ML20237K949
| ML20237K949 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| FRN-49FR4628, RULE-PR-50, RULE-PR-55 NUDOCS 8708200014 | |
| Download: ML20237K949 (175) | |
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PDR L
UN11EU STATES ,
NUCLEAR REGULATORY. COMMISSION 1
OR G NAL -
IN THE MATTER OFi DOCKET NO:
NRR MEETING FINAL RULEMAKING FOR OPERATORS LICENSES l
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LOCATION: ROSEMONT, ILLINOIS PAGES: 1 - 173 l
DATE: THURSDAY, APRIL 16, 1987 1
Aa-FEDERAL REPORTERS, INC..
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444 North Capitol Street. l Washington, D.C. 20001 l
'~~ N I (202) 347-3700 hog 82gggl4 g 0b . NATIONWIDE COVERACE PDR I
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1 1 S.21548 2
, UNITED STATES OF AMERICA 3
NUCLEAR REGULATORY COMMISSION 4
5
x 6 :
In the Matter of: :
7 :
HEARING ON FINAL RULE-MAKING :
8 :
FOR OPERATOR LICENSES :
9 :-
x 10 ,
11 Ramada Inn O' Hare 6600 North Mannheim Road 12 Rosemont, Illinois 13 Thursday, April 16, 1987 14 The meeting in the above-entitled matter convened at 15 8: 30 A. M. -
16 PRESENT:
17 MR. NICK CHRISSOTIMOS, 18 MR. JOHN H ANNON, 19 MR. BILL HEIL, 20 MR. WILLIAM T. RUSSELL, 21 MS. SUS AN SH ANKMAN ,
22 MR. JERRY WACHTEL.
23 24 s 25 Sonntag Reporting Service, Ltd.
. Geneva, Illinois 60134 (312) 232-0262
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.1 P.R O C E E D I N G S 2 MR. RUSSELL: We have about nine sets of 3 presubmit'ted questions and answers. Because we have 4 more than we've received in any other region and because 5 we've had the situation already occur where we've gotten l I
6 to close of business and people still had questions that j 7 weren't answered, we'll follow that same practice.
8 If you have a question and don't get an opportunity 9 to have it asked, simply write it down and pass it up to l
10 the front, particularly in case you've got to leave. to 11 catch an airplane later this af ternoon and it looks like 12 we' re running out of time.
13 We will answer all questions received, whether l l
14 orally or in writing, and we will document the responses
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1 15 to those in NUREG. )
16 While we're getting set up here at the front, let's 17 take a minute and stretch in place. Then we'll start in '
18 just a couple minutes.
19 (WHER EU PON , a recess was had, after which 20 the meeting was continued as follows:)
21 MR. BEIL: Could we have everybody take their 22 seats, please.
23 As Bill indicated, we're going to be starting this 24 question-and-answer session with the questions that were 25 submitted in response to the Generic Letter.
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3 1 We would ask that you please, when you get up to 2 ask a question, state and spell your name before you ask i 3 the question. That's a request f rom. our Court Reporter. l 4 Otherwise, she has difficulty with the names.
5 MR. RUSSELL: Let me clarify. The purpose 6 for having the name or the affiliation is so we can 7 follow up in putting the information together with 8 requests from companies. We don't intend to put your 9 name in the NUREG and say, "This is your question."
10 (Laughter.)
11 The second point is that, in my opinion, there are 12 no dumb questions. If it's not understood at this 13 point, the purpose of this meeting is so that you can 14 get an answer to your questions.
15 MR. HEIL: What we would like to do is as we 16 go into these questions, which is a departure from what 17 they've done in the past, we're going to take it 18 f acility submittal by,' f acility submittal, rather than l i
19 subject areas, because we have so many submittals. l 20 We would like to have you key off on the question ;
i 21 the subject area that's in the question. In other I
22 words, if the question deals with a certain particular j l
23 portion of the regulation, we'd like you to stay with j 24 that portion of the regulation at least through that
. 25 question.
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I 1 Also, when you get up and ask a question, if you ]
2 have. the particular part of the regulation that deals I
3 with this question, please state that, also. !
i 4 I'm going to start with the first submittal we 5 received, and that was from Indiana & Michigan Electric ,
6 Company, dated March 30th.
7 The first question deals with the' final rule. I'm 1 8 going to go ahead and read it because we're going to 9 ref er this one to you.
10 "How (by what means).is a utility to certify to the 11 Commission that their requalification program is both 12 accredited and based upon a systems approach to .
13 training?
14 "The interpretation for implementing a systems 15 approach to training is somewhat different by the NRC j 16 and INPO.
17 "By what specific standards is our certification J
18 for using a systems approach to training based; i. e., {
l 19 the NRC's criteria utilized in conducting pre / post 20 accreditation site evaluation or using the INPO 85-002 21 criteria?"
22 MR. RUSSELL: First, I'd like to believe that 23 the two are equivalent; that is, the NUREG approach in q
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24 1220-, which is essentially a series of questions related 25 to each of the five elements of a systems approach to
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- 5 1 training as it's described in the policy statement.
2 In'that same policy statement, the Commission has 3 endorsed the INPO accreditation. objectives and criteria i 4 as being a systems approach to training.
5 The difference comes about ' that INPO has 12 6 objectives and some number of subordinate criteria on 7 the order of 60. The Commission in the policy statement i
8 identified five elements, and the Staff has a number of 9 questions that we use for information-gathering in our reviews.
10 11 We believe that those two are equivalent. However, 12 we would pref er that you use the INPO accreditation l
13 objectives and criteria and supporting documents; in '
14 particular, for your requalification program, to 15 consider the guidelines contained in INPO Document 16 86-025, continuing training program for licensed I 17 ope rator s.
18 There is clearly a hierarchy of documents within 19 the INPO program. Objectives need to be met. Criteria
- 20. may or may no,t be met if you can still meet the 21 objectives. Guidelines are just that: They are 22 guidelines, an acceptable way of doing business as INPO 23 would review it.
24 That is very similar to the Staff's approach in We have questions
( 25 doing our postaccreditation audits.
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6 1 that relate to each of the five elements that the 2 Commission has endorsed. Those questions do not imply 3 criteria. They are simply areas where we gather
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4 information.
5 So the simple answer to the question it follow 6 INPO, and we believe that if we were to come and do an 7 evaluation after the fact, that it would be 8 satisfactory.
9 Most importantly, though, if you are accredited, 10 that is a sufficient indication to the Staff that you 11 know how to do the process.
12 We have seen several cases where the 13 requalification program was not based upon a systems 14 approach to training; rather, it was based upon a l
15 training program docketed with the NRC, that the NRC had l 16 approved.
17 It was very prescriptive. It was, " Conduct X 18 number of hours of classroom training, perf orm certain 19 practical factors on the simulator in accordance with 20 the Denton letter," et cetera.
21 Because of a reluctance on the part of the utility 22 to change commitments that are required by license, 23 condition or regulation, many of those programs were not 24 changed to be a systems approach to training.
y 25 Effective May 26th, you can remedy that prior Sonntag Reporting Service, Ltd.
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1 restriction by simply sending a letter to the NRC which l
2 indicates you are accredited and you have developed ycur 3 requalification program on a systems-approach-to-4 training basis.
5 That's the most important aspect, I believe, of 6 this rule. It gives you the flexibility to control the 7 content of continuing training based upon the needs-of 8 the individuals who have been trained and the feedback 9 mechanisms which are described.
10 Most important is Element 5 of the systems approach 11 to training: program revision based upon evaluation of 12 perf ormance on the job. That's where we see the major 13 payoff, and we think that we are giving you back the 14 flexibility that you need to fully implement the 15 industry commitments through training and accreditation. j 16 MR. BEIL: Thank you, Bill.
17 The next question has been termed a simulator i l
18 question, and it's going to go to Jerry Wachtel. )
i 19 The question is: "By what means are utilities to I 20 determine the NRC's interpretation of ' reference plant' j j
21 as it applies to multi-unit plants at one site (from the 22 same vendor and vintage)? ;
23 "It seems compliance with this Part 55 is 24 contingent on a clear interpretation of this term, 1 25 ' reference plant.'"
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8 1 Jerry?
2 MR. WACHTEL: As I mentioned in my 3 presentation earlier, the definition of " reference 4 plant" has been provided in Section 55.4 of the 5 regulation. Section D, which is the implementation 6 section of REG GUIDE 1.149, provides clear guidance for 7 the use of one simulation-facility at more than one 8 plant or unit, since each plant has a unique docket 9 number.
10 The greater the similarity between the units, of 11 course, the more it is likely that you'll be able to 12 submit one certification form for each', identifying any 13 exceptions as necessary against ANS 3.5.
14 As I mentioned in my remarks earlier, if your 15 operators are dual-licensed, tha'c's a pretty good 16 indication that a certification with exceptions, as 17 opposed to the necessity for an application for. our 18 approval, would be considered satisf actory for multiple 19 units or multiple plants.
20 MR. BEIL: Thank you, Jerry.
21 The next question is f airly obvious. I'll take 22 that one. "Will copies of REG GUIDES 1.134, 1.149 and 23 1.8 be available for review at the public meeting?" {
24 I think you all received copies of those.
( 25 The next question again deals with a simulator, and Sonntag Reporting Service, Ltd.
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9 1 we'll address that again to Jerry.
2 "Would the Commission find a formal simulator 3 facility review board / committee (consisting of training 4 management, operations management and senior reactor 5 operators) a suitable forum for making judgments 6 regarding the simulator scope requirements versus_ l l
7 training value? !
l 8 "For example, ANSI /ANS 3.5-1985 states that all 9 accidents analyzed in the facility's FSAR must be l
10 included in plant malfunctions in the simulator's scope.
11 It then later states that this is required only when the 12 simulator is determined to be appropriate for training. '
13 "However, in a few cases the accidents provide 14 little, if any, training value to an operator. Can a l i
15 board, such as proposed, be considered a legitimate
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16 forum for making these decisions, judgments?"
l 17 MR. WACHTEL: I think you need to remember j 18 that we are concerned with the applicability of your f 19 simulation facility to conduct operating tests, and not i 20 as it applies to your training programs.
21 Generally speaking, when you look at the ANS 3.5 ;
i 22 document, you can safely substitute the term " operating 23 tests" wherever the term " training" appears in the 24 standard.
25 Although we recognize that your simulator's scope, I l:
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- I when applied to procurement of a simulator as part of 2 your training program, may exceed that which is !
3 necessary for the simulator's applicability to use in 4 operating tests, it doesn't matter to us what process 5 you use internally to identify those differences.
6 We have tried to indicate clearly the scope 7 requirements for use of your simulation f acility to 8 conduct operating tests, and it must meet those 9 minimums.
10' These include, as I discussed earlier, the 1
11 evolutions and malfunctions that are identified in the 12 standard Section 3.1.2 and the appendices to the 13 standard, the performance test appendix and the j 14 operability test appendix using the required operating 15 test criteria in Section 55.45(a) as the criterion.
16 However you meet those requirements is your 17 decis!xn to make; and as to whether you need to certify 18 or provide additional perf ormance testing data for 19 anything additional, that's also your decision to make.
20 MR. RUSSELL: Let me add something.
21 I think a real practical aspect is that you will be 22 submitting performance test abstracts with the Form 474 23 that describe the testing that you' re going to perform.
24 When you look at the list of malfunctions and you !
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25 see a malfunction that says " loss of power," that's very Sonntag Reporting Service, Ltd.
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11 I broad. It could be loss of power to an individual 2- panel. It could be loss of power to a vital bus. It
- l 3 could be loss of power to the station. I 4 Which ones do you choose in developing the test 5 abstract for various losses of power?
6 Another example may be.a reactor trip from 100 7 percent power or, in fact, your simulator may be able to 8 simulate a reactor trip from any power level.
9 You should look at the testing that you propose 10 and, if possible, combine some of 'those malfunctions so
, 11 that you have a smaller number of perf ormance tests than l
l 12 would otherwise be the case and describe how those tests l 13 in your abstracts meet the intent of the ' standard.
14 In doing that, we would then use those tests in i
15 making a judgment as to what the capabilities are. That 1 16 does not mean that we would limit our examinations, l
17 however, to those particular tests or scenarios. !)
l 18 Obviously, if you demonstrate that the simulator 19 works well for an event at high power and for some tests ;
20 at low power, we may be able to mix those just as we do 21 now.
22 What I'm trying to do is indicate that you have a 23 rather substantial amount of control in deciding what 24 testing you want to propose for the performance tests 25 and that list of malfunctions is quite general.
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1 12 1- Small-break LOCA is another one. Single-tube 2 _ ruptures, multiple-tube ruptures, reactor cold-pump seal 3 failures -- those all fall into the category of 4 small-break LOCAs. You need to-look into how you're 5 going to describe those, and that's the reason we have 6 permitted you to propose that in your test abstracts for 7 performance tests that are submitted along with the 8 certification, 9 .InLthe case of using the panel that was proposed, 10 that would be an appropriate vehicle for deciding what f i
11 tests are going to be proppsed by way of performance !
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12 tests. It clearly could be a subset of all the j 13 malf unctions the simulator is capable of perf orming.
14 You may literally have hundreds of malfunctions which 15 you can implement. ,
16 We don't want to see a performance test for each 17 and every malfunction. We do want to assure that all of 18 the malfunctions that are listed in the standard can be 19- performed.
20 MR. BEIL: Just to make note, as we are going 21 through these questions, if you do have related 22 questions, feel f ree to step up to one of the 23 microphones and address that question.
24 The next question again deals with simulators: l 25 "When does the Commission project that their guidance Sonntaq Reporting Service, Ltd.
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1 for conducting simulation facility audits will be made 2 public?"
3 Jerry?
4 MR. WACHTEL: Well, the answer, of course, is 5 that that guidance is available today in the form of 6 draft NUREG-1258 and that we will accept your comments' 7 on that NUREG until the 26th of May.
8 MR. BEIL: You might as well keep the mike.
9 The next question also deals with simulators: !
10 "Suggest that the Commission distribute single 11 copies of Form 474 to attendees of the public meeting to 12 help illustrate the certification process."
13 MR. WACHTEL: Suggestion accepted. It's in 14 your slide handout t' hat everyone ought to have.
15 MR. BEIL: Again, "Do we understand correctly 16 that Form 474 is to be submitted directly to the 17 Director of NRR in Washington, D.C., as opposed to 18 regional administrators?
- 19. "Related to this question, will simulator 20 certification audits be performed by NRC 21 Washington-based Staff, regional NRC Staff or some 22 combination?"
23 MR. WACHTEL: The assumption is correct: It 24 was a conscious effort on our part to ensure that the '
25 Form 474 certifications and also the applications for 1
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i 14 1 approval for those cases will be submitted to )
2 Headquarters to NRR and.not to the regions.
3 The answer to the second part is that in all 4 probability, the simulation facility inspection program 5 will be a combination of Headquarters and regional 6 effort, starting out largely as a Headquarters function 7 and over time transitioning to a more region-based ,
l 8 function as we move into the inspection procedures.
9 MR. BEIL: Thank you, Jerry.
10 MR. HANNON: Excuse me, Bill. Can I expand 11 on that answer a little bit based on a question we got 12 in another region about documents that are submitted to 13 the Director of the Office of Nuclear Regulation 14 pursuant to Part 55.
15 They should be filed in accordance with 10 CFR 16 50.4, which is basically saying that those submittals go 17 to our Document Control Center in Washington.
18 MR. BEIL: Thank you, John.
19 The next question deals with, "Under Section 55.45, 20 Part A, Items 12 and 13 were reworded to include the j l
21 phrase 'as appropriate.' j 22 "What is the significance of this phrase for the i
23 Commission to classify this change as major in Generic 24 Letter 87-07?"
25 MS. SH ANKMAN : If you look at Section Roman Sonntag Reporting Service, Ltd.
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1 Numeral II D 2, the comparison that we're making in the P
2 statement o,f considerations is between the proposed rule 3 that was' published in November of '84 and the final rule
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4 as it's published in.the' Federal Register.
4 5 There have been other copies of the rule that have 6 been circulated at different. times, and they were not * '
l 7 official copies. So I think someone may4 have been 8 comparing something that was an unofficial copy.- i 9 But the comparison is that we rewrote 12 and 13 10 signi'ficantly between the November, '84, proposed rule 11 and the. final rule.
~ 12 But just to clarify, we have made sure that you're 13 held accountable for performing as appropriate to the 14 assigned position. So Ros are not expected to pass a 15 test at the SRO level. -
16 MR. BEIL: Thank you, Susan.
17 The next question is again a simulation facility 18 question dealing with 55.45:
19 "55.45 requires that within one year after the 20 effective date of this part, each f acility licensee 21 proposing to use a simulation facility must submit a 22 plan detailing how and when'their simulation facility j 23 will be . developed and submitted for approval.
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24 Considering this:
s 25 "Must a utility that operates-dual units at the Sonntag Reporting Service, Ltd.
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1 same plant and that currently obtains a multi-unit 2 operator license from the NRC submit this plan for the 3 unit not being replicated?"
4 . MR. WACHTEL: As I mentioned earlier, the 5 availability of current multi-unit' licenses would lead 6 us to believe that you do not under those circumstances 7 need to submit an application for approval for the 8 simulation facility for those units for which we grant 9 multiple licenses.
10 We in all likelihood will accept certification's on 11 Farm 474 with the exceptions noted for each case.
12 MR. HEIL: Jerry, a second part to that is, 13 "What format requirements, if any, does the Commission 14 wish to see in this application? It appears a Form 474 15 will not be used f or this purpose."
16 MR. WACHTEL: Well, since the 474 would in 17 all likelihood be used, that should be not applicable.
18 MR. RUSSELL: Let me give'an example, a 19 simple example, of what we'd expect.
20 Let's assume that you have a dual unit control room 21 and that the control rooms are identical with the 22 exception that one is right hand and the other is left 23 hand; they're mirror images of each other.
24 The standard is that doing the physical fidelity 25 comparison would identify as an exception the Sonntag Reporting Service, Ltd.
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- l 17 1 mirror-image' layout.
L 2 One Form 474 would come in and identify that the 3- mirror-image issue was a difference, but you conclude :
4 that's acceptable for conduct of an operating test and
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5_ you reference the certification form for the other unit
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6 where you do all the other stuff; that is, you identify 7 all the other exceptions that you may have. So one is 8 tied to-the other.
9 That way we get a form that says it's certified for l i 10 each plant'it's referenced to, all right.
11 The intent in going with certification with 12 exception was to minimize the number of cases for 13 application. We really only want to see those I 14 applications which are similar to the case of Sanonof re 15 Unit 1 proposing to use'the Zion simulator with some l 16- sof tware reprogrammed. That is the kind of case that we 17 want submitted and reviewed. !
i 18 In the case where you have a simulator now which is ;
i 19 on site which replicates two units, we would expect you !
i 20 to use the certification process.
21 MR. BEIL: Okay. The last part to this -j i
22 question is, "Is this plan required within one. year ;
4 23 regardless of whether the utility is in the process of 24 procuring a simulator?"
25 The second part of this last part is, "Several Sonntag Reporting Service, Ltd.
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I simulators are still in the manufacturing pipeline,'to l
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2 be delivered in the next two years, while a few are' !
1 3 still just beginning their procurement activities."
E 4. MR. WACHTEL: I think there may be some 1 J
l 5 confusion in this question.
6 The plan that is referred to is required only for
- 7 those utilities who are not submitting . certification on 8 Form 474. The rest of this question seemed to be with j 1
9 reference to the 474 certification. j i
10 If you are procuring a certified simulation '
11 facility, there is no plan required and there is no 12 application for approval' required. I 13 If you are not procuring a simulation facility that 14 is to be certified on Form 474 when there is a plan I 15 required and there is an application for_ approval, the 16 answer is yes, we would expect to see that plan 17 submitted to us within one year of the effective date of 18 ' the regulation, regardless of where you may be in the 19 cycle of the procurement of that simulation f acility.
20 MR. BEIL: The next question is, "The NRC 21 released a final draf t of a NUREG entitled 'Bandbook for 22 Software Quality Assurance Techniques Applicable to the l 23 Nuclear Industry,' dated February,1986. j 24 "This handbook was prepared by Pacific Northwest 25
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l . I s I 1 specifically to address the applicability of 10 CFR 50 2 Appendix B , requirements associated with computer uses in ;
3 the nuclear industry.
4 7 "This final draft'nandbook specifically included 5 training simulators as requiring stringent software 6 quality assurance. This draft handbook seems to imply 7 that the si;mulator's software should be treated as 8 though it were safety-related, with the appropriate 9 programmatic and procedural controls applied. ,
5 {
10 "What are the. commission's plans in this area and {
< : i' 11 what relationship, if any, will this draf t NUREG have on t 12 '
the' topic of simulator certification?"
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- - 13 i MR. WACHTEL
- As a result of the very recent j
\ 4 1;4 NRC reorganization, the area of sof tware quality 15 assurance somes under Bill Russell's purview. I 16 I think it's safe to say that there is no intent 17 for us to review your sof tware development or quality 18 control procedures as they apply to Part 55 and to 19 simulation facility certification.
20 You, of course, have to manage your own simulator 21 ' sof tware program in order to meet the regulations that 22 are in Part 55 as required to support and maintain the 23 certification for the simulation f acility suitability in 24 the conduct of operating tests.
25 The vehicle to confirm the simulation facility's l
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1 adequacy is the performance testing program, which we, 2 of course, will review once you submit your Form 474s.
3 We are going to take a look at this draf t 4 contractor NUREG to determine its status, but I think it 5 is safe to consider it not applicable to these 6 regulations. '
1 7 MR. RUSSELL: I want to add to that what I i I
8 consider a very practical aspect.
9 If you have a simulator you can operate and see 10 whether it performs in accordance with the plant's 11 design characteristics, that is the best way of-12 determining whether the sof tware is any good or not. ]
1 13 We don't need to have a very prescriptive software
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14- control program protocol that is subject to NRC review i
15 and evaluation. ]
l 16 We've described how we intend to inspect the I l
17 simulators and we have put that into the simulator i
18 facility evaluation procedures, and that is based upon 19 running things like licensee event report scenarios and 20 seeing how tbr simulator compares to the plant.
l 21 Let me also point out, however, that if you start l 22 tweaking the software in one area, if you do something 23 to affect feed water, you may affect other areas. So l
24 for your own sake, you need to understand what the I 25 impacts of the change are in the sof tware to the overall 1
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1 performance tests.
2 If yog make a modification in the sof tware that 3 could cause a performance test to f all outside of its 4 acceptance values -- that is, the 2 percent and the 10 5 percent -- you need to rerun that test and make sure 6 that the simulator is still performing in accordance 7 with the design specification.
- I 8 That's the concept that we're looking f or. We're 9 looking for a machine that will replicate what we expect 10 to happen in the plant.
