged" available,it is the Commission s intent operators.These comments are no under requalification. A licensee can that no simulation facility audits will be longer applicable since the Commission now maintain licensed status by c nducted until this guidance has been has deleted these licenses from the final successfully completing the facility fully developed and made publicly rule. I censee's NRC-approved requalification available for a minimum of 6 months. (2) " Actively performing the functw.ns program and passing the requalification

16) Applicability to future facility of on operator or sernor operotor* examinations and op? rating tests.

hcensees. Several commenters Altaough only one commenter However, to return to active questioned whether the Commission,a specifically questioned the definition f. performance after a period of not regulations regarding simulation

actively performmg the [ functions] of. participating on shift, the conditions of a facilities were intended to apply to a great many commenters questioned future facihty licensees. this phrase in regard to R.G.1.8. license in i 55.53(f) must be met. In this manner, a licensee without current it is the Commission's intent that , Personnel Qualifications and Training knowledge of the facility would not be these regulations apply to future facihty for Nuclear Power Plants." as it was able to perform shift duties.

licensees as well as current facility published for pubbc comment in For test and research reactors, the hcensees. conjunction with the proposed rule. (7) Test ondirsearch reactor From the comments made in response to requ rements for" actively Performing operators. Several test and research the regulatory guide and other the funct, ions 0f reactor operators were concerned that 9P , ,, 9 }d et comments made regarding the provision the requirements in the rule changed the in the rule under "Requahfication." o.f f ur hours per calendar quarter. licensing process for them. As stated which required that an operator or Similarly. under i 55.53(f). a minimum of above, the rule does not change the senior operator be " actively and six bours parallel work would be status quo for this category of opera *or. extensively engaged" as an operator or required to return to active status. The definition of " simulation facility"in senior operator. It in clear that many (3) Notification of the Commission. l 55.4 allows the plant to be used to commenters were confused about the Some commenters noted that the meet the requirements of i 55 45(b). In degree of participation in tant Commission had no need to know about addition, specific wording in i 55 45(b) operations that is require as a the criminal conviction of a licensee. ermits test and research reactor facility condition to maintain an operator's or However. 6 55.53(g)is intended to cover icensees to be exempted from crimm, al behavior. NRC is interested in senior operator's license. To prevent submitting a plan for the use of a further confusion, the rule has been felonious criminalconvictions of a simulation facility that is other than a modified in i 55.4. " Definitions." to licensee.The NRC considers that there plant. referenced simulator. provide the following definition: may be a relationship between (F) Licenses-(1) Specialsenior condchon for a felony and % Actively performing the functions of an operotor heenses. Many commenters operator or senior operator" means that an performan,ce, questioned the issuance of special individual has a position on the shift crew (G) Expsrotion. 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 re uirements were sufficient, others specifications. and that the individual carries and the NRC, a five year expiration was in icated that industry. accredited out and is responsible for the duties covered proposed. Many commenters suggested programs include instructor evaluation, by that position. that 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 " active" requirements.The renewal cycle has Personnel as conflicting with these status following a period during which a been changed and licenses will now licenses. licensee has not been " actively expira after 6 years. The Commission has deleted the performing the functions of an operator (H) Requalification andrenewol-0) provision for the inseance of special or senior operator" for a period of 4 Requahfication progmm and B-6 {

,. . ~ - - -- Fed:r .I Regist:r / Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 9459 examination content. A great many successfully maintaining the proficiency licensed will be a much more effective commenters were unclear about the and knowledge oflicensed personnel. training tool than one which is not. relationship of the NRC requalification To this end, the rule requires in 5 55.57 The Commission decided, however, requirements and performance-based that each applicant for renewal of a six- that because there might br 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 it a Although the requirement for NRC NRC will administer these requirement. This kind of case. specific l approval of requalification programs requalification written examinations special circumstances is precisely what j will remain, the list of content areas and operating tests on a random basis our exemption procedures are intended under il55.41,55.43 and $5.45 will be so that no operator or senior operator to handle. If a licensee had appropriate referenced in 5 55.59 to clerify 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 $5.59(c) content year license is issued. exemption to the regulation. Instead, the ) requirements (formerly Appendix A to (I) Modification ond revocation of Commission chose to water down the 10 CFR Part 551 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 \,iews 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 Personnel, the Commission endorsed Atomic Energy Act. Moreover, inherent broad objective that operators be mdustry-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 rnay indeed need to to a maximum of every 2 years and of (J) Editorial. Many commenters had examine operators every six years: in I 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 l be conducted for a continuous period by an NRC technical editor and ability to conduct high quality, I not to exceed 24 months. The specific incorporated as appropriate. performance-based examinations in ! cycle will be approved by the NRC as pa o, a fa a g program. (K) Conforming amendments. A accordance with i 55 57(b)(2i(iii). such I j j, conforming amendment,10 CFR 50,74, licensee performance may well justify requires the facility licensee to notify extension or relaxation of th,si engaged." As explained above, many the Commission of a change m operator requirement. This approach would have commenters were concerned with the . implementation of the provision for status. This amendment complements been consistent with the Commission a

                  " active:y and extensively engaged as an              i 55.53(g).                                   policy of rewarding Food licensee operator or senior operator" as it related               (L) Revision to 10 CTR 50.54 ond 10        performance and focusing attention and to renewal. This provision is deleted in              CTR 50.34/b//B/. Revisions have been          resources on deficient performers. The the final rule. This action complements               made to 10 CFR 50.34(b)(8) and 50.54 to       Commission thus could have provided reflect the   changes made  to 10 CFR    Part  mcentive to licensees and flexibility to the additions i 55.53 (e) and (f) to
                  " Conditions of Licenses."                            55.                                            the NRC examiner staff and should have thereby focused NRC's limited         i (3) Test ond research reactors.                   Separate Views of Commissioner Several commenters were concerned                                                                   teEulato # resources where they are Asselstine                                     most urgently needed.

that the requalification requirements for operators at this class of reactor were This rule is a good idea, but it does I also continue to beheve that the time changed. The requirements in not go far enough. The Commission has come (gis en the decreased cost and i 55.59(c)[7] continue the requirements should have required alllicensees 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 306 of the Nuclear reference simulators for operator (4) NRC administration of Waste Policy Act of 1982 (Pub. L 97- training. While there may be some requahfication examina!!ons. Some 425) requires it. Second. plant referenced special cases that would quahfy for i commenters questioned the NRC sirnulators are an excellent way for exemption from such a requirement, on ! administration 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, hcensees could in those l 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 especial!y important in exemption. that an operator or senior operator can training the operators to deal with emergency or other situations w hen the III. Regulatory Anal3 sis operate the controls in a safe and competent manner and that a senior plant is not in its normal state. It is a The regulatory analysis descnbes 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 rnanipulate implementmg 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 memonze accuracy of these estimates in the examinations provide assurance that emergency procedures. Further, a regulatory analysis is hmited by the lack facihty licensee administered simulator which is referenced to the of extensive data on human requalification programs are plant on which the operator will be performance imprm ement associated

9460 Fed 2ral Register / Vol. 52. No. 57 / Wednesday. March 25, 1987 / Rules and Regulations with an improved licensing process. by the Office of Management and Subpart S-Exemptions Where possible, quantitative measures Budget approval number 3150-0018. 55.11 Specific exemptions. were qualitatively compared to related Vill. Regulatory Flexibility Certification " 23 '""*I ' * * *P'i ^ *' information from other sources for Subpert C-tseecal Requirements venfication. The full text of the As required by the Regulatory regulatory analysis on these Flexibihty Act of 1980. 5 U.S C. 005(b). n21 Mcal examinauon. amendments is available for inspection the Commission hereby certifies that $$$c", ej, yon because of disability or en the NRC Public Document Room.1717 this rule will not have a significant tiin,,,, il 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 Subpart D-Applications from Chief. Operator Licensing Branch. conforming amendment to 10 CFR Part telephone: (301) 492-4868. 50 and the revision of 10 CFR Part 55 55.31 How to apply.

                                       .                                                                                      affect primarily the companies that own                                      55.33 Disposition of an initial application.

15,. Backfit Analysis 55 35 bapphcations. and operate light-water nuclear power The Commission has determined that reactors and the vendors of those Subpart E-Wrftten Examinations and these rules are in re6ponse to section reactors. They also affect individuals Opereung Teste 300 of the Nuclear Waste Policy Act of licensed as operators at these 55 41 wntien examination 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 Operstmg tests. Individuals fall within the scope of the 55 47 waiver of examination and test V. Regulatory Guides definition of "small entity" set forth in requirements. Three regulatory guides were section 501(b) of the Regulatory "4 8 I"I'8"'F 'I '***i"* 'i "' ""d ' l published in draft form for public Flexibility Act. NRC's Size Standards Subpart F-Uconses comment in conjunction with the adopted December 9,1985 (50 FR 50241). 55.51 lesuance of licenses. proposed rule.These gwdes were or the Small Business Size Standards set 55.53 Conditions of licenses. intended to provide guidance on out in regulations issued by the Small 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. 55.50 Requahfication. of public comment and additional staff Subpart G-Modmcate and Rmcadon W Ust of Subjects review. these three guides are being t.icenses issued in final form: 10 CFR Part 50 55 et Modification and revocation of licenses. I (1) R.G.1.134. Revision 2. " Medical Antitrust. Cla ssified information. Fire Subpert H-Enforcement Evaluation of Licensed Personnel for presention. Incorporation by reference, 55.71 Violations. Nuclear Power Plants." Intergovemmental Madons. Nudear (2) R.G.1.149, Revision 2. " Nuclear Authority: Secs 107.1e1.182. ea Stat. eso, power plants and reactors. Penalty- $48. 953 as emended. sec. t.34. 83 Stat.444 as Power Plant Simulation Facilities for Radiation protection. Reactor siting amended (42 U.S.C. 2137, 2201. 2232, 2:a2); Use in Operator License Examinations... criteria. Reporting and recordkeeping secs. 201. as amended. 202, an Stat.1242 as r "9" *** * **"d'd' # I'* *" and T riins o Pe nnelf N Secti ns 55.41. 55.43. 55.45 and 55.59 also Power Plants." 10 CFR Port 55 irsued under sec. 308. Pub. L 97-425,96 Stat. Copies of these guides may be Manpower training programs. Nuclear 2262 (42 U S C.10:28) Section 55.81 also purchased from the Government Printing power plants and reactors. Penalty, issued under sees 186.187, es Stat. 955 (42 Office at the current CPO prir.e. Reporting and recordkeeping U.S C. 2236,2237). Information on current GPO prices may For the purp ses ! sec. 223. 88 Stat. 958. as requirements' be obtained by contacting the amended (42 U.S.C. 2273) 18 55.3. 55.21. 55.40 For the reasons set out in the and 55 53 are issued under sec. tell. es Stet. Superintendent of Documents. U.S. preamble and under the authority of the 949, as amended (42 U.S.C. 22m(l)); and Government Printing Office. Post Office Atomic Energy Act of 1954, as amended, il 55.23. 55.25 and 55.53(f) are issued under Box 37082. Washington. DC 20013-7082. sec.1eto. 88 Stat. 950, as amended (42 U.S.C. the Energy Reorgar ization Act of 1974, telephone (202) 275-2060 or (202) 275-

  'g' as amended, the Nuclear Waste Policy                                            22011o1).

