ML20237K946
| ML20237K946 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| FRN-49FR4628, RULE-PR-50, RULE-PR-55 NUDOCS 8708200012 | |
| Download: ML20237K946 (105) | |
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UN11ED STATES
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NUCLEAR REGULATORY COMMISSION 4 IN THE MATTER OF: DOCKET NO:
NRR MEETING FINAL RULEMAKING FOR OPERATOR'S LICENSES
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l LOCATION: DENVER, COLORADO PAGES: 1 - 101 i
I DATE: TUESDAY, APRIL 14, 1987 l
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1 Aa-FEDERAL REPORTERS, INC.
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o 1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3
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11 12 13 Tuesday 14 i April 24, 1987 15 16 17ll 18 19 20 Stouffer Concourse Hotel Ballroom A 21 Denver, Colorado i
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i l SPEAKERS: 3 3 R. A. Cooley 3
4 William Russell ,
5 c. L. Turner 30 Jim vandergrift 42 6
49 7 Bob Pate 53 8 Ron Maiser 54 9 Jim Molden I 79 10 l Jerry Wachtel 92 11 Philip Barely 12 lJoeGasper 93 e 94 13 , Dan Packer l
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3 I EEEEEEEIEEE 2- MR. R. A. COOLEY: This afternoon-we're' going 3 to address the questions that were sent in prior to the t 4 meeting. A lot of these questions I've talked to some of the 5 facilities about and they've essentially gotten the answer to 6 some of those, but we'll discuss them anyway and go over them-7 .so that everybody will be aware of what those questions are,
'8 a in c?.se it was something that you didn't ask, or in case we 9 don't cover i t in one of the . other topics.
10 ,
The first one we're going to discuss is the I
11 ; KMC questions that were sent in in April by Paul Collins,Jand 12 f since it addresses questions from several utilities, we thought a'we'd go through those first.
13 MR. WILLIAM RUSSELL: Before we start, we have 14k b.
15 a mike in the center of the room and if, in the process of 16 l'discussingasubjectarea, there's a question f rom the floor 17 lthat'addressesthat same subject area, if you'd just please come 18 'up to the mike, and if we see someone standing there we'll stop 19 at that point, take the question from that person. If you would 20 ! just indicate what your name is and what part of the. rule or i
21 reg oaide or ANC standard your question refers to, that will 22 help us when we go to put together the report fc11owing the 23 meetings, to make sure that we get the questions and the 24 answerd associated with the right section of the rule on the 25 reg guide for the examiner standards.
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4 1 MR. COOLEY: The first questions we're going to i
take are questions pertaining to the rule, and then we will 2
3 take questions pertaining to the simulator, and then we will 4 take questions pertaining to requal, and the first KMC question 5 has to do with a rule. It's talking about approved training 6 programs, and the question is: "Is it the Commission's 7 intention that these programs will continue to be approved 8 until accredited, and that the use of the simulators referenced 1991?"
9 lthereinwillbeacceptableforuseuntilMaythe26th, 10 I And the answer to that is yes.
I 11 ! The second question has to do with the rule, and 12 Susan will answer this question. "When the new rule becomes 13 effective, will all training programs previously accredited by 14 the National Nuclear Accrediting Board be considered approved in
'accordancr with the final policy statement on training and i
15 16 qualification of nuclear power plant personnel?"
17 l MS. SUSAN SHANKMAN: Just to clarify, they won't i
18 !be approved in accordance with the policy statement, but they l
19 will be approved in accordance with the statement of 20 considerations statement that says that if you have been 21 approved--if you have been accredited by the National Nuclear 2? Accreditation Board, you're considered to have NRC approval.
23 MR. COOLEY: The third question has to do with 24 the rule and it's Question No. 7: "What, if any, utility 25 l actions will the NRC require to achieve the incorporation of the l
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1 . utility's learning objectives into the NRC test objectives?"
2 - They must be good objectives related to the 3- operator's job performance, and closely related to the KSA's 4 or other examiner standards.
5 Any other questions?
6 (No response.)
7 The next question, No. 8, to do with the rule l 8 is: "Is it the intention of the Commission to consider that an i
9 individual who~is engaged full time as an operations supervisor 10 is in an active status as a senior operator?"
! 11 And the answer to that is no. He must be 12 current in either the seven out of eight per quarter, or the 13 five out of twelve per quarter in order to be considered 14 actively involved.
l 15 MR. RUSSELL: Let me expand on that question 16 just a little bit. First, the question's come up as to what 17 constitutes a shift, and a shift is eight hours or twelve hours 18 and it's not the number of hours that adds up to 56 or 60.
19 It's from watch relief to watch relief, in a position required 20 by the technical specifications, and I'll give you an example 21 for a single unit facility where you have two SRO's required 22 by the tech specs in a control room or on shif t, and two RO's. )
1 23 You may have the situation where there are more l
1 24 licensed operators on that shift, 3 RO's, for example. Two of 25 those individuals are in the positions required by the technical
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1 specifications and are responsible for manipulating the 2I controls. They generally sign the watch relief and turnover.
I They are generally the individuals who have the responsibility, j 3
4 either as the reactor, operator or the balance of plan operator, ,
i 5 or some equivalent terminology that you use in your facility. I 6 Those are the positions that must be stood for a shift in order 7 for it to count for proficiency in manipulation of controls. ]
8 Similarly, for directing the activities of a 9 licensed operator, the two senior operators must actually be in I
10 the control room, in a position responsible for directing the 11 activities of the two reactor operators in the positions f 12 required by ,he tech specs. Whether that's the shift supervisor 13 position or shift foreman position, it is the two positions for 14 a single unitLsite that are required by the Commission's rules 15 and the tech specs. It is not tied to the type of license the i 16 l individual holds. That is, if a senior reactor operator is
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j 17 l standing a watch on the boards as a panel operator, he is l
18 . maintaining proficiency as a reactor operator in manipulating ,
l 19 the controls. He is not maintaining proficiency as a senior 20 operator directing the activities of others. The regulation is J
21 very clear; it's in the position which he's maintalving j 22 proficiency.
23 Now, a senior operator that stands in a senior 24 operator position is active for both; that is, he can eitler 25 , direct or manipulate. A senior operator who only stands a panel I
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.' 1 watch is only authorized to manipulate the controls, and prior 1
2 to directing the activities of others, he would stand the 40 3 hours of parallel watch.