11 We're not looking for developing a software control 12 system which is appropriate to a reactor protection 13 system where you cannot test by operation how 14 eff ectively the perf ormance of the RPS works. That's 15 the difference. '
16 HR. HEIL: We have a question over here.
17 MR. SHORT: Will Short with Interfacts, 18 Incorporated.
19 Jerry, I apologize. I have to go back to the 20 previous question, but I wanted to validate some data.
21 The comment was regarding those who have simulators !
22 that are currently under procurement and regarding 23 whether they have to submit for certification or submit 24 within one year for the simulation facility that is 1 25 acceptable to the Commission.
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22 1 The situation is I have a particular customer that 2 is undergoing the procurement process right now.
There 3 is certainly the realistic possibility that that 4 simulator will not be delivered and declared ready for 5 training until sometime in 1990. At that time it will 6 be approximately two and a half years since design data 7 freeze. j 8 In that period of time with design data freeze, 9 it's reasonable to expect that that customer would not 10 be able to meet the requirements of the ref erence plant 11 simulator being current within 12 or 18 months of the 72 reference plant, which is a requirement for meeting )
i 13 those requirements set forth in ANSI 3.5 '85, to which l i
14 you are signing at the bottom, at the 1 t
15 material-false-statement signature, that, in fact, you 16 have an ANSI 3.5 '85 simulator.
17 I need an answer on this because the customer, 18 theref ore, may have to submit his plan f or an l l
19 alternative within 12 months of May, 1986.
l 20 So in that particular case, there are going to be )
21 two or three people out there who are in the process of i l 22 procuring a simulator that may fall within the l 23 requirements.
24 Thank you.
25 MR. WACHTEL: Sure.
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- 1 I think the answer to that would be that we would 2 still expect a certification f rom those utilities on l 3 Form 474, rather than the application for approval.
4 The area where you take exception to meeting the 3 i
5 requirements of ANS 3.5 would have to be identified as j 6 to what those discrepancies are and indicate a timetable 7 for resolution of those discrepancies.
I 8 MR. SHORT: So in other words, they would not
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9 be held to the statement that says they are or are not 10 in compliance with ANSI 3.5?
11 MR. WACHTEL: Again, we would have to address 12 them as exceptions to ANS 3.5 in the proposed 13 resolution. 4 l
14 MR. SHORT: I didn't see in the proposed Form 15 474 that there was an area in there that addresses 16 exceptions.
17 MR. WACHTEL: There is a block on the form.
18 It might not have been on an early version of the form; 19 but if you look at it in your handout, you will see an 20 area near the top which indicates exceptions taken to 21 the standard.
22 MR. RUSSELL: Let me add, also, that that's 23 not an unusual circumstance just for those who are 24 buying new simulators.
25 Because design modifications are made in the plant, Sonntag Reporting Service, Ltd.
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1 you may indeed at the time of certification have 2 modifications in the plant you have not yet put into the ;
- I 3 simulator.
l 4 The process provides for reference plant data and j l
5' design data for the simulator, and there can be as much ]
6 as two years' difference between when you bring those f i
7 two into conformance.
8 If you' re not in conf ormance at the time you I 9 certify, if there's some exception, identify that in the 10 exceptions sections and indicate on what schedule you're 11 going to correct it.
12 It's like a near-term operating license. You never 13 get the backlog to zero at the time you apply for a 14 license. You recognize it's a -- we hope it's a small 15 list of exceptions, but there will be some. That's the 16 reason we put that in there and why we want to go with 17 that approach.
18 If you tell us what the exceptions are, if we 19 disagree, we'll come out and visit you. But if you've 20 done a reasonable job of identifying it and we still 21 conclude that we can conduct an operating test, we'll go 22 forward with it and accept that certification.
23 MR. HEIL: The next set of questions were 24 submitted by Wisconsin Electric. This is a f airly short 25 list. I think we can probably get through these prior i
Sonntag Reporting Service, Ltd.
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1 to lunch.
2 The first question is, "On Page 6 of the 3 supplemental-information provided to Generic Letter 4 87-07 is the following statement: 'These rules 5 supersede all current regulations for operator 6 licenses.' With regard to this statement, we pose the
- 7 following questions: 1 8 "Are training requirements from Mr. H. R. Denton's 9 March 2 8,1980, letter superseded by these changes?"
10 The answe'r is yes insofar as it applies to the 11 operator licensing area. You may have other commitments 12 resulting f rom that letter which may still be in ef fect.
13 " Are experience requirements in NUREG-1021 for the 14 RO and the SRO superseded by this change?"
15 The answer to this is no. ES-109, as you saw 16 previously, will be changed in about one year, in 17 addition to the changes that are occurring now, to 18 reflect the changes that are going to occur to REG GUIDE ]
i 19 1.8, which reflects ANSI 3.1-1981.
20 Basically, the RO experience requirements are going i 21 to be going to three years under that ANSI standard and 22 Regulatory Guide.
23 The next question is, "Are requirements for NUREG 24 0694" -- which I think is 0094 - " superseded by this -
25 change?"
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26 l
l 1 The answer is yes.
2 "W111,NUREG-1021 be changed to agree with 10 CFR 3 Part 55?" j l
4 As you've seen, the answer is yes.
l 5 "Other than as stated in 10 CFR 55, are there any i
6 other requirements that must be included in initial or j 7 continuing training programs for licensed personnel?" ,
i 8 The answer to this is yes. All your previous ..
9 requirements are in effect until accredited. I J
10 The last.part of this question is, "Are utility ,
(
11 commitments made regarding license operator training and I
(
12 retraining superseded by compliance with 10 CFR 55?"
13 The answer is yes, unless these commitments are 14 more restrictive. Then there will have to be a 15 modification. !
16 MR. HANNON : Can I expand on that a little !
i 17 bit? !
18 MR. BEIL: Sure. J l
19 MR. HANNON: The modification, depending on )
l 20 what the more restrictive -- how the vehicle of those l 1
o 21 more-restrictive requirements are composed, might be i i
22 done under a 50.59 change or, alternatively, could be
]
23 the subject of an administrator license amendment, for 24 example, if you needed to change your technical i 25 specifications.
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27 1 MR. HEIL: Thank you, John.
2 MR. RUSSELL: We've got a question here. Do 3 you want to use the mike, please?
4 MR. BRUNO: My name is Ron Bruno from 5 Wisconsin Electric. I wrote these questions.
6 (Laughter.)
7 On B there, "Are experience requirements in 8 NUREG-1021 for the RO and SRO superseded," you said no; 9 that there were experience requirements that would still 10 apply.
11 Is that still in effect even if you have an ,
12 accredited program?
13 MR. BEIL: The accreditation process has its l'4 own experience requirements identified within that q 1
15 program. 1 16 For those f acilities who have an INPO-accredited j 17 program and a simulation facility acceptable to the NRC,
]
18 you do not have to designate on the Form 398 those 19 experience requirements f or those individuals. You 20 simply need only check the blocks associated with the 21 simulation facility and the accredited program.
22 MR. BRUNO: Do you still have to have the !
23 experience requirements in your program? Do you still l
24 have to meet them if you have an accredited program? ;
25 Let's say that in my systematic approach, I have Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 ;
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28 1 determined that it doesn't take three years of 2 experience to meet the requirements.
I complete the 3 program with whatever experience we determine'is 4 appropriate, and we've got an accredited program.
5 MR. RUSSELL: Let me be very' clear, I hope.. j 6 The industry,- through NUMARC,' has made a commitment d l
7 to the NRC,in the area both of training and 8 qualifications. Qualifications were endorsed in Generic 9 Letter 84-16, which endorsed ANS 3.1. ',
l" 10 We did not take exception to the three-year 11 requirement for experience. In the past we have 12- accepted two years f or reactor operators. )
i 13 One year from publication of REG GUIDE 1.8, we I I
14 would expect people to meet ANS 3.1 unless they have 15 already committed to that. )i 16 The Generic Letter that was issued applied to 17 near-term operating licenses at that time. As a result, j 18 many of the older facilities which had licenses prior to i
19 1984 were committed to earlier versions of the I i
'20 standards; in particular, N1-87, which was the old basis 21 for Examiner Standard 109. Those facilities have, 22 hopefully, accredited programs. l 3
1 23 Within that accreditation process, there are a )
24 hierarchy of guidelines just as there are a hierarchy l
25 within the regulations. An acceptable way of meeting I
f Sonntag Reporting Service, Ltd. )
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h 29
'l the regulation, as it relates to experience 2 requirements, is by conf orming to ANS 3.1. Through the 3 accreditation process, there are similar guidelines.
4 In the case of a review and approval by the Staff, 5 we would look at any bases-for waivers of those
'6 requirements and alternatives that are proposed. _In the 7 accreditation process, the mechanisms are already built 8 in for you to do that on a case-by-case basis.
9 So accreditation, criteria.for entering into
' ~
10 training as it relates to qualifications, are described
. 11 in the training guidelines for each position, where they 12 articulate what are the entry levels for entering into 13 training.
14 They.also have in that process a mechanism for j l
15 examining or interviewing or on some other documented 16 basis granting waivers'to certain requirements.
{
17 The Commission, through this rule-making, has said, I
18 "We will accept the candidate at the end of training if 19 he is certified to have been a graduate of an accredited 20 program." We have done that through the endorsement of l
21 the policy statement on training and qualification.
22 That means that you control the review waiver 23 process, and you control that through your vehicle with !
24 IN PO.
25 Now, if you want to deviate significantly from the )
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1 . INPO guidelines, I would suggest . that you need to touch ~
2 base with INPO and they may need to touch base with 3 NUMARC if you want to come up with a radically new
.1 4 interpretation.
5 'But, in fact, if you have a basis for what you're
. 6 doing and you document that and you do that on an 7 individual basis, we do not intend to second-guess that.
8 In fact, we would not see it on the application. i 9 I think that's a major change in the way we have 10 done business in the past, and'it puts a lot of trust l 11 into the industry 'through the self-initiative of .INPO 12 and NUMARC in order to provide both training and 13 qualifications.
14 MR. BRUNO: Thank you.
15 MR. BEIL: I'd like to add that for those - l 16 facilities that do not fall into those categories, it 17 would be basically business as usual as far as review 18 and evaluation of the experience and qualifications. ;
19 The second question is, "If not required by 20 technical specifications, are there any licensed 21 positions, other than those standing watch, required by 22 NRC to maintain an active license?"
23 The answer is no.
24 Now, I guess there's a little more to add to that, 25 for a lot of f acilities routinely license and maintain Sonntag Reporting Service, Ltd.
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31 1 licenses for eventualities that may occur with regard to !
2 people who are assigned to those shif t technical staff 3 positions.
4 So it may behoove.some facilities to maintain a 5 cadre of people who f all into the actively performing 6 role to meet those contingency requirements.
7 But the NRC does not require any other individuals, 8 other than those specified in your technical 9 specifications, to maintain an active license.
10 MR. RUSSELL: Let me_give an example of a 11 position that's required by the tech specs that would 12 not require an active license, so that everybody 13 understands what we're talking about.
14 An operations superintendent is required to hold a i 15 license by the NRC. He need not have an active license, 16 unless you intend him to go on shift and direct the l
17 activities of licensed operators, j 18 We will also renew a license if you have zero hours 19 or shift and in the renewal application. The renewal is 20 o. . .! ed to perf ormance of requalification; it is not 21 tied to perf orming duties on shif t.
22 It is clearly an economic decision on the part of 23 the company as to how many licenses you want to have.
24 We have made it relatively straightf orward to regain 25 proficiency with the 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch Sonntag Reporting Service, Ltd.
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32 1 standing.
2 So in,the case that you have a number of licenses 3 that are inactive and you want to put them back into an-4 active status because you have a strike coming up or 5 some other event which may cause you to not have so many 6 active licenses, you need to anticipate that and 7 maintain or have some advance warning so that you have 8 licensed operators to operate the f acility.
9 MR. HEIL: A question?
10 MR. ANTONELLI: Doug Antonelli.
11 Could you clarify what you mean by " parallel watch 12 standing"?
13 MR. RUSSELL: It simply means that the 14 individual who has the watch who is signed in the logs 15 observes and agrees with everything the other operator !
16 does. It's very similar to "being directly under the 17 supervision of," as we use that phrase for a trainee; 18 that is, the individual that has the watch still has the 19 responsibility.
20 The person that's in the parallel situation, even 1 21 though he's licensed, is not considered to be 22 proficient. The regulation requires that he not 23 manipulate the controls or direct the activities except 24 under the direct supervision of someone who has a 25 license that is active.
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33 1 MR. ANTON ELLI: Do those 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> have to be 2 consecutive; i. e., eight hours a day?
3- MR. RUSSELL: No. It has to be 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.
4 You can have four tens or ten fours or any other 5 combination that adds up to 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.
6 The only area where it is explicit in the 7 regulation is with the seven eights or the five twelves.
8 That's a full shift, and that's watch relief to watch 9 relief.
10 MR. ANTONELLI: Would you expect those dates 11 to be concurrent or could they be broken up?
12' MR. RUSSELL: They need to be in the same 13 calendar quarter.
14 MR. ANTON ELLI:- Thank you.
15 MS. SH ANKMAN : A question over here. 3 i
16 MR. BEIL: Yes? ]
17 MR. LE BLOND: Pete LeBlond from Commonwealth 1
18 Edison. )
19 Following up on your guidance you just gave a 20 moment ago, would you consider it possible for an 21 operations superintendent to direct activities f rom off 22 his shift, and if so, then would that individual be 23 required to maintain an active license by actual shif t l
24 time for calendar quarter?
25 MR. RUSSELL: Let me give you what I think is Sonntag Reporting Service, Ltd.
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1, 34 1 the most practical example: in an emergency.
2 Typically, the operations superintendent is the 3 individual who goes back and forth between the Tech 4 Support Center or provides assistance in a casunity.
5 That individual gives his direction to whoever it 6 is, the shift superintendent or the other SR0s. They 7 discuss it. So he is not directing the manipulation of 8 the controls; he's providing guidance on how he wants 9 the event to be handled.
10 There is an individual in the decision process who 11 is actually deciding whether he agrees with it or 12 doesn't, and he actually directs the activities of the 13 licensed operators in manipulating controls.
14 So in that case we do not feel that he is on shift 15 in the position; he is off shift, responding in 16 accordance with the emergency plan, which is covered by 17 a different portion of the regulations.
18 So the answer is that the operations' superintendent 19 need not be active for anything that we determine unless 20 you intend him to go on shift and stand as a shift 21 superintendent.
22 MR. LE BLOND: That same logic would apply to 23 day-to-day operations, then, if I understand you 24 correctly?
25 MR. RUSSELL: There is no day-to-day Sonntaq Reporting Service, Ltd.
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j 1- operations issue. He's there fulfilling the position !
2 that's required by the tech specs as the operations 3 superintendent; that is, independent of proficiency in j 4 manipulating controls.
5 MR. LE BLOND: Thank you.
6 MR. RUSSELL: I would not expect the 7 operations superintendent to go in, for instance, and 8 line up systems or manipulate controls on the board, 9 He needs to be proficient to do that in order-to be ,
10 consistent with the requirements of the regulations, so 11 he would either have to stand 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel or 12 maintain proficiency or keep his hands off the controls.
13 MR. HEIL: Although in the process of 14 - examining him for requalification purposes, we would 15 examine him both at the RO and the SRO level. So that 16 has to be taken into consideration in your continuing 17 training program to ensure that he doesn't lose those 18 manipulative skills because he is not required to 19 maintain an active license.
20 The next question is, "On Page 24 of the 21 supplementary information provided to Generic Letter 22 87-07 is the following statement: 'The frequency of the 23 comprehensive requalification written examination has 24 been changed to a maximum of every two years.' With 25 regard to this statement, we pose the f ollowing Sonntag Reporting Service, Ltd. I j' Geneva, Illinois 60134 (312) 232-0262
36 4
1 questions: ,
i 2 "Where is this statement to be found in the text of 3 10 CFR 55?"
4 The statement " maximum of two years" with regard to 5 examination frequency can be derived from 10 CFR 6 5 5.59 (a) (1) , in that under "Requalification 7 Requirements," "Each licensee shall successf ully 8 complete the requalification program developed by the 9 facility licensee that has been approved by the 10 Commission and that the program shall be conducted for a 11 continuous period not to exceed 24 months in duration."
12 So by inf erence, because the program is required to 13 be conducted on a 24-month duration, then the -- excuse 14 me. The next paragraph says " pass a comprehensive 15 requalification examination and an annual operating 16 test."
17 '3v inf erence, the written examination only has to 18 be administered on a two-year basis, where the annual 19 examination is required on an annual basis. l 20 The second part of this question is, "Does this 21 statement mean that written requalification exams can 22 occur less often than every two years?"
t 23 The answer is no. It must be conducted concurrent 24 with the two-year program.
25 7he last part of this question is, "Can the written !
Sonntag Reporting Service, Ltd.
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37 1 requalification examination be given in several sections 2 over a period of time or is the intent to administer one 3 c?mplete examination at one time?"
4 MR. RUSSELL: Susan wants to answer that one.
5 MR. BEIL: Go ahead, Susan.
6 MS . SH ANKM AN : If you currently have a 7 requalification program in which you've committed to an 8 annual comprehensive written exam, you have to continue 9 giving that annual comprehensive written exam until you 10 have sent in the appropriate documentation that you have !
11 an SAT-based progran and that you're moving to a 12 continuous program that is going to be conducted over a 13 period of 24 months. That's one way of doing it, t
14 sending us a letter telling us when you are accredited i 15 and that you have a requalification program that's 16 SAT-based.
17 The other alternative is what we have done in the 18 pa st , which is the 50.34 change, where you would notify i
19 us that you're changing your program. So if you're {
l 20 committed to an annual written exam during this l 21 transition period, you have to continue to meet your 22 commitments until you've notified us that you' re 23 changing.
24 MR. BEIL: Along those lines, with regard to' 25 the segm'ented exams, if you currently have in your l I
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i i program an annual comprehensive examination, then we 2- will expect you to continue that.
3 If you-have an-accredited program and the segmented '
4 approach to evaluation is an acceptable methodology 5 under that program, we will allow you to implement your !
i 6 program.
- 7 But realizing that the NRC examination will be a I 8 comprehensive examination, we expect that the program 9 evaluations that you implement will be comprehensive in 10 nature, also.
11 MR. BRUNO: Ron Bruno f rom Wisconsin
'12 Electric.
13 Can I assume, then, that the only notification that 14 we need to make is that we are accredited and we do have i
15 a systematic approach to training f or a requalification 16 program and we do not have to get into the specifico 17 that we are either giving an annual test or a segmented 18 test, all we have to do is make thocs tv- sts tements?
19 MR. RUSSELL: That's correc..
20 In fact, I would prefer tnat when you make that on f
21 the next update to the FS AR, you delete references to 22 what your program is, because in an SAT-based program, 23 that program is subject to continuous review and change.
1 24 I would prefer not to have the inf ormation in the j l
25 FSAR. We have access to that inf ormation on-site, and {
Sonntag Reporting Service, Ltd. l Geneva, Illinois 60134 )
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39 I we have access to that information at INPO.
2 MR. BEIL: I guess just to further emphasize 3 that comprehensiveness, weekly quizzes that may be given 4 following a week of instruction tallied together to form 5 one exam probably would not meet the comprehensive ]
6 intent of this evaluation process. )
{
7 The next question -- J 8 MR. SCHOL AND: Jerry Scholand from 9 Westinghouse. )
1 i
10 If I heard the previous answer correctly, the exam 11 could be segmented if it was an approved process.
12 How can the Commission administer a comprehensive 13 written exam once during the six-year cycle if the j 14 utility is administering their. written exam spread out 15 'over a segmented period?
16 MR. RUSSELL: It works very easily: We just ;
l 17 go in and give a comprehensive exam, j 18 (Laughter.)
19 We have had that experience already. Duke Power 20 Company uses a segmented exam. I believe they have six j 1
21 segments to their program. In evaluating that facility, i i
22 we gave them a comprehensive exam. They did 23 exceptionally well on that. I believe 25 out of 26 l 24 candidates passed. ;
25 MR. SCHOL AND: If they're on a two-year ,
1 Sonntag Reporting Servicer Ltd, Geneva, Illinois 60134
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40 1 cycle, you'd have to catch a full third of their 2 operators in that one exam; right?
'3 MR. RUSSELL: Not necessarily. That gets to 4 the issue of how we choose to go in and examine on a 5 random basis. We'll cover that some more.
6 Essentially, the intent is to do it during our I
7 planned visits to the f acility when we are conducting 8 replacement license exams.
9 To the extent we can, we will coordinate those to I 10 dovetail with whatever the facility' exam'ining schedule 11 is for their program so that if I have a program where 12 you're coming to the end of a requalification cycle and '
13 you have examinations scheduled, we would like to also !
14 schedule at that same time replacement examinations. l 15 However, if we have reason to believe that there is 16 some problem with the program, we reserve the right to 17 come in at any time and conduct comprehensive i
18 examinations in order to judge the quality of the 19 program as it's going on. i 20 MR. SCHOL AND: And the percentage of people 21 that you would examine at that time? l l
22 MR. RUSSELL: Right now, the percentage is 20 f i
23 percent every other year, because of a goal of examining i J
24 10 percent of the operators annually.
25 I have not made that goal nationwide for the last l l
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41 1 three years in a row. We've been running about 6, 7 2 percent.
3 When w'e go into steady state, we're going to have 4 to get to the point where we do at least 16 percent 5 two-year.
6 MR. SCHOL AND: You've got to get 100 percent 7 in six years.
8 MR. RUSSELL: That's correct.
9 In fact, it will be greater than 16 percent because 10 of the randomness aspect of assuring that candidates 11 don't have prior knowledge of when we are coming in to 12 examine.
13 MR. SCHOLAND: Am I correct in saying that 14 any given individual is limited to only one exam in the ;
15 six years? l 16 MR. RUSSELL: He may be examined more than 17 once.
18 MR. BEIL: We have two requirements here.
l 19 One is to examine each operator prior to renewal of his ;
1 20 license.
21 My understanding is we have not been relieved of 22 the requirement to still conduct requalification l 23 programmatic evaluations, which are also described in i
24 601, so there may be some overlap there. The final 25 determination as to how we're going to implement all l
Sonntag Reporting Service, Ltd.
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l 42 1 these things is an ongoing process right now.
2 But you have to remember that the intent of the 3 requalification program is to maintain those operators j 1
4 on a continuing basis at a certain minimum level of i 5 compe tency. So for that reason we feel fully justified I
6 in conducting a comprehensive examination at any time {
7 that we feel it necessary.
1 8 MR. SCHOLAND: And where do we find the !
9 standards and criteria for administering those 10 comprehensive exams for the requals, not the initials?
11 MR. HEIL: The standards and criteria are 12 identified in 55.59, and as far as our implementation, 13 they will be clarified in ES-601.
14 MR. SCHOLAND: 55.59 refers right back to the 15 standard initial examinations; right?
16 MR. RUSSELL: It requires a sampling of 17 those.
18 Let me answer the question more correctly as to 19 what I see as the solution we' re moving to.
20 If your requalification program is based upon a 21 systems approach to training, you will have reviewed the 22 tasks f rom the initial program which are appropriate for 23 continuing training. You will have chosen those on some 24 criteria, such as f requency of performance, saf ety 25 significance or other criteria.