Act of 1982, and 5 U.S.C. 553, the NRC is VI. Environmental Impact: Categorical adopting the following amendments to Subpart A-General Proviolone Exclusloc 10 CR Part 55 and 10 CFR Part 50. l 55.1 Purpose. The NRC has determmed 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 j in categorical exclusion 10 CFR for the issuance of licenses to operators ' 51.22(c)(1). Therefore, neither an PART 55-OPERATORS' LICENSES and senior operators of utilization environmentalimpact statement nor an facilities licensed pursuant to the Subpart A-GeneralProvisions Atomic Energy Act of 1954, as amended, environmental assessment has been prepared for this regulation. Sec. or section 202 of the Energy 551 Purpose. Reorganization Act of 1974. as amended. Vll. Paperwork Reduction Act 55.2 Scope. and Part 50 of this chapter. Statement 55.3 License requirements. (b) Provide for the terms and This final rule amends information $* "[n cItions. c nditions upon which the Commission collection requirements that are subject 55 e Interpretations. willissue or modify these licenses, and to the Paperwork Reduction Act of1980 55 7 Additional requirements. (c) Provida for the terms and (44 U.S C. 3501 et an ). These 55 e information collection requirements: conditions to maintain and renew these paperwork requirea,unts were approved OMB approval. licenses. l

Federal Regleter / Vol 52 No. 57 / Wedn:sd3y, M:rch 25,1987 / Rules and Regulations 9461 1SLR Soaps. 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. c ntrols of any utilization fae:ility which the simulator has been designed (2) Any application for a license or licensed pursuant to Part 50 of this to respond- license renewal filed under the chapter, and " Reference plant" rneans the specific regulations in this part involving a (b) Any individual designated by a nuclear power plant from which a nuclear reactor licensed under 10 CFR f2cility licensee to be responsible for simulation facility's control room Part 50 and any related inquiry, directing any licensed ac+Jvity of a configuration, system control communication, information, or report licensed operator. ' arrangement, and design data are must be submitted by mail or in person l SE.8 , t.aoense requirements. [ or operator"means any to the Regional Administrator.The A persea must be authorised by a Regional Administrator or the individual licensed under this part to lloenas issued by the Commission to Administrator,a designee will transmit manipulate the controls of a facility and perform the function of an operator or a to direct the licensed activities of to the Director of Nuclear Reactor senior operator as defined in this part- licensed operators. Regulation any matter that is not within

                                                                                         " Simulation facility" means one or         the scope of the Regional I'E4                                                                           more of the following components. alone Administrator's delegated authority.

p used in this pa* or in combination, used far the partial (i)If the nuclear reactor is located in Act means the Atomic Energy Act conduct of operating tests for operators, Region I, submission must be made to cf1954, including any amendments to senior operstors, and candidates: the Regional Administrator, Region I, the Act. (1)The plant, U.S. Nuclear Regulatory Commission.

      " Actively performing the functions of                                             (2) A plant-referenced simulator,            631 Park Avenue, King of Prussia, en 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 11, trchnical 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. (2)Imarning objectives derived from

      " Commission" means the Nuclear                                                                                                 Gmgia 30303.

the analysis which describe desired Regulatory Commission or its duly performance after training. (iii)If the nuclear reactor is located in authorized representatims. (3) Training design and Region 111. submission must be made to

      " Controls" when used with respect to                                             implementation based on the learning          the Regional Administrator, Region !!!,

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 60137, the objectives during trainin8-lavel 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 personnelin 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, ftcilities," facility" means all facilities and all territories and possessions of the Arlington, Texas 70011. identifled in the license. United States. Facilitylicensee' means an applicant (v)If the nuclear reactor is located in Region V, submission must be made to for or holder of a license for a facility. I 55.5 communications.

       ,IJcensee means an individual                                                      (a) Except as provided under a b                               &         R@ %

U.S. Nuclear Regulatory Commission. licetsed operator or senior operator, regional licensing program identified in Operator" means any individual paragraph (b)of this section,an 1450 Maria Lane. Suite 210. Walnut Creek, Cabfornia 94596. licensed under this part to manipulate a applicant or licensee or facility licensee control of a facility. shall submit any communication or i 55.6 interpretations.

      " Performance testing" means testing                                          report concerning the regulations in this conducted to verify a simulation                                                 part and shall submit any application                 Except as specifically authon. zed by facility's performance as compared to                                            filed under these regulations to the               the Commission m wnting, no actual or predicted reference plant                                              Commission as follows:                             intnpretation of the meaning of the performance.                                                                           (1) By mail addressed to-Dnector of          regulations in this part ,by any officer or
      " Physician" means an individual                                              Nuclear Reactor Regulation. U.S.                   employee of the Commission other than licensed by a State or territory of the                                           Nuclear Regulatory Commission,                    a written interpretation by the General United States, the District of Columbia                                           Washington. DC 20555, or                          Counsel will be recognized to be binding 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 55.7 Additionai requirements. medicine. NW., Washington, DC or (ii) 7930

      " Plant-referenced simulator" means a                                          Norfolk Avenue, Bethesda. Maryland.                   The Commission may, by rule.

simulator modeling the systems of the (b)(1) The Director of Nucles Reactor regulation, or order, impose upon any reference plant with which the operator Regulation has delegated to the Regional bcensee such requirements,in addition interfaces in the control room, including Administrators of Regions 1. II. 31. 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 bcenses minimize danger to hfe or property. B-9

9462 Federal Register / Vol. 52, No. 57 / Wednesday. March 25, 1987 / Rules and Regulations 155.s information conection Subpart C-Medical Requirements Licensee," available from Publication requirements: OMB approval. Services Section Document (a) The Nuclear Regulatory ISE21 Memeal examinauon. Management Branch, Division of Commission has submitted the An applicant for a license shall,have a TechnicalInformation 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 m,edical 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-398, together with the that the applicant or licensee meets the information required in paragraphs Reduction Act of1980 (44 U.S.C. 3501 et 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 the appropriate Regior,al Administrator; contamed in this part under control 5 55.23 Certification. (3) Submit a written request from an To certify the medical fitness of the authorized representative of the facility number 31M018 applicant, an authorized representative (b) The approved information licensee by which the applicant will be of the facility licensee shall complete employed that the written examination collectwn requirements contained in this and sign Form NRC-3%," Certification part appear in i 6 55.45,55.53, and and operating test be admmistered to of Medical Examination by Facility l 55.5% the apphcant; L censee." available from Publication (c) This part contains information (4) Provide ev,dence i that the opplicant Services Section Document collection requirements in addition to Management Branch, Division of has succesMy completed the "acility those approved under the control licensee s requirements to be licensed as TechnicalInformation and Document number specified in paragraph (a) of this Control, U.S. Nuclear Regulatory chi perator or senior operator and of the section. These information collection facility licensee s need for an operator Commission. Washington, DC 20555. requirements and the control numbers r a semor operator to perform assigned (a) Form NRC-396 must certify that a under which they are approved are as duties. An authonzed representative of physician has conducted the medical follows: examination nf the applicant as required the facility licensee shr.ll certify this (1) in iI 55.23,55.25, 55.27,55.31, Form in ! 55.21. evidence on Form NRC-398. This NRC-396 is approved under control rti cati,on m ude de i s of the (b) When t p} ,n , q number 3150-0024. conditional h,he certification cense based on medical requests a 9n,,,nd evidence, the medical evidence must be courses of instruction administered by (2) In 1155.31,55.35. 55 47, and 55.57, the facility licensee and describe the Form NRC-398 is approved under submitted on NRC Form 396 to the nature of the trainir g received at the control number 3150-0090 Commission and the Commission then fac lity' and the startup and shutdown (3) In 155 45, Form NRC-474 is makes a determination in accordance

                                                                                                                                                                                                                                                                                    ,xp,,;ence received. In lieu of these approved under control number 3150-                                                                                                                                  with I 55.33.                                                                                                   details, the Commission may accept 0138.                                                                                                                                                                 $ 55.25 incapacitation because of                                                                               certification that the applicant has esability or litness.                                                                                           successfully completed a Commission-Subpart B-Exemptions                                                                                                                                                                                                                                                                 approved training program that is based If, during the term of the license, the
$ 55.11 Specific esemptions.                                                                                                                                          licensee develops a physical or mental                                                                         on a systems approach to training and The Commission may, upon                                                                                                                                           c           ndition                                          that        causes    the   licensee    to fall   that uses a simulation fa,cility
                                                                                                                                                                       'O. meet the requirements of i 55.21 of                                                                       acceptable to the Commission under application by an interested person, or upon its own initiative, grant such                                                                                                                                   this part, the facility licensee shall notify 5 55.45(b)of this part:  ,                                                            ,

esemptions 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 i r which a conditionallicense (as manipulated the controls of the facility describing in i 55.33(b) of this part)is for which a license is sought. At a endanger life or property and are requested, the facility licensee shall minimum, five sigmficant control otherwise in the public interest. provide medical certification on Form manipulations must be performed which

$ $5.13 General exemptions.                                                                                                                                            NRC 396 to the Commission (as                                                                                 affect reactivity or power level. For a The regulations in this part do not                                                                                                                                  described                                                         in 5  55.23  of   this  part).              facility that has not completed require a liceme for an individual
                                                                                                                                                                        ! 55.27 Documentation.                                                                                        fest p g m as escribedin is i a The facility licensee shall document                                                             Safety Analysis Repcrt, as amended and (a) Under the direction and in the                                                                                                                                   and maintain the results of medical                                                                           approved by the Commission, the presence of a licensed operator or sem.or qualifications data, test results, and                                                                                                                                                                                                                            accept evidence of operator, manipulates the controle of-                                                                                                                                  each operator's or senior operator's                                                                          Commission satisfactory per maformance of simulat (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.'Ite                                                                          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 individual's training in a facility                                                                                                                                     documentation while an individual                                                                              l 55.45(b) of this part. For a facility licensee's training program as approved                                                                                                                                 performs the functions of an operator or                                                                       which he, (i) completed preoperational by the Commission to quahfy for an                                                                                                                                       senior operator.                                                                                              testing as describet 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 fii) is presence of a licensed senior operator,                                                                                                                                  9 55.31 How to apply.                                                                                         In an extended shutdown which manipulates the controls of a facility to                                                                                                                                               (a) The applicant shall:                                                                       precludes manipulation of the control of load or unload the fuelinto, 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