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4 MR. COOLEY: You'just answered Question No. 9, 5 also. Question No. 9 says: "Will SRO licensed individuals 6 that are normally a part of the RO shift operating crew be 7 allowed to retain active status as RO's/SRO's while they hold a 8 license, a senior license?"
9 i What Bill just went through--does anybody have l
10- lanyquestionsotherthanthewayheexplainedthat?
11 (No response.)
I 12 l Question No. 10: "Is the following 13 interpretation correct? The utilities believe that SRO's who 14 are current in the requalification program and hold valid, 15 but not active, licenses may perform SRO administrative duties 16 such as approval of procedure changes, plant design changes, 17 classroom and simuletor instructions, and so forth, even though 18 these individuals are not considered part of the operating 19 shift crew."
20 ! The answer to that is yes.
21 The next section--well, let's see if we've got 22 any more rules. I think that's all of them.
23 l (Pause.)
24 I
Back on page 13 is the next one. This has to do 25 with initial applications. "Does the NRC agree that each i
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1 1 utility should define their specific set of significant control 2 manipulations in their program description to satisfy the rule 3 in Paragraph 55.31(a) , the five reactivities, or-five 4 significant control ma,nipulations?"
5 Must be accredited or an NRC-approved program.
6 Reg Guide 1. 8 spells this. out under Item C (1) (h) , if you want 7 to take a look at that reg guide and see if anyone has any 8 questions, or is that clear to everyone?
9 MR. FUSSELL: Let me also expand on this one j 10 because there's a very practical issue here. We have seen 11 many on the job training qualification cards that are coming 12 out of the INPO accreditation process, and there has been an.
13 emphasis, on INPO's part, to have the person perform more in the !
14 job setting by actual performance, particularly during the time ;
15 he's on shift.
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We believe that the number of activities that
'17 have the coding P for perform, are such that uost facilities 18 would not have a problem meeting the five manipulations on the 19 facility. If you also look at the items--I believe it's A 20 through F under the on the job training for requalification 21 under 55. 59 (3) (a) , which is reactor or plant startups, (b) 22 plant shutdown, (c) manual control of steam generators or feed 23 water, boron--boration or dillution during power operation, 24 power changes greater than 10%, and power reductions are the 25 types of things we are talking about with respect to control l
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1 manipulations. For requal, they may be performed on the plant 2 or on the simulator; for initial licensing they must_be done on 3 the facility to which the person is seeking a license.
4 MR. COOLEY: The next question is No. 22.
5 "Will any combination of the cbove manipulations be acceptable, 6 as dictated by the facility's mode of operation during which 7 the applicant is training?"
8 The answer to that is unless something is 9 specifically required by your training program, but the plant 10 should not be in a shutdown mode in order to perform these 11 manipulations.
12 The next question to do with the rule, John 13 Hannon will answer this question. "Will startup and shutdown 14 i experience gained on a certified simulator be considered as 15 { adequate star tup and shutdown experience for operator and i
16 l senior operator candidates?"
MR. JOHN HANNON: I think the answer is yes.
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'.It also applies to the next question, too. The only difference 18
'19 in the next question is we're talking about an approved 20 simulation facility as opposed to a certified simulator, and 21 for the application, basically goes to whatever is in your 22 approved--either NRC approved training program, or your INPO 23 ' accredited program for startup and shutdown experience.
24 MR. COOLEY: The next question is Question No.
25 28--well, I had requal down, but we can cover it now if you want.
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"What records will the Commission require to insure that a l l
~ 2. licensee has maintained active status per 10 CFR 55.51(e)?
3 What would be the record retention period?"
4 Either the shift log or other facility records
- 5. to track shift work on a quarterly basis. These records 6 should be on site and should be audible if somebody wants to 7 come in and take a look at the records.
8 The next question, No. 28: "What guidance 9 will the Commission provide to the facility licensees and the 10 staff that Section II.F(2) is Commission policy?"
11 I'll let John Hannon a nswer that one.
12 MR. HANNON: Basically, the answer on this is l 13 that now that the' rule is effective, it has transcended 14 Commission policy and it is, indeed, a regulation now, so it's 15 no longer policy. 'It is, in fact, a regulation.
16 MR. COOLEY: The next question, the need for a 17 license: "Is it the intention of the Commission to limit the i
18 number of licensees at a facility to a specific position?"
19 No. It's still up to you to make the decision 20 as to whether you should have that person in a licensed position 21 or not, and how many of them you should have.
22 And the last one I'm going to ask Bill Russell 23 I to answer on the medical requirements. "Will the Commission 24 develop a protocol that will insure that detailed medical records l 25 will be f orwarded to the NRC medical experts and not made I
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1 available to lay persons?"
2 MR. EU SSELI. : This is an issue for which I 3 believe industry initiative is appropriate, and it's one that 4 I have discussed with INPO and with the accrediting board.
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l 5 The situation that exists is that we want to 6 have assurance that the medical examination that was completed 7 was done in accordance with the ANC standard. We do not need 8 to see the private medical record from the doctor, which may I
9 include other medical information not related to the standard, 10 or may get into the area of privileged information between the 11 doctor and the patient.
12 What we suggest would be appropriate would be 13 to develop an examination form which would track the standard, i
14 such that the doctor would provide a statement back to the l 15 responsible officer that the examination had been completed 16 and these were the areas evaluated. Such a report of 17 examination would be all that's necessary to go into the 18 individual's file, and that would be available on site.
19 If, in the case of a request for a license l 20 condition based upon some medical disqualifying condition that 21 can be accommodated through medication or therapy or something 22 else, the doctor submits the examination form. He would then 23 provide additional supporting information for the staff medical 24 doctor to review and make a determination as to whether to issue J 25 a conditioned license.
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.2 1 That information will be handled in the same
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manner as we handle information now of a confidential nature, 3l . which relates to the Privacy Act. That information would be 4 submitted to the NRC. It would be exempt from further public 5 disclosure, and it would be the basis for our review. !
6- We don't anticipate developing any new protocols 7 for handling that type of information, but the one suggestion 8 is that we recommend you have some evidence available on site 9 that shows that the medical doctors did, indeed, conduct the 10 examination in accordance with the ANF standard, or you could i 11 simply provide the doctor a copy of the standard and let him 12 write you back on whatever form you use now for that type of 13 examination. It's only a suggestion.
The actual requirement 14 [ is that the examination be conducted in accordance with the i
15 standard.
16 MR. COOLEY: Okay, we'll go back to Question 17- 5 now, which has to do with the simulater, and the next l No.
18 group of questions will have to do with the simulator.