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l 43 1: That's one way of determining the content of your 2 continuing training program.
3 Another way is the feedback from performance in the 4 plant licensee event reports, et cetera.
5 Another thing which goes into the program are what 1
6 I will characterize as facility design changes and/or j
-7 changes in procedures. Those are th,e subject areas that !
I 8 we would tend to focus on for a requalification 9 examination.
10 When you move to the point where you have learning ]
1 11 objectives for your.requalification program that have j 12 conditions and standards, then we would use that as the 13 basis for sampling for determining the content of the 14 examination. ,
l 15 -
In the meantime, because that's not fully in place l 16 yet, we are using such things as the KA catalogs, which 17 identify the importance of the tasks of the job and are 18 based upon the industry generic job task analysis.
19 We are also using a sampling plan -- it was l 20 referred to as the " examiner handbook" -- where we 21 sample from that catalog to ensure that we get a 22 representative sample of the knowledge, skills and 23 abilities -- the skills being done on the simulator --
24 that are appropriate for an NRC examination.
s 25 The initial examination we intend to be different Sonntag Reporting Service, Ltd.
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i 44 1 from the requalification examination. We will look at '!
2 the two, even though we developed them in parallel; and !
3 questions which are not appropriate for a job incumbent 4 -- questions, for instance, on watching relief and 4 5 turnover or other things which he does on a repetitive 4 6 basis -- would be excluded f rom the requalification 7 examination.
8 That's our intent. We've got a ways to go. We }
9 believe that through the informal review process I 10 described t'his morning of appeals and the facility 11 review of the written examinations, that in the f
12 transition period there are sufficient safeguards in 13 place to ensure that there was a content-valid 14 examination that was indeed related to job performance. ;
15 Now, I can tell you, from having had the Staff j 16 review all examination reports f rom all regions and !
17 summarizing that information, that the kinds of things 18 that we are seeing as weaknesses fall into the category 19 I mentioned earlier; that is, knowledge of events that !
20 have occurred at their own plant, significant events at 21 other similar plants, changes to design, changes to 22 procedures and selecting those tasks from the initial 23 program which are relevant to training on a continuing 24 basis, i
25 I think we do not help the operators at all if we !
~
l Sonntag Reporting Service, Ltd. I j Geneva, Illinois 60134 (312) 232-0262
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1- simply repeat the initial program for continuing 2 training. , That's not the intent.
.3 MR. SCHOLAND: So would it be also your' goal 4 to somehow document those differences that you expect 5 between the initial exams and the requal exams?
6 MR. RUSSELL: That's why I want you all to 7 certify, that you've got a requal program that's based 8 upon a systems approach to training: because you know 9 the job a whole lot better than we do, and you should 10 document what those~ differences are. ~
)
11 That's why we keep identifying that when you do the l 12 initial task analysis, you should identify that subset 13- of those tasks which are appropriate 1for continuing -
14 training.
I 15 Now, we believe that to the extent you follow the 16 INPO guidelines in 86-025, you will have done that. We 1 17- believe that that's a fair representation of the type of 18 material that should be contained in continuing training 19 and should be used for the basis of a requalification l 20 examination.
21 MR. SCHOLAND: Thank you.
22 MR. BRUNO: Ron Bruno again f rom Wisconsin 23 Electric.
24 As of May 26th, all of us will have a whole bunch 25 of people that have licenses that have a two-year Sonntag Reporting Service, Ltd.
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1 expiration.
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1 2 Is 1,t the intent before or when we apply for 3 renewal for those two-year licenses that sometime during a 1
4 the next couple years, you're going to re-examine every !
l 5 operator in the next two years?
]
6 MR. RUSSELL: No.
4 7 (Laughter.) 1 8 !
MS. SHANKMAN: Six.
9 MR. RUSSELL: Within the next six.
10 MR. BRUNO: 'They will not grant a renewal l 1
11 unless he's been examined by the NRC.
12 MR. RUSSELL: The rule is very specific: You 13 only need to have an examination by the NRC for the 14 renewal of a six-year license, not a two-year license.- 1 15 MR. BRUNO: So they can get renewed on the 16 regular basis, and then they've got to get a test in the 17 next six years?
18 MR. RUSSELL: For any license issued by the 19 NRC af ter May 26th, whether it be an initial or renewal, 20 it will have a period of expiration six years f rom the ,
21 date of issuance. '
22 Licenses in effect on May 26th will expire on a ;
23 two-year basis, as they are currently expiring. So it's 1 \
l 24 new licenses issued after that date. i l
l 25 MR. BRUNO: Who will make sure that every guy l
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1 :gets his exam before he gets renewed; you or me?
2 MR. RUSSELL: That's the NRC's obligation.
3 'MR. BRUNO: Thank you.
'4 MR. RUSSELL: If an individual makes a timely l 5 application for a renewal and has not been examined by 6 the NRC, his license will remain in effect and we would l
7 have to then go out and promptly examine him before l t
- 8. issuing a new license. It's the timely renewal 9 .provlsionsnder u the regulation.
10 , , At the same time, we would have to understand how 11 we erred such that that occurred. But it is an Ib obligation for the NRC. It is not a condition of the i i
13 He does not have to come in and individual's license.
14 volunteer to be examined.
15 (Laughter.) l 16 That's for us to do.
17 MS. SH ANKMAN : Ron, just to clarify, that 18 doesn't mean that if you have a two-year license, that i 19 you couldn't be examined.
20 MR. BRUNO: I understand that. They don't 21 have to.
22 MS. SHANKMAN: Right.
23 MR. RUSSELL: The current process for ,
24 evaluating programs is we have a pilot program ongoing ^ i q
l 25 now through NUMARC to evaluate the f acility's ability to ;
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1 examine themselves where you are preparing the written 2 examinations and we're doing parallel grading, where 3 you're developing the scenarios and administering the 4 operating tests and we're grading the guy on a simulator 5 at the same time.
6 I owe a report to the Commission at the end of 7 that. It's ending in May, and I owe a report sometime 8 in June.
9 I am hopef ul that that process will be able to be 10 used on a continuing basis to judge programs such that 11 the Commission would be able to accept the certification 12 for the five operating tests that you do and the two 13 written examinations that you do during the period of a 13 six-year license. I want to keep it to the one that's 15 required for renewal to the extent we can, 16 MR. STIL ES : Steve Stiles f rom Dresden 17 Station, Commonwealth Edison. I have a question 18 regarding this NRC-administered exam during the period 19 of the license.
20 The question is: Considering that every utility 21 does have or will have an accredited retraining program, i 22 what is the justification for the random selection, 23 which would include the possibility of having more than 24 one exam in a six-year period, versue the possibility of 25 doing an orderly schedule to include only one exam in Sonntag Reporting Service, Ltd.
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1 that same six-year period? q
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.2 MR. RUSSELL:
The answer to that is very j i
3 simple: Anybody that knows what date they're going to
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4 be examined is going to make sure that they're prepared )
5 for that. Then they're going to breathe a sigh of 6 relief, and the knowledge level would drop off. I i
7 The basis is that the Commission has moved out of I B the review of programs. We have given that over to the 3 1
9 industry through the accreditation process. We are 10 moving into the mode of evaluating the product and 11 assuring that the product at the end meets the 12 performance standards that we expect. So we will be ,
13 examining on a' random basis.
14 We did initially consider at one point in time 15 examining at the point of the second written I 16 requalification examination by a facility. That was l
17 found not to be acceptable, and the Staff was directed 18 instead to do it on an unannounced basis.
19 Now, to the extent we can, we will coordinate that 20 with your. regular cycles. But if we have reason to 21 believe that there is something wrong with the program )
i 22 or we have other indications for reasons that will be i 23 determined by the NRC, we will come in at times other 24 than your requalification cycle to conduct examinations.
1 25 MR. STIL ES : Has consideration been given to i
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50 1 how many tests a person would be open to"taking during a 2 six-year period?
3 MR. RUSSELL: As a practical matter, we 4 expect that we would eliminate f rom the pool those 5 candidates who had already been examined. So, for !
6 example, we have indicated we would intend to visit a 7 facility up to twice a year. That's our budgeting 8 assumption.
9 If an individual who has a six-year license is 10 examined, we would tend to look at other candidates 11 before we would go back to that individual. So while.
12 it's random, it's not totally random for all candidates; 13 it's random with respect to when that individual can 14 expect to be examined by the NRC.
15 So everybody would get a crack at having at least 4 16 one before we would intend to.go back and pick up the 17 guy on the second one, unless we have reason to believe 18 that there is something wrong with the program at the 19 facility.
, 20 For a program we evaluate as unsatisf actory, we l
21 would te.,d to go in and select candidates randomly or we We have done that 22 may go in and examine all operators.
23 at facilities where we have concluded their programs 1
24 were unsatisfactory. -
25 We're not trying to raise the apprehension level on Sonntag Reporting Service, Ltd.
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51 I the part of the operators; we're trying to make it as 2 straightforward as we can. But we also have specific 3 direction and guidance that we intend to carry out, and 4 this is one.
5 MR. SHORT: Will Short with Interfacts.
6 In Section 55.31, the statement is made in Part 4, 7 "In lieu of these details, the Commission may accept 8 certification that the Applicant has successfully 9 completed a Commission-approved training program that is 10 based on a systems approach to training."
11 Then again in 59 in the requal program 12 requirements, it states that, "In lieu of Paragraphs C2, 13 3 and 4 of this section, the Commission may approve a 14 program developed by using a systems approach to 15 training."
16 Is it reasonable to assume that the Commission i 17 could approve a systematic approach to training other 18 than INPO accreditation? I 19 MS . SH ANKMAN : The systems approach to !
20 training is defined in 55.4, Will, and that is the same 21 definition that endorses the INPO accreditation process.
22 I don't see that they're different. 1 23 MR. SHORT: You can have a systematic 24 approach to training and not necessarily be 25 IN PO-accredi ted.
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1 Ma. RUSSELL: That's correct. Let me i 2 identify it. ;
3 If yo'u have a near-term operating license or \
4 someone.who has not yet been accredited because they 5 have not yet operated and, thus, not been able to 6 include the job performance feedback -- the industry
- l 7 commitment is to be accredited within two years of 8 receiving a license -- in that case an applicant for a 9 facility license could propose in their initial training 10 program a program which is systems-approach-to-training ,
11 based.
12 We would consider the guidelines that are in 13 NUREG-1220 and other documents, and that would be 14 reviewed on a case-by-case basis, f
15 I really do want to get out of the review of 16 training programs, however, and I don't have a lot of 17 resources budgeted for that.
18 It's the clear signal from industry to the 19 Commission that that is an area where industry has said, 20 "We can do it ourselves, and, NRC, you get out of it."
21 So I'm not going to look f avorably upon a whole bunch of ;
i 22 applications to revise programs that are different f rom k 23 the INPO processes.
24 We intend to use that and to approve it without 25 further review as long as the policy statement remains ,
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1 in effect.
2 The Commission has clearly endorsed that policy 3 statement through this rule-making, so it's now time for 4 the industry to continue to follow that process and that 5 appr oa ch.
6 MR. BEIL: We'll take one more question
- 7 bef ore lunch.
8 MR. BORDINE: Tom Bordine from Consumers
, 9 Power Company.
10 Continuing on,-the systems approach to training in 11 itself is subjected to revisions to the training 12 program. Some of these changes may be considered, at 13 least by the utility, as a reduction in scope.
14 The statement in 50.54 is still there, where it 15 says that the Commission approval is required for a 16 reduction in scope in a training program.
17 How do we define 50.54 to meet 50.54 and still 18 comply with 55.59?
19 MR. RUSSELL: First, the key words in that 20 are "except as specifically authorized by the 21 Commission."
22 The Commission itself in the policy statement, 23 particular3y Element 5, indicates it expects that the 24 program will be evaluated and revised as necessary, 25 based upon job performance needs occurring.
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1 We recognize that if you only added and never 1
2 subtracted, at some point in time you would get to the l
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l 3 point where you're putting all the time in training and 4 never doing anything on the job. ]
i 5 We expect that evaluation to be reasonable based l i
6 upon what you're doing. If you want to substitute )
i 7 something that's more important, the f act that you've f 8 dropped something off does not constitute a reduction in 9 scope for a systems approach to training. I 10 We believe that that is one of the major 11 improvements in the whole training process over what it 12 has been in the past. You are not locked into doing 13 something for the next six years, seven years or eight 14 years because you committed to it back in 1980.
15 You now review it and evaluate. If it's meaningf'il 16 to perf orm, you perf orm it, and you control that 17 evaluation process. It's right there in Element 5 in 18 the Commission's policy statement.
i 19 MR. BORDINE: Thank you.
20 MR. BEIL: We're going to break for lunch 21 now. We're going to restart promptly at 1:30.
22 (WHEREU PON , the meeting was recessed until 23 the hour of 1: 30 P. M.)
24 25 Sonntag Reporting Service, Ltd.
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55 i '
1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
)
4 ----------~~~~~~-----------~~x 5 In the Matter of: :
6 HEARING ON FINAL RULE-MAKING :
- 4 7 FOR OPERATOR LICENSES : }
- i 8 -----------------------------x j 9 l l
Thursday, April 16, 1987 10 1:30 P. M.
11 ,
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12 MR. BEIL: If you could take your seats, l 13 we'll get started again. ;
14 We basically have three more questions lef t on the 15 Wisconsin Electric submittal.
16 The first of these is a four-part question. It 17 reads, "Also on Page 24 of the supplementary information 18 provided to Generic Letter 87-07 is the following ,
19 statement: 'The requalification program must be I 20 conducted for a continuous period not to exceed 24 I
21 months.' With regard to this statement, we pose the
]
22 following questions:
i 23 "What is the purpose of the 24-month limit?"
24 That's basically consistent with what was in the 25 previous Part 55 rule. I'm not sure that there's any i
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i 2 other purpose than to define a fixed-length program, and 2 .the 24 months was the accepted previous period. We 1
3 retained that period. )
1 4 Item B is, "What is the difference between a
)
5 requalification program 24 months long followed by
~6 successive requalification programs and a. continuing j i
7 training program administered throughout the term of the l
8 individual's license?" i l
9 There is basically, I guess, little difference j 10 between the two. We expect you on some basis to step 11 back and take a look at the performance of your licensed 12 operators and modify your program appropriately to 13 reflect those areas which you feel need continuing )
l 14 training. )
l 15 From that aspect, I think we chose 24 months, i 16 consistent with the previous program, to be a point at 17 which you would take that formal look at your program.
18 " Item C: Does the Commission mean to imply 19 something by use of the word 'requalification' versus 20 ' continuing training'? If so, what is the distinction?"
21 There is no distinction except that the law used 22 the term "requal," and that's why we continued with that 23 term.
24 *What is the intent of the Commission to approve l 25 specific cycles as a part of each facility's training i
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i 57 1 program?"
2 Once the programs are certified as SAT programs, 3 it's not our intention, I believe, to recertify these 4 programs on any particular basis.
5 As Bill has pointed out in the past, Item No. 5 6 brings in the continuing process of change that should 7 reflect the feedback f rom your performance evaluation of 8 your program.
9 MR. RUSSELL: Let me just supplement that, in 10 that the Commission will not be requesting periodic 11 certification. You certify once, and then we assume 12 that you continue to maintain that. You would update to 13 indicate when subsequent accreditation was achieved.
14 So, for instance, in the first round of ;
15 accreditation, you have a specific date that you were 16 accredited. Through that process you have a requirement 17 to submit a report at two years and be reaccredited at 18 four years.
19 You would simply send in another letter that says, 20- "My programs have been again accredited," and that would 21 be all that's required based upon the Commission's 22 endorsement in the policy statement as it exists today.
23 MR. BRUNO: Ron Bruno from Wisconsin 24 Electric. I have just a couple clarifying questions.
25 On Page 24 where it says that a specific cycle will
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58 1 be approved by the NRC as a part of each facility's 2 train!.ng program --
3 MR. RUSSELL: That covers programs which are 4 not approved through the accreditation process.
5 MR. BRUNO: Okay. g 6 Is there an intent to look at a 24-month period as 7 kind of an isolated section and try to meet certain 8 requirements within a 24-month period?
9 MR. RUSSELL: The intent of the time frame is 10 as Bill indicated earlier; that is, at the end of your 11 program, we want you to do a comprehensive evaluation of 12 that program and decide how you need to modify that for 13 the next cycle.
14 A period of that training program cycle of up to 24 15 months is acceptable. If you want to do it on 12 16 months, that's also acceptable, or 18 months. If you 17 want to tie it to refueling schedules or whatever, it's 18 also acceptable. It cannot be longer than 24 months.
19 MR. BRUNO: But you do want to see some kind 20 of a comprehensive evaluation of the program on a 21 biennial basis?
22 MR. RUSSELL: At least on a biennial basis.
23 MR. SEIL: That's the intent of the biennial l 24 qualification examination being comprehensive in nature.'
25 Ideally, that examination -- not, I guess, " ideally,"
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59 I but it's required by Part 55 that you evaluate that 2 examination and use that as some of the input in 3 determination of subsequent continuing training
. 4 requirements.
5 The next question is, "How will the Commission 6 administer examinations pursuant to 10 CFR 55.45 during the 48-month period when the plant-referenced simulator !
7 i
8 may not be available for conduct of the operating 9 tests?" ;
10 At this point in time and until. say 26th of 1991 or 11 until such time as those facilities that do not have 12 simulators at the present time start using simulators.in i
13 their training program, it's going to be business as 14 usual with regard to the use of simulators. I l
15 If you currently do not have a simulation facility 16 and we are presently just conducting the oral portion of l 17 the operating examinations, then through the 1991 18 period, we will continue to do that.
19 But as you bring your simulators and simulation 20 facilities into being and you start conducting training 21 and your own operating examinations on those facilities, i
22 we will then start conducting operating examinations 23 using your simulation facility.
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24 The next question is, " Programs developed using a 25 systems approach to training are, by intent of the l
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l I systematic approach, subject to revision on the basis of i
2 feedback and input to the system f rom legitimate 1 3 sources.
4 "Once a training program.is accredited and 5 appropriate certifications are made to the NRC, do 6 subsequent revisions to these programs need to be 7 certified to the Commission?"
8 The answer is no. I think we've answered that 9 several times in the past; that for accredited programs i tha't is-part of the process: l 10 the particular evaluation, '
11 feedback and modification of your program. j 12 For those programs that are not accredited or 13 SAT-based programs, then in accordance with 50.54, you 14 will have to notify the Commission when you make changes 1 15 that would decrease the scope of that program.
16 MR. RUSSELL: Let me expand on one point, 17 also, just to make sure it's clear.
18 The program of record is the program to be 19 implemented until such time as you change it, whether it 20 be an SAT-based program or an NRC-approved program.
1 21 We do not intend f or the change process to be used j 22 to, after the fact, justify what training has already 23 been done; that is, a f ailure to implement your existing 24 program -- you don't get out of that failure-to-25 ' implement loop by going back and, after the fact, i
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61 1 changing it.
2 Essentially, the program is a forward-looking; that 3 is, you evaluate your program, you decide what you're 4 . going to conduct by.way of training, and then you 5 implement that and conduct it.
6 If you need_to revise it, you revise it based upon 7 feedback and experience. You don't revise it to justify 8 what you're already doing, particularly in cases where 9 there may have been f ailures to implement.
10 MR. HEIL: The next set of questions that .
11 we'll address were submitted by the Westinghouse 12 Electric Corporation Nuclear Training Center, Zion. All 13 of these questions deal with the simulator portions of 14 the new rule; and f rom that standpoint, Jerry Wachtel 15 will address those questions.
16 Just go ahead.
17 MR. WACHTEL: The first question reads, "10 18 CFR 55.45(b)(4) (1) states, 8In accordance with the plan 19 submitted pursuant to Paragraph (b)(2) (i) or (b) (3) (i) 20 of this section, as applicable submit an application f or 21 approval of the simulation facility to the Commission, 22 in accordance with the schedule in Paragraph (b)(2) (ii) 23 or (b) ( 3) (ii) of this section, as appropriate.
24 " 'The application mutt include:
25 " '(A) , a statement that the simulation f acility Sonntag Reporting Service, Ltd.
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62 1 meets the plan submitted to the Commission pursuant to 2 Paragraph (b) (2) (i) or (b) (3) (ii) of this section, as 3 applicable; 4 "'(B) , a description of the components of the 5 simulation facility which are intended to be used for 6 each part of the operating test; and 7 " '(C) , a description of the perf ormance tests l 8 conducted as part of the application, and the results of 9 such tests.'
10 "My question is: What performance tests are q 11 required and what standard is used to evaluate whether 12 the tests are satisf actory or not?"
13 The answer is that, to the extent applicabis, the 14 requirements of ANS 3.5, as endorsed by REG GUIDE 1.149, 15 is the standard to be used.
16 The performance tests, as we've discussed earlier, 17 include the malfunctions identified in Section 3.1.2 of 18 th'e standard to be done at a rate of approximately 25 19 percent per year over an ongoing f our-year cycle; the 20 performance tests that are specified in Appendix A of 21 the standard, also at the rate of 25 percent per year; 22 and the operability tests identified in Appendix B to 23 the standard that are to be done completely on an annual 24 basis.
25 The criterion for the performance of these tests is Sonntag Reporting Service, Ltd.
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1 that the simulation f acility must be capable of being 2 used for the conduct of the operating tests which are 3 identified'in Section 55.45(a) of the regulation, and 4 the Staff will inspect simulation f acilities against 5 that requirement.
6 If you'll recall from our definition of 7 " plant-ref erenced simulator" that we talked about 8 earlier, one way in which we differ f rom the ANSI 9 standard is that we require that a simulation f acility i 10 be capable of being used f or the use of the plant's 11 control room procedures, and we would inspect against 12 the ability to use those procedures as well.
13 In the second letter, also from Westinghouse, "I 14 have the following questions related to facilities which 15 consist of both a plant-referenced simulator and a 16 simulator f acility which would use a simulator other 17 than a plant-referenced simulator:
18 "1. If the standard f or perf ormance tests '(for a 19 simulation facility which consists of other than a 20 plant-referenced simulator) is ANSI /ANS 3.5 as modified 21 by REG GUIDE 1.149, will it be possible to deviate from 22 the standard in certain areas or must it be adhered to 23 in its entirety?"
24 The answer is we recognize that at any given point i
25 in time, there will be a number of outstanding !
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'64 1 discrepancy reports on the simulation f acility against 2 its referenced plant.
3 We expect that for certified simulation facilities 4 as well as those that achieve approval after 5 application, exceptions will have to be taken f rom the 6 requirements of ANS 3.5. There is a block on Form 474 7 for certified simulation f acilities to address the 8 exceptions that you take at any given time. ;
- 9. The same would apply-to non-certified simulation 10 facilities where you would address those exceptions in 11 your application.
12 The second question reads, "55.45(b) (2) (i) and (ii) 13 state that within one year a plan shall be submitted for 14 a simulation facility (other than a plant-referenced 15 simulator), and within 42 months an application for use 16 of the simulation facility must be submitted.
17 "When will the facility licensee'know if the plan 18 for the simulation f acility is acceptable to the NRC?