Feder:1 Regist r / Vol. 52. No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 9463 application and may administer the under i 55.33(a)(1) of this part, the (b) The written examination for an ) written examination and cperating test Commission may approve the operator for a facility willinclude a required by ll 55.41 or 55.43 and 55.45 application and include conditions in representative sample from among the of this part, but may not issue the the license to accommodate the medical following 14 items, to the extent license until the required evidence of defect. 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 evidence of the facility licensee and of including fission process, neutron operator license, certification that the the examinh7g physician (provided on multiplication, source effects, control operator has successfully operated the Form NRC-3%)in arriving at its rod effects, criticality indications, controls of the facility as a licensed decision. reactivity coefficients. and poison operator shall be accepted; and effects. (6) Provide certification by the facility I 55.35 Re-appucations. (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-390, to a license has been demed because of elements, control rode, core comply with El 55.21.55.23 and failure to pass the written examination instrumentation. and coolant flow. 55.33(a)(1). or operating test, or both, may file a new (3) Mechanical components and (b)The Commission may at any tirne 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 eIstem before the license has expired. require submitted on Form NRC-398 and include (4) Secondary 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 determme whether to grant or deny the whom the applicant will be employed during steady state and transient application or whether to revoke, that states m detail the extent of the conditions, including coolant chemistry, modify, or suspend the license. applicant a 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 medical 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. sup tement to the application. apphcation, and may file further (6) Design. components, and functions I ( ) Each application and statement successive applications two years after of reactivity control mechanisms and must contam complete and accurate the date of denial of each prior disclosure as to all matters required to application. The applicant shall submit I"'{D s n components, and. functions be disclosed.The applicant shall sign each successive application on Form I C luding na 'in, 'erl

ks.

statements required by paragraphs (a)(1) NRC-398 and include a statement of t me n and (2) of this section. additional training. failure modes, and automatic and (b) An apphcant who has passed i 55.33 D6epoeltnon of an initial menual features. either the written examination or (8) Components, capacity, and appuc h 1 perating test and failed the other may functions of emergency systems. ! (a) Requirements for the approvalof " on initio/ application. The Commisstor will approve an mitial application for a [8 3 to Pp cati 0n on!orm xcu d {,9 , e examination on the portions of the (9) Shielding, isolation, and e ntamment design features, including ; license pursuant to the regulations in examination or test which the applicant access limitations. I this part. Ifit finds that- (10) Administrative, normal. has passed. The Commission may in its (1) Heo/th. The applicants medical abnormal. and emergency operating discretion grant the request, if it condition and general health will not determines that sufficient justification is procedures for the facihty. adversely affect the performance of presented. (11) Purpose and operation of assigned operator job duties or cause radiation monitoring systems, including operational errors endangering public Subpart E-Written Examinations and alarms and survey equipment. health and safety.The Commission will Operating Tests (12) Radiological safety principles and base its finding upon the certification by procedures. i 55.41 wrttten examinatiorv 9perators. the facility licensee as detailed in (13) Procedures and equipment ) l 55.23. (a) Content. The written examination available for handling and disposal of l [2] Written examination and for an operator will contain a radioactive materials and effluents. operating test. The applicant has passed representative selection of questions on (14) Principles of heat transfee the requisite written examination and the knowledge. skills, and abilities thermodynamics and fluid mechanics. ! operating test in accordance with needed to perform licensed operator il 55.41 and 55.45 or 55.43 and 55.45. duties.The knowledge. skills, and i 55.43 written examination: Senior These examinations and tests determine abihties will be identified. in part, from operators. whe*her the applicant for an operator's learning objectives derived from a (a) Content. The written examination lice: se has learned to operate a facihty systematic analysis of licensed operator for a senior operator will contain a competently and safely, and duties performed by each facility representative selection of questions on additionally,in the case of a senior licensee and contained in its training the knowledge, skills. and abihties operator, whether the applicant has program and from information in the needed to perform licensed senior learned to direct the hcensed activities F nal Safety Analysis Report, system operator duties. The knowledge skills, of licensed operators competently and descnption manuals and operating and abihties will be identified, in part, sa fely. procedures, facility license and license fro n learning objectives derived from a (b) Conditionallicense. If 6n amendments. Licensee Event Reporte, systematic analysis of hcensed senior applicant's general medical condition and other materials requested from the operator duties performed by each does not meet the minimum standards facihty bcensee by the Comminion. facihty licensee and contained in its B-11

i 9464 Federal Register / Vol. 52, No. 57 / Wednesday March 25, 1987 / Rules and Regulations training program and from inforn ation (2) Manipulate the console controls as (i) A simulation facility which the in the Final Safety Analysis Report, required to operate the facility between Commission has approved for use after sytem description manuals and shutdown and designated power levels. application has been made by the operating proceduras, facility license (3) Identify annunciators and facility licensee, or j and license amendments, Licensee cond, tion-indicating signals and perform (ii) A simulation facility consisting Event Reports. and other materials appropriate remedial actions where solely of a plant referenced simultator requested from the facility licensee by 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 for facility licensees. (i) senior operator int a facility willinclude 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 i 55.41 of this part, to the facility. pursuant to paragraph (b)(1)(i) of this I extent applicable to the facility: (6) Perform control manipulations section, except test and research j (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 rem val systems, including pnmary (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 relations of the proper operation of months after the effective date of this (4) Radiation hazards that may arise these systems to the operation of the rule, shall submit an application for use during normal and abnormal situations. facility. of this simulation facihty to the meluding maintenance activities and Commission, in accordance with (8) Safely operate the facility's vanous contamination conditions. auxiliary and emergency systems, paragraph (b)(4)(i) of this section. (5) Assessment of facility conditions neluding operation of those controls (iii) Those facility licensees which I and selection of appropriate procedures associated with plant equipment that propose to conform with paragraph during normal, abnormal, and could affect reactivity or the release of (b)(1)(ii) of this section, not later than 46 emergency situations. radioactive materials to the months after the effective date of this (6) Procedures and limitations environment. rule, shall submit a certification for use involved in initial core loading. (9) Demonstrate or describe the use of this simulation facility to the alterations in core configuration, control and function of the facility's radiation Commission on Form NRC-474, rod programming, and determination of monitoring systems inicuding fixed " Simulation Facility Certification " s arious internal and external effects on radiation monitors and alarms, portable available from Publication Services core reactivity. survey instruments, and personnel Section, Document Management Branch, (7) Fuel handling facilities and monitoring equipment. Division of TechnicalInformation and procedures. (10) Demonstrate knowledge of Document Control U.S. Nuclear f 55.45 Operating tests. significant radiation hazards, including Regulatory Commission, Washington, permissible levels in excess of those DC 20555,in accordance with paragraph (a) Content. The operating tests a uthorized, and ability to perform other (b)(5)(i) of this section. administered to applicants for operator procedures to reduce excessive levels of (iv) The simulation facility portion of and senior operator licenses in radiation and to guard against personnel the operating test will not be accordance with paragraph (b)(1) of this exposure. administered on other than a certified or section are generally similar in scope. (11) Demonstrate knowledge of the an approved simulation facility after The content will be identified, in part, emergency plan for the facility, May 26,1991, i from learning objectives derived from a including, as appropriate, the operator's (3) Schedule for facility applicants. (i) i systematic analysis of licensed operator or senior operator's responsibility to For facility licensee apphcations after l or aenior operator duties performed by decide whether the plan should be the effective date of this rule, except test ; each facility licensee and contained in executed and the duties under the plan and research reactors, the applicant ! its training program and from assigned. shall submit a plan which identifies information in the Final Safety Analysis (12) Demonstrate the knowledge and whether its simulation facility will Report, system description manuals and ability as appropriate to the assigned conform with paragraph (b)(1)(i) or operating procedures. facility license position to assume the responsibilities (b)(1)(ii) of this section at the time of and license amendments, Licensee associated with the safe operation of the application. Event Reports, and other materials facility, (ii) Those applicants which propose to requested from the facility licensee by (13) Demonstrate the applicant's conform with paragraph (b)(1)(i) of this the Commission. The operating test. to ability to function within the control section, not later than 180 days before the extent applicable, requires the room team as appropriate to the the date when the applicant proooses applicant to demonstrate an assigned position,in such a way that the that the Commission conduct op-rating understanding of and the ability to facihty licensee's procedures are tests, shall submit an application for use perform the actions necessary to adhered to and that the limitations in its of its simulation facility to the NRC, in accomplish a representative sample 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) (iii) Those applicants which propose the facility. including operating of those Administration. The operating test will to conform with paragraph (b)(1)(ii) of controls associated with plant be administered in a plant walkthr:geh this section, not later than 60 days equipment that could affect reactivity. and in either- before the date when the applicant B-12

I Fed:rd Registrr / Vol. 52. No. 57 / Wednesday. March 25. 1987 / Rules and Regulations 9465 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 (vii) 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 ondopprovolof section must include a description of the subsequent four years. simulation facilities. Those facility performance tnting completed for the licensees which propose,in accordance simulation facility, and must include a 1 55.47 Walver of examination and test requirements. with paragraph (b)(1)(1) of this section, description of performance tests,if , to use a simulation facility that is other different to be conducted on the (a) On application, the Comm,ssion i than solely a plant-referenced simulator simulation facility during the subsequent may waive any or all of the as defined in i 55.4 shall- four-year period, and a schedule for the requirements for a written examination (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)(1) of this section, as subsequent four years. (1) Has had extensive actual operating applicable submit an application for (5) Certificofion of simulation experience at a comparable facility. as approval of the simulation facility to the focilities-Those facility licensees determined by the Commission, within Commission. in accordance with the which propose,in accordance with two years before the date of application; schedule in paragraph (b)(2)(ii) or paragraph (b)(1)(ii) of this section to use (2) Has discharged his or her ' (b)(3)(ll) 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 i 55.4. shall- and facility meets the plan submitted to the [i) Submit a certification to the (3) Has learned the operating Commissinn 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. , I (D) 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)(iii) or (b)(3)(iii) 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 tes's 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 i 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 responsibihty. (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 decertification 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 I censee or of a holder of an these performance test failures,if any. testing, that a ecrtified simulation authorization where the applicant's (iv) Retain the results of the facility does not meet the requirements TVIC'8 "III b' "'Iliz*d' 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. 555.49 integrtty of examinations and application under paragraph (b)(4)(i). (v)If thr: Commission determines, tests. I 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 certif.ed 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 decertification to the required by this part. based upon the results of performance Commission on Form NRC-474. This testing, that an approved simulation decertification must include a Subpart F-Ucenses j facility does not meet the requirements description of corrective actions taken. ! of this part, the simulation facility may including results of completed l 55.51 lasuance of Heenses. { I not be used to conduct operating tests. performance testing as required for Operator and senior operator (vi)If the Commission determines. decertification. /icenses. 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 decertification submitted pursuant to or a senior operator license meets the facihty does not meet the requirements paragraph (b)(5)(i). (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 apphcation must include completed for the simulation facility. hmitations it considers appropriate and a description of correctise actions taken, and must include a description of the necessary. l l B-13