19 Question No. 5: "Will the NRC continue to 20 examine operators on plant referenced simulators following the 21 effective rule date, but prior to the submittal of the simulator 22- certification?"
23 l Yes, we will continue to do that. In other 24 words, no change. If we're giving exams on your simulator now, 25 we will continue to do so. The two plants that we haven't given l
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13 7 _l 1 exams on yet are. South Texas, which have exams coming up in May {
2 'and they will get orals only, but they have exams coming up in !
3' November, and at that time we have already talked about using 4 the simulator for those November exams. The other one is ANO2,
- 5. which we won't use in August, but which we will use the next 6 time around.
7 The next question, No. 6: "Will the NRC 8 examine operators on non-plant referenced simulators for those 9 utilities that have accredited training programs, and use a 10 non-plant referenced simulator from the date that the new rule 11 i becomes effective until simulation facilities approval by the 12 NRC is achieved?"
13 Bob Pate will answer that.
14 MR. BOB PATE: Yeah. Actually, I don't believe l
15 'we have any difference than what we're doing today, and it'll 16 be continued, doing it the way we do business today. For 17 l instance,onSONGS-1,whichhasanon-plant referenced simulator 18 they use, they go to Zion, we don't do our exams at Zion. NRC i
19 performs just a wcik-through and no simulator test.
20 MR. COOLEY: The next question is on 1 21 certification of simulators, and the next few questions are 22 going to be a combination of mine and Jerry's, so the first one 23 is going to be for Jerry to answer.
24 "Is it the intention of the Commission to permit !
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will.a review and approval process be required?"
-MR. ~ JERRY WACHTEL: The answer to that is yes.
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It is NRC's intention to permit the use of a certified 4 simulation facility with exceptions, and as I pointed out this 5 morning, there is a block on Form 474 specifically for that 6- purpose'.
MR. COOLEY: Question No. 12: "Will the
'7 8 gridance document be issued for public comment prior to its 9 final iustrance?"
10 We passed out copies of all those today.
11 Question 13: "Will the staff, at its regional 12 meetings,' inform the participants of the status of the guidance
'13 documents and their projected date of issuance?"
14 Jerry?
15 MR. WACHTEL: Well, the answer to that is the 16 same. You've.got the guidance documents and the projected date 17 of issuance, and of course, we're looking for your comments back 18 by May 26th to John Hannon, who's the Chief of the Operator 19 Licensing Branch.
MR. COOLEY: Question No. 14: "Will the 20 21 guidance document be limited to auditing the provisions of 22 ANSI /ANS 3.5-1985?"
23 Jerry?
24 MR. WACHTEL: The answer to that is no. It will 25 be limited to auditing certification against the requirements of I
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15 1 Section 55.45(a) of the regulation, which delineates the 13 2 components of the operating test, and ANS 3.5-1985, as endorsed 3 by Regulatory Guide 1.149.
4 MR. COOLEY: And Question No. 15 is similar 5 to that question. "Will the performance testing documentation 6 maintained for NRC review be limited to those items addressed in 7 ANSI 3.5?"
8 MR. WACHTEL: And the answer to that is the 9 same. The performance testing documentation will go to 55.45(a) 10 ; of the regulation, ANSI 3.5 malfunction testing and its two 11 ! appendices, and the endorsement by reg guide 1.149.
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12 l MR. RUSSELL: We had a comment that was made i
13 l earlier this morning and I want to make sure that it's i
14 !understoodwithrespect to performance testing and the i
15 j operability test.
16 l The operability test is done annually. We have I
We have incorporated that 17 lnottakenexceptiontothat.
18 { operability test into the reg guide and have endorsed it, i
19 l Perf ormance testing, which is in the first appendix, plus the 20 repeat of the malfunction testing which is described in 21 Section 3 of the standard, that set of testing at approximately l
22 Ia rate of 25% per year over four years, will constitute the i
23 i, additional annual testing done.
24 So you have an annual operability test, and then l
l 25 1 25% of the performance tests that are described in the first i
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16 1 appendix, plus 25% of the malfunctions that are listed. To the 2 extent the operability test itself duplicates a portion of 3 the' performance test, that's sufficient. You don't need to do 4 it twice, but that's the scope of the testing we are. expecting 5 to be done on an annual basis, and it's an annual, Webster 6 ' dictionary-type approach. It's not exactly 25% with the other 7 kinds of things that you've seen in tech specs of, thou shalt
'8 get them all done within the periodicity, plus or minus 25%
9 extended over--common sense approach. We are interested in you
- 10. doing the performance tests over a period of four years, and not 11 putting them all off and doing them in the last year. So it's-12 approximately 25% per calendar year after certification. It's 13 not on a rolling twelve months, that you have to keep track of 14 the number of months between tests. So there's quite a bit of .
I 15 flexibility. It's the intent to insure that the simulation l 16 facility continues to behave in an appropriate manner for 17 conducting an operating test, l
18 MR. WACHTEL: And just one further comment, as i 19 we said this morning, when you submit your certification for the 20 first time, or your application for approval, you should have 21 completed a hundred percent of the operating tests and the 22 performance tests before you submit that--serve it to us the 23 first time. After that, the 25% por year will begin.
MR. COOLEY: The next set of questions has to 24 25 do with use of plant referenced simulators, and I'm going to FEDER AL REPORTING SERVICE INC.
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i 17 1- read the introduction of this--it's not very long--just so 2 that everybody knows what the questions are going to be 3- concerning.
4 "Several utilities are not planning to obtain
~5 plant referenced simulators. They prefer to use a simulation 6 device. A facility licensee has constructed and is operating 7 a plant referneced simulator that meets the provision of Reg 8 Guide 1.149 and ANSI 3.5 and has been certified to the NRC for 9 use for operators, senior operators who operate the reference.
10 plant or are candidates for a license at that plant.
11 I A utility wishes to use the above simulator 12 as'their simulation device rather than construct and operate 13 a plant referenced simulator."
14 Question No. 16, and Jerry will answer this "What procedure must the utility follow to obtain
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16 approval to use the above simulator?"
17 MR. WACHTEL: The answer to that assumes, as ;
18 I stated in the preamble to the question, that the utility who ;
19 wants to use it is treating it as a non-certified, non-plant Basically, it does not matter to us j 20 referenced simulator.