19 "What criteria will the NRC use to determine 20 acceptability? Can the plan be modified after the first 21 submittal?"
22 Again, we're talking in this question about 23 simulation f acilities which are other than those which 24 are certified on Form 474.
25 The minimum criteria for acceptance of ;
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l l-65 I non-plant-referenced simulators as simulation facilities 2 has been indicated earlier to include the capability for L 3 conducting the operating tests ' identified in Part 55 and 4 for the ability to operate under the use of the control 5 room procedures.
6 The non-plant-referenced simulator alone or in 7 combination with other devices must be demonstrated as 8 being acceptable for the conduct of these operating 9 tests.
10 The Staff will review the plans for such simulation 11 facilities against the criteria specified in the 12 regulation for the conduct of the operating tests; and 13 to the extent applicable, we will also apply the 14 requirements of ANS 3.5 as endorsed by REG GUIDE 1.149 15 even f or non-certified plant-ref erenced simulators.
16 The Staff intends to promptly inform any facility 17 licensee if the Staf f's review of the plan submitted or 18 the application is not satisf actory, in the Staff's 19 opinion, for being able to conduct these exams.
20 We plan to meet with those five f acility licensees 21 who have indicated an intention to request Staff 22 approval of simulation facilities during the year 23 following the effective date of the regulation and prior
.24 to the deadline f or their submittal of a plan f or 25 application for approval.
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66 1 Finally, since we expect the approach to the five 2 non-plant-referenced simulators to be a give-and-take 3 process over.the next year and beyond and to deal with
~4 them on a case-by-case basis, we would expect that the >
5 plan would not only be permitted to be modified but.
6 would in all likelihood have to be modified after it was 7 initially submitted.
8 The third question is, "For a plant-referenced 9 simulator are ANSI /ANS 3.5 Appendices A and B the ,
10 minimum required operability tests? If not, what other 11 tests would be required?"
12 The answer is that it is Appendix B of the ANSI 13 standard that defines operability tests. These are 14 minimum acceptable standards, and they must be performed 15 annually, as indicated in the standard itself.
16 In addition, Appendix A, which identifies 17 perf ormance tests, makes up one component of the 18 periodic performance testing that would need to be 19 performed on a 25-percent-per-year basis.
20 Question 4 reads, " ANSI /ANS 3.5 Section 3.1.1(7) 21- requires that the simulator be capable of performing 22 startup and power operations with less than fu11' rated 23 reactor coolant flow.
24 "If the facility licensee is not allowed by 25 ' technical specifications to conduct such operations, is Sonntag Reporting Service, Ltd.
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l' this capability still required?" 4 2 I think the simple answer to that is no. If a 3 . plant is constrained in any particular area by its tech 4 specs, then the simulation facility need not possess L 5 that capability. . 1 6 MR. RUSSELL: As it applies to routine '
7 operations.
8 MR. WACHTEL: Okay.
9 -Question 5: " ANSI /ANS 3.5 Section 3.1.1(9) states 10 that measurement of reactivity coefficients and control i
11 rod worth using permanently installed instruments be 12 pe rf ormed.
13 *What is meant by ' permanently installed )1 14 instruments tion? '" 1 15 The question of the meaning of the term 16 " permanently installed instrumentation" is in ANS 3.5, 17 and official definition or clarification really has to ,
18 come f rom ANS and not f rom the Commission.
19 We have an operational definition that we would 20 intend to use that essentially says that portable or 21 temporary instrumentation that is brought into the 22 control room for specific modes of operation, such as 23 startup, would not be required as part of the simulation 24 facility.
25 MR. RUSSELL: Let me give a specific example 4
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68 1 of the kinds of instrumentation that we would conclude 2 are not part of the permanently installed 3 instrumentation.
4 In particular, there is a lot of instrumentation 5 brought in by the reactor vendor during the initial 6 startup for a coal plant, other instrumentation such as 7 reactivity meters or devices of that type.
8 We intend that you use the normally installed 9 instrumentation that's available in the control room 10 w'hich is used in the procedures that are employed in the 11 control room, and not instrumentation associated with 12 special tests.
13 So if it's part of your normal plant operating 14 procedures and it's instrumentation you rely on -- and I 15 hope you all have instrumentation that f alls into that 16 category for calculating rod worth for doing startups.
17 (Laughter.) .
1 18 That's what we intend you to use. You need not 19 simulate other instrumentation that is outside of the 20 scope of what your normal procedures would call for.
21 MR. WACHTEL: There's one more question. Let 22 me just get to that.
23 Question No. 6 in this letter says, " ANSI /ANS 3.5 l 1
24 Section 3.1.1(10) states that the simulator be capable i 25 of perf orming operator-conducted surveillance testing on !
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69 1 safety-related equipment or systems.
2 "To what extent should the simulator be capable of l
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3 operations that are performed outside the control room?"
4 The answer to that is that operations performed ,
5 outside the control room, such as on a remote shutdown l 6 panel, need not be reproduced on the simulation facility l
7 to comply with this regulation.
8 Questions?
9 MR. BERGNER: Ted Bergner, Davis-Besse.
10 My question relates to the definition of
]
11 ,
" site-specific plant-ref erenced simulator."
12 Can I get a f eeling f rom you as to what you mean by I 13 "it's been designed and uses plant procedures"?
14 With this explanation, could you kind of give me a 15 feeling for if I have to N/A some steps because of 16 non-modeled systems, does that need to be highlighted in 17 my perf ormance testing exceptions?
18 MR. WACHTEL: What we mean by "use of 19 procedures" is simply that: The procedures that your 20 operators use in the control room should be able to be 21 run on the simulator without change.
22 MR. BERGNER: Without change?
23 MR. WACH TEL : Yes.
24 MR. BERGNER: In other words, I can't take 25 exception to any step in the procedure because of Sonntaq Reporting Service, Ltd.
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w a 70 1 non-modeled systems?
2 MR. RUSSELL: Let me give a couple of 3 examples that I hope will help clarify it.
4 Let's assume that it is a procedure that's used in 4 5 the control room, but you direct the activity outside 6 the control room. It's one where the reactor operator 7 tells the auxiliary operator to do something, and you 8 have not modeled that capability in the simulator. That 9 would be N/A, as you have just described it.
10 If it is an action which is normally conducted f rom 11 the control room and it is part of the , operating 12 procedures for the control room and it is- one which 13 falls into one of the categories appropriate for the 14 operating test, then you need to model that and describe 15 that as a part of your certification of the simulator.
16 If it' need not be used as a part of the operating 1
17 test, if it's some ancillary system that's outside of 18 what we would test on -- you may have something I
19 associated with fire suppression or some other system, '
20 for example, that's not explicitly covered in the items 3 21 for the operating test -- then that need not be 22 included.
23 So you have _ to look at the scope of the operating ;
1 24 test, the required capability of the simulator as !
25 described in the ANSI standard.
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i 1 You must be able to use controlled copies of the J l- 2- control room procedures -- that is, not modified in some 3 fashion or ' pen-and-ink changed, et cetera, but they i i
4 actually need to be controlled copies -- and you can go . j L 5 through and indicate which steps cannot be performed. .j 1
6 Then you certify to that. )
l 7 ,
MR. BERGNER: I believe I've understood what L 8 you said.
9 I'm a little confused in that I believe that in the 10 absence of a modeled system or a modeled cabinet within 11 the control room area, I wculd believe that it would be l
12 permissible to use the plant to train on that particular 13 component and, in essence, have an exception on my 14 performance test plan which would normally require the 15 use of that cabinet but to identify to you that, through 16 actual on-the-job training in the actual control room, I l
17 can give the equivalent of that training that I would 18 have performed on the simulator.
19 Now, I guess my question is: Have I rolled out.cf i
20 the plant-referenced simulator category and moved into 21 the other category here? If so, how do I address that?
22 MR. RUSSELL: That's why I said you need to i 23 look at whether that system is, for instance, a safety 24 system.
25 If it's not a safety system and it's not otherwise I I
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72 1 called out in the categories under the operating test, 2 then you need not model that system as a part of the 3 control room. The saf e-shutdown panels in some 4 facilities aren't modeled. They are outside . the control 5 room. We do not require that you model that in the 6 simulator.
7 There are rad monitor panels in the control room 8 and things like that that you may not have modeled in 9 your simulation. We understand that. That should not 10 preclude you from using certification with exception.
11 You need not go to the application process. It's 12 only when there is some portion of the operating test 13 which has not been replicated by way of the controls in 14 the control room to the controls in the simulator that 15 you would have to go to the application process.
16 MR. BERGNER: That answers the first part of 17 my question. Thank you.
18 The second part of my question has to do with the 19 list of required malfunctions in performance testing and 20 the ANS 3.5-1985.
21 For my clarification, I guess, are those not more 22 " events" versus " malfunctions"?
23 MR. WACHTEL: Yes.
24 MR. BERGNER: Do you understand that this j 25 'causes confusion on the part of the simulator vendors in Sonntag Reporting Service, Ltd.
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73 l
1 that if I was to go to a vendor and tell him that I want 2 a reactor trip malfunction, he's going to look at me l
3 like what am I talking about? Do I want power to the ]
4 CRD breakers? Do I want to lose all reactor coolant 5 system flow?
6 How do I want to do this to create the abnormal I
7 event that ANSI 3.5 is asking me to perform?
J 8 Is that really referring to a list of abnormal 9 transients?
10 MR. RUSSELL: Yes.
11 MR. BERGNER: Thank you.
12 MT- -VERBECK: Gregg Overbeck, Detroit 13 Edison. I'd like to explore a little more the tech spec 14 issue that was just raised.
15 The tech specs clearly bind the conditions under 16 which the plant is allowed to operate.
17 Am I correct in what I heard: that the simulator 18 only needs to be bound by the same parameters?
19 MR. RUSSELL: No. The question came up in 20 the context of what I will characterize as the N-minus-1 21 loop operation; for instance, continued operation with a
- 22 recire pump out of service or continued operation with 23 one reactor coolant pump out of service.
24 You need not model the simulator for operation in 25 that mode if you are not permitted to normally start up
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l 1 in that mode. It was with respect to the context for 2 startup.
3 Clearly, emergency procedures, for example, which 4 go into function restoration guidelines and go beyond 5 design basis accidents are not covered by tech specs, (
1 6 for example, but we expect the simulator to be able to' 7 reasonably model those events.
8 So yes, there are -- and also when you insert 9 malfunctions. If you turn of f power to a panel, you' re 10 clearly outside the bounds of the tech specs. You would 11 not be operating with that panel de-energized.
12 So in general the answer is if you are conducting 13 malfunctions, you may be in that mode.
14 For normal evolutions in accordance with your 15 procedures that are normal startup and shutdown 16 practical-factor type of evolutions, you need not model 17 those to be outside the bounds of the tech specs.
18 MR. OVERBECK: To follow up on that, then, 19 emergency operating procedures.
20 In order to get into those emergency operating 21 procedures on most plants, you have to have a variety of 22 different types of f ailures that are compounded, which 23 goes beyond the design scope of the plant as 24 single-failure-proof and would be very difficult to run 25 on a simulator. We have the REOPs and quickly get I
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75 1 outside the bounds of simulation.
2 How do you propose that we address that issue on 3 EOPs?
4 MR. RUSSELL: There are two ways: One, the 5 standard indicates that when you go beyond the bounds of 6 modeling, it should indicate that in some way during the ]
-7 simulation.
8 .The second thing is that we do conduct examinations 9 that'go outside U.e bounds of your Chapter 15 accidents 10 and transients. That's necessary in order to get you 11 into the function restoration-guidelines. ;
1 12 We intend to see and.the regulations require.that 13 we understand that an operator can effectively implement 14 those procedures. The tolerances, however, for those 15 procedures are quite large.
I 16 When you get into casualties, the standard j 17 essentially requires that the parameter go in the same 18 direction it would go during the actual transient in a 19 plant; that you don't get spurious alarms and that the 20 alarms that are supposed to come in are the ones that 21 you get.
i 22 It does not have a time dependence to it. It's '
23 really the ability to look at the parameter; decide,
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24 based upon that parameter, what procedure you' re 1 25 supposed to be using; and then implement that procedure.
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76 1 That's the extent of what we are looking for.
2 We are not looking for a high-fidelity 3 severe-accident simulator in order to be able to 4 exercise the emergency procedures.
5 MR. OVERBECK: Okay. That's the answer I was 6 looking for.
7 MR. HALVERSON: I'm Mike Halverson. I'm from 8 Westinghouse.
9 I'd like to go back to the very first question that !
10 you answered. I believe there was a problem in maybe 11 the way that you were interpreting our question.
12 If you have the letter in f ront of you that we 13 mailed which begins, "The Generic Letter announcing the ]
14 upcoming NRC public meeting," it also states, "My 15 question is in regards to a simulation facility 16 consisting of other" -- and the word "other" is i 17 underlined - "than a plant-ref erenced simulator, and 18 the performance testing related to such a f acility."
19 The basic question there was, "What performance 20 tests are required and whct standard is used to evaluate 21 whether the tests are satisf actory or not?"
22 I think you answered that with regard to a i 23 plant-referenced simulator and not --
24 MR. RDSSELL: No. We answered it as l 25 applicable to the device which you have proposed. We l
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1 1 would intend sto follow the guidelines in the ANSI l
2 standard. ]
3 M'R . BALVERSON: Okay.
4 MR. RUSSELL: If the device has features !
5 which are not applicable to the standard or for which l 6 performance testing is not applicable, you don't have to 7- do that.
8 MR. HALVERSON: You are taking it, then, and j 9 applying ANSI 3.5 to it?
10 MR. RUSSELL: To the extent it is applicable 1 11 to that particular device.
12 Let's say that you want to use another plant 13 simulator for the performance of reactor startup and 14 that you can model effectively the controls and 15 indications that you would use for reactor startup. j 16 We would expect, then, that you would f ollow the !
17 ANSI standard as it related to the startup scenario j 18 modeling.
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19 You may not be able to model it for capabilities 20 because you don't have that capability on the simulator. 1 l
21 You would not have to follow ANS 3.5 guidelines in that !
i 22 instance.
i 23 MR. BALVERSON: You can take an exception? l 24 MR. RUSSELL: That's correct -- it's not an l l
25 exception; it's just not applicable.
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1 MR. HALVERSON: Secondly, going back to the 2 very last question that we asked, which would be on your 3 second document, " ANSI 3.5 Section 3.1.1(10) states that 4 the simulator be capable of performing 5 operator-conducted surveillance testing."
6 I understand your direction there. You were
- 7 ref erring to the remote shutdown panel.
8 I guess I would have to ask: Are you only 9 considering the remote shutdown panel --
10 MR. RUSSELL: No.
11 MR. HALVERSON: -- or what about things 12 like --
13 MR. RUSSELL: Any surveillance that cannot be 14 perf ormed f rom the control room need not be modeled.
15 For example, if you have to go out in the spaces to 16 perform it, if you're doing a diesel startup from the 17 local panel for the diesel and that's the way you 18 conduct the surveillance, you need not model anything 19 that's done on a routine basis f rom outside the control 20 room.
21 MR. BALVERSON: The comment I have here on 22 that is if I'm reading you correctly, would it be wise 23 to evaluate, for example, the plant's surveillance 24 procedures and identify which of those we think that 25 would be applicable to being done actually on this?
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1 1 In other words, generally the operator from the ;
2 control room would be doing that evolution. Naturally, j 3 all of those valves exist on the control board and so 4 on, and' you can legitimately perf orm that.
5 Would that be acceptable in meeting the intent of 6 Item 10 there in the ANSI? -
7 MR. RUSSELL: I think that would be one way 8 of doing it.
9 But if you look at the performance testing, 10 particularly when you' re getting out 'of component
, 11 testing and into system testing and you're evaluating 12 the capability of the system to actually model the 13 system, a way of doing that would be to take and see if 14 you can model the surveillance system on that.
15 The way you describe is an acceptable way of doing 16 it. You may choose some subset of the surveillance 17 that you can perform on those particular systems to show 18 that those systems are operating within the bounds 19 expected by the plant.
20 After all, that's where you have a source of data 21 on the actual performance of the system: the records 22 from the surveillance tests that you've conducted on 23 those systems, particularly where they have 24 specifications for flow or pressure or some other 25 characteristic which is modeled in the control room.
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80 1 MR. BALVERSON: Thank you.
2 MR. HEIL: I just want to point out that if 3 we do not get to your question or you have a question, 4 if it's a submitted question, then it will appear and 5 will be answered in the NUREG to follow.
6 Along those lines, though, we will not accept af ter 7 this date any questions unless you go on to Region I and i l
8 attend that meeting.
9 But if you write out a question and drop it in the 10 box in the back there, we will accept that question and 11 answer that question in the N,UREG.
12 Going on, our next list of questions was submitted 13 by Illincts Power Company on April 8th. ;
i 14 The first question: "We have non-shif t personnel 15 who hold an NRC license due to FSAR commitments or to i
16 maintain a reserve of licenses.
17 "May these people maintain their licenses in a l 18 non-active status if they participate in the licensing 19 biennial requalification program?"
20 The answer there is yes. As we've discussed 21 bef ore, the renewal of a license is not tied to whether 22 it's active or inactive; it's tied to successful 23 completion of the requalification program and 24 NRC-administered requalification examination.
25 "It is recognized that to regain active i
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81 1- proficiency, a minimum of 40_ hours should be spent _on 2 ,
shif t under instruction," and that is true.
3 MR. TILL: I'd like to follow up on that, if 4 'I could.
l 5 Ernest Till, Illinois Power.
6 .The business of maintaining a license without ;
l-
,7 having it active -- how long can we let this go on?
8 The~ indication is forever.
l 9 MR. RUSSELL: That's correct. On the L d l 10 application for renewal, you can indicate the !
11 approximate number of hours that the person has spent at 12 the controls in a position on shif t, ' and we will renew 13: licenses even if that shows zero hours.
14 MR. TILL: Thank you.
_15 MR. HEIL: The second question is, "Does the 16 revised.10 CFR 55 supersede the Barold Denton letter of 17 March 18,- 19807" 18 I think we've already answered that, and the answer 19 is yes, 'insof ar as it applies to the operating licensing 20 function.
- 21. The third question: " Instructors who have been 22 certified or who have held a license previously may 23 instruct students in courses needed to prepare 24 applicants for NRC licensing examinations.
25- "Are these instructors required to participate in a Sonntag Reporting Service, Ltd.
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B2 1 requalification program?"
2 There are two parts: If you have an accredited 3 program or an SAT program, then that program will define 4 the continuing program requirements qualification and 5 retraining of instructors.
6 If you do not have an accredited program, then the 7 instructors will have to be licensed. From that aspect, 8 their requalification program is defined under Part 55.
9 The NRC is no longer going to be in the business of 10 doing and issuing instructor certifications.
11 MR. ANTONELLI: Doug Antonelli with Illinois 12 Power. I'd like to follow up on that. l 13 As I understand, what 'you said is that only people 14 that hold a license for the Clinton facility may do 15
- instruction of license-type material to a hot license 16 class.
17 The consultants that are previously licensed who 18 have been certified by General Electric would not be 19 able to teach such material?
20 MR. RUSSELL: Well, first, if your program is 21 accredited, then you determine subject matter expertise 1 22 and instructor skills in accordance with the accredited 23 program.
l l 24 If your program is not yet accredited and you were l
! 25 previously under the commitment contained in the Denton l
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83 1 letter to assure subject matter expertise for 2 instructors -- which was essentially for those who were 3 instructing integrated plant operations; that they have 4' a level of knowledge comparable to that of a. senior 5 reactor operator -- then the process we've allowed'in i
-6 the interim is for you to certify your instructors * '
7 yourself based upon their successful completion of your 8 senior operator training program.
9 We have also allowed that for those who have 10 previously been examined in the past by the NRC and were 11, certified by the NRC in the past, they can continue but 12 they should have the additional training on, changes to 13 procedures or changes to plant, that portion of the 14 requalification program.which is applicable- to what 15 they're teaching. -
16 Now, the practical aspect is that those people who 17 are instructing have to learn that material to a depth 18 greater than that which they instruct, and your program I
19 also has mechanisms for evaluating instructor
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20 perf ormance.
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21 What we are trying to do is we are trying to move 22 out of the area of specifying training program content 23 or qualifications for instructors.
24 So in your case, depending upon what your 25 commitment is in the presently approved program, you may Sonntag Reporting Service, Ltd.
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l 1 need to review that in accordance with 50.59.
2 We would not consider it necessary for the NRC to 3 certify it.' You may do that yourself under your own j l
4 . program.
5 MR. ANTON ELLI: Thank you. -l 6 MR. WEST: Tom West of Westinghouse.
i 7 How would that apply to vendors such as j 1
8 Westinghouse? l j
9 We cannot get accredited by INPO. Therefore, if we 10 hold a staff of instructors, are they then going to have 11 to go to the utility and the utility is going to have to l l
12 either license or certify them? !
I 13 MR. RUSSELL: For contractors that are l 14 providing instruction for facilities, it is the 15 responsibility of the f acility to ensure that the 16 contractors have the appropriate subject matter 17 expertise and instructor skills to meet the requirements i
18 of their program. l 19 The Staff will not be certifying or approving 20 instructors who are contractors, nor will we be 21 certifying or approving instructors who are facility 22 employees.
23 MR. BRUNO: Ron Bruno from Wisconsin 24 Electric.
25 Did I understand it correctly that you said that if Sonntag Reporting Service, Ltd.
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4 1 you're not accredited, that you would have to license 2 instructors?
3 hR. RUSSELL: My comment was that some 4 facilities in their commitments, in their existing i 5 training programs, have committed to have either 6 licensed senior reactor operators or individuals who 7 were certified instructors, the old instructor 8 certification, which was comparable to a license.
9 The certificate. looked the same. He went through 10 the same examination, but he was not authorized to 11 manipulate the controls.
12 We no longer issue such certificates, which would 13 imply that you would be obligated to have licensed 14 operators to conduct your program.
15 I also indicated that you could perform a 50.59 16 type of review that would meet the same intent. By you 17 having your instructors complete a program comparable to 18 your,own senior reactor operator program and be
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19 examined, that would be sufficient in the interim. j l
20 When we.get to the point where everyone has been
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i 21 accredited, that issue is superseded. The accreditation 22 process covers instructor qualification and training.
23 MR. BRUNO: I understand that. I guess it i
24 goes back to the question that I asked earlier about I 25 whether or not the new Part 55 superseded the I l
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I 86 1 requirements in Denton's letter, and you said yes.
2 .Now you're saying, "Yes, but maybe not if you don't 1 1
3 get accredited."
'4 MR. RUSSELL: No. It supersedes all 5 requirements where those requirements are less 6 restrictive.-
7 Where your individual commitments are more 8 restrictive than the requirements of the regulation, you 9 must follow those commitments until such time as you i 10 change them.
11 Now, in some cases that change may require an 12 amendment to the license. In other cases it can be done 13- by yourself under 50.59, and you simply inform us that 14 that's what you're doing. !