9466 Fed ral R:gisttr / Vol. 52. No. 57 / Wednesday, March 25, 1987 / Rules and Regulations i 55.53 Conditions of licenses. 5 55.55 E mpiration. (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 cperator 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 empicyment 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 riaintain a license. (iii) Has passed the requalification ) for which it is issued. (b)If a licensee files an application for examinations and annual operating tests 1 (c) The license is limited to those renewal or an upgrade of an existing as required by i 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) %e license is subject to, and the existing license. it does not expire until operating test administered by the

        !lcensee 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 is deposited in the facility designated in the application. resume activities authorized by a license mail or with a telegraph company. (4) ne past performance of the issued under this art except as licensee has been satisfactory to the I55 * *"8 ' #C' ***- Commission. In making its finding, the permitted by paragraph (f) of this [a] The applicant for renewal of a section. To maintain active status, the Commission will include in its j bcensee shall actively perform the license shall- evaluation information such as notices l 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 renewalis sought. g ,53 gg, quarter. For test and research reactwo. (2) File an original and two copies of the licensee shall actively perform the Form NRC-368 with the appropriate (a) Requalification requimments. functions of an operator or senior Regional Administrator specified in F.ac ce se a operator for a minimum of four hours i 55.5(b). per calendar quarter. (3) Provide written evidence of the applicant s experience under the the facility licensee that has been (f)If paragraph (e) of this section is 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 p a hall b d di c u a period not o exce7d 24 part, an authonzed representative of the operated the facility. facility licensee shall certify the (4) Provide a statement by an Ms b dMa (2) Pass a comprehensive following: authorized representative of the facility requalification written examination and (1) That the qualifications and status licensee that during the effective tenn of of the licensee are current and valid; an annual operating test, the current license the applicant has and satisfactorily completed the (i) the written examination will sample the items specilled in 18 55.41 ( That the licensee has completed a

           ,2)                                             requalification                  program                   for the facility      and 55.43 of this part, to the extent minimum of 40 hours of shift functions              for which operator or senior operator applicable to the facility. the licensee, under the direction of an operator c                license renewalis sought.

and any limitation of the license under senior operator as appropriate and s (5) Provide evidence that the app!! cant $ 55.53(c) of this part. the position to which the individuan .11 has discharged the license be assigned. The 40 hours must havs ( i) The operating test will require the responsibilities competent 8y and safely, operator or senior operator to included a complete tour of the plant %e Commission may accept as demonstrate an understanding of and and all required shift turnover evidence of the applicant's having met the ability to perform the acticas procedures. For senior operators limited this requirement a certificate of an necessary to accomplish a i i to fuel handling under paragraph (c) of authorized representative of the facility comprehensive sample ofitems I this section, one shift must have been i licensee or holder of an authorization by specified in i 65.45(a) (2) through (13) I completed. For test and research which the licensee has been employed. reactors, a minimum of six hours must inclusive to the extent applicable to the (6) Provide certification by the facility facility. have been completed. licensee of medical condition and (g) The licensee shall notify the general health on Form NRC-396, to (iii)In lieu of the Commission accepting a certification by the facility Commission within 30 days about a comply with Il 55.21,55.23 and 55.27. licensee that the licensee has passed conviction for a felony. (b) The license will be renewed if the written examinations and operating (h) The licensee shal: complete a Commission finds that- tests administered by the facility requalification prograr.a as described by (1) The medical condition and the licensee within its Commission-i 55.59. general health of the licensee continue approved program developed by using a (1) The licensee shall have a biennial to be such as not to cause operational systems approach to traininF under medical examination. errors that endanger public health and paragraph (c) of this section, the (j) The licensee shall comply with any safety.The Commission will base this Commission may administer a other conditions that the Commission finding upon the certification by the comprehensive requalification written may impose to protect health or to facility licensee as described in 155.23. examination and an annual operating minimize danger to life or property. (2) The licensee- test. B-14 u-_----------- - -

FId:ral Regist:r / Vol. 52. No. 57 / Wednesday, March 25, 1987 / Rules and Regulations 9467 (b) Additionaltmining. If the performed annually: all other items must (V) Turbine or generator trip. requirements of paragraphs (a)(1) and be performed on a two-year cycle. (W) Malfunction of an automatic (2) of this secticn are not met, the However, the requalification programs control system that affects reactivit;. Commission may require the licensee to must contain a commitment that each (X) Malfunction of reactor coolant complete additional training and to individual shall perform or participate in pressure / volume control system. submit evidence to the Commission of a combination of reactivity control (Y) Reactor trip. successfulcompletion of this training manipulations based on the availability (Z) Main steam line break (inside or before returning to licensed duties. of plant equipment and systems.Those outside containment). (c) Requohfication pmgram control manipulations which are not (AA) A nuclear instrumentation requirements. A facility licensee shall performed at the plant may be failure. have a requalification program reviewed performed on a simulator.The use of the (ii) Each licensed operator and senior and approved by the Commission.The Technical Specifications should be operator has demonstrated satisfactory requalification program must meet the maximized during the simulator control understanding of the operation of the requirements of paragraphs (c)(1) manipulations. Senior operator licensees apparatus and mechanisms associated through (7) of this section. In lieu of are credited with these activities if they with the control manipulations in paragraphs (c) (2). (3), and (4) of this direct control manipulations as they are paragraph (c)(3)(i) of this section, and section, the Commission may approve a performed. knows the operating procedures in each program developed by using a systems (A) Plant or reactor startups to include area for which the operator or senior approach to training. a range that reactivity feedback from operator is licensed. (1) Schedule. The requalification nuclear heat addition is noticeable and (iii) Each licensed operator and senior program must be conducted for a heatup rate is established. operator is cognizant of facility design continuous period not to exceed two (8) Plant shutdown. changes. procedure changes, and facility years, and upon comlusion must be (C) Manual control of steam license changes. promptly followed, pursuant to a generators or feedwater or both during (iv) Each licensed operator and senior continuous schedule. by successive startup and shutdown. operator reviews the contents of all requalification programs. (D) Boration or dilution during power abnormal and emergency procedures on (2) Lectures. The requalification operation. a regularly scheduled basis. program must include preplanned (E) Significant (;10 percent) power (v) A simulator may be used in lectures on a regular and continuing changes in manual rod control or meeting the requirements of paragraphs basis throughout the license period in recirculation flow. (c)(3)(i) and (3)(ii) of this section, if it those areas where operator and senior (F) Reactor power change of to reproduces the general operatirig operator written examinations and percent or greater where load change is characteristics of the facility involved facility operating experience indicate performed with load limit control or and the arrangement of the that emphasis in scope and depth of where flux, temperature, or speed instrumentation and controls of the coverage is needed in the following control ls on manal (f,or IITGR). simulator is similar to that of the facility subjects: (G) Loss of coolant. includmg- involved. If the simulator or simulation (i) Theory and principles of operation. (1) Significant PWR steam generator device is used to administer operating (ii) General and specific plant leaks tests for a facility, as provided in 5 55 45 operating characteristics. (2) Inside and outside primary (b)(1). the device approved to meet the (iii) Plant instrumentation and control systems. 7,j {A requirements of I 55 45(b)(1) must be

                                                         'Ie n small, includin8 lead. rate used for credit to be given for meeting i"

(iv) Plant protection systems. {in dr eador coolant response the requirements of paragraphs (c)(3)(i) (v) Engineered safety systems. (G through AA) of this section. (vi) Normal, abnormal. and emergency (PWR)' (4) Ero/votion. The requalification operating procedures. (H) Loss of instrument air (if program must indude-(vii) Radiation control and safety, simulated plant specific). (i) Comprehensive regalification (1) L ss of electrical power (or written examinat;ons and annual (viii) Technical specifications. (ix) Applicable portions of Title 10. degraded power sourcesJ. operating tests which determine areas in Chapter L Code of rederal (J) Loss of core coolant flow / natural which retraining is needed to upgrade

       ##"#" ##                                                                               licensed operator and senior operator (3) On.the. job training. The (I)L s of feedwater (normal andknowledge.

requalification program must include on. *y(,',#;'f service o water,if required (ii) Written examinations which the-job training so that- determine licensed operators and senior (i) Each licensed operator of a go,,,regy's (y) to, of shutdown cooling. operators' knowledge of subjects utilization facility manipulates the plant covered in the requahfication program (N) Loss of component cooling system controls and each licensed senior or cooling to an individual component. and provide a basis for evaluating their operator either manipulates the controls knowledge of abnormal and emergency (O) Loss of normal feedwater or or directs the activities of individuals normal feedwater system faiLire. procedures. during plant control manipulations (iii) Systematic observation and (P) Loss of condenser vacuum. during the term of the licensed (Q) Loss of protective system channel, evaluation of the performance and operator's or senior operator's license. (R) Mispositioned control rod or rods competency uf licensed operators and For reactor operators and senior (or rod drops). senior operators by supervisors and/or operators. these man;pulations must (S) Inability to drive control rods, training staff members includmg consist of the following control (T) Conditions requiring use of evaluation of actions taken or to be manipulations and plant evolutions if emergency boration or standby liquid taken during actual or simulated they are applicable to the plant design. control system. abnormal and emergency procedures. Items descnbed in paragraphs (c)(3)(i) (U) Fuel cladding failure or high (iv) Simulation of emergency or ( A) through (L) of this section must be activity in reactor coolant or offgas. abnormal cond.tions that may be B-15