21 who built the simulator, who owns it, where it's located. The 22 facility licensee who wants to use a particular simulator for 23 ' the conduct of operating tests is 'the organization that is 24 required to file a certification or to apply for approval to 25- use it. So in this case, the answer would be that the procedure I"
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that the utility must follow would be to go through the 2i development of a plan within a year, followed by the application 3 for NRC approval to use that simulation facility, whether they are uhe owner of it or,not, f 4
5 MR. COOLEY: Question No. 17, which Jerry will f i
6 also answer, has to do with the same thing. "Has the staff l 7 developed guidance and/or criteria regarding the use of a f 8 certified plant referenced simulator by individuals other than 9 > those from the referenced plant?"
I l The answer to that is, it is j 10 ! MR. WACHTEL:
11 possible for one simulation facility--any particular simulation 12 facility--tc be certified as referenced to more than one plant, 1 13 to the extent that those plants are similar. But again, only 14 the facility licensee who wishes to use a simulation facility 15 for its. referenced plant should submit the certification for use 16 of it. So if one simulation facility is intended by several 17 i different facility licensees to be used for different plants, i
18 }then we would expect to see several different certification 19 forms coming in, one for each of those facility licensees.
MR. COOLEY: Question No. 18: "Does this 20 l l
21 Iguidance apply to facility licensees that wish to use another 22 facility licensee's plant referenced simulator?"
23 MR. WACHTEL: And the answer, as I just said, 24 is yes.
MR. COOLEY: The next set of questions--
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19-1 MR. RUSSELL: Let me expand on that last one 2 for just a minute because I think that there are some very 3 practical issues that utilities are going to have to address 4 i'n the area of configuration control, plant design changes, and 5 getting those' plant design changes referenced back into the 6 simulator.
7 Some of those can be taken care of with 8 software, by having a different data pack, tapes, et cetera.
9 Others are going to be very difficult to take care of where 10 they relate to control board location or systems that you'd have 11 on the device that are different. Clearly, in the case where 12 two utilities want to use the same simulator, they are going 13 to have to work out agreements with each other as to how they 14 are going to maintain configuration control such that that 15 device can be used for the operating test. Clearly, it gets 16 to be more complicated.
17 He have not precluded that, A facility may 18 certify a simulator to his referenced plant, and it may be owned
- 19 by someone elser but the requirements for having an appropriate 20 configuration control system still exist, and you must still 21 follow the ANSI standard. I believe the practical answer is 22 that if you get into that mode, you're going to find it very 23 difficult over the long term, and that we are probably talking, 24 in most cases, about a plant referenced simulator on site, 25 controlled by that utility, and the use for multiple plants is a i
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i case where you have three.like plants on the same site, or two 2 that you wish to use the simulator for.
3 MR. COOLEY: The next part of the questions j 4 have to do with non full-scope simulators, and I'm going to 5 read just a brief introduction to this, just to get cverybody 6 thinking the same way.
7 "It is very important for utilities that are 8 not committed to the acquisition of a plant-referenced mulator.
9 to understand the. position of the Nuclear Regulatory Commission.
10 The NRC regulation appears to present two options to these-11 utilities.
12 option A: Obtain an exemption from the rule; 13 B, develop and implement an NRC-approved simulation facility 14 plan."
15 Question'No. 19, and I'll have Jerry answer {
16 this question: "If Reg Guide 1.149 and ANSI 3.5 become the only 17 standard for determining the acceptability of a simulation 18 facility, the simulation facility must be a full-scope 19 simulator. Is this correct?"
i 20 MR. WACHTEL: The answer is no. Reg Guide l 21 1.149 in regulatory position (c) (2) within that document takes 22 exception to certain segments of ANS 3.5 that relate to 23 full-scope simulators. It says that simulation facilities, j 24 as defined in the regulation in 55.4--and this includes, of 1 25 course, the non-plant referenced simulators--should meet FEDERAL P.EPORTING SERVICE INC.
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21 1 applicable requirements of the standard.
2 Also, remember that a Reg Guide is only l
3 one acceptable means of meeting the requirements of the 4 regulation, and utilities may propose approaches other' than 5 that which is set forth in the Reg Guide.
6 MR. RUSSELL: Let me add, thouah, that the 7
j controlling issue is going to be when you can conduct an 8 operating test using the facility procedures, and the facility 9 procedures, in most cases, relate to controls, instrumentation, 10 et cetera, available in the control room at the facility for i
So, to the extent you 11 l which the simulator is referenced to.
i 12 'want to use a device other than the plant, or you want to use 13 a simulator which does not represent the control room layout of 14 icontrols, indications and alarms, you're going to have a ,
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15 l difficult time, I believe, showing that such a device is 16 I appropriate for the conduct of an operating test, and that you I
17 can effectively use the facility procedures for that test.
18 I also would direct your attention to the {
i 19 Comnission's statement of considerations with the dissenting 20 view of two Commissioners, who were in favor of the staff i
21 requiring a plant referenced simulator., and only approving by 22 exemption. From the discussions that we had with the 23 ' Commission, and that I had with the Commission, we indicated 24 that we believed most facilities would go with a certified 25 simulator, and that there would only be a few that would not, i
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i 22 l' and we would handle those on a case by case basis, as is I
2 currently described in the regulation.
3 We intend to use, to the extent applicable,
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4 Reg Guide 1.149 and the ANSI standard in evaluating those l 5 facilities, and we will look very hard at the plan and whether
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6 a meaningful operating test can be conducted on whatever device )
7 is proposed.
8 MR. PAUL COLLINS: Bill, the staff is not going 1
9 jto take such an attitude towards simulation devices that they're 10 ladoptingaminorityCommissionview?
11 MR. RUSSELL: No, we are not. I indicated what a 12 guidance we're going to follow. A plan has to be submitted, and 13 the regulation requires that such a device be appropriate for 14 conducting an operating test. l 15 MR. COOLEY: "If Reg Guide 1.149 and ANSI 3.5 16 do not represent the only standard for determining the
. 17 acceptability of a simulation facility, will the NRC identify 18 the minimum standards and criteria that are acceptable to them 19 for non full-scope simulators?"
20 Jerry?
21 MR. WACHTEL: I think, as Bill just mentioned 22 to you, these two documents taken together do describe the 23 only standards, but as I stated in answer to the previous 24 question, you may propose an approach for the Commission's 25 consideration other than that which is described in Reg Guide FEDERAL REPORTING SERVICE INC.