15 That's a change within your authority to do under 16 50.59, and it does not constitute a reduction in the 17 effectiveness of the program, because it's being done to l
18 conform to the rule. ,
19 We are no longer, under the rule, permitted to do ,
20 instructor certifications. That's been recognized for 21 some time.
22 Are you ready for the next letter? l 23 MR. HEIL: Yes. ;
24 MR. RUSSELL: Illinois Power.
25' MR. HEIL: Continuing with Illinois Power,
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1 "Will the implementation of the six-year license renewal 2 requirements be retroactive to outstanding licenses that' !
3 were to expire af ter two years?"
4 No,_they are not retroactive. On renewal, when it 5 comes time for renewal of a. two-year license, assuming 4 6 the individual meets the requirements f or renewal, he 7 will then be issued, af ter May 26th of this year, a 8 six-year license.
9 "If so, at what point is it unnecessary to apply 10 for renewal of two-year licenses?"
l 11 I think that has been answered: You have to renew If they expire after May I 12 the licenses when they expire.
13 26th of 1987, then they will be renewed with a six-year j 14 license.
15 MR. KELLEY: Larry Kelley, Dairyland Power.
16 I have some submittals coming up for renewal that-17 will have to be submitted bef ore the May 26th date, but 18 the renewal is not' until af ter.
19 Do I submit them under the existing rules and 20 they'll come back as a six-year license?
21 MR. RUSSELL: The 398 form that you use up to j 22 the 26th of May is the same one that's in effect today. ,
23 Even though you submit on that form, if we issue a 4
24 license af ter the 26th, it will be a six-year license.
25 Any applications submitted after the 26th of May Sonntag Reporting Service, Ltd.
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1 should be on the new 398 form with the new 396.
2 MR. HEIL: Question No. 5: "It appears that 3 comprehensive requalification written exams are required 4 only every two years and operating tests are' required 5 once per year. Is this true?"
6 It is true that the written examination will go to 7 every two years unless your program commitments are more 8 stringent.
9 I think Bill has indicated that if currently your j 10 program requires you to do it on an annual basis and it
~
11 is not an accredited program, then you will have to 12 notify us if you intend to reduce that commitment. If 13 it's an accredited program, then you can make the j 14 changes as appropriate.
15 That concludes the Illinois Power comments.
16 The next set of questions we have was submitted by 17 Commonwealth Edison Company.
18 The first question: "Will the people presently f
19 holding two-year licenses have to reapply at the 20 expiration of the two years or will they be 21 automatically extended to the six-year cycle?"
22 We already answered that. They need to reapply 23 prior to the expiration date, as indicated.
24 "What will be the duration of the grace period f or 25 the implementation of the new 10 CFR 55?"
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89 1 The rule goes into effect on May 26th of 1987.
2 There are grace periods identified within the rule for 3 certain aspects of the rule, and those are stated in the 4 rule.
5 MR. RUSSELL: Let me give you an example of 6 how you determine what those are, because it doesn't say 7 specifically this goes into effect on some date other 8 than May 26th.
9 Operating tests on an annual basis: If an 10 individual is licensed on May the 26th,1987, and holds 11 a license, he must have had an operating test by May the 12 26th,1988, within one year.
13 For an application which you submit in the middle 14 of that period -- af ter, say, six months has expired --
15 he may or may not have had an operating test, because 16 you would not have been required to complete an 17 operating test for everyone until after cne year, j 18 It's in that context that we say that the rule 19 itself provides the basis for the period of when you 20 must be in conformance.
21 So if it says you've got to examine annually, then 22 one year after the effective date of the rule, everyone ,
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23 should have had an operating test.
24 If it's a comprehensive written examination and the 25 rule says it must be done at least each 24 months, then Sonntaq Reporting Service, Ltd. )
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90 1 after the rule has been in effect for 24 months,-
2 everyone who was licensed on the first day that the rule 3 went into effect shall have had a comprehensive 4 examination, unless, of course, you are accredited, and q 5 then you may use a segmented exam.
6 Is that clear?
7 MR. ZANK: Brian Zank, Commonwealth Edison.
8 We've talked about an annual operating exam to be 9 administered by the utility.
10 What constitutes an " operating exam"?
11 MR. BEIL: I think that's defined in the 12- regulation to include an oral and a simulator 13 examination if you currently have a simulator that's 14 acceptable for -- let me rephrase that.
15 If you currently have a simulator that you are 16 conducting examinations on or we are conducting 17 examinations on, then you must include an oral and a 18 simulator examination.
19 MR. Z ANK: The oral exam out in the plant 20 walk-around? k 21 MR. RUSSELL: Let me really get to the point.
22 It is not performance of practical factors in a 1
23 training environment. J 24 We've had, for instance, the requirement of the s, 25 Denton letter to perform certain practical factors on an ,
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91 1 annual basis.~ People go in for simulator training, and 2 they perfor,m the practical factor until successf ul, 3 whether it takes one try, two tries or three tries.
4 Ne are interested in a structured examination. We 5 are not interested in training on the simulator. The i'
6 structured examination must meet the requirements of the 7 regulation as it relates to sampling those various areas 8 that are specified under the regulation.
9 It is a combination on the simulator, if you have 10 one, and in the plant. If you don't have a simulator, 11 it must be done in the plant.
12 MR. HEIL: The next question is: "Will the 13 Commission question the utility's judgment regarding the 14 need for an individual's license? If so, what criteria 15 apply?"
16 We will not be questioning your judgment. Your 17 facility management makes that decision and certifies on 18 the application or the reapplication that there is a !
19 need for that license.
20 Question 4: "Is the systems approach to training 21 development referred to in the new 10 CFR 55 based on 22 the systems approach described in NUREG-1220 or the INPO 23 standards?"
24 You can take that, Bill.
25 MR. RUSSELL: I answered that earlier today,
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l 1 and it's both.
2 The Commission has specifically endorsed the INPO 3 . accreditation objectives and criteria as being a systems 4 approach to training.
~5 The NUREG-1220 simply repeats the criteria that are 6 contained in the policy statement. It then has 7 subordinate questions that we use for information-8 gathering to determine whether a systems approach to 9 training is in place.
10 We have reviewed with .INPO extensively NUREG-1220. j e "
1 11 Beth parties agree that it is appropriate.
12 There have been some questions in the past about 13- the level of detail we are looking for in some areas.
14 Those are continuing to be discussed. They generally 15 relate to conditions and standards associated with 16 learning objectives and whether you need to develop KSAs i
17 or not.
18 We've reached agreement with INPO on that process l
19 on how you're back-fitting existing programs that do not
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20 have KSAs but have learning objectives. j i
21 In general the agreement has been that if it's a ]
22 new task or new training, it should be developed with 23- KSAs. If its existing panel of subject matter experts, 24 job incumbents, could conclude that the existing 25 ' training programs adequately cover the material, it need Sonntag Reporting Service, Ltd.
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1 not be back-fit. I 2 MR. BEIL: The next question from 3 Commonwealth Edison: "How are the current guidelines, 4 which allow requalification examination site visits to 5 be extended to every three years based on good SALP l 6 ratings or accreditation, going to interf ace with 100 7 percent requalification every six years?"
8 Well, basically these are two different programs.
9 One is a programmatic evaluation looking at the adequacy 10 of the requalific'ation program. The other deals with 11 the Commission-directed re-examination of each licensed 12 operator on a six-year basis.
13 MR. RUSSELL: The short answer is, though, 14 that in the next couple years, we don't expect it to 15 change very much.
16 It's going to take some time to build up a pool of 17 six-year licenses so that we would be conducting the 18 examinations in accordance with this regulation.
19 So in the near term, those facilities which have 20 better performance and have achieved INPO accreditation 21 would have a longer period of time between NRC visits.
22 MR. FEURY: Ed Feury, Consumers Power.
23 I've got a question pertaining to this 24 NRC-administered requirement to renew your license. I'm 25 thinking of a situation where an operator may f ail the Sonntag Reporting Service, Ltd.
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l 1 administered exam.
i 2 I know that won't apply to my utility, but there
)1 3 may be some others here. l 4 (Laughter.)
I 5 In the past when one of the guys f ailed an exam, 6 they would go into an accelerated requal program 7 normally administered by the utility.
8 Is that going to remain the same here and, once he !
9 completes the accelerated requal and the examination by
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10 the utility, would that be acceptable as f ar as meeting 11 the requirement of passing the NRC-administered exam?
12 MR. BEIL: There's two different questions 13 there. One deals with the acceptability of the 14 facility's accelerated retraining program to return that 15 individual to licensed duties.
16 That will depend upon the status of your 17 requalification program. If your requalification 18 program is deemed satisfactory, then that's indicating l
19 to us that you have the capabilities under your program 20 of dealing with the failure of a requalification 21 examination, be it ours or yours.
22 But with regard to satisfying the requirement for a 23 six-year re-examination, the Commission has directed 24 that the Staf f perf orm that; that the individual must 25 pass an NRC-administered requalification examination Sonntag Reporting Service, Ltd.
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95 I during that six-year period.
2 So what that means is if he fails and you have a 3 program th$t has been deemed satisfactory, you can 4 retrain him and return him to shift duties.
5 But the NRC will still have to, at some point in 6 time before the end of that six-year license, examine 7 that individual and have him successfully pass an 8 NRC-administered requalification examination.
9 MR. FEURY: Thank you.
10 Take the situation where this guy happens to be 11 picked up very close to his license expiration, okay. ,
12 He fails the exam. Obviously, he will not be relicensed 13 until he passes the exam.
14 What kind of a time frame am I looking at to get 15 him re-examined?
16 MR. HEIL: We're shooting for and identifying 17 scheduling-resources for basically two visits to a 18 facility per year.
19 I think we've already addressed the situation where 20 the NRC does not administer and the individual does not 21 successfully pass an examination within the six-year 22 pe riod.
23 My understanding at present is that as long as 24 there's timely application, the f acility conducts the 25 accelerated retraining, assuming he has --
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1 I i 1 MR. BUSSELL: No.
2 (Laughter.)
3 MR. HEIL: Go ahead.
4 MR. RUSSELL: The timely application process 5 covered an error on our side; that is, we failed to 6 examine the guy because we just missed it, not the case 7 where we exam,ined him and he failed it.
8 If t>e individual is examined and he fails it and 9 it's getting close to the point in time of renewal of 10 his license, we would have to look at that on a 11 case-by-case basis as to whether our resources permit us 12 to go back and give another examination before the next 13 regularly-scheduled exam.
14 But the regulation is clear: He must have passed.
15 We will allow youe program in some cases to be the 16 basis for returning him to watch. In other cases we'll j 17 go in and not only examine that individual again, but in 18 some cases we've examined all licensed operators, 19 particularly in those cases where we conclude a program 20 is uncetisfactory.
l 21 MR. FEURY: I understand. Thank you.
22 MR. RUSSELL: But with the issue of license 23 renewal, if it's getting down to the wire and he's 24 within, say, six months of renewal and that's when he's 25 targeted to come up for an exam, I think that's a pretty l
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3 MR. FEURY: Thank you.
4 MR. HEIL: The next question states, "With an 5 accredited program and plant-referenced simulator 6 certified to ANS 3.5 requirements, what are the specific 7 experience and education requirements for initial 8 license applications and what has been deleted?"
9 MR. RUSSELL: Well, I think we answered that 10 earlier. We haven't deleted anything, because what 11 we've been using is ANS 3.1 as it was committed to by 12 industry through NUMARC and described in Generic Letter-
)
13 84-16.
14 The difference is who handles waivers of and review 15 of diff erences f rom a specific candidate's 16 qualifications; that is, the interpretation within those 1
17 standards.
18 In the case of facilities that are accredited but j 1
19 do not yet have an approved simulation f acility, the NRC 20 will be reviewing and making a determination on the
'1 21 qualifications and eligibility to sit for an exam.
22 In the case of a utility that has both an l
23 accredited program and a simulator, you simply certify 24 that the candidate has completed the training program, 25 that it was accredited and that you have a simulator. l l
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1 You will make those determinations, and not the Staff.
2 We will proceed to conduct an examination on that 3 ba si s.
. 4 MR. BEIL: The next question: "Will there be 5 any effort by the NRC to ensure a consistent level of 6 detail in the facility's learning objectives?"
7 Do you want to take that?
8 (Laughter.)
9 MR. RUSSELL: Yes.
10 This is probably one of the more significant areas, 11 because we have seen a rather large spectrum of 12 difference in learning objectives.
13 As a part of our examination development efforts, 14 we have been reviewing the quality of the learning 15 objectives submitted with materials f or the 90-day 16 letters. This is the boxes of stuff that you send in to 17 assist the NRC in preparing an exam.
18 We're actually' going through those and evaluating 19 the quality of those and using that as a feedback 20 mechanism back into the evaluation process of how well 21 accreditation is working.
22 We are also going to use it in making 23 determinations as to whether we can use your materials 24 to construct an examination or not, or whether we 25 ' substitute our own and use the KA catalogs and the l Sonntag Reporting Service, Ltd.
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1 sampling plans and the examiner handbook.
2 So, yes. It's clear that we have a major effort 3 under way to evaluate the quality of. learning objectives 4 that are submitted for the construction of an exam.
5 .W here we find that they are not adequate, we won't j 6 use them and we'll use our own materials. Where they 7 are adequate and they have conditions and they have 8 standards of perf ormance that can be turned into testing 9 objectives, we will use them.
10 Hopefully, a few years down the stream, we'll find 11 that we can use yours more and have to do things .j 12 individually less.
13 We have been also opening up our examination 14 training program to INPO and others. We have provided information to them on how we construct examinations and
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16 the training that we're providing to examiners, and i 17 there are activities under way within INPO to improve 18 development of testing objectives.
19 We hope that in the next few years, both of those 20 will come to maturity and that we will be writing 21 examinations that even the guy receiving it will agree 22 was a fair examination.
23 (Laughter.)
l 24 Be might not have known everything, but he'll agree 25' that it was relevant to his job. i Sonntaq Reporting Service, Ltd.
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100 1 A VOICE: Great. When is that?
2 (Laughter.)
3
$R. RUSSELL: When the first guy that fails 4 it feels that way, then I'll really feel it's been 5 successful.
6 (Laughter.)
7 A VOICE: When is that? .Two years?
8 (Laughter.)
9 MR. HEIL: And the Region believes we're 10 doing that now; right?.
11 MR. RUSSELL: Yes. Everybody does.
12 MR. HEIL: The next question: "When'an 13 applied science degree is considered, what constitutes 14 an acceptable degree?"
15 This is a Commonwealth Edison question, and maybe 16 they can supplement this a little bit. I think we had a 17 little bit of difficulty in determining what the context 18 was of the question. ,
19 If it's to do with an STA --
20 MR. RUSSELL: If this is engineering 21 expertise on shift as it relates to the dual role 22 SRO/STA, then the policy statement on engineering 23 expertise on shif t identifies the type of degree that '
24 the individual must hold.
'25 If there's a question on a plant-specific basis as Sonntag Reporting Service, Ltd. .
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to whether a particular degree, as supplemented with 2
additional training, would be consistent with that 3 policy stacement or not, the vehicle to use would be to 4
submit that program to the NRC for review and get a 5 specific determination back.
6 But it is not applicable to the eligibility 7 requirements for holding a degree for the instant SRO 8
for waiving the training requirements or the experience 9 requirements when you substitute two years of experience 10 for a degree. The guidance in that area is in REG GUIDE 11 1.8 and the ANSI standard.
12 MR. BEIL: A question?
13 MR. SNOW: Art Snow from Commonwealth Edison.
14 What we are talking about is that at Quad Cities 15 there was a fellow turned down as an SRO who had a 16 degree. The degree was not deemed acceptable. I'm not j 17 sure what the degree was, physics or something like I
18 that.
The question is: How do we know, if a guy has got 19 20 a degree, what specific degree allows him to be an 21 instant SRO or does he have to be an RO first?
22 We don't know the cutof f points. The problem is 23 that when we make application and get turned down, then 24 we have to send him back up to be an RO.
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1 program and an acceptable simulator, you will be making 2 that determination.
3 I'm buying time right now.
4 (Laughter.)
5 MR. MC MILLEN: Joe McMillen.
6 MS. SH ANKMAN : Who?
'7 (Laughter.)
8 MR. MC MILLEN: M-c -M- I- L- L- E- N . I represent 9 myself.
l 10 I think the particular degree he's talking about l 11 was an education degree, because I'm the guy that turned 12 them down, so that may have some bearing on it.
13 (Laughter.)
14 MR. SNOW: No. This was a recent one. '
15 (Laughter.) i 16 MR. BEIL: We have been dealing with these on 17 a case-by-case basis. If they do not meet the strict 18 interpretation of an engineering degree or an applied 19 science degree that would have included -- do you want 20 to take it up?
21 MR. RUSSELL: Let me give what I think is the
]
22 best answer to this question; that is, the Staff reviews l
23 those and we use our best judgment and the people in the 24 Region do in making a determination on an application. I 25 If you feel that an application has been unf airly Sonntag Reporting Service, Ltd.
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rejected, you have the ability to request it to be 2 reviewed by regional management and then reviewed again 3
by Headquarters management.
4 We have had a couple of cases recently that have 5 come to Headquarters. One related to a chemist for i
6 experience equivalent to that of an engineer on shift or 7 equivalent, to that obtained by a ' control room operator B either in a fossil plant or a nuclear plant. When you 9 get into those types of judgment decisions, you have 10 vehicles where you can request that review.
11 I don't know the specifics of this case, and so I'd 12 be hesitant to discuss it at this point. But if you 13 want to bring it up through a review, we can certainly 14 do tbat ch a plant-specific basis.
15 MR. SNOW: For the future it won't be a 1
16 problem, because' you won't check up on us.
17 If we send a fellow in and say he's an SRO -- not
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l 18 to be f acetious, but you will accept it because you j i
19 won't know what degree he has. It won't be listed on j l
20 his application. j 21 MR. BEIL: Well, only for the situation where 22 '
you meet those two concurrent requirements.
23 MR. SNOW: And assuming that we do --
t 24 MR. BEIL: It's our understanding that that 25 determination will be made in accordance with guidelines j l
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.104 l' that have been established under your 'INPO-accredited 2 program.
3 MR. RUSSELL: Let me make sure this is clear, 4 because this is an issue that I've discussed with the -
5 accrediting board in plenary session and with several 6 company. vice-presidents. I 7 The Commission has made a determination that.we're 8 going to trust the industry and'let the industry-9 programe be operative in the area of training and 10 qualifications under the policy statement. We 11 understand generically what these commitments mean, and 12 we've reviewed them'quite closely.
13 If we find that'that is being abused, either 14 through an inspection program or through any other 15 vehicle, that's going to cause grave concern as to 16 whether the industry is able to police itself and act 17 responsibly, given what we have delegated to you through 18 those programs.
- 19 At the same time, we don't expect to nit-pick the 20 judgments that you make if you make those judgments in 21 an appropriate way and you document the bases for those ,
22 judgments. The process of accreditation includes a 23 review of how you go about making those determinations.
24 I've been on team visits and I've been at board 25 ' meetings and I've seen utilities being put through thei:
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1 paces to describe what mechanisms they use to review and 2 make determinations about the eligibility for candidates j 3 to enter into training and whether they are qualified to 4 perf orm in that job position.
5' What we're saying is we believe that process is the 6 appropriate one to use. If you do that and you do that
. 4 7 in a straightforward, rigorous manner and you don't use f
8 the fact that because we're not looking, you're not 9 going to do it, then that's what we're looking for.
I 10 We're not going to nit-pick and second-guess your ;
11 judgment s, provided you have an adequate basis for them ;
12 and provided they are consistent with what has been 13 approved generically through the accreditation process 14 and the guidance that INFO has issued.
15 MR. SNOW: My point was if Quad Cities had
'16 happened to have been accredited with a simulator, the ]
17 fellow probably would have been licensed, because 18 obviously the station felt he was qualified. i l
19 MR. BEIL: And that may well be the case.
20 I guess one other thing to point out is the rule 21 does say "NRC-approved training programs," not 22 "INPO-accredited training programs."
23 So the approval and acceptance of the training i 1
24 program remains with the Commission and is not 25 continuing forever or irrevocable.
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1 So that's'something to keep in mind, too._ l L i 2 MR. RUSSELL: Let me emphasize that.
3 We chose to not specifically endorse It: ?O',n program 4 in the rule, but instead we stated that during the 5 continued endorsement by the commission of the policy i 6 statement on training and qualifications, accreditation 7' would constitute the basis for NRC approval for the 8 program.
9- If we were to find that the program is not being 10 implemented, that would be a basis for us removing that 11 approval. It would be through that type of process --
12 and I believe it is f air to say that if we found that 13 there were abuses of the responsibility and authority 14 that have been delegated through this program, it would 15 be likely that some could lose that approval.
16 MR. SNOW: I have one other question while 17 I'm here. You said several times that you don't have to i 18 list the specifics of education, training and experience 19 on the new 398.
20 Now, there will be a box that will say 21 "INPO-accredited" or "NRC-approved" f orm. If we mark 22 that box, could we leave all other sections, such as 23 whether he was a high. school graduate, what his position 24 is, how many years he's been around? 1 25 MR. RUSSELL: That's correct. It identifies Lonntag Reporting Service, Ltd.
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1 the specific sections of the form that need not be ]
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2 filled out, provided you check "yes" to both the boxes 3 of a graduate of an accredited program and you have a 4 certified or approved simulation facility.
5 MR. HEIL: There is one thing that's still 6 required which relates somewhat to experience, and that 7 is the number of hours at the operating facility. That 8 still remains even if you check both boxes.
9 MR. RUSSELL: Particularly for renewals.
10 MR. HEIL: The next question: "Does a 11 simulator certification form NRC 474 have to be ,
12 submitted prior to each operating examination?"
13 I'll save you the time, Jerry.
14 No. Assuming that you maintain the acceptability 15 of the simulator, it is a one-time certification. l 16 MR. WACHTEL: That's correct.
17 MR. HEIL: The next question: "Why we re n ' t 18 the utilities allowed to make public comments on 10 CFR 19 55.57 (b) (2) (iv) , license renewal requirements?"
20 I'm going to let Mr. Russell handle that one. l 21 (Laughter.)
22 MR. RUSSELL: The straightforward part of the 23 answer is that because it was. reviewed by the General 21 Counsel and determined to be legally not required.
I 25 Part of the reason for that is that we indicated in sonntag neporting service. r+ a _
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1 the policy statement on training and qualifications that 2 ue would use requalification examination as a mechanism 3 for judging the validity of the industry-accredited ;
4 training program process.
5 The Commission is continuing to do that, and will 6 do so.
7 The fact that we have moved out of the training 8 review area in providing prescriptive guidance and 9 training and moving into the area of judging the ability 10 of the individual to perform after training, the way we 11 . make that judgment is through an examining process.
12 That's the reason for it.
13 The Commission has indicated that that was their 14 policy, both through the policy statement, which was 15 publicly noticed and available, and it is a continuation 16 of Staff practice.
17 The mechanism that it was tied to renewal was 18 chosen by the Commission to insure that there was a 19 clear understanding on the part of all operators that ,
20 this was required, and to eliminate the question about, 21 "Why me," because in the past, when the Staff went out 22 and selected operators for examination, there was always l 23 a question of, "How did I get chosen, why not someone 24 else?"