                                                                                                                              --_A

04G8 Federal Register / Vol. 52, No. 57 / Wednesday, March 25, 1987 / Rules and Regulations j accomplished by using the control panel from this record retention requirement. violation of any provision of: of the facihty involved or by using a (6) Alternative trainingprogroms. The (1) The Atomic Energy Act of 1954. as simulator. Where the control panel of requirements of this section may be met amended; the facility is used for simulation, the by requalification programs conducted (2) Title !! of the Energy actions taken or to be taken for the by persons other than the facility Reorganization Act of 1974, as amended; emergency or abnormal condition shall licensee if the requalification programs or be discussed; actual manipulation of the are similar to the program described in (3) Any regulation or order issued plant controh,is not required. If a paragraphs (c)(1) through (5) of this under these Acts. simulator is used in meeting the section and the alternative program has (b) A court order may be obtained for requirements of paragraph (c)!4)(iii) of been approved by the Commission. the payment of a civil penalty imposed this section. it shall accurately under section 234 of the Aomic Energy reproduce the operating characteristics (7) Applicability to research and test of the facility involved and the reactorfacilities. To accommodate Act for violation of: s ecialized modes of operation and (1) Sections 53,57,62,63,61.82,101, arrangement of the instrumentation and differences in control, equipment, and 103104107 or 109 of the Atomic controls of the simulator shall closely e parallel that of the facility involved. operator skills and knowledge, the , After the provisions of 9 55.45(b) have requalification program for each rg d m-ert fied r pp v imu ati n. facility ' reac a o e ac o ac must conform generally but need not be y&% ayb& issued under these Acts. d must be used to comp 1y with this , identical to the requalification program (4) Any term, condition orlimitation (v) visions 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. Sigmficant deviations of fr m the requirements of paragraphs (c) (5) For any vio;e gor w a Participate in an accelerated (1) through (6) of this section will be license may be revoked under section perfo an evalu t ons co ucted te only isu ported by tten 1 it to c et pursuant to paragraphs (c)(4) (i) through {e P (iv) of this section clearly indicated the ommission. any provision of the Atomic Energy A t or any regulation issued under the Act. (5)hecords. The requalification subpart G-Modification and including the regulations in this part, rogr a entation must include Revocation of Ucenses [gny cti ay e pun she ine or (i) The facility licensee shall maintain f 55.61 Modification and revocation of imprisonment, or both, as provided by records documenting the participation of Heensas, law. each licensed operator and senior (a) The terms and conditions of all operator in the requahfication program. licenses are subject to amendment. PART 50-DOMESTIC LICENSING OF The records must contain copies of revision or modification by reason of PRODUCTION AND UTIUZATION written examinations administered, the rules, regulations, or orders issued in FACluTIES answers given by the licensee, and the accordance with the Act or any results of evaluations and amendments thereto. 2.The authori citation for Part 50 documentation of operating tests and of (b) Any license may be revok'e d, continues to res[t as follows: any additional training administered in suspended. or modified, in whole or in Authority: Secs.103. m 1e1.182.183. m arere in which an operator or senior part'. 189, es Stat. saa, s37. 94a. ess,954. 955. sa a e operator has exhibited deficiencies. The (1) For any material false staternent in fu"N 21 x facility hcensee shall retain these, the application or in any staternent of records until the operator e or semor 2239. 22a2): .ecs. 201. 202, ace, as Stat.1242, fact required under section 182 of the 1244.1248 u amended (42 U.S.C. 5641. 5842. operator's license is renewed. Act. 5846), unless otherwise noted. (ii) Each record required by this part (2) Because of conditions revealed by Section 27 also issued under Pub. L 95-must be legible throughout the retention not. sec.10, s2 Stat. 2951 (42 U.S C sost). period specified by each Commission the application or statement of fact or Sections 50.58,60 91. and 50 92 also terved regulation.The record may be the any report, record, inspection or othar under Pub.1. 9745, 96 Stat. 2071, 2073 (42 original or a reproduced copy or a means that would warrant the U.S.C 2133. 2230). Secuan 60.7e also tes ned microform provided that the copy or Commission to refuse to grant a license under sec.122, sa Stat. 930 (42 U AC 2152k microform is authenticated by on an original application. Sections 50.80-5021 also inued under sec. authorized personnel and that the (3) For willful violation of, or failure to 164. 68 Stat. 954, as amended (42 U.S.C 2234). microform is capable of producing a observe any of the terms and conditions Sections 50.10%50.102 also inued under sec. too,86 Stat. 955 (42 U.S.C 2238). J clear copy throughout the required of the Act, or the license, or of any rule, j tetention period. regulation. or order of the Commission' For the purposes of sec. 223 es Stat. 958, as (iii)If there is a conflict between the or amanded (42 U.S.C 2273). II mio (a). Ib). and (c). no 44. 50.46, m48, 30.54, and so.m(s) Commission's regulations in this part, (4) For any conduct determined by the are issued under sec. telb. es Stat. 948, as and any license condition, or other Commission to be a hazard to safe amended (42 U.s.C 22o1(b)); il so lo(b) and written Commission approval or operation of the facility. (c) and 50.54 are issued under sec 1611. e6 authorization pertaining to the retention Stat. 949, as amended (42 U.S.C 2201(i)), and period for the same type of record, the Subpart H-Enforcement il 50 55[e). 50.59(b). 50.70. 50.71. 50 72, 273. retention period specified for these and 278 are issued under sec.1810,68 Stat. records by the regulations in this part i 55.71 Mstions. 950, as amended (42 U.S.C 2201(o)). apply unless the Commission, pursuant (a) An injunction or other court order 3. In l 50.34. paragraph (b)(8) is to i 55.11. grants a specific exemption may be obtained prohibiting any revised as follows: B-16

Faderal Regist:r / Vol. 52. No. 57 / Wsdnesday. Mrrch 25. 1987 / Rules end Regulations 9469 interested persons an opportunity to I 50.34 Contents of appucations; technical DEPARTMENT OF TRANSPORTATION participate in the making of this information.

                                                 .                                   .                                   .                                 .   . Federal Aviation Administration              amendmenL Due consideration has been given to the comments received.

(b) * *

14 CFR Part 39 The Air Transport Association (ATA)

(8) A description and plans for IDocket No. 86-MM-2t5-AD; Amdt. 39- of America. representing operators of imp!ementation of an operator aj Boeins Model 747 and 757 airplanes I requalification program. The operator stated that the proposed rule requiring ' Airworthiness Direcuves; Boeing requalification program must as a inspection of au 747 and 757 airplanes is minimum, meet the requirements for Model747 and 757 Series Airplanes r these prograrne contained in 155.59 of AGENCY:l'ederal AVlation records list the serial numbers and Part 55 of this chapter; Administration (FAA). DOT. applicable aircraft of the subject AcTeoN: Final rule. reservoirs installed. Re ATA. therefore.

4. In i 50.54, paragraphs (i) and (i-1) requested that paragraph A.of the sumuAnY:This amendment adopts a proposed rule be deleted and that the are revised to read as follows:

new airworthiness directive (AD). d"

                                                                                                                                                                                                                 '                      ed 5 50.54 Conantons of toenees.                                                                                     applicable to Boeing Models 747 and 757 Appl es to IM el 747 nd 757 ns
                                                   *                                   *                                   *                                *

series airplanes, which requires airplanes equipped with emergency inspection of the y assenger door power reservoirs listed in H.R. Textron (i) Except as provided in 155.13 of emergency power reservoir for integrity Service Bulletin No. 803300-52-05." 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 necensary, and replacement of facility by anyone who is not a licensed inspect the airplanes if records are

                                                                                                                                                                                 *k retainers. This             ava table to determine the serial operator or senior operator as provided                                                                          amendment is prompted by numerous in Part 55 of this chapter.                                                                                                                                    numbers of the reservoirs installed. and 8
                                                                                                                                                                                                             "    the AD has been revised accordingly.

(i-1) Within three months after $n o e ema ure y scha however.in absence of such records, issuance of an operating licensa, the This condition. if not corrected would pe on m"' licensee shall have in effect an operator render the emergency power reservoir , g ac n i requalification program which must as a incapable of providing power to assist m plie in buH h minimum, meet the requirements of opening the door quickly when required he ATA also .:ommented that the i 55.59(c) of this chapter, for emergency evacuation. NOTE" in the proposed rule which Notwithstanding the provisions of DAtts: 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. P.O. Box 3707, Seattle, field since the affectivity of the program. Washington 98t24; the applicable H.R- proposed rule is clearly only against

                                                       *                                   *                                   *                             *

Textron service information may be Boeing aircraft. The FAA concurs that obtained from H.R.Textron. 25200 West the affectivity is only Boeing aircraft and

5. Immediately following i 50.73, Rye Canyon Road. Valencia. California specifically Models 747 and 757; "Ucensee Event Report System." a new 91355. This information may be however, the " NOTE" should not be I 50.74 is added as a conforming deleted because, while some Boeing 747 examined at the FAA. Northwest amendment to read as follows: Mountain Region.17900 Pacific thghway and 757 aircraft may have been i 50.74 Houhcotxm of change in operator South. Seattle, Washington. or the delivered without defective reservoirs. a or senior operator status. Seattle Aircraft Certification Office. defective reservoir could hase been 9010 East Marginal Way South. Seattle. installed in the field since delis ery. The Each licensee shall notify the note has been revised to reflect "Doeing Washingon 98168.

Commission in accordance with I 50.4 Model 747 and 757 series airplanesJ within 30 days of the following in regard FOR FURTHER INFORMATION CONYACT: Mr. Pliny Brestel. Airframe Branch. The ATA also requested that the l to a licensed operator or senior initial compliance period in paragraph l ANM-120S; telephone (206) 431-1931. ' operator: Mailing address: FAA. Northwest A of the proposed rule be changed from (a) Permanent reassignment from the Mountain Region.17900 Pacific liighway 60 to 90 days to afford those operators. . position for which the licensee has S uth. C-68966. Seattle. Washington who may not have records hsting senal certified the need for a licensed operator . numkn d resm ks. ahnal Unw to or senior operator under i 55 31(a)(3) of sueruutNTARY INFORfAATION: A complete the fleet inspection to this chapter, proposal to amend Part 39 of the Federal determine if they are affected by the rule.The ATA stated that in some (b)1ermination of any operator or Aviation Regulations to include an semor operator: a rworthiness directive which requires instances (likely 50%). the installed (c) Disability or illness as descrided in inspection of the passenger door reservoirs would require removal to emergency power reservoir on Boeing read the serial number. Further, some I 55 25 of this chapter. Models 747 and 757 series airplanes for operators check the reservoirs every Dated at Wash.ngton. DC. thin 20th day of four days and, therefore. need time to { integrity of the pressure rehef rupture March 1987. change their maintenance program to j disk, repair,if necessary. and For the Nuclear Regulatory Commission replacement of defective disk retainers, comply with the daily check requirement i John C. llople, was published in the Federal Register on of paragraph B.The FAA does not l Actmg Secretory for the Commasmn- December 24.1980 (51 FR 46687). The concur with an extension of the initial I jfR Doc.87-6478 Filed 3-24-6. 8 45 am! comment period for the NPRM. which compliance period from 00 to 90 days in l ended February 10,1987. aff orded that air safety and pubhc interrst l aw o coon tswa l l i B-17 l