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2 MR. COOLEY: That concludes all the questions 3' on the simulator. We'll go back to the first part of the KMC l 4 ' questions, and now we'll cover those questions having to do l
5 with requal, and the first questions to do with requal is 6 Ouestion No. 3.
l 7 "With respect to licensed operator / senior 8 operator requalification training, is it appropriate that 9- utilities assume they.can take credit for the required annual 10 and biennial plant control manipulations completed on a j; 11 simulation facility (non-plant referenced) if their programs
-l? have been approved by the National' Nuclear Accrediting Board?"
'13 The answer to.that is yes.
I 14 Question No. 4 is essentially the same as the 15 iquestion above. "Can a utility whose training programs have i
16 not been accredited by the National Nuclear Accrediting Board h
~l
'17 and does not have a plant referenced sin.atator take credit for 18 plant control manipulations that are performed on a non-plant 19 referenced simulator?"
20 If that's what you're approved progran is now I
)
21 then there will be no change to that approved program until 22 you get your own simulator.
23 MR. RUSSELL: The caveats to both those 24 answers are between now and May 26, 1991, at which time the i
25 regulation requires that the training portion be done on a ,
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24 1 plant referenced simulator, so it's the transition period; 2+ with the exception, that you'll note that Section 3 on the job 3 training, classroom training and evaluation, you may 4 substitute your accredited program for those requirements.
5 So if you are able to talk INPO into accepting some simulator 6 other than a plant referenced simulator, that's between you 7 and INPO, but for the purposes of the staff's review, we would l 8 expect you to use the simulator after it has been certified if 9 you do that before the 26th of May,.1991, with one minor 10 exception, and the minor exception has to do with the first six 11 on the job items listed under 55.59 (c) (3) , and in that case, 12 you need not have a certified simulation facility or an 13 approved facility. The words permit you to use another 14 l simulation device, and this is under 55.59 (c) (3) (v) , okay, and 15 I
it permits the use of a simulator which reproduces the general 16 operating characteristics of the facility involved, and the 17 arrangement of instrumentation and controls of the simulator 18 'similar to that of the facility involved.
19 It only requires the fidelity of a plant 20 referenced simulator for the casualties. It's the same option 21 performed on the plant, or perfor med on a simulator. You can 22 also perform them on another simulator, and that's the only 23 exception that's within the rule.
24 MR. COOLEY: That covers all of the KMC
-25 questions.
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25 i j i
i The next set of questions are the questions i 2 we received from Fort Calhoun. Does anybody have any questions ,
! l i i that they want to ask before we start on the questions from j 3
1 4 Fort Calhoun? '
I 5 (tha response . ) l 6 The first question from Fort Calhoun has, j i
7 essentially, to do with their exams that are scheduled, but I'll j i
l 8 read it anyway.
9 "The utility currently has an NRC requal I
10 examination scheduled for the first week of June in 1987. What {
I 11 will be the impact of this rule on the examination? Will the j 12 examination content be covered by the old rule, or will the I l 13 content be upgraded to the requirements of the new rule? If i s
14 the examination will be covering the content by the old rule, )
l 15 jwhen can we expect examination utilizing the content covered j l
16 in the new rule?"
17 The answer to that is there's going to be no i l !
i 18 change for the June exams. Any exams given after 1 July of (
19 this year will be under the new rule, which means that the 20 exams that Calhoun has slated for January of 1988 will be under l
21 the new rule.
1 22 The second question has to do with 55.21. I l
I l 23 "During what period prior to administration of his license exam l i
24 must an individual have had a medical exam?"
25 That's going to be the same as before, if it's 1 .
i FEDER AL REPORTING SERVICE INC.
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26 1 l
1 in the standard 1021, it should come'in at the same time the !
2 application comes in. It'll be good for six months from the 3 date of the signing by'the physician, and waivers, as stated l
- 4. in ES 111 will apply.
5 The next question: "Has' Form NRC-396 changed?"
6 Yes, and there was a copy of that passed out to everyone at 7 the meeting.
8 The next question: "Has Form 398 changed?" j 9 The answer to that is not yet, but it's being changed as we sit 10 and talk, so they're in the process of changing that form.
11 Any' estimate, John, on when that will--398 will be--
It is scheduled to be available !
12 MR. HANNON:
13 for ordering sometime mid-May time frame.
14 MR. COOLEY: Relative to 55. 31 (a) (4 ) : "What I l
15 is considered evidence of the facility licensee's need for an 16 operator or senior operator to perform assigned duties?"
17 The facility, as we've answered already, still 18 does that by a completed 398. When you send us that, that's-I 19 saying that you need this guy to have a license.
20 (off the record to change the tape.)
I 21 MR. RUSST* ' : Let me go back to the question on 1 22 exams being conducted after the effective date of the rule. )
23 There are clearly some changes in the rule that will change the 24 examination. He answered the question in the context of the 25 content of the exam, based upon a recall program that's already FEDER AL REPORTING SERVICE INC.
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27 1 been done under the current examiner standard, 601, where we 2 are auditing individuals who have two-year licenses and auditing 3 the company's program. We don't expect that there will be 4 changes in content. ,
5 Clearly, however, the operating test portion 6 will be. documented on the new Form 157, and we_will be addressine 7 areas that are required by the regulation in constructing the 8 examination. We aren't going to be going and testing on areas j 9 outside of the requal program, or the current licens'ing program 10 as you have it at the facilities, but there will be some change 11 in forms and some change in documentation process.
12 The reason for that is that those examinations 13 are aircady in preparatio." now, and you can't do 90 days worth so we will be continuing to use 14
[ofworkinthe_transitionperiod, 15 the materials that were previously submitted prior to the 16 effective date'of the rule to construct the first few exams 17 after the effective date of the rule, but there will be some 18 changes in forms and processing and how it's handled.
MR. COOLEY: . Question No. 6: "If the utility i 19 20 has an INPO-accredited operator training program, but does not 21 yet use a simulation facility acceptable to the Commission, l 22 will an application which states the information that the 23 operator training program is accredited by INPO and gives 24 details of the simulator instructions be adequate for the 25 license application?" !
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28 1 John Hannon is going to answer that question.
2 MR. HANNON: The 398 will have'a block on it !
3 toLindicate whether or not the applicant has graduated from'an 4 INPO-accredited training program. If the answer to that 5 Equestion is yes, and the facility has an approved or a certified 6 simulation facility, then the information on education, 7 experience and training will not need to.be filled out on a 398.
8 on the other hand, if the individual is a 9 graduate of an INPO-accredited training program and the facility 10 does not have a approved, or a certified simulation facility, 11 then all that information will still need to be submitted.