25 In this case, it's clear that it applies to all 4
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1 licensed operators who hold a six-year license.
2 MR. HEIL: The next question deals with -- [
3 M5. RUSSELL: Bill.
4 MR. ZANK: Brian Zank, Z-A-N-K, Commonwealth 5 Edison.
In regards to that, we touched on this in the I 6
7 morning. You only said it fleetingly, but we have not 8 got into detail'on it, i
9 Is the appeal process for the recall examination 10 the same as the initial exam?
11 There's two problems with this. .one is the 12 individual's own self-respect if he fails that exam and 13 he feels he should not have.
14 Many utilities have bonus money attached with 15 passing annual recall exams. I 16 The other one is our program is being judged f 17 against the results of that recall exam.
18 If there's something that we feel was amiss during 1 19 the exam, that we ought to have some kind of recourse in 20 having that evaluated.
21 MR. RUSSELL: The answer is yes, the appeal 22 process does apply in particular as it relates to the 23 administrative process.
24 You are provided the opportunity to comment on the l
25 written examination through the normal process for any i
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l 110 1- written examination.
2 ,
That is, you are given the exam. Following the
- t 3 last candidate having completed the exam, you provide 4 comments on'it. l 5 The only thing that does not apply is he does not i
6 have the right to request a hearing because his license '
7 has not been taken away. He still has a license. He 1
8 goes.into accelerator training, j 9 So he can request an administrative review up to my l 1
10 level; a review in the Region by the Division Director (
l 11 in the Region and a review at headquarters. 1 12 If we were to, for example, deny the renewal of his 13 licerse and he had at that time pending an issue which 14 was telated to his requalification exam -- that is, he's 15 contesting the failure of that exam administrative 1y --
16 he would have, at that point, the right to a hearing 17 because we had not granted the licence renewal because 18 he had failed to pass an exam, in our opinion, when, in 19 his opinion, he felt he had passed it.
20 So in that context, he would be eligible to request 21 a hearing on the denial of his application for a license 22 renewal.
23 But since that only occurs each six years, for the
! 24 case where an individual fails an exam early on, that l
25 would be through the administrative appeal process as annneng napnreing carvi ca r+a.
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1 has been described and will be articulated in.the 2 examiner standards, Standard 112.
3 M'R . HEIL: The next question deals with 10 CFR 4 50.23, Decertification.
5 "Can the Form NRC-396 be held at the stations for 6 the two-year update or do they have to be submitted to 7 the Commission? l 8 "If the forms do have to be submitted, how often do 9 they have to be submitted?"
10 They should be held as a documentation of 11 continuing medical acceptability of the individual, and 12 should only be submitted to the Region, along with the 13 application for renewal, in the case of a six-year 14 license, or for initial application.
15 MS. SHANKMAN: You don't have to keep the 396 16 form on file. You just have to keep some documentation 17 that the medical exam has occurred and that the operator 18 meets the ANSI standard.
19 396 is only how you transmitted that information to 20 us on a six-year basis.
21 MR. HEIL: Good point.
22 MR. RUSSELL: Let me cover an issue that 23 hasn't come up yet in this meeting, and I don't think we 24 have other questions that relate to it, but I brought it 25 up in the past two regional meetings, and this is by way gonntag neporting service. T+ a .
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112 1 of a recommendation or something to consider.
2 I would recommend that you develop a medical 3 examination form that would identify the disqualifying 4 conditions covered by the ANSI standard that_you could 5 have reviewed and signed by the doctor that would come 6 back to whoever your authorized representative is such 7 that he has assurance that, indeed, the medical 8 examination has been performed in accordance with that 9 standard, and that you would then have that medical 10 examination sheet, with the appropriate check saying 11 that the guy, you know~, is not physically disqualified 12 for any of the specified reasons, a part of your onsite l
13 records.
14 This will resolve a number of potential concerns.
15 One, we would not have to have the com'plete medical 16 record. There may be other things that he visits the 17 doctor for that would fall into the category of 18 privileged information between the doctor and the 19 candidate, but it would confirm that he does not have a 20 medically-disqualifying condition.
21 The second advantage is that it may keep your 22 vice-president out of trouble from the standpoint of 23 what he is certifying to. That is, he's certifying 24 that the individual has been examined and has been 25 examined in accordance with ANS 3.4.
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1 He'has to have some mechanism in place to assure- l 2 himself that that has, indeed, been the case,before he 3 signs, under penalty of perjury, the statements he has 4 made on that form are correct.
5 This is an area where I feel that an industry-6 initiative would,be appropriate. You could clea" y- i 7 develop an examination report from a medical doctor that-
-8 could be used and would meet the requirement of the 9 standard without having to carry the standard around or 10 without. stapling it to all the medical examinations that 11 are completed.
12 We're not requiring it. It's up to you and the '
13 responsible official to decide what evidence he.needs 14 before he signs off, but it is an area that we think.
15 would be of benefit.
16 It's one I've discussed with INPO and the 17 accrediting board, and I think it's one that would be i 18 appropriate for some type of an industry initia'tive to 19 assure uniformity so you don't have different medical 20 doctors applying different standards as it relates to 21 ANS 3. 4.
22 MR. HEIL: Let's take about a 10-minute break 23 and resume about 10 after 3:00.
24 (Whereupon a recess was had, after which 25 the meeting was resumed as follows:) !
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114 1 MR. HEIL: We've got quite a bit more to go 2 here. Do you want to go ahead and take your seats.
3 Commonwealth Edison has indicated, I guess, that 4 not a lot of their questions remain or have been -
5 answered in one form or another or they will be able to 6 read about it in the NUREGS, so with their permission, 7 we're going to skip ahead to the next set of questions 8 and try to give everybody an opportunity to hear some 9 answers to their questions.
10 The next set of questions was submitted by Northern 11 States Power for the Prairie Island Training Facility.
12 The first question: "Will the format of the 13 written exams change? If so, what will be the new 14 format?"
15 The simple answer is at the present time the 16 format of the examinations is not expected to change, 17 although, as Bill has indicated, there are numerous 18 initiatives under way which may lead to format changes 19 in one way or another as we refine the process.
20 Do you want to add anything, Bill?
21 MR. RUSSELL: No. ,
l 22 MR. HEIL: The next question is a simulator 23 question, Jerry.
24 "We currently have a site specific simulator, and ,
i 25 it has been used~ to administer the simulator portion of !
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1 the operating tests.
2 "Do we have 46 months from the effective date of 3 the rule to submit Form NRC-474, ' Simulation Facility 4 Certification'? Will the simulator tests continue to 5 be administered on our non-certified simulator before we.
6 submit the Form NRC-474?"
7 Lastly, "Under what conditions would the NRC refuse 8 to administer operating tests on the simulator?"
9 MR. WACHTEL: The answers to the first two 10 parts are yes, you have 46 months.to submit Form 474, 11 and, yes, the simulator will continue to be used for the 12 conduct of exams until you submit that Form 474 or until 13 you reach the four year deadline.
14 The answer to the final part is that NRC would 15 refuse to administer operating tests if the simulation 16 facility has not been certified by the deadline or if, 17 after it has been certified, an inspection proves that 18 it is unable to meet the requirements of conducting an 19 operating exam, and if certification is pulled, then it 20 needs to be decertified.
21 MR. HEIL: The third question deals with 55.57 22 Paragraph (a) (3) .
23 It, " States that written evidence of the 24 applicant's experience under the existing license and 25 the approximate number of hours that the licensee has snnntag neporting service, r+ a _
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operated the facility must1be provided.
2 "Will licenses'be renewed if zero hours have been 3, spent operating the facility? Will inactive licenses be- q 4- renewed?"
5 The answer is yes, provided the person otherwise. ,
i C ' meets.the requirements for renewal with regard to the 7 requalification program and-the requalification 8 examination by the NRC.. !
9 No. 4, "May an SRO perform the functions of an RO.
10 to satisfy the requirements of Paragraph (f) of 55.53 11 for an SRO7" 12 The answer is no. 55.53 (f) Subparagraph (2) and 13 the definitions of active license require the individual 14 to function in the capacity for which he's going to'--
15 ,in the position to which he's going to be performing. .
16 I.e., if you are in the process of trying'to bring 17 active an RO license, then he has to stand parallel with 18 someone in that RO position. If he is going to 19 reactivate an SRO license, then it will have to be stood 20 parallel with a shif t type of. SRO position.
21 MR. AMUNDSON: Ted Amundson, A-M-U-N-D-S-O-N, 22 Prairie Island. !
23 The specific question, I think, deals with the 24 situation where you have some people who are performing 25 as Reactor Operators, but you have licensed them as Cnnn>an DannrF4nn terufen. T.V R .
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-1 SRO's as a pool of candidates to become shift' 2 supervisors or shift superintendents or whatever the i 3 case may be.
. 1 4 MR. HEIL: In atsituation'-- 1 1
5 MR. AMUNDSON: Those will we also have to 6 shift into the shift supervisor role periodically to
)
.7' maintain that SRO?
8 MR. HEIL: He may be inactive for the i 9 purposes of performing' duties as an SRO in directing the 10 activities of reactor operators. He may be active"for 11 the purposes of manipulating the controls.
12 In other words, an SRO licensed individual can and 13 do perform in the position of an RO, but by performing 14 those functions in the position'of an RO, he is only 15 active for performing the manipulative functions of an 16 RO and is not active for providing the supervisory --
17- ,
directing the activities of~and RO capabilities of an 18 SRO. I 19 MR. AMUNDSON: Okay. Thank you.
20 MR. RUSSELL: Bill.
21 MR. HEIL: Yes, Petc.
22 MR. LE BLOND: Pete LeBlond, Commonwealth 23 Edison.
24 With regards to fuel handlers, in the case where 25 you may refuel once a year, it's probable that the !
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110 1 requirement won't be maintained.
2 The subparagraph suggests that one shift of 3 supervised duty is required before the fuel handling 4 foreman with the license can maintain -- or can assume 5 his full duties.
6 Is the intent that that supervision be performed by ~
7 another fully qualified SRO who may not be a fuel 8 handling. specialist?
9 MR. HEIL: That is correct. An active SRO 10 license includes the capability and responsibilities 11 associated with monitoring fuel-handling activities.
12 The fifth question is: " Paragraph (c) (3) (1) of 13 55.59 requires certain manipulations to be performed 14 annually. This list of annually-required manipulations 15 differs from the list in the Harold Denton letter of 16 March 28, 1980. Our requalification program is based on 17 the Denton letter. How long do we have to modify our 18 requalification program to be in compliance with the new 19 55.59 requirements?"
20 The rule supersedes the requirements of and should 21 include the requirements of the Harold Denton letter of 22 March 28, 1980.
'23 If there are commitments in your program that go 24 above and beyond those identified within the March 28, 25 1980, letter, then you will have to, either under 50.59 annntac noonr+4ne garvice. r+ a .
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1 evaluation, or if they are, in fact, referenced in your 2 technical specifications, then you would have to i 3 entertain an' amendment to your tech specs to bring your 4 program -- if you desire,.to reduce it to that minimum 5 level specified within the rule.
6 Otherwise, we expect you to have a program that is 7 modified and in compliance with rule by May 25, 1987. ;
I 8 Yes. !
9 MR. AMUNDSOM: Ted Amundson, Prairie Island 10 again.
11 I think specifically 50.59 now has added fuel 12 manipulations to the required to be done annually. They l 13 are on the job setting or on the simulator more than 14 what's in the Harold Denton letter.
15 The specific problem we have is we're going to have 16 some renewals coming up, say, the summer of 1987, and 17 the training program has been ongoing for the last year 18 or two years -- well, for the last year.
19 There may be some manipulations that, in fact, have 20 not been accomplished on the simulator on an annual 21 basis . .
say, July of 1987 that the 50.59 now says 22 should have been done on an annual basis.
23 MR. RUSSELL: A year from the effective date 24 of the rule.
25 MR. AMUNDSON: A year from the effective date ,
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2 MR. HEIL: Yes.
'3 MR. RUSSELL: The same as- the operating , test.
l '
4 The new requirement -- the requirement exists, but 5 -it doesn't have to be completed for everybody until the
? 6 first year has expired.with the new requirement in I.
7 -place.
8 MR. AMUNDSON: All right. Thank you.
L 9 MR. HEIL: Question No.16: "Are licensees who 10 are maintaining an inactive license required ~to 11 participate in a requalification program to the same 12 extent as licensees who are maintaining an active 13 license?"
14 Yes. A condition of their license under the new 15 Part 55, 55.53 (h), requires participation in the 16 requalification program.
17 Question No. 7: "Have the experience requirements 18 to sit for an RO or SRO exam stated in Reg Guide 1.8 and 19 NUREG 1021 changed?"
20 Yes, just the change that will be effective with 21- regard -- well, ES-109 will be changed under the 22 revision to 1021 and under the Reg Guide 1.8, which 23 becomes effective one year following the May 26, 1987, 24 date. Those are the revisions. .
25 "How does having an INPO-accredited training Manntag Report {ng Aarvice. Y,t d _ ,
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121 1 program affect.these requirements?"
2 I think we've addressed'that satisfactorily here 3 today.
4 The last set of' questions we have, as far as 5 previously-submitted questions,'are from KMC, 6 Incorporated.
7 T have a note here that since part of the questions 8 have.already been answered sufficiently.today, we're
- 9. going to look at question numbers.as specified.
10 Let me find those and we'll go through them.
11' The first question is their Question No. 7.- Let's 12 see. "What, if any, utility actions will the NRC 13 require to actieve the. incorporation of utility learning 14 objectives into the NRC testing objectives?"
15 MR. HANNON: It's been previously indicated 16 that we're not going to require any actions.
17 What we're doing is, in the 90-day letters that go 18 out prior to the' administration of an exam, we're 19 requesting the learning objectives be submitted, and 20 we're evaluating them, and if they are appropriate for
' 21 use in our exam, both the written and the operating 22 test, we would employ them to the extent that they are 23- consistent with our sampling plan in the examiner's 24 handbook and the KA catalogues.
. - 25 MS. SHANKMAN: I just want to say a quick word ennneng n pnreing marv4c . v.& a _
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1 about the learning objectives.
2 I'm sure you are aware that we've been training j 3 examiners to look at learning objectives and to.use them, 4 for testing obj ectives, i
'5 To the extent that you can provide material to the 6 examiner where the learning objectives provide a j 1
'7 standard of performance and you key the training )
.I 8 materials in which the material to develop that question. 1 9 is available, and if you know a KA in the catalogue with. )
i 10 an importance rating that's above 2.5, you will have !
- 11 provided the basis for developing a good question and a l 12 good examination. I 13 It's been our experience in many cases where the 14 learning objectives, depending, may have conditions and 15 may have standards of performance, but the supporting 16 training materials are not there to. develop the 17 appropriate questions or they're cast in such a way it's 18 unclear whether they are an important KA or a lesser 19 important KA.
20 We also did not want to see the, quote, " enabling 21 objectives," because, obviously, that's for training 22 purposes and isn't grounded in job performance.
23 It may be certainly appropriate for the training
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24 program, but we want those objectives that are, quote,
. 25 " terminal," and have to do with job performance; and the l i
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123 1 better the material is that you supply, the closer our 2 exam will mirror those objectives.
3 We've spent a great deal of time looking at how one 4 judges a question based on the learning objective.
5 So that the question should elicit the kind of 6 performance or knowledge or response that lets us infer 7 that the person has mastered that particular aspect of 8 the job.
i' 9 (Indicating.)
10 MR. RUSSELL: There's a related point that I'd 11 like to discuss, also. .
)
12 We issued Generic Letter 87-01, which announced the 13 availability of the NRC examination bank, and we 14 indicated in there the mechanisms that could be used for 15 utilities to either request the information on what's 16 contained in the bank on their particular facility or on 17 other similar facilities, and a mechanism for you to 18 provide input to us to update questions on the bank, 19 either in the cases where we have inaccurate references 20 or the design of the facility has changed, et cetera.
I 21 You should also be aware that we purged the bank of I 22 questions that were more than two years old.
23 I felt that some of the older questions did not 24 meet the standards that we are imposing today upon the 25 quality of questions on an examination, and so in some l
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1 l I 1 cases, we have only four or five examinations on the ]
2 bank for a particular utility.
3 We are interested in improving that and are {
i 4 interested in your providing comments to us and/or ]
5 questions that could be loaded into the bank, and we'll 6 also provide the bank to you so you can use it in .
1 7 constructing your own questions.
8 Now, this is a part of the activity associated with 9 improving MRC exams; that is, the KA catalogue being-10 used to identify subject area for sampling with the 11 handbook, going into the exam bank and using questions 12 from that area that match those catalogue numbers which 13 are tied to the INPO job task analysis data base, and, 14 other aspects of improving examination quality.
15 So I highlight that to you, and I would encourage 16 you to take advantage of it.
17 It is voluntary. You need not do that; and to the 18 extent you provide us information that's in a format 19 which is compatible with loading into the bank, we can 20 do that directly, either through hard copy or 21 electronically.
22 But for security reasons, why don't give you access 23 to the bank directly.
24 f4R. HEIL: The next question identified, 25 Question 9, I think we just answered.
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125 1 It referred to, "Will SRO licensed individuals that 2 are normally a.part of an RO,'s shift operating crew be 3 allowed to retain active status as RO/SRO while they 4 hold an SRO license?"
I 5 I think we answered that, that if your watch I i
6 stander is an RO, your active is an RO; if your watch 7 stander is an SRO, your active is an SRO.
8 . Question No. 10: "Is the following interpretation 9 correct: Utilities believe that SRO's who are current-1 10 in the requalification program and hold valid but not -l 11 active licenses may perform SRO administrative duties 12 such as approved procedure changes, plant design 13 changes, classroem simulator instruction, even though 14 these individuals are not considered part of the 15 operating crew?"
16 The answer to that is yes, but thef cannot perform 17 the duties of an SRO, i.e., in directing or manipulating 18 the plant.
19 In order to perform those duties, he will have to 20 upgrade his license through the identified mechanism.
21 The next question is a simulator question, Question 22 No. -- two of them -- Question =No. 14 and 15.
23 You've got those there, Jerry?
24 MR. WACHTEL: Yes.
25 14 asks: "Will the guidance document," which is Ronntag R9 porting Service. Ltd.
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1 referring to the SF2P, "be limited to auditing the 2 proceedings of AMS ANSI 3.5, 19857"
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3 The answer to that is no. It will be limited to 4 auditing certification against the requirements of Part 5 55.45 (a) and ANS 3.5 as it is endorsed by Reg Guide 6 1.149.
7 Question 15: "Will the performance testing 8 documentation maintained for NRC review be limited to 9 those items addressed in ANSI ANS 3.5, 1985?"
10 The answer to that is the same as the answer to the 11 previous question.
i 12 MR. HEIL: Let's see. Jerry, I think the next 13 questions are 17 and 18, which are also --
14 MR. WACHTEL: 17 asks: "Has the Staff 15 developed guidance and/6r criteria regarding the use of 16 a certified plant referenced simulator by individuals 17 other than those from the referenced plants?"
18 If I understand the question correctly, it is 19 impossible for one simulation facility to be certified 20 as referenced to more than one plant or more than one 21 unit. To the extent that those plants or units are 22 similar, only the facility licensee may submit a 23 certification to the NRC or may submit an application 24 for approval.
25 Question 18 -- is that next -- yes - "Does this ennnean nannreinn sa rvi ca . T.ea -
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i 1 guidance apply to facility licensees that wish to use 2 another facility licensee's plant referenced simulator?"
3 The answer is yes.
4 Question 19 --
5 MR. RUSSELL: Before we go on to 19, there's 6 one thing I'd like to add on 18, and it relates to 7 configuration control, what I will characterize as a 8 very practical issue.
9 If you have two different plants using one 10 simulator, mechanisms have to be worked ou't between the 11 two facility owners to insure that the simulator itself 12 maintains an adequate configuration with respect to the 13 control rooms and the design of the facility.
14 In some cases, that can simply be handled easily by 15 a data tape to represent the different characteristics 16 of the plant. In other cases, it may. require such 17 things as changing alarm tile window enunciators or 18 other things like that, but'in other instances, it may 19 require some modifications to the simulator itself.
20 It can be done, but it's something that needs to be 21 worked out between those two facility owners as it 22 relates to the simulation facility being used.
23 So there are some practical aspects that need to be 24 considered as it relates to configuration control as 25 that's described in the standard.
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128 1 MR. WACHTEL: The next question, I believe, is 2 No. 19: "If Reg Guide 1.149 and ANSI ANS 3.5, 1985, 3 become the only standard for determining the 4 acceptability of a simulation facility, then the 5 simulation facility must be a full-scope simulators is 6 this correct?"
7 The answer is no. . Reg Guide 1.149, in regulatory 8 position C2 of that document, takes exception to certain 9 segments of,the standard.
10 It says that simulation facilities, as they were 11 defined in Part 50 -- 55.4 of the reg -- remember that 12 they may include the plant and the other simulation 13 devices -- should meet, quote, " applicable requirements 14 of the standard," unquote.
15 Also, remember that a Regulatory Guide is not a 15 regulation. It indicates one acceptable means of 17 meeting the requirements of the Commission's <
18 regulations, and you, as the utility, are free to 19 propose alternative ways of complying with the )
20 regulation other than Reg Guide 1.149, 21 Question 20 is next: "If Reg Guide 1.149 and ANSI l 22 ANS 3.5, 1985, do not represent the only standard for 23 determining the acceptability of a simulation facility, 24 will the NRC identify the minimum standards and criteria 25 that are acceptable to them for non-full scope
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1 simulators?"
2 The answer to that is that those two documents do 3 describe the standards, but as I just stated, it is i
4 possible for a facility licensee to use and suggest an 5 approach that is other than that described in Reg Guide 6 1.149. !
7 MR. HEIL: Okay. The next question is 8 Question 21: "Does the NRC agree that each utility 9 should define their specific set of significant control 1 10 . manipulations in their program descriptions to satisfy 11- the rules stated in 55.31(a) (5) ?"
11 2 Reg Guide 1.8 defines significant control 13 manipulations, gives some examples.
14 Yes, the utility should define a specific set 15 applicable to their facility with the Reg Guide 1.8 as 16 guidance.
17 MR. RUSSELL: Let me answer this. Just a 18 minute, j 1
19 MR. HEIL: Sure. I 20 MR. RUSSELL: One of the things that I've 21 observed through the accreditation process is that 22 there's been a tendency lately-to shift the on-the-job 23 training more to a perform rather than simulate or 24 discuss activity as it relates to what INPO, through the 1
25 accreditation process, is looking for.
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straightforward to identify, out of the OJT call card, 3 those portions which would constitute the control 4 manipulations appropriate and just simply identify those ;
5 in the call card. That would be a vehicle for doing
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6 this. -)
l 7 You could identify all of those in the call card 8 which would meet the standard and- simply identify that ,
9 you need five from List -- whatever that list is or 10 howe.ver you want to identify it.