I l Appendix C Regulatory Guide ,1.134 Medical Evaluation of Licensed Personnel for Nuclear Power Plants l 4 i

C-1 Raision 2* April 1987

                 #"%                 U.S. NUCLEAR REGULATORY COMMISSION 4
             @/$) REGULATORY                                                                                            GUIDE
                    .....             OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 1.134 (Task OL 4015)

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,"llow 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 guile. in Subpart C of part 55, " Medical Requirements." Sec- The information collection requirements in 10 CFR Part 55 tions 53.33, " 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 endangermg public Section 55.23, " Certification," of Subpart C, " Medical health and safety. Paragraph li) of 55.53, " 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 licensce, who becomes incapacitated because of a mental or which will then transmit a completed Form 396 to the N RC. The intent of these requirements is to have the facility pnysical condition that might cause impaired judgment licensee certify the health of its operators. Ilowever, the or" motor coordination. facihty licensee is expected to maintain those records that Section 55.27, " Documentation," requires that the n.ay 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 medicalinformation as a result of This guide describes a method acceptable to the NRC the biennial physical examination and provide that informa-tion to the NRC on request. The certification form would staff for providing the information needed by the staff for its evaluation of the medical qualifications of apphcants be sent by the facihty licensee to the NRC. for initial or renewal operator or senior operator beenses for nuclear power plants r,nd 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 conditionallicense based on medical evidence is requested under the provisions of paragraph 55.33(b). The second instance is when a licensed

              ~e The substantial number of changes in this revision has made it          individual has become mentally or physically unable to impractical to indicate the changes with lines in the margin, The guides are issued in the following ten broad divisions:

USNRC REGULATORY GUIDES Regulatory Guides are issued to describe and make available to the 2. Power Reactors 6. products pubilC methods acceptable to the NRC staff of implementing 2. Research and Test Reactors 7. Transportation specific parts of the Commission's regulations, to dehneate tech- 3. ruens and Materiais Facilities 8. Occupat6onal Health niaues used by the staff in evaluating specific oroblems or postu- 4. Environmental and siting 9. Antitrust and Financial R eview lated accidents or to provide guidance to apohcants. Requiatory S. Materials and Plant o otection 10. General Gu6 des are nol substitutes f or regulations, and comphance with them is not required. Methods and solutions different from those set out in the pu6 des will be acceptable if tney provide a basis f or the Copees of issued guides may be purchased from the Government findings requisite to the issuance or continuance of a permit or Prmting Of fice at tr e current GPO price. Information on current itcense by the Commission. GPO prlces may be obtained by contacting the Superintendent of j This guide was issued af ter consideration of comments received from Docu ments. U.S. Government Printing O f fice, Post Office Dom j 3 7082, Washmetoi, DC 20033 7082, telephone (202)275-2060 or ' the pubHc. Comments and suggestions for improvements 6n these (202)275-2371. guides are encouraged at all times, and gu6 des will be revised, as appropriate, to accommodate comments and to reflect new Informa-16on or experience. issued guides may also be purchased from the National Tecfmical informat6on Serv 6(e on a standing order basis. Details on thes Written comments may be submitted to the Rules and Procedures serv 6ce may be obta6ned by writmg NTIS, S285 Port Royal Road, ADM, U.S. Nuclear Regulatory Commission, Branch, D A R, Spf mgfield, V A 22161. Washington, DC 20S$5.

C-2 perform job duties. In this case, the factlity bcensee Nothing in ANSI /ANS 3.41983 or this guide should must notify the NRC within 30 days after learning that be construed to mean that such matters as an indi-the diagnosis has been made. The facility licensee must vidual's reading habits, political or religious beliefs, or forward to the NRC Form 396 and medical records attitudes on social, economic, or political issues should describing the disabihty. This related information is l be investigated or judged. ' required by 0 55.27 to be documented and maintained by the facihty. C. REGULATORY PQSITION An American National Standard developed by the The requirements contained in ANSI /ANS 3,41983, American Nuclear Society, ANSI /ANS 3.41983, " Medical " Medical Certification and Monitoring of Personnel Certification and Monitoring of Personnel Requiring Requiring Operator Licenses for Nuclear Power Plants,"I Operator Licenses for Nuclear Power Plants,"1 prescribes provide a method acceptable to the NRC staff for minimum requirements necessary to determine that the determining the medical qualifications of applicants for medical condition and general health of nuclear reactor initial or renewal operator or senior operator licenses. operators will not cause operational errors. The criteria presented in this standard provide an examining physician D. IMPLEMENTATION a basis for determining whether a potentially disqualify-ing abnormal health condition exists. Estabhshing mini- The purpose of this section is to provide information mum health requirements should aid in more uniform to applicants and licensees about the staff's plans for medical evaluations. Ilowever, it is necessary to recognize using this regulatory guide. that, although it is the physician's responsibihty to identify and evaluate any potentially disquahfying Except in those cases in which the licensee proposes medical conditions, NRC raakes the final determination an acceptable alternative method for complying with of the applicanFs medical fitness. specified portions of the Commission's regulations, the methods desenbed in the guide will be used in evaluat-ing the part 'of an application for irutial or renewal opera. 1 Copies may t>e obtamed from the American Nuclear Socicey, tor or senior operator beenses on NRC Form 396, "Certifi- $$s North Kensangton Avenue, La Grange Parit, tihnons 60s25. cate of Medical Examination by facihty 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 ments to 10 CFR Part 55 published on March 25, 1987, copying for a fee at the NRC Public Document Room, a copy of which was placed in the Public Document 1717 11 Street NW., Washington, DC. I 1 i 1.134-3

i Appendix D Regulatory Guide 1.149 Nuclear Power Plant Simulation Facilities for Use in Operator . License Examinations i - J

i 1 D-1 Revision 1' ! April 1987 U.S. NUCLEAR REGULATORY COMMISSION 4 l

             @,,(#"%gg REGULATORY                                                                                             GUIDE
                    *....                 OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 1,149 (Task OL 402-5) l

) NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE 1 l IN OPERATOR LICENSE EXAMINATIONS L A. INTRODUCTION B. DISCUSSION Paragraph 55,45(a) of 10 CFR Part 55, " Operators' Although ensuring that individuals who receise opera-I Licenses," requires that an applicant for an operator or tot or senior operator licenses possess the knowledge, I senior operator license demonstrate both an understand- skills, and abilities necessary to operate the facility in a ing of and the abdity to perform certain essential job safe manner is the responsibihty of facility licensees, the tasks. Paragraph 55.45(b) specifies that these operating Nuclear Regulatory Commission must perform an inde-tests will be administered, in part, either in a sirnulation pendent audit of this process through its operator facihty consisting solely of a plant-referenced simulator licensing examinations. Section 55.45, " Operating Tests," that has been certified to the Commission by the of 10 CFR Part 55 requires the cand:date for a license facility bcensee or in a simulation facility approved by to demonstrate (1) an understanding of and the abihty the Commission after application has been made by the to perform tbc actions necessary during normal, abnor-facility licensee 8 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 to the NRC staff for complying with those portions of function within the control room team in such a way the Commission's regulations regarding (1) certification that the facility licensee's procedures are adhered to and of a simulation facility consisting solely of a plant- that the hmitations in its license and amendments are referenced simulator and (2) appbcation for prior ap- not violated. proval of a simulation facility. The use of a plant referenced simulator for testing ' The Advisory Committee on Reactor Safeguards has enables the examiner to evaluate a candidate's perfor-been consulted concerning this guide and has concurred mance in an environment closely correlated with condi- l in the regulatory position. tions in the specific plant for which that candidate has applied for a license. With major facility differences Any mformation collection activities mentioned in minimized between the testing and operating environ-this regulatory guide are contained as requirements in ments, examiners have been able to make pass-fail those sections of 10 Cl R Part 55 that provide the judgments with confidence. , regulatory basis for this guide. The information collec- ( tion requirements in 10 CI R Part 55 have been cleared Although the increased use of plant-referenced simu- ) under Clearance No. 3150-0018 and No. 3150-0138. lators has provided to examiners the capability for ]

                 *The substantial number of changes in this revision has made it            better discrimination between success and failure in a impractical to indicate the changes with hnes in the margin.                   candidate than could be achieved with non-plant-                                    l referenced simulators, the staff recognizes the existence IA simulation facility is defined in C 55.4 as one or more of the         of several factors that could suggest the use of alterna-following components alonc or in combination, used for the partial conduct of operating tests for operators, senior operators,and candi-          tive systerns or devites for conducting the non-                                    I dates:                                                                         walkthrough portions of operating tests. These factors simulat(ion device,i) the plant, (ii) a plant-referenced simulator, (iii) another                                                                                  J USNRC REGULATORY GUlOES                                     The guides are issued 6n the fol6owing ten broad divessons:

Regulatory Guides are issue.1 to describe and make available to the public rnethods acceptable to the NRC staff of implementing 1. Power Reactors 6. Products

2. Research and Test beactors 7. Transportal 6on speciflC parts of the Commission's regulations, to delineate tech. 8. Occupational Health niques used by the staff in evaluating specafic problems or postu- 3. F uels and Materials F acelities lated accidents, or to Af ovide guidance to applicants. Regulatory 4. Environmental and $stang 9. Antstrust and Fsnancial Review Guides are not substitutes f or regulations, and compliance with 5. Materials and Plant Protection 10. General them is mot reClutred. Methods and solutsons d6f ferent from those set out in the guides well be acceotaDie et they provide a basis for the Copees of issued guides may be purchased from the Government fsndings requesste to the issuance or Continuance of a perrnit of Pranting Of fice at the current GPO ptsce. In f ormation on current isCense by the Commission. GPO prices may be obtained by contacting the Superintendent of This guide was issued af ter consideration of comments receeved from Documents. U.S. Government Printing Of fsce, Post O f fic e Box the pubitc. Comments and suggestions for improvements in these 37082, Washington, DC 20013 7082, telephone (202)2 75-2060 or guides are encouraged at all times, and guides will be rev6 sed, as (202)275-2171.

appropriate, to accommodate comments and f 1 reflect new informa. tion or experience. Issued guides may also be purchased from the National Tectin6 cal Written comments may be submitted to the Rules and Procedures I nf orma tion Service on a standing order bases. Detasis on t his Branch, D R R, ADM, U.S. NvClear R egulat or y Commistoon, service may be obtained by writing NTIS, S285 Port Royal Road, Washington, DC 205SS. Springfield, V A 22161. Ir* *

 -                                                                                                                                                   ____________________._____b

I

D- 2 m

include the cost and lead time associated with procure- to ensure the continued acceptability of the simulation ment or upgrading of a plant-referenced simulator. More-facility. These malfunctions, if applicable to the facuity, over, rapidly changing technology in the simulation indus. should be tested in their entirety not less than every try is resulting in previously unavailable options that four years, approximately 25% per year. When con-could lead a facility licensee to seek alternative ways to ducted in addition to the tests required by Section 5.4 meet ~ the ' requirements of @55.45. ANSI /ANS-3.51985, and when subjected to the performance criteria for

    " Nuclear Power Plant Simulators for Use in Operator                 transient operations specified in Section 4.2, " Transient Training"2 (the standard), in conjunction with this                  Operation," these malfunction tests provide an accept-regulatory guide, provides guidance in these areas, able means of demonstrating the performance and operability of the simulation facility.