12 MR. RUSSELL: That's the carrot and the stick.
13 We would like you to get into the mode of certifying simulators 14 earlier, and since nearly everyone has accredited programs 15 with graduates, the process gets much simpler when you reach 16 those two major milestones and it stays difficult with you i 17 providing all of the details, which we will then subsequently 18 review and make a determination on eligibility in each case.
19 The sooner you get that done, the sooner you can take advantage 20 of filling out the two simple check-offs in the form. Up 21 until then, you must provide all of the information, including 22 the description of the t.aining program courses, et cetera.
23 MR. COOLEY: Question No. 7, and John Hannon 24 will answer this question: "Is a Commission approved training 25 program defined as an INPO-accredited training program, or are FEDER AL REPORTING SERVICE INC.
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29 j l l 1 there other criteria for approval by the Commission of a i
)
How is a training program approved ! l 2 utility's training program? l 3 by the Commission?"
4 4 MR. HANNON: The answer to that is that we, i 1
5 the NRC, is getting out of the approval process for training 6 programs. If there is an INPO-accredited training program, it 7 only needs to be certified to us as indicated in Generic Letter 8 87-07. If a utility wishes to submit a revision to the j l
9 presently NRC-approved training program and asks for an NRC I 10 review and approval of that, we are not geared up to do that ,
11 now, and we would probably have to deal with that using the !
l I
12 SAT-based, performance-based approach in NUREG 12.20.
13 MR. RUSSELL: Let me identify and make sure 1
14 that there's a clear understanding on this point. If a utility l
15 has a program that has been accredited by INPO, we expect that I
16 .that's the program of record. The staff does not see that there 17 is any need for, or value, to doing a review to try and come up 18 lwithalesserstandard, because that's the standard of record I i
19 with the NRC. If you are accredited, we expect you to follow j 20 the accredited program. We have revised the approach to j 21 inspection of training programs, and we do not expect you to l 22 try and maintain a lesser standard for licensing with NRC than 23 you have for training the people.
24 The Commission endorsed this program based upon 25 the industry commitments to improve training, and the Co=.ission FEDER AL REPORTING SERVICE INC.
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30 1 is moving out of the role of reviewing and approving training 2- programs. So if you are accredited--and by the way, we have l l
-3 that information; I have probably attended the majority of the j 4 accrediting board meetings and I know who's accredited and who's 5 not--if you are accredited, don't bother to send in to the staff 6 a long review trying to get your old program modified to get ..
7 relief to have a lesser standard than has already been approved 8 by INPO.
9 You don't have to submit the programs to us.
10 .All you have to do is say you're following it, and that the I
11 individuals are a graduate of your accredited program. If we 12 see a significant number of these, we would likely have to go !
l 13 back to the Commission to get further guidance on what is 1 14 intended, because it is not consistent with the industry 15 icommitment, through NUMARC to the Commission, which has been l
16 endorsed in a policy statement.
.17 MR. C. L. TURNER: C. L. Turner of TU Electric 18 (phonetic), regarding the time and timing for transition between , i 19 the INPO-accredited species and the NRR-approved program, it 20 might be likely that you would want to implement what it was 21 that you developed in the INPO-accredited SAT-based program so 22 what you do in that int'erim--you just said you don't want to 23 review it or give approval, so you do need to go ahead and run L 24 that instead of running parallel programs.
l i
25 MR. RUSSELL: I agree. My comments were directed FEDER AL REPORTING SERVICE INC.
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31 1 particularly at plants which are already licensed for the cold ,
i 2 j license training programs, and particular for those facilities ! l l
3 that are not yet accredited, because they've not yet operated 1
4 and have not yet implemented all the programs. INPO has--and
)
5 the accrediting board has not been accrediting operational )
6 programs for plants that are not yet operating.
(
7 In those cases, the staff would entertain a 8 review of amendments or modifications to the cold license 9 training program, which is SAT-based, and we would use, for 10 guidance in doing that review, the kind of information that 11 is contained in NUREG 12.20, or you could propose that you have 12 done it in accordance with the TSD process, which INPO is using, 13 and if you show that it's comparable to that, we would also 14 consider that. That is a venicle for getting a Commission 15 approval of a performance-based or an SAT-based program on a 16 case-by-case basis for a cold plant. We don't mean to exclude 17 jyoufrombeingabletodoperformance-basedtraining.
18 l MR. COOLEY: Question No. 8. This question was 19 answered on KMC, but I'll go over it again since there is one 20 part to this that KMC didn't have on theirs.
21 i "Must the five significant control manipulations 22 be performed on the reactor?"
23 i My answer to that is yes. This is for 24 applications for a license.
25 "Will manipulations on a simulator be adequate?"
l l 1
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l-32 1 Those five control manipulations have to be-2! performed on the plant, in the case of Calhoun.
1 3 "What is the definition of significant control 4 manipulations? Mast each manipulation be different, or are the 5 same manipulations repeated five times? What constitutes an 6 extended shutdown?"
7 We'd rather not see you do the same thing five 8 times, because that doesn't really prove anything. We'd like 9 to see those be a combination like Reg Guide 1.8 spells out 10 jthatyoushoulddo,andthesamething,theplantshouldn'tbe 11 in a shutdown mode when you're doing one of these. !
i 12 An extended shutdown would be anything that is I 13 long enough that the applicant cannot complete his manipulations 14 or training prior to taking the examination. So, essentially,
.15 in the case of Calhoun, it's the.same as before.
16 MR. RUSSELL: Let me give some examples of past 17 practice so that you understand exactly what we mean by an 18 extended shutdown. If the plant is in, for example, a refueling 19 outage that lasts for a year, such that the candidate did not 20 get an opportunity to perform the control manipulations because i
'21 the plant never got to Mode 2 or Mode 1, we would consider 22' giving that individual anexam, and even issuing him a license ,
I 23 which is conditioned to shutdown.
24 At the time that he performs and completes the ,
(
25 control manipulations on the hot plant, we would then remove the f l
FEDER AL REPORTING SERVICE INC. l DENVER. COLORADO {
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33 j i
1 condition on his license which limits it to shutdown. We do not 2 intend'to penalize the individual in the case where there is'an l 3 extended outage, but we don't intend to also give uaivers for
. 4 that requirement. Th,at's clearly a requirement of the 5 regulations.- So that's the process, and extended means, 6 essentially, the candidate did not have an opportunity to "t 7 perform during his training, and the training programs are 8 generally on the order of 26 weeks to a year, so if you've 9 got an outage that covers his training program time, that's the 10 kind of case where we would consider going ahead with an 11 examination and possibly issuing a conditioned license.