11 There have been'a few plants that I've looked at 15 those call cards on, and there are many more than five 13 that would qualify if they were performed on the plant 14 in lieu of performing them on the' simulator.
15 That would be a straightforward and relatively 16 simple mechanism for identifying and tying it right into 17 the qualification card process.
18 MR. HEIL: A related question is Question 22:
19 "Will any combination of the above manipulations be 20 acceptable as dictated by the facility's modes of 21 operation during which the applicant is in training?"
22 Here again, I guess I refer you back to Reg Guide 23 1.8 for the definition of significant manipulation. l 24 That will have to be determined on a case-by-case 1 l
25 basis by the facility. I nnnnemg popnreing ma rvi ca. u a. ,
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1 Obviously, some significant manipulations may not s 2 -
be possible in Mode 4 of a plant. It may be possible in
! 3 Mode 5 or 6, whichever you use for refueling for the 4 case of a fuel handling foreman, so it's going to have 5 to be on a case-by-case determination.
6 MS. SHANKMAN: We had a question at the break.
7 Someone asked, "Why did we change from reactivity )
l 8 manipulations to control manipulations?"
{
9 I want to make sure that if you look at the 10 definition in 55.4 of what we mean by controls, we've 11 basically not changed. For the purposes of Part 55, the 12 controls are the::e controls that affect reactivity or {
t 13 power, just in case somebody thinks that we've gone away 14 '
from reactivity.
15 MR. HEIL: The next question: "Will start-up 16 and shutdown experience as requested in 55.31(a)(4) 17 gained on a certified simulator be considered adequate 18 start-up and shutdown experience for operator'and senior 19 operator candidates?"
20 That's yes.
21 24: "Will start-up and shutdown experience as 22 requested in 55.31(a)(4) gained on an approved simulator 23 facility be considered acceptable for start-up and l 24 shutdown experience for the operator and senior operator 25 candidates?" ,
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i 1 Again, yes.
2 Question 25, which deals with requalification 3 control manipulations, "May a utility use a certified 4 simulator for requalification training programs, -
5 on-the-job training control manipulations, or must some 6 control manipulations be performed using the plant 7 controls?"
8 Yes, they can use the certified simulator, 9 although I gaess just a re-edification that the first 10 six -- well --
11 MR. HANNON: Items A through F in 55.49 12 are -- I mean, 55.59 are eligible to be performed either 13 on the plant or with an approved or certified simulator.
14 MR. RUSSELL: If you look at the list, it just i
15 says you can't do casualties on the plant.
16 Items A through G, the top ones, relate to i 17 start-ups and shutdowns and changes of power of more 18 than 10 percent, et cetera, things which you can do on 19 the facility without putting the facility in a dangerous 20 situation.
21 It is your option. You may either do those on the 22 plant or on the simulator.
23 For the remaining items that are required annually 24 or required for the operating test, those must be done 25 on a simulation facility. They may not be done on a nnnnema neonrtino service. r+ a .
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2 So it's your choice on whether you use the plant or 3 not for those first on-the-job evolutions that you 4 perform which are related to start-up and shutdown. {
5 MR. HEIL: Question 26 is the same question, 6 " substituting an approved simulator facility for a l l
7 certified simulator facility," and the answer is the 8 same as was specified.
9 27: "What records will the Commission require to i
10 insure that a licensee has maintained active status per 11 10 CFR 55.51(e) ? What will be the record retention 12 period?"
13 That's up to the facility to determine how he 14 wants to be able to document the active status.
15 I would think that shift turnover logs would be 16 appropriate documentation. The key is that the 17 documentation is retained and available for review.
~
18 Record retention, that's covered, I believe, 19 six-year -- well, during the term of the license, I 20 think is -- 1 21 MR. RUSSELL: There are two answers to this, i
22 Let's say that the record that you are using is the 23 control room log. That has its own record retention 24 requirement, which is essentially for the life of the ;
i 25 plant. j i
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- 1. If you are using the control room log as the basis 2 for whether the guy was signed in the log and in 3 position, that's adequate.
4 The certification for he returning to duties were 5 based upon standing four hours of parallel watch. Being 6 a parallel watch, he's not signed into the control room 7 log or need not be signed into the control room log. l 8 That is a simple certification by the responsible 9 official onsite which would go into your local records 10 onsite and be available for audit.
11 That locally-prepared form for that certification 12 for returning him to watch standing duties would have a 13 record retention requirement . of for that person's 14 license; that is, the six years of that particular 15 license.
16 MR. HANNON: We've received some written 17 questions, and to the extent that we have time 18 permitted, perhaps we could go ahead and deal with them.
19 They are only a few short ones, so I thought I'd 20 deal with them.
21 MR. RUSSELL: Any surprises that I don't know 22 about?
23 (Laughter.)
24 MR. HANNON: Yes. You can correct me if I 25 misspeak.
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135 1; This was from Point Beach, Wisconsin Electric.
2 "Can trainees participating in aspects of'a program, 3 eg., systems' training for instructor. certification 4 purposes, manipulate controls of the facility under the
~5- appropriate supervision of licensed personnel?" .
i 6 The answer is that if the training program that q 7 they are enro'lled in can lead to a license, if carried I i
8' to completion, the trainees may manipulate controls 9 under instruction if they have been properly trained.
10 In other words, the sequence of training-that has led 11 them up to that point is appropriate for the 12 manipulations that they are doing. ,
q 13 I see that generated another question.
14 MR. BRUNO: Ron Bruno from Point' Beach. i 15 The question was really a follow up to what has 16 been said earlier in that if they are in the act of 17 doing all these things, it's okay.
18 If, for example, we would like to have somebody 1
19 teach systems -- okay -- a systems level instructor, not 20 integrated ops, not gradient fractional analysis, not 21 EOP's, but I would like that guy to teach systems to 22 RO's and have him qualify on what it takes to manipulate 23 a switch -- okay -- he may not get all the reactor and 24 he'may not get all the thermodynamics, he may not get 25 all the program, just the systems part of it -- okay l
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136 1 can he go operate even though he's going to manipulate 2 the control under the direction of a licensed operator?
3 MR. RUSSELL: You need to look back at the 4 operations which constitute control which can affect 5 power or reactivity. It is only in those cases, by the 6 definition, that you would need to be enrolled in such a' 7 program. l 8 So, for instance, if you are teaching systems and 9 that system does not affect power or reactivity, balance 10 of plant systems, other than, say, feedwater or
-11 something like that, then you would not need that 12 exemption, or rad waste system, for example.
13 If the systems training that he's involved in is a 14 part of the normal systems training that would lead to a 15 license occurring, and normally there is systems i
16 training that they go through, and has he had the i 17 equivalent training himself leading up to the point i
18 where he would be expected to do the practical factors, 19 where he goes in plant to do the walkdown on the 20 systems, to do the start-up, align the components, l 21 whatever, then that is appropriate to use. It falls L l l 22 within what we intended with the exemption. That is, he 23 may manipulate those controls if he's enrolled in the 24 course associated with the systems training.
25 MR. HANNON: The next question: "Does the NRC nnnneng nepnreing servico r+ a .
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intend to do start-up certifications as a part of the If so, 2 operating test for every new licensed applicant?
3 what is the status of the present start-up 4 certification?" .
\
5 Well, as I indicated this morning when I was 6 talking about the new 157 form, the start-up l
7 certifications are done on an audit basis, and they are 8
left to the chief examiner for the initial applicant to 9 determine which of the candidates would be audited. I 10 So in this regard, there are no changes from our 11 past practice.
12 The next question: "For a person who has dropped 13 his license, what, if anything, must be done to later !
14 upgrade his status to an SRO beyond meeting the 1 15 requirements of an accredited SRO training program?"
16 The answer is he must submit a 398 and a 396 and 17 be examined as an SRO upgrade. However, the Region is 18 in a position to entertain waiver requests, if it's been 19 less than two years, under Part 55.47, 20 Certain portions of the examination may be waivered if the time has not been too long, j 21' The next question: "Must medical records be kept 22 23 at the facility or is retention in corporate medical 24 files allowed?"
25 Susan, I think that the answer is it's up to the ,
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1 facility where you keep the records, but you might want 2 to comment.
3 MS. SHANKMAN: Yes. The requirement is in 4 the rule, they be available for our review upon request, 5 so they have to be available upon request.
6 MR. BRUNO: This morning you just said the 7 facility.
l 8 I just wanted to make sure I didn't have to have 9 the records in my files at my plant.
l 10 MS. SHANKMAN: For you it's different.
11 (Leughter.)
12 MR. HANNON: The next question: "When will 13 the requirements for an applicant to be examined by the 14 NRC prior'to renewal be implemented?"
l 15 I think that's been answered already. The renewal 16 requirements are effective for six-year licensees 17 granted after May 26, 1987. j l
18 The next question: "Who will schedule and track 19 each licensed operator to insure he has had an NRC exam 20 prior to renewal?"
21 The answer has been given already. That's the .q l
22 NRC's responsibility, and it will be tracked in the ]
I 23 Regions, and the Regions will maintain the docket files j j
24 on each individual, and the file will necessarily j 25 contain the last NRC-administered recall exam.
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1 The next question: "What will the Commission do to 2 assure operators' exams are both valid and reliable from j 3 a psychometrics perspective?
4 (Laughter.)
5 MS. SHANKMAN: Well, you may or may not be 6 familiar with the catalogues.
7 We're working on a sampling plan which we developed 8 for the purposes of subject matter experts. The 9 sampling plan we expect to change, and it will better l
10 reflect, we hope, the job of the operator rather than 11 the 25 percent, 25 percent that we now have in the 12 examiner's standard, so that's one thing.
13 We'll be sampling only those items that got a high 14 importance rating, so that will make sure of the content 15 validity, and that's the model we are using.
16 We have a meeting on May 18th to the 22nd in which 17 we're bringing together another panel of experts to look 18 at the sampling plan, and then after that, they are also 19 going to see whether the passing point is appropriate, 20 and then make recommendations to the Commission.
21 We can't change the passing point without the 22 Commission's approval.
23 We're also doing extensive training, and have been 24 on a continuous basis, with our examiners on writing 25 questions. We're also, I think, getting better at Annntag neporting service _. T.e a .
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140 4 L- I I reviewing them.
2 So that both the development of the question itself
- 1 3 and the review will,- I hope, innure a little more 4 consistency. l t
5 The exam question magazine is another. To the )
6 extent that you want to have input, that would help, 7 too.
i 8 Does that answer your question?
9 MR. HANNON: All right. The next question:
10 "To have a program approved by the Commission, must one 11 have a-simulation facility or is an accredited program 12 with the SAT all that is needed?"
13 Well, the regulation requires, effective May 26, ,
t 14 1987, to have a program; that one way of satisfying the 15 requirement is to be accredited based on an SAT.
16 It also requires, though, by May 26, 1991, that the 17 facility have an acceptable simulation facility.
18 So I'm not sure that I-answered that question, but l 19 if I need to clarify it further, I will.
20 MR. BRUNO: That's okay.
21 MR. RUSSELL: There's -- {
22 MR. HANNON: Go ahead.
23 MR. RUSSELL: There's one other issue that I'm 1 l
24 not sure has come up today. It's come up in other 25 regional meetings.
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l 1 That is, who is the responsible official? At what 2 level within the hierarchy does that individual reside?
3 We will accept, and we are modifying the forms to 4 so indicate, that the senior individual onsite 5 responsible for operations is the level of individual 6 that we would accept as the responsible official.
7 It need not go offsite to a corporate office unless 8 that is the choice of the corporate office.
9 So that those cases where you have a station 10 manager who is responsible for operations onsite, it 11 would be appropriate for him to sign. If you want to 12 have it to go offsite to a vice-president level, that's 13 appropriate.
14 We do not require that it be the same official who 15 is responsible under Part 50 as the facility licensee to 16 sign. That is, you may have a senior vice-president who 17 is charged with signing off all requests for amendments 18 to licenses, and is, by Part 50, the responsible 19 official for operation under the f acility license. ,
20 We will not require that everything go through that i
21 individual. You can use the senior man onsite I 22 responsible for operations. i l
23 MR. HEIL: That concludes most of the j l
24 previously-submitted questions.
25 At this time, I would like to open it up to any new l
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l' ' questions from the floor. !
2 MR. LE BLOND: Pete LeBlond, Commonwealth 3 Edison.
4 ' Prior to the issuance of this rule, I think a 5 common situation was that people developed th'eir recall 6 program with two taskmasters: One, the INPO 7 accreditation process, and the other, the relatively 8 non-task based aspects of the Appendix A.
I 9 Now that the utilities have got the flexibility to-10 withdraw or to remove the non-task based aspect of the .I 11 oid programs, but that may take some time, what is the .
12 approved program in the interim? What should be 13 utilized as the approved program in the interim, the old 14 program?
15 MR. RUSSELL: Yes, you must follow the 16 NRC-approvedfprogram, which was based previously on 17 Appendix A to Part 55, until such time as you send to us 18 a letter which certifies that you are _ accredited and 19 that your program has been based upon an SAT approach.
20 I don't believe, however, that that is that big of 21 a task. Hopefully, some of the stuff that we have 22 required in the past 'a'ln into the kinds of things that 23 you are doing in an SAT-hssed program.
24 Whether that set constitutes 80 percent coverage or i
25 70 percent coverage, I'm not sure; but the real issue is Manntag Reporting Me rvi ce. Ltd. ,
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143 1 the flexibility to. design your program based upon 2 program evaluation.and fee,,dback from on-the-job j 3 performance to factor in changes in procedure, changes 4 in design, licensee. events, industry events, and if you
- 5. look at the programs.that have been approved by the NRC, 6 those have been required.
7 What's happened, though, in some cases, because of 8 the prescription to also cover so many hours in 9 classroom, you've had a competition for time available 10 to conduct training, and where.more important items have 11 come up, you've been required to do those with the 12 discretionary time that you have left and not been able 13 to substitute those for some of the less-significant 14 activities that were required by Prescription A.
15 Okay. So I think-that's a major advantage, and' 16 it's one that I would encourage you to look at carefully 17 and to implement as quickly as you can, 18 MR. HEIL: Just to add to that: That you have 19 to follow your approved program, but by May 26th of 20 1987, that approved program has to be brought up to at 21 least meet the requirements under the new rule.
22 MR. RUSSELL: .You can't send me the 23 certification before the 26th of May. You can't 24 implement it prior to that time. That's the effective 25 date of the rule, sonntag neporeing service. r+ a _
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144 1 MR. HEIL: And if you have an Appendix 2 A-approved program in place right now, that program has 3 to meet the requirements of the new rule on May 26, !
4 1987. !
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-5 MR. RUSSELL: And specifically there was an
~
6 earlier question as to whether the Commonwealth Edison 7 topical report on training, which we have reviewed in 8 Washington,_would meet an SAT-based training program.
9 The answer is no. That was designed to meet the j 10 old Appendix A, the Part'55 requirements, and it did not 11 have all the elements of an SAT-based.
12 So yes, there is some work to be done in order to 13 implement that, that relief that we have just diceussed.
14 MR. LE BLOND: Right, I think I know that.
15 (Laughter.)
16- MR. LE BLOND: However, I just heard a little 17 bit of conflicting information up there.
18 Mr. Russell said that the program we follow should 19 be the old Appendix A. Mr. Heil said that it should be .
20 a compendium of both.
21 So is it a compendium of be.h, which was the most )
1 22 restrictive? !
23 MR. HEIL: No, no. If you have an Appendix A 24 program in place, then on May 26th, you can either 3 1
25 submit a certification that you now have SAT programs l l
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145 I which now meet the requirements of the new rule, but if 2 you do that on May 26th, to upgrade to the SAT program, 3 the program you have in place has to comply. No matter 4 what it is, it has to comply with the new rule on May 5 26, 1987.
6 If you do not intend to upgrade to an SAT program, 7 you can continue to follow the format'of your old 8 program,-but that old program has to meet the 9 requirements of the"new rule on May 26, 1987. I.e., at 10 that point in' time, if your old program did not. include 11 annual operating examinations,' then one year from that 12 date, you will have to have completed annual operating 13 examinations. I.e., you have implemented the new rule.
14 MR. RUSSELL: When I commented that the two 15 are essentially the same, they are as it relates to the 16 classroom training, on-the-job training, with some very 17 minor changes in the annual activities to be performed.
18 It is not a significant change in those two areas.
19 The changes that are significant are the area of 20 annual operating tests, which had not been required 21 before, and I think that -- I just assumed people 22 recognized that, but you must conform with the NUREGS or >
23 your approved program, whichever is more restrictive, 24 starting on the 26th of May.
25 MR. LE BLOND: Okay. Thanks.
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I 1 MR..AMUNDSON: Ted'Amundson, Northern States 2 Power.
l 3 'My' question is related to performance'on the-4 simulator. Mr. Wachtel indicated that when we' submit !
o 5 the form, we should have 100 percent of the performance 6 tests completed.
7 My question is: Performance ' tests that were i 8 performed ~ as part of an acceptable test procedure, say, -
9 three years ago, can we count that towards having i
10- performed that part of the performance test one time or '
11 do we have to redo it again before we submit the form?
. 1 12 Specifically malfunctions, I think, is probably the 13 most common area.
14- MR. WACHTEL:- I don't think there's any need l
15 to redo those performance tests.
16 The concern, if any, is the delta in time from when 17 they were done and changes to the plant configuration 18 that would be required by the ANSI standard to be 19 brought up to the simulator, so if there have been no I l
20- changes that would require you to reconduct some of i 21 those performance tests to be in compliance with the j 22 standard, then those tests should be acceptable.
23 MR. AMUNDSON: So if we conducted an 24 acceptable test program, testing all the malfunctions, 25 and since then have had a program in place to test all 1
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4 147 1 of the modifications to the software, including .
2 malfunctions, if appropriate, that we might be -- we've 3 got-a basis for starting, anyway?
4 MR.'WACHTEL: Yes, I would say so.
5 MR. RUSSELL: We intentionally did not. specify 6 a time frame prior to certification by which time you 7 had to-have them all completed.
8 It's not significantly different from the way it 9 exists for a power reactor licensee as to when he does '
10 testing prior to getting a license and when the 11 requirements for periodic testing under his tech specs 12 go into place.
13 But the situation you have is that once you do 14 certify, then you start performing those same 15 performance tests over again on a 25 percent per year 16 basis over.the 4 years to assure that changes to. l i
17 configuration are, indeed, incorporated in the l 18 simulator, but the rule itself is silent on how long 19 before. l 1
20 You just have to assure yourself that, one, the 1 21 testing has been done adequately to meet the standard.
22 There were some changes in the standard between the 23 earlier version and the 1.8 1985 version. You have to 24 show that you have met the 1985 version, and that any 25 design changes or software changes that 9ou have made manntag neporting service, r+ a .
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1 since then have not impacted the validity of those 2 earlier tests.
3 It'may be easier to repeat them than to'go through ,
4 that entire' process, but that's up to you. >
5 MR. AMUNDSON: Thank you.
6 MR. BRUNO: Ron Bruno, Point Beach.
7 The question related to the three month -- or the I 8 , active participation, actively maintaining a license, 9 you said earlier that a guy could stand his 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in 10 January and then again in June or something, and meet it 11 by a calendar -- by calendar quarter; is that correct?
12 MS. SHANKMAN: You have to do the required 13 number of shif ts, whether it's 5 12's or 7 8's, each 14 calendar quarter.
15 Since a calendar quarter runs January to March, 16 April to June, then, of course, you could do them in 17 January and then not do them until June.
18 The reason I brought that up is in the current 19 rule, we mentioned four months as the outside amount of 20 time, and this, really, is six months.
21 MR. BRUNO: Okay. Well, I really want to --
22 let me just rephrase it to make sure I understand this, i 23 If a man gets sick, let's say, in the middle of 24 February, who has been actively on watch in January and 25 February and has got this requirement met -- is sick for
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1 three months, before he goes back on the watch, he 2 doesn't have to stand a 40-hour watch?
3 MS. SHANKMAN: Right.
4 MR. BRUNO: You don't have to demonstrate in 5- the prior 3 months he has served 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />; it's by 6 calendar quarter?
-7 MS. SH ANKM AN: Right.
8 MR. BRUNO: Thank you.
9 MR. HEIL: But during the remainder of that 10 quarter lef t over, he's going to have to complete his 1 1
11 time.
- 12 MR. BRUNO: Yes.
13 MR. SNOW: Art Snow, Commonwealth Edison.
14 Susan Shankman, earlier in the presentation.this 15 morning, talking about the 398, said that all phases of 16 the facility license training program had to be l 17 completed prior to submittal of the license application.
18 MS. SHANKMAN: That's correct. j 19 MR. SNON: Which is what we do not do now.
20 MS. SHANKMAN: That's correct.
21 MR. SNOW: So what you are telling me: I ;
i 22 can't even send the application in until the last day of 23 that license training program.
24 The fellow will sit there for one to two months 25 waiting for his exams.
1 I
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1 MR. HAMNON: Maybe not.
2 MR. SNOWS Is this really what you mean? ,
l 3 MR. RUSSELL: It is correct that we will not 4 accept promissory notes about something to be done in 5 the future.
6 The Commission, in the regulation, is very specific' 7 that the applicant has completed the fa'cility training 8 program; and the clause that we used to have in there, 9 "has completed or will complete at the time he is 10 examined," has been changed to conform to the 11 regulation.
12 We have had some experiences in the past where 13 commitments that were made to be completed in the future 14 were not completed, and they have resulted in some 15 significant enforcement actions associated with the 16 failure to complete training programs, even after 17 examining, let alone whether they would be complete at ,
l 18 the time of examining. !
19 MR. SNOW: You have just canceled my exam for 20 the next exam, if that is truly the case.
21 MR. RUSSELL: The case is that your program, 22 at ths time it's signed by the responsible official, 23 that that program is complete.
I 24 If you, at that point in time, want to have j 25 preparatory refresher review, whatever you want to call l
1 l
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151-1 it, between then and the time the person takes the
'2 examination, that's up to your but at the point you 3 certify him, all the requirements of your program by way 4 of OJT, classroom training, examining,yet cetera,'she.11 5- be complete.
~
^
15 MR. SNOW: I just have one other small 7_ question.
8 You talked about your ability to come out.and do 9 the random testing.
10 Will we get any notification, like two weeks, a 11 week, before you come out?
l 12 MR. RUSSELL: You will know at least 90 days 13 in advance before us showing up onsite.
14 In fact,Las a practical matter, the Region 15 H generallyLdiscusses the examining schedule with you well i
16 Ein advance of that. They try and lay out their i 17 schedules in the future. i l
18 MR. SNOW: I guess I misstated my question.
i 19 I guess I wanted to know who, 20 MR. RUSSELL: You will know who two weeks 21 prior.