C. REGULATORY POSITION

6. Appendix A to the standard, " Guide for Document-Requirements are set forth in ANSI /ANS-3 51985 for ing Simulator Performance," and Appendix B to the specifying minimum performance and configuration cri- standard, " Simulator Operability Tests," should be con-teria for a simulator, for comparing a simulator to its sidered integral parts of the standard, reference plant, and for upgrading simulators to reflect changes to reference plant response or control room D. IMPLEMENTATION configuration. These requirements provide a method i

acceptable to the NRC staff for a facility licensee (1) to The purpose of this section is to provide information j certify a simulation facility consisting solely of a plant- to facility licensees about the NRC staff's plans for using referenced simulator or (2) to obtain approval of a this regulatory guide. simulation facility for use in portions of reactor opera-tor and senior eperator license examinations subject to In accordance with the requirements in 55.45 of l the following: 10 CFR Part 55, the simulation facility portion of the operating test will not be administered on other than an

1. The references to operator training in Section 1, approved or a certified simulation facility after:

   " Scope," of the standard should be taken to apply to operating tests for operators, senior operators, and candidates.                                                               1. The facility licensee h.:s submitted a certification in accordance with paragraph 55.45(b)(5)(i), or

2. Simulation facilities as defined in @55.4 of 10 CFR Part 55, to the extent that the facility licensee applies 2. The staff has approved an application submitted for approval under the requirements of paragraph 55.45(b), by the facility licensee in accordance with paragraph should meet the applicable requirements of the standard. 55.45(b)(4), or

3. The standard identifies in Section 1.1, " Background," 3. May 28,1991, whichever occurs sooner, other documents to be included as part of the standard.

The applicability of one of these documents, ANSI / Until that time, the NRC will continue to give exami-ANS-3.1,2 should be determined by refering to Revi- nations for a facility licensee's reference plant in accord-sion 2 to Regulatory Guide 1.8, " Qualification and ance with Generic Letter 8218, " Reactor Operator and Training of Personnel for Nuclear Power Plants." Senior Reactor Operator Requalification Examinations,"3 October 12, 1982.

4. Section 5.2, " Simulator Update Design Data," re-quires that reference plant modifications be reviewed Licensees and applicants may propose means other annually against the simulator and that the simulator than those specified in Section C of this guide for meeting update design data be revised as appropriate. This applicable regulations. Except in those cases in which a l should be taken to mean that the first such annual facility licensee submits a certification for its simulation review and update should take place within one year facility or proposes an acceptable alternative method for following the facility licensee's certification as specified complyirig with specified portions of the Commission's in paragraph 55.45(b)(5)(i) or within 18 months follow- regulations, the NRC will use the method described in ing the submittal of the application for approval as this guide in the evaluation of the application for specified in paragraph 55.45(b)(4)(i). approval submitted by the facility licensee for its simula-tion facility. The guidance provided in Section C has

5. Section 5.4, " Simulator Testing," requires the con- been approved for use by the staff in the evaluation of duct of specific tests to establish simulator performance all submittals as an acceptable means of complying with and verify its operability. In addition to these proce- the Commission's regulations specified in Section A.

dures, applicable malfunctions, identified in Section 3.1.2, " Plant Malfunctions," should be periodically tested If a facdity licensee wishes to utilize a simulation facility for more than one nuclear power plant, it must 2 3 Copies may be obtained from the American Nuclear Society, Available for copying for a fee or inspection at the NRC 555 North Kensington Avenue, La Grange Park,IL 60525. Public Document Room, 1717 11 Street NW., Washingtan, DC. 1.149 2

D-3 demonstrate to the NRC in its certification or in its 2. Technical specifications; application that the differences between the plants are not so significant that they have an impact on the .. ability of the simulation frcility to meet the require- 3. Procedures, primarily abnormal and emergency ments and guidance of ANSt/ANS-3.51985 as qualified operating procedures; in this regulatory guide for each of the plants. This demonstration should include an analysis and summary of the differences between each plant and the simula- 4. Control room design and instrument / control loca-tion facility, including: tion; and

1. Facility design and systems relevant to control room personnel; 5. Operational characteristics.

l

l l l 1.149-3 l 1 l 1

D-4 VALUE/ IMPACT ANALYSIS A separate value/ impact analysis has not been pre- Room at that time. This analysis is also appropriate to pared for this regulatory guide. A value/ impact analysis Revision 1 of Regulatory Guide 1.149. A copy of the was included in the regulatory analysis for the amend- regulatory analysis is available for inspection and copy-ments to 10 CFR Part 55 published on March 25,1987, ing for a fee at the NRC Public Document Room, a copy of which was placed in the Public Document 1717 11 Street NW., Washington, DC. i 4 2.I49-4

Appendix E Regulatory Guide 1.8 Qualification and Training of Personnel for Nuclear Power Plants l 1 l

{ l E- 1 Revision 2' s [,n%4 U.S. NUCLEAR REGULATORY COMMISSION April 1987 W,oM

      %W /

REGULATORY GUIDE i

                                                                                                                                                        -(
           **...             OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 1.8 (Task OL 403 5)

QUALIFICATION AND TRAINING OF PERSONNEL FOR NUCLEAM POWER PLANTS - A. INTRODUCTION training of nuclen power plant personnel. This standard was approved by ths American National Standards Paragraph 50.34(b)(6)(i) of 10 CFR Part 50, " Domestic Institute (ANSI) Comnuttee N18, Design Qteria for Licensmg of Production and Utihration Facilities," requires Nuclear Power Plarets nd designated ANSI N18.1-1971, that an application for a license to operate a nuclear " Selection and Traines af Nuclear Power Pbnt Person-power plant include information concerning organizational nel." Regulatory Guide 1.5, " Personnel Sc'. ction and structure, personnel qualifications, and related matters. Traming," endorsing ANSI N18.1 1971, was issued in Subpart D, " Applications," of 10 CFR Part 55," Operators' March 1971, and Revtsinn I was issaed P September Licenses," requires that operator license appbcations 1975. A revision of ANS', N13.14 971 was subsequently include information concerning an individual's education approved by the ANS) B ar6 of Standards Renew and and experience and related matters. This regulatory guide designated ANSI /DS 3.1-1978, "Lelectica and fraining 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 quahfications A first proposed Revision ? t, Regulatory Guide 1.8 of nuclear power plant personnel. Personnel cf test, endorsing ANSI / A NS-3.1-1978 was issucJ for pubbe traming, researcli, and mobile reactors are not covered comment in February 1979. As a result of experience by this regulatory guide. gamed from the accident at Thru Mi'e Islan:1 Unit 2~- (TMI-2), additional public cow ents in the area of The Advisory Committee on Reactor Safeguards has personnel quahfications were a quested on proposed been consulted concerning this guide and has concurred Revision 2 to Regulvory Guide 1.8 :n May 1979. All in the regulatory pontion. of the comments flout both requests were forwarded to the ANS-3 Subcommittee for its t,*e during the develop-Any information collection activities mentioned in rnent of a revision to ANSI /ANSJ.1-M78. Subsequent-this regulatory guide are contained as requirements in ly, Draft Standard ANS 3.1, dated Dm mtser 6, IM, 10 CFR Parts 50 and 55, which provide the regulatory incorporating the upgraded requiren ena wa1 issued in basis for this guide. The information collection require- September 1980, public comments wcM requestea en a ments in 10 CFR Part 50 have been approved under secor.<1 proposed Revision 2 to Regaiory Guide 1.8 OMB Clearance No. 3150-011, those in 10 CFR Part that endorsed Draft Sta d id ANS 3.1. The public 55, under OMB Clearance No. 3150-0018. comments received w ere h id in abeyance pending Commission action on proccsed rules on operator B. DISCUSSION quahfications and beensmg in SECY 81-84, "Qualifica-tion of Reactor Operators,"3 f ebn ary 2, 1981, and Subcommittee ANS-3, Reactor Operations, American SECY 81-84 A, "Discussiot' of R : visions to Reactor Nuclear Society Standards Committee, developed a Operator Qualifications,'l J t. ie 15, 1981. The Commis-standard containing criteria for the quahfication and sion did not approve eitht r of these proposals and directed the staff to cr 1tinue to study the issue. The substantial nurnber of changes in this revision has made it Copics are available for inspection or to ing fes a fee in the impractical to indicate the changes with lines in the margin. NRC Public Document Roorn, 17 8 711 Street ? ., Washington, DC. j I USNRC REGULATORY GUiOES The gusoes are issued in the folkwilng IN brot j civisions: Regulatory Guices are issued to oescrine and make avanable to the I pubHc methoot acceptable to the NRC staf f of 6 implementing 1. Power Reactors 6. P oducts i specific parts of the commsssion's regulations, to ochneate >mch. 2. Research ano Test Rectors 7. > ansc+rtation nsaues used by the staff in evaluating specific problems or postu- 3. Fuels anc Materials F acuh.,r4 8. Or ctMoral Health litoo accioents or to provice guicance to appiacants. Regulatory 4. E environmental anc swr g 9. A..htrust ano Financial Review Guices are nol substitutes f or regulations, and compliance with 5. Materlass ana Ptant Protection 10. Generat them is not reautrea. Methods ano sosutions omerent from those set out en tfie guices wati be acceptable if they provios a t, asis for the

 'mdings requisite to the issuance or continuance of a permit or            Copies of issued gulces may be surci ated f r on the Government hcense by tne commission.                                                  Prmtmg Office at tne ca rent GPO r. ica. Inforr'hation on current GPO prices may be obtaineo by con acimo tne Superintendent of This aulae was issued after consideration of comments receivea from        Doc u ments. U.S. Government Prmt mg O f fice. Post Orf ace Box the pubhc. Comments ano suggestions for improvements m these               3 7o82, Washmotor DC 20013-7082, temphone (202)275 2060 or ounces are encouraged at au times, ano pu6ces will be revised, as          1202)275-2171.

appropriate, to accommooste comments and to reflect new informa. tion or emperience, lasueo guices may also be purchas41 / rem the National Ternn6 cal written comments may be submitted to the Rules and Proceoures in f or mation service on a stanomt or r.e r basis. Details on this Brancth DRR ADM, U.S. Nuclear R egulat ory commession, Washington, Dd 205%. servece may be obtained oy writan :1T 5, 52 85 Port Hoyal Road, Sprmefielo, V A 22161.

o-f2 During 1981, Drah SbWd ANS 3.1 was updated to 10 CFR iv 50) and the requirement to have a shift 4 factor in additional levort learned from the TMI-2 tc4hrinal aJ isor (STA) available to *he shift (NUREC-accident and changing regulatory requirements. The 073'i, !. A. I .1 ). One option in ths irriity Statemr t.