I 12 '
MR. COOLEY: The next questions has to do with 13 55.41, and I'm going to ask susan to answer this after I read 14 l the question., or do you want to--
15 MS. SHANKMAN: I can recd it. I have to put my-16 l glasses on.
17 "How does the Commission intend to implement 18 , written examinations based upon the knowledge, skills and i
19 abilities identified in the learning objectives derived from 20 the systematic analysis of licensed operator duties?"
21 This morning when we were discussing this 22 section, it's our intent, and in II I think we just say it flat 23 out, to ultimately reach the point where the training program's 24 learning objectives become the major source for our examination, 25 and that we will sample according to a scheme that looks at the I
l FEDER AL REPORTING SERVICE INC.
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1 34 1 most important job performance, knowledge and abilities, and 2 in that area we have that documented with our KA catalogs. !
3 In fact, there's a supplement to the PWR catalog that should be l
4 in the mail. I know you've heard that before, right? But '
5 anyway, the PWR supplement is being published or printed as 6 we're speaking, and what that will do for the PWR plants is 7 have the same sections as the BWR catalog, and you will have a 8 theory and a component section that's been pulled out, and the 1
9 system-wide generics and the plant-wide generics in the catalog i 1
10 have been re-rated. 1 l
11 In addition, we asked the PWR panel of subject 12 ' matter experts, and the BWR panel of subject matter experts to !
l 13 rate the testing emphasis that they thought we should have. l
(
14 That forms the basis of the NRC's sampling plan. So we will i Then what vi)1 we expect in 15 lsamplethemostimportantcontent.
16 terms of conditions and standards of performance will be driven !
1 17 by the learning objectives, and that will form the basis of 18 our testing objectives, and as I think I said this morning, the 19 only slight difference between testing and learning objectives 20 has to do with the context in which you judge performance, 21 because one is a limited--time-limited testing situation, and 22 the other might be a longer training or job performance period.
23 The only other thing I wanted to say was that 24 to the extent that you, as a facility, can key what you're 25 doing to those catalogs and your learning objectives clearly have FEDER AL REPORTING SERVICE INC.
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1 standards in'which'we can use them in a testing situation, as 2 well as questions that you have used and have some item stats 3 on, I think--I know Spade has been with.Waterford and in other 4 instances, and I'm sure John and Bob are open to that informa- 1 5 tion. We don't want our exam to be devoid of contact with 6 your: training program. The purpose'is to get into the same 7 spot, butLwe, of course--the reason those other items are in 8 there is we have to reserve the right to look at LER's and other 9 events, and.to further investigate our questions, with your 10 assistance, manuals, license amendment, or other materials, 11 because often we have to judge our question in terms of your 12 learning objectives, but the material to develop the question 13 has to come from something--some place other than the learning 14 . objective. I hope that clarifies that.
l 15 MR. COOLEY: Question No. 10: "55. 41 (b) 'does 16 not address technical specifications. What knowledge of the 17 technical specifications is required for an operator?"
'18 Well, if you'll look at the rule, under Item 19 55.41 (b) (5) , it says: " Facility operating characteristics 20 during steady state and transient conditions, including coolant 21 chemistry, causes and effects of temperature, pressure and 22 reactivity changes, effects of load changes, and operating 23 limitations and reasons for these operating characteristics,"
24 which is part of tech specs, plus if you look at 55.41(a), one 25 of the items there says that the content of the exam should i
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1 cover the facility license and license amendments, which is l 2 your tech specs. So it'll essentially be the same as now, !
l' 3 since the facility license and license amendments are part of 4 the tech specs. We'll still use the same criteria.
5 The next question is a simulator question, 6 and I'll refer to Jerry for this. " Relative to 55. 4 5 (b) (5) (ii) ,
7 what does the Commission consider an adequate schedule to 8 correct performance test failures identified in the four-year 9 anniversary certification?"
10 ,
MR. WACHTEL: That question also refers to 11 55. 4 5 (b) (4 ) (iii) for the non-plant referenced simulators, and 12 I there are really two answers to that.
13 Although the rule requires a report on every 14 ffour-yearanniversaryofcertification, or four-year anniversary I
15l of applic tion, we intend to have a much closer working 16 relationship with you so that we will know on an ongoing basis 17 about any such performance test failures, and we've talked 18 about earlier today, there are several mechanisms to do that.
19 One is the 90-day letter prior to examinations, 20 in which uncorrected performance test failures would be 21 identified. Another would be simulation facility fidelity 22 reports that come back from our examiners, and the third, of 23 course, would be the results of our periodic audit and 24 inspections of simulation facilities.
25 The reasonableness of the schedu?e to correct FEDER AL REPORTlNG SERVICE INC.
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-37 1 performance-test failures, as we talked about earlier, is really 2 based upon the seriousness and the magnitude of the failures !
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3 that are discovered. Anything ranging from purely an NRC i 4 recommendation that the failures be corrected, on to a
< l 5 recommendation that a failure be corrected within the normal i 6 cyc'le of updates required by ANS 3.5. The next level would
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a J
7 require a correction on an accelerated schedule, and of course, 8 the ultimate would be essentially a shutdown of a simulation !
9 facility until such time as the performance test failures are 10 ,. corrected.
11 MR. COOLEY: Number 12 is essentially--did you 12 include that there?
13 MR. WACHTEL: Number 12 asks: "How long must 14 the results of the performance tests be retained by the 15 licenseee?", and that, as well, goes to 55. 45 (b) (5) (iii) and 16 (b)'(4 ) (iv) . The results of performance tests must be maintained 17 for a four-year period from the date of filing of the document 18 which they support, whether that document is a Form 474 19 certification, whether it is the four-year report subsequent 20 to that certification, or whether it is an application for 21 approval. So essentially there's a four-year retention period 22 regardless of whether you're going the certification route or 23 the application for approval.
24 MR. COOLEY: And along that same vein, the next 25 question is: "What detail of description is the Commission FEDER AL REPORTING SERVICE INC.
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i 38 i 1 anticipating in the report? Should the report be revised if a 2 schedule for conducting a performance test changes year to. year 3 during the four-year period?"