22 MR. HEIL: That's typically been, although the 23 Commission would like to have us show up onsite and 24 point out who's going to take the exam, j 25 We understand some restraints as far as scheduling, I
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1 and in the past practice, it's been given about 10 j i
2 working days of'a notice regarding the individuals to be 3 examined, and we expect that to continue, 4 Yes. ,
5 MR. PERSSON: Chris Persson from Perry.
6 My question concerns simulators.
7 I'm a little unclear as to how much we have to put 8 into the simulator with regard to back panels.
9 The very simulator we have, what's called a main 10 horseshoe, we have up to 50 to 60 back panels in the 11 simulator which are used during surveillance testing, '
12 and recently there have been a lot of bypass switches 13 that we use during our emergency plan training, EOP's.
14 Must we have all those back panels in our simulator i 15 or can we substitute the plant for that part of the 16 training?
17 MR. RUSSELL: You asked him to raise that 18 question.
19 MR. PERSSON: It's a very big main control l
20 room, I guess about twice the size of this room, and we 21 put all our back panels in there instead of outside the I 22 main control room, f I
23 MR. RUSSELL: Our intent is not to model the l l
24 entire plant, but the issue you raise -- I'm not sure j 25 whether the particular evolutions that you are calling annneng nepnreing service, r+a.
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1 for are a part of the plant procedures, they are in use 2 in that control room, or whether these are things that !
3 can be done to respond to area contingencies in using 4 the full capability of the plant, for example, in an 5 emergency.
6 If it's part of your operating procedures for the 7 facility and your emergency procedures for the facility, 8 and it's an evolution which is conducted from within the l 9 control room by the regulation, we would expect that to 10 be modeled or you would have to show us how that could 11 be done without that and identify that as an exception.
12 But for facilities that have a large number of back 13 panels or other equipment available in the control room, 14 it's not the intent that you mock up all those panels.
15 Generally, they are merged in the main control boards.
16 Those where you control electrical line-up, calance r 17 the plant, reactor controls and the electrical plant 18 line-up are the typical ones that we're looking for. ,
19 MR. PERSSON: Would it be safe to assume that 20 you might have in mind what we call our surveil 2ance 21 area, the area that the operating shift typically does 22 not leave during normal operation of the facility?
23 MR. RUSSELL: It's those portions of the 24 facility where the individual is defined as being at the 25 controls, which is described in Reg Guide 1.14. It's l Annneng neporting servica_. r+ a .
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154 1 typically'that area.
~2 .Some people mark it off with a red line on the 3- floor or wi,th a fence or whatever. I 4 .It's that portion of the controls where the.
5 individual is at the controls as defined in the 6 regulation that we're interested in simulating.
7 MR. PERSSON: Thank you.
8 MR. SHELLIN: Steven Shellin, Wisconsin
'9 Electric.
10 As a follow on to that, is there any intent to 11 include remote shutdown panels in any of the simulation 12 facility requirements?
1 13 MR. RUSSELL: No.
14 MR. POHLOD: Craig Pohlod, P-O-H-L-O-D, 15 University of Illinois.
16 I sort of saved my questions to last, because they 17 don't really apply in what most of the previous 18 questions have been, but I wanted to get -- I wanted to 19 clarify something here.
20 We don't have to have an accredited program, but we 21 have to provide to you a letter indicating that we've 22 done a 50.59 review of our existing program or modify l 23 our existing program so that it conforms to the new Part 24 55; is that correct?
25 MS. SHANKMAN: You are a testing and research AnnnFag Reporting Rervice. Ltd_ ,,
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f 155 1 facility?
2 MR. POHLOD: Yes.
3 MR. RUSSELL:- I don't believe there is, in 4 fact, any change to the substance of your program other
~
5 than the requirement to perform the annual operating 1
L 6 test in an at least a once each two year written 7 examination.
8 So that it's only in the evaluation of the 9 candidate where there's been a change for your program, 10 so a change to conform to the regulation, where the 11 . regulation is more restrictive, is automatic. Okay?
L 12 MR. POHLOD: Okay.
13 MR. RUSSELL: And so I don't believe that you 14 need to submit anything.
15 If you do, it would be done in accordance with j 16 50.59, and the reason would be to conform to the 17 regulation.
. 18 You could make that change and simply note that, at 19 the next time you submit your.FSAR update or the next 20 time you submit information on the docket --
21 MR. POHLOD: Okay.
22 MS. SHANKMAN: -- you have an approved 23 program.
24 MR. POHLOD: Yes.
25 MS. SHANKMAN: You have an approved recall?
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156 1 MR. P0HLOD: Yes.
2 MS. SHANKMAN: All right. Then you don't have 3 to do anything else because there's nothing specific 4 spelled out in the regulation. It just says you have to 5 have an NRC-approved program, and you have that.
6 MR. POHLOD: Okay. The other question I had 7 is in regard to 55.13, general exemptions.
8 I'd like to give you a couple situations and see if 9 you are interpreting these things the same way I am.
10 First of all, in Item 1 there, I assume that you 11 are using research -- I'm sorry -- you are using 12 training and education interchangeably?
13 MR. RUSSELL: You mean for the student versus l 14 the trainee?
15 MR. P0Hl.0D : Yes.
16 MR. RUSSELL: We're not using them 17 interchangeably, but the student is intended to be a 18 student that's in the test or research facility as a 19 part of a training program where he is studying a course 20 or is involved in manipulating the controls as a part of 21 that course of instruction.
22 MR. POHLOD: Okay. What about someone that i 1
23 is in a course that is coming from a visiting j l
24 institution: Is that the same application? j i
25 MR. RUSSELL: He's a student.
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157 1 MR. ~ POHLOD: Okay.
2 ,
MR. RUSSELL: He's enrolled in that course.
3 MR. POHLOD: All right. Suppose I have a 4 group of high school students that are visiting the 5 university for a couple weeks to familiarize themselves. !
1 6 with the university, and I sit that person down at'the- J l
7 . control panel and tell them what steps to go through to
{
8 operate the panel.
-9 MS. SHANK: TAN: Are they students of the-10 university?
11 MR. POHLOD: No, they are not.
12 MS. SHANKMAN: Well, it says individual 13- training as a student, and you are not training them, 14 are you? l 1
15 MR. POHLOD: Right. l I
16 So, in other words, even though effectively they -
17 have the same background as far as familiarity with the o l
18 facility, that's not an acceptable practice?
19 ,
MR. RUSSELL: There are colleges and -l 20 universities that have exchange programs with high 21 schools and other institutions where you bring students
.22 in for a period of time, whether it's a one-week summer 23 course or it's something which is set up that's taught 24 as a part of the curriculum at the university.
25 What you are saying is these students are brought I
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1 in for'two weeks and they attend some part of classroom 2 training, and as a part of that activity, they do ,
3 manipulate the controls. Then that's part of their 4 course of instruction, i
5 They are a student. They are not a. student in the 1
6 context of being enrolled and paying tuition at the 7 university, but they may be paying fees or not for that 8 particular summer course or that two-week course of 9 instruction, or it could even be shorter.
10 The situation we don't want is we don't want an 11 individual coming in off the street that has not been i
,'- 12 previously trained, understand what's going on, and then L i
13 start' manipulating the controls of facilities.
1 14 MR. POHLOD: Okay.
)
15 MR. LE BLOND: Pete LeBlond, Commonwealth 16 Edison.
17 I'd like to expand a little bit on the -- perhaps J 18 the microphone --
19 (Laughter.)
20 MR. LE BLOND: -- on the issue that Mr. Snow 21 just uncovered a few moments ago. 1 22 First, perhaps a question that will resolve the 23 issue.
24 In reviewing the Part 5 -- the new Part 55, I 25 didn't uncover any explicit time requirement for l l
I i
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159 1 submitting the application.
2 Previously, I think it was 30 or 60 days, something 3 like that.
4 I didn't note it in the existing -- in the new Part 5 55. I i
6 Is that a correct reading of the rule or did I miss' 7 it?
8 MR. RUS3 ELL: It's not in the rule, but it 9 will be in the examiner standards.
~
10 We hope to get to the point -- and if you are 11 accredited and if you have an approved simulation ,
[ 12 facility, where all it requires is the certification, 13 "He's a graduate," and there is no prior review of the l
14 application to determine eligibility, then the time '
15 frame between submittal of the application and the ,
16 conduct of the exam could be very'short. l I
17 In the case where the application is submitted and
]
18 the Region needs to review it, they are obviously going 19 to have to have time to review it to determine whether 20 the candidate is eligible, and have an opportunity to 21 interact back and forth with the training department to 22 supplement that application, potentially, in some cases. !
23 In those instances, we're still going to want to l 24 see it on the order of 30 to 60 days prior to the >
25 examination.
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, 160 1 MR.'LE-BLOND: So if a facilit'y has.an 2 accredited initial program that's SAT based and h.as a
- 3. plant referenced simulator acceptable to the Staff, then !
4 the time-frame between application of the submittal.--
5' submittal of the application, rather, and the exam can 6 be of the order of a couple weeks? '
7 MR. HEIL: Well, we're going to need to know I 8 well in advance of that how many candidates there are 9 for licenses, obviously; but with regard to the review 10 for. eligibility.and experience requirements'that we are i
11 required to perform, that review is significantly 12 reduced in magnitude if, in fact, all we have to do is 13 look at two blocks on the form.
14 In the past, there has been a requirement to submit 15 those, and an understanding that we had to have both the 16 medical and the application, the 398 and 396, both 17 processed prior to the administration of the 18 examination.
19 Under the new rule, with the certification by the 20 facility on the 396 form, that, too, we expect, unless 21 there is a need, based on a medical condition, to 22 perform an independent evaluation of that information --
23 then I would expect that the time frame for review of j 24 that process would be reduced significantly.
25 We will have to work out the problem that exists annn&ng n.nnreing c rv4c . r.t a .
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1 there and come to some solution.
2 You know, that's something that will have to be
'3 done on ar. individual basis.
4 MR. RUSSELL: But overall, the intent and 5 everything we've done with this rule making is to make 6 the application process easier and to give the facility i 7 of that and to put the burden of the determination of 8 completion and eligibility on the facility, rather than 9 on the staff, and accept that certif.ication.
10 The issue that is significant is one of managing 11 our own resources and knowing how many candidates are 12 going to be put up and how many examiners we have to 13 arrange for, and because that's a very 14 resource-intensive effort, we have to know, at about the 15 time of the 90-day letter, how many candidates are you 16 going to have for an exam on this date?
]
17 We don't need to know the specifics of who they are 18 and lay it out for the scheduling of the exam week at 19 that point in time, and the hope would be to get to the 20' point where that could be done, for the case where he.
21 has completed an accredited training program and have a 22 certified simulator and the guy has no exceptions from 23 3.4, sign the forms, he's not been convicted of a j l
24 felony, check him off and send in the two forms, and he 25 should be ready to sit for the exam, and the time window l
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4 162 1 for that being done~and completed could be very short, L
2 on.the order of two weeks.
l' L 3 MR. LE BLOND: In the interim, until the l
E 4 facilities get.--
5 MR. HEIL: -There are going to be-6 implementation problems associated with implementing .
r l l
7 this new rule, and we will have to work out those H
}
8 . problems on a case-by-case basis.
9 MR. LE BLOND: So you don't want to hear the I l 10 question ~. j 11 MR.~ HEIL: Get with me later, Pete. I 1
12 (Laughter.)
13 MR. RUSSELL: But be aware, the requirement in l i
14 the _egulation is that the program be complete at the 15: time you submit the application, and I realize that may 16 cause some dead time or delays in the near term, but we 17 are not going to accept commitments that something will 18 be done in the future.
19 If an officer signs, under penalty of perjury, that 20 it is complete, I'm sure he wants to know that it is, 21 indeed, complete at the time he signs it.
22 MR. LE BLOND: If I can just get you to j 23- respond to one quick question in deference to Bill here. 1 24 I, in reading that rule -- well, past practice has 25 been to use future dates openly on those applications. ;
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+163 1 In my reading of the rule, I didn't detect any 2 intent, either in the rule or in the statement of the 3 consideration, to-alter that practice from the 4 pre-existing rule.
5 Is that contained in either of those two documents?
6 MR. HANNON: Let me cite the particular part.
7 55.31(a) (4) says, " Provide evidence that the applicant 8 has successfully completed the facility licensee's 9 requirements."
10 MR. LE BLOND: The old Part 55 had past 11 tense, also, though.
12 MR. RUSSELL: I understand that.
13 But we have also had claims on the form and we have i
14 also had experience under the practice that we used 1 15 before that that did not work very well.
16 MR. HEIL: Okay?
17 MR. LE BLOND: Okay.
18 MR. RUSSELL: We had 'a rather significant
)
19 ~ issue of that type associated with the enforcement 1 20 action taken on Grand Gulf with the training records.
21 MR. HEIL: Okay.
22 MR. SCHUdTER: Larry Schuster, Consumers Power ,
23 Company.
24 Despite the large number of comments and questions, 25 clarifications, on the whole new rule making, I guess Sonntag Reporting Service. Ltd.
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164 1 the point that I see in the entire evolution of the INPO 2 accreditation process and the trust the NRC is showing 3 in the industry in this rule making -- I view that as 4' definitely a positive trend as the utilities mature and 5 as the NRC matures.
6 This question is directed at Mr. Russell.
7 Does he have any other ideas in other areas other 8 than training where this could perhaps bear fruit?
9 (La ughte r . )
10 MR. RUSSELL: Yes, I have a few other 11 responsibilities.
12 One is in the maintenance area. I have the 13 responsibility for the maintenance and surveillance 14 program and evaluation of the industry initiative in the 15 maintenance area.
16 Quality assurance is another area that's been added 17 to the division's responsibilities.
18 In the changing of the name of the division from 19 Human Factors Technology to Licensee Performance and 20 Quality Evaluation, it's broadly involved in licensee 21 performance; that is, both industry as a whole, through 22 INPO or industry initiative through NUMARC, as well as 23 individual utility performance and/or individual 24 operator performance through the licensed operator 25 program, nnnneng napnreing nervico r+ a .
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l
. i 1 So, yes, I spend quite a bit of time dealing with 2 various working groups on NUMARC issues and training, 3 qualifications. We're working on emergency procedures, 4 a number of areas. ;
5 I personally believe this is the direction the NRC 6 and the industry ought to be going, and that we ought to 7 be able to take the risk that some mistakes are going to 8 be made in order to move in the direction of fostering ;
l 9 trust-between the two groups, and the commission, 10 through this rule making, has said, "We will separate ;
11 training from examining issues and licensing and we are 12 giving the responsibility for that to industry."
13 MR. HEIL: Yes.
14 MR. TILL: Ernest Till, T-I-L-L, Illinois 15 Power.
16 I'd like to revisit this business of submitting an 17 application for a license in advance of completing all 18 the requirements.
19 We do have one situation where you say you can 20 administer the written exam and operating test but not .
i 21 issue a license until required evidence of, in this 22 case, control manipulations is supplied.
23 It would seem a logical extension of this to allow l 24 us to put somebody up who hasn't completed all the 25 requirements, pass him and request, "Do not issue a l
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c i 166 1 license until he's subsequently certified."
2 Does that make sense or is that completely 3 prohibited?' l 4 MR. RUSSELL: The reason for the exception in 1
5 .the control manipulations is only where the individual !
6 has not had an opportunity to perform the contro1 7 manipulations because the facility has been shut down.
8 It is a condition beyond that candidate's control, and 9 it's an extended shutdown on the order of the same 10 length as-the training program, and most of these 11 training programs are on the order of six months.
- 12 That was explicitly identified in the regulation, 13 and the regulation is the applicant has completed the 14 program, certification f rom the responsible of ficer is 15 that it's complete, and issues that relate to whether it 16 is not complete or something to be done in the future, 17 based upon past experience, we have stopped doing that.
18 We hope that in the long term, when the time frame 19 between the two is shorter, that it will not have an 20 impact on a candidate waiting for a substantial period 21 of time before taking the exam; but we are moving into 22 the role of accepting that certification and we don't 23 want that certification to be with any conditions.
24 MR. TILL: I hear what you are saying.
25 The situation that I have is I've gone forward and annneng n pnreing marvice, r+ a .
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1 requested an exam date based on completion-of a training 2 . program. Because of schedule problems, the Region could 3 not accommodate those dates. They proposed. earlier 4 dates. I'm now caught between a rock and a hard place.
5 I think, from what you are telling me, I have to go 6 back to them and say, "No, I can't take the earlier Schedule me later."
I 7 dates.
8 MR. RUSSELL: Issues like that will have to be 9 worked out on a case-by-case basis with the Region; 10 that's correct.
11 MR. HEIL: A question.
12 MR. JESSOP: Bill Jessop, Union Electric.
l 13 My question has to deal with the use of the term, 14 " Continuous for requalification programs." J 15 Does the program -- will the program that breaks 16 for, say, a two month refueling outage be considered a 17 continuous program?
18 MR. RUSSELL: By " continuous," we mean that 19 it's the same program for operators on shift as well as 20 off shift, and it's the program as you've described it.
21 There may be cases where you want to stop it for a 22 period of time, where you are using segmented training 23 and you want to teach one segment, and in the next 24 segment you, in fact, may have some particular training 25 in the outage that you want to cover prior to the sonntag neporting service, i.ea. ;'
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1 outage.
2 That's the flexibility you have under the systems 3- approach to' training in defining what your needs are and 4 ' the ' sequencing of that training.
5 What we are not interested in seeing is a situation 6 where people who are on shift spend, for instance, one 7 week'out~of five or one week.out of six uninvolved in 8 training, and there's some other schedule or some other 9 program which is different from that program.for people 10 . who are not normal watch standers on shift.- One program 11 for all licensed operators.
12 MR. PERSSON: Chris Persson from Perry.
13 This question concerns the operating exam, the 14 annual one for requalification.
15 Must that be given in one time frame or can that 16 also be broken up into various pieces throughout the i
17 , year?
18 Do you have to -- it's very difficult to get
- 19. everybody done in one year by the training staff, and 20 can we do it piecemeal through the year?
21 MR. RUSSELL: For a candidate, it needs to be 22 done at one time -- okay? -- but if what you are saying 23 is you have 30 people that need to have an operating 24 test, can vou spread out the 30 tests over the period of 12 5 a year, the answer to that is yes.
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'l can you take an individual and give him a walk l 2 through today and some simulator evaluation tomorrow and.
3 .then some six months from now and add those three pieces- i 4 'up? I don't believe that would meet the intent of an 5 annual operating test.
l l 6 MR. PERSSON: Not even if you broke up the 7 in-plant and the simulator between the different weeks 8 in recall, and catch them one cycle a week, get a crew 9 in on the simulator and maybe the next. time they come L
10 up, five weeks from then, get that same crew up on the- i
. 11 plant?
12~ MR. RUSSELL: We would have to look at it, but 13 my initial reaction right now is I don't believe that l
14 that would be acceptable, i 15 MR. PERSSON: .Thank you.
16 MR. RUSSELL: lie have explicitly approved j 17 that, however, for the. written examination, where you i i
18 are using segmented tests on the written examination, i 19 provided you show the sum of the parts equals the whole ]
20 in the comprehensive exam.
?
21 MR. PERSSON: That's my question.
22 We have three in the whole year. I thought maybe 23 that would be acceptable. I 24 MR. SHORT: I have a question regarding the simulation facility evaluation procedures, i 25 sonntaa nenoreino service. r+ d .
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m 170 1 Mr. Wachtel stated earlier that once the submittal.
2' is made-of the Form 474, that the simulation facility is l 3 at that time-certified in accordance with ANS ANSI 3.5.
4 You mentioned that there are three different 5 mechanisms that trigger the process of further 6 evaluation.
7 One would be questions regarding the Form 474 8 submittal, one would be random visits.to the facility to 9 evaluate, and.the third would be the post-examination 10 activities associated with the examination at the facility. j 11 .
12 The one thing that is not clear to me, because we 13 don't have the information in front of us, is whether 14 the procedures for the simulation facility evaluation 15 feedback that are forthcoming by May -- specifically, 16 ES-104 -- are they going to be fairly specific as to the !
17 utandards and criteria and the mechanisms by which the 18 6xaminers will make some sort of post-examination 19 evaluation of that facility that would then trigger the evaluation procedure? j
-20 21 MR. RUSSELL: No. It's intended to be k
22 essentially a simple comment sheet, "During Scenario X, l l
the simulator failed to perform as expected. There was 0 23 24 no flow coast down associated with reactor cooling pumps 25 on a loss of power."
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1 It's that type of iodmenit which we wod1d t. hen f .
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6 It's'not significantly different from what you;are
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20 MR. SHORT:. pE Q %ypically af ter that ;,c type .
i' of 1 21 amount evaluation, there'sgj o{ 1- going ki t tg n bp a 4:u . kt. s 'ni'fi@tn {g q k: t,
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1- understand that there's a significant number of freezes..
2 If, during an overpressure incident, pressures 3 - continues to' rise to 3,500 pounds, these are obviously 4 examples of a problem with the simulator, but there are 4 other-things that are'not quite so clear-cut, that in 5
L 6 one-person's opinion may be a problem and in another 7 person's opinion may tue a . problem, but in the conduct of ~
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8 true performance testing, you have the data available by 9- which to make a simulator and determine whethei it's 10 acceptable or~not, but someone giving the examination is 11 not. l 12 The reason I bring this up is you are seeing a 13 potential of a lot of activity where, perhaps, activity 14 is not warranted, and it could be very difficult to 15 determine if activity is warranted by someone that was 16 not there when the event occurred.
17 MR. RUSSELL: That's why we're getting the 18 feedback from the examiner who was there at the time it 19- occurred.
20 You will also receive a copy of it with the
, . 21 inspection report, and I'm sure it will be the subject Tj 22 of the exit briefing with the chief examiner, at the end 23 of the exam week, as to what occurred.
24 We think there are adequate mechanisms in place to 25 alert the facility as to what the potential concern is, I
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but most importantly, we want to get feedback back on 2
how well ide simulation facility is working during an 3
examination Lased upon an examiner's observation of that- 1 4 facility.
5 So that's the process we put in place and that's
- 6. how we intend to use it.
7 MR. HEIL: And more and more.ue-are requesting 8 facilities, during the conduct of some simulator 9.
examinations, to record data as much as possible so that' 10 information should be available for you to review maybe 11 on a more objective. scale.
12 Any.further questions?
13 (No response.)
14 MR. HEIL: Now, we have addressed the written 15 questions and taken question's from the floor.
16 If you have any further questions we have not 17 answered, drop them in the box on the way out.
'1;8 We appreciate your indulgence and your time and we 19 thank you for coming.
20 MR. SHORT: When did you say you expect the 21 NUREG to be issued?
22 MR. RUSSELL:
We expect to issue this 30 days 23 following the last public meeting, which is next Monday.
(Whereupon, at 4:45 P. M., the meeting was 24 25 concluded.)
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CERTIFICATE OF OFFICIAL REPORTER
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is to certify that the attached proceedings before This UNITED STATES NUCLEAR REGULATORY COMMISSION in the the matter of:
NAME Ol' PROCEEDING: NRR MEETING FINAL RULEMAKING FOR OPERATORS LICENSES DOCKET NO.:
PLACE: ROSEMONT, ILLINOIS THURSDAY, APRIL 16, 1987 DATE:
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
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(TYPED) [ ((YY NANCY HOPP Official Reporter SONNTAG REPORTING SERVICE Reporter's Affiliation l
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