           .. standard was approved by the American Nuclear Society's                 yhich r ,' referred Fy the Commission. Qlm combinmg Nuclear Power Plant Standards Committee (NUPPSCO)                      the functions of the STA with one ed the required senior and the ANSI Board of Standards Review and was                         operators as long as specific training and education reissued as ANSI /ANS-3.14981, " Selection, Qualification              requirements are met. The other option allows for con-and Traising of Perscnnel for Nuclear Power Plants."2 A                 tinuation of an approved .ndependent STA program.

third poposed Revimon 2 of Regulatory Guide 1.8 was Regulatory Position C.l.j reflects the guidance provided developd to endorsd nb SI/ANS-3.1-1981. hh certain in this Policy Statement. additions and cenim and was issued for tublic com-ment ir4 January W! As a result of the public com- C. REGULATORY POSITION ments .and Commission ..tions concerning trainirg and qualificaths. this Revision 2 of RegWatory Guide 1.8 1. Positions in ANSI /ANS3.1-1981 that Are Endorsed now er:. Q Sections 4.3.1.1, "Sluft Supervisor," 4.3.1.2, by thir. Regulatory Guin

                 " Senior Opt 1 tor ( 4.5.1.2, " Licensed Operators," 4 M,
                  ' Shift Technical Auvisor," and 4.4.4, " Radiation Protei-                 For th: positions ked in ANSI /ANS-3.1-1981,
              , tion," of ANSip,'S-3.1-1981 Erdortmuent for all other                   " Selection, Qualification and Training of Personnel for positions w?! amain with ANSI N18.M971, " Selection                     Nuclear Power Plants," as shift supervisor, tenior < pt:ra-
               ' and Triamg r oi Nuclear Pour Plant versonnel." The                      tor, licensed operator, and shift technicei advuor, the l>ases for the @unons and exceptionJ to ANSI /ANS-3.1-                  requirements contained in the standard prmide an 1981 are contmed ir. NUREG-0737, " Clarification of                   approach acceptable to the NRC staff for complying with TMI Action Plan Requirements,"3 which includes the                      the qualifications and tninmg rt quirements of 10 CFR           i March :'8,1980 letter to all power reactor applicanu                   Parts 5') and .45 subject to P,e zuidance regard.ng the and beenst.cs regardmg qualification of reactor operators,             STA function provided in the Commission's "Pobcy and NUREG-0094, " Guide for the Licensing of Facility                  Statement on Engineering Expe.tise on Stuft" and the Operators, including Senior Operators,"3 and the Commis-               clarifications, additions, and excepuns in paugraphs a sion'e  Policy Statement on Engineering Expertise on                 through k below. For radiation rm'ection supervisory Sbift" L50 FR 43621). 'Ihe regulatory position related.                personr el, Section 4.4.4 of the sta; dard s or.tains an to the adiatio, protection manager is revised from what                approa:h acceptable for the position uf bdurion protec-was ind ded m Revision 1 of Regulatory Guide 1.8 (1975).               tion manager (RPM) subject to the following The kJustry has adopted the requisite qual:fications in MI, ANS 3.1 1981, and the current change mdorses                            a. In lieu of the description in Sectia 5.1 m ANSI /

that idustry position. ANS-Al-1981, cold license examination # Lhould be defined n those that are administered before the unit has com. On March 20,1985, the Commission issued a "Polky pleted preoperational testing and mital operations as Statement on Trainmg and Qualification of Nuclear described in its Final Safety Analysis Report m; amended Power Plant % rsonnel" (50 FR 11147) that recog- and approved by the Commission, liot examinations are nizes irdusty wmitment to accredit training pro- those admir.istered after this condition is attained, grams. In the pctry .tatevent, the NRC endorsed the training accreditation progra a m:maged by the Institute b. Ho; license appheants must meet the training of Nuclear Power Dperations (INPO) because st encom- clements m Sections 4.3.1.1.c, 4.3.1.2.c as d 4.5.1.2.e of passes the elements of performanc -ba. sed trainir.g and the studard and the experience elements 'n 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 sward. Cold guslifications commensura'.c with tM performance re- license applicants are subject to the training ekments quirements of their jobs. The Comrnission has decide *l identified above, but they are exempt from the expe-to withhold action on promulgating new trWJrg and rience elements. qualifications regulations during an evaluatio.t period. During that period, NRC will continue to evanaate the c. Paragraph 2 of Section 4.3. .l.9 a f ANSI /AN3-3.1-results of the screditation program to determine if the 1981 is not applicable. An in6vidual who met ts the voluntary industry f fforts ensure qualifications that meet Commission's "Pohey Statement ca, Engmee. sng lixpenise or excetd the min"num standards inMed in this p.ide$ on Shift" is required on all duits to provide engmeeting

                                       ~                                                  expertise (see Ryuiatory Position C.I.1).

The Commissim's " Policy Stakmed or inrgineermg Expertise on Shift" issued on Octobet N, 1985 (50 FR d. The trinimum educationa: requirement for shift 43621) provides two options for meetir 3 nuclear l awer supervisors, Section 4.3.1.1.a, and for senict orentors, plant staffing reesirements 4 ragrn h !C.54(m)(2)(2) of Section 4.3.1.2.a. is a high school dirlom; or eqWvent. 2copio may us Eabed Pom she Are icas. Nuclear Dcuty, c. An apphant Wa senim m um M Mme 555 Ny.a Xensingwl6.venc, t.aGrange fartt II, 60s25. r,hould have 4 years of responsble power plant exper-ka bst uhes may defmed as having actively perfarmed as a designated e Boxt>c oMained 37052. frorn theDC Washington, Governme.at Prk.dng Orfice, 20013-7082.

                          *C 1.8-2

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            *A
             .f                                                                                                     ,

s- 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 trn:init sufficient ta ensure that the STA is cognizant of of the facility during or after the final year of construc- facihty and procedure changes that occurred during the tion. A maximum of 2 years of responsible power plant a W nce, experience snay be fulfilled by academic or related tech- ' nical training on a one-i&one time basis. Two years sho ald Conibining the functions of a senior operator and the be tws. lear power plant experience. At least 6 months of STA is 9ecepable if the provisions of the Commission's tb;owlear power plant experienes should be at the " Policy Statement on thgineering Expertise on Shift" plaat for which an appl 1Jant sects a ',icense. In addition, are met. In addition . to the requirements specified in

    ,                 a$ cants for an SO positivn act holding a bachelor's                 Section 4.4.8.c of ANSI /ANS-3.1-1981, the STA should O'                     degree in engineering or equivMent should have held an               have specific trening in.the response to and analysis of operator's license and should hm e been actively involved            plant transients and accidents and training in the rela-in the performance of licensed c.uties for at least 1 year,          tionship of accident conditions to offsite consequences 3                                        and protective action strategies.

f. In addition to Uw requirements stated in Section 5.2.1.2.1 of ANSI /ANf3~t-1981, classroom instruction k. The radiation protection manager should have the for all license splicants shoult incluoe training in the qualifications described in Section 4.4.4 of ANSI /ANS-use of insta!!cd p.%ntwerns for the control and mitiga- 3.11981 with :.% clarification that 3 of the 4 years of tion of an Weident n, which the core is severely damaged. experience in 4thed radiation protection should be i profession.tMevel nperience,

g. In addition to the requirements M 5ection 5.2.1.3.1

,~

of ANSI /ANS-3.1-7 981, each applicant fos an operator or 2. Positions in ANSI /ANS N18.11971 that Are Endorsed senior operder leew Avuld serve 3 months as an utra by t!b F.egulatory GuHe person on shift in traming for that position. The 3 months as an extra ferson c,n shift in training 6ald For positions listed in the :tandard other than those include all phases of day-to-day operations unkt Q under Regulatory Postion 1 above, the requirements con-supervision of licensed personnel. tained in ANSI N18.11971, " Selection and Training of Nuclear Power Plant Personnel," provide an approach

h. Control room operating experience for hot licena acceptable to the NRC staff for complying with the quali-applicants, deacribed 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 552 facihty during a minimum of five reactivity changes. tivery effort should be made to have a diversity of reactivity U. IMPLEMENTATION changes for each applicant. Startups, shutdowns,large load t chantr.s, and changes in rod programming are some esam- The purpose of this section is to provide information pies and could be accomplished by manually using such to applicants and heensees regarding the NRC staff's f (t ,

                 ' systems as rod control, chemical shim control, or recircu-             plans for using this regulatory guide.

l lauen flow. l A- A pplicant t and licensees may propose means other

i. All cold beense applicants should participate in than those specified in Section C of this guide for meet-( pvactical work assignments as described in Section 3 31.4 ing applicable regnations.

of ANSI /ANS 3.1-1981 for a minimum of 6 months l L in addition to the r:sponsibihties described in Sec- Except in those cases in which the applicant or hcensee tion 4.4.8 of ANSI /ANS-3.1 1981, the STA snould assume proposes an acceptable alternative means of complying an active role in shift activities. For uample, the STA with the Commission's regulations specified in Section A,

      ,            should review plant logs, participate in shi.ft turnover,              the guidance provided in Section C has been approved and mainttin awareness of plant configuraticin 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 qualificatiora and traming requirements for Section 4.4.8.a of ANSI /ANS-3.1-1981 are not a ppli-                (1) nuclear power plant personnel as described in appli-cable. An independent Sl A should have a bachelor's                   cations for an operatmg bcense. (2) Orlicants for opera-degree or equivalent in a scientific or engineering discipline.       tot and senior operator licenses, ard (3) replacement personnel in those positions n operating nuclear power "Acuvely performing ST A functions" means perform-              plam whose training programs have not yet been accred-ing at least three saifts per quarter es the STA. If an               ihd bp an accreditation program endorsed by the NRC.

f l.g.3 4

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 11 Street NW., of which was placed in the Public Document Room at Washington, DC. l f 1.8-4

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