4 MR. WACHTEL: Let me answer the second part of 5 that first, and the answer to that is yes. If your schedule 6- for performance testing changes between the time you submit a 7 certification and any subsequent four-year report, you should 8 advise us of the changes to the schedule, and there is a 9 i statement on the top of the Form 474 to indicate that.
10 With regard to the first part, there are three
! 11 documents in the case of certified simulation facilities that 12 govern here. The rule, specifically the operating test in 13 55.45(a), with its listing of 13 items that make up the content 14 domain of the exam; ANS 3.5, which sets out the requirements 15 for the simulation facility's capabilities, as well as the 16 performance testing requirements; and, of course, Form 474 17 itself, which tells you that what we want is performance test l
18 abstracts and performance test schedules.
19 We don't want reams of material on the details 20 of all of your performance tests and all of the results. The 21 mechanism in the simulation facility evaluation procedure is 22 such that if we find that there is additional information that 23 we need in the course of conducting an off-site or an on-site 24 simulation facility review, we will request it from you, so we 25 are really looking for summaries and abstracts submitted with FEDERAL REPORTING SERVICE INC.
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39 1 that certification form.
2 MR. COOLEY: The next question, No. 14:
3 " Relative to 55.53 (f) (1) . Before a licensed operator can resume 4 active status, the fa,cility licensee must certify that the 5 qualification and status of the licenses are current and valid.
6 What does this certification consist of, and how is it 7 accomplished?"
8 If you have a satisfactory requal program, then l
9 I
the operator must stand the 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> on watch, with an RO or an 10 SRO, depending on what he is. That 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> has to be in the
\ 11 duties that he would be assuming if he's going to be the 12 ; senior reactor operator, foreman, shift foreman, or shift i
or in the case of an RO, the RO on the console 13 jsupervisor, i
14 ; manipulating the controls.
15 A letter from the VP that signs all the other 16 l training materials, should put a letter in the guy's file that-17 this has been completed. This should be able to be audited so 18 that you've got a paper trail saying that this has been 19 completed, signed by the VP or authorized representative that 20 ! signs those kind of letters, and should be available if somebody 21 wants to come in and take a look at the training records.
22 The next question, 55. 57 (b) (3 ) : "What 23 ! constitutes the continued need for a licensee to direct operators l
24 of the facility designated at the application? Many facilities 25 have senior reactor operators who are there to fulfill staff I
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l 40 1 functions, and who will not meet the seven shift per quarter 2 requirement. What will the Commission consider to be adequate 1
I 3 direction of operators at the facility in order to renew the 4 license?"
5 I talked with Joe Gasper a little bit about !
6 this question, and what he was getting at here was if a senior 7 operator wants to direct an operator at the controls or in the j 8 control room, does he have to have an active license, and yes, 9 he does. He can do the administrative-type duties without an i
10 active license, but if he wants to direct reactor operators or 11 other licensed operators, then he must have an active license, 12 and if he hasn't satisfied the seven eights or the five twelves, 13 then he has to perform those 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> in a parallel job prior 14 to going back as an active senior operator.
15 In order to renew that license, he must have 16 satisfied the requal program, his medical has to be up to date, 17 and he has to have passed an NRC requal sometime during the {
l 18 isix-year period of the license. {
19 Any questions?
l 20 (No response. )
21 Relative to 55.57 (a) (3) , "What is written 22 evidence of the applicant's experience and how is this supplied?"
l 23 ! Same as now, in the 398.
24 Relative to 55.57 (a) (5) , "What is the evidence 25 that the applicant has discharged the license responsibilities FEDER AL REPORTING SERVICE iNC.
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41 1 competently and safely, and how .4s this information provided?"
2 Same as now, on the 398 when you send in the 3 application.
4 The n, ext one I'll ask Jchn Hannon to answer.
5 Relative to 55.59 (c) , "What criteria is the Commission going to 6 use to approve programs developed using a system approach to :
7 training?"
8 MR. HANNON: This goes to--again, to the 9 Generic Letter 87-07. If you are asking the NRC to approve a 10 requalification program that's based on a systems approach to 11 training,.again, we may--we don't look forward to trying to do i
12 those kind of reviews. What we'd rather see come in would be 13 a submittal indicating that you have an INPO-accredited program, 14 which has also--both initial training and requalifying are 15 based on an SAT.
16 If'you were to ask for the NRC to review a 17 training program that was not INPO-accredited, that you claimed 18 was based on a systems approach to training, we would again try 19 to use the docaments that we have now to evaluate that, NUREG i
20 12.20.
21 MR. RUSSELL: Let me make sure that this gets 22 into the record at this point, and I realize I'm hitting the I
23 same issue I talked about before.
24 If your program is accredited, and you're not 25 a cold plant licensee, prior to receiving an operating license, l'
l j FEDERAL REPORTINC SERVICE INC.
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1 42 1 we fully expect that you will use the INPO accreditation 2' process and the guidelines that have just recently been issued 3 by INPO in their continuing training guidelines for licensed 4 operators to develop your requalification continuing training a
5 program.
6 We will accept a simple statement to that effect, 7 that that has been done. We accept as fact that you have been 8 accredited, and therefore, you understand the process of 9 developing performance-based training. We do not expect to 10 review such programs. I don't think INPO would like us to 11 review programs against their criteria and to put them into 12 that context. We are trying to, in this rulemaking, clearly 13 differentiate between training programs, which are being handled 14 by the industry initiatives through NUMARC and INPO, and 15 licensing requirements and the NRC examination. We don't want 16 to mix those_two, and I would look very carefully and probably 17 have a number of discussions with facilities that propose to 18 do otherwise.
19 MR. JIM VANDERGRIFT: Jim Vandergrift, Arkansas 20 Power and Light. With respect to that area of 50.54 changes, 21 that basically states that we will have a requal program and From an I&E viewpoint'I kind !
22 that we cannot lessen the scope.
23 of take a look at that. What documents would be looked at as a .
I 24 base document to see whether we did or did not reduce the 25 scope; would.it be 0267 I
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43 1 MR. COOLEY: It would be your approved requal l
2 training program, I would assume.
3 MR. VANDERGRIFT: Well, based on having a--
4 just putting in a certification saying that we're accredited, 5 there's a lot of documents that's involved with the accreditation 6 process, so as an I&E inspector came in and looked and says, 7 "Well, we think that your program is less than the scope," what 8 is he basing that on?
9 MR. RUSSELL: If you make a change to your 10 program through the accreditation process using the mechanisms 11 for revising and updating your program, based upon feedback and l
12 need, okay, and that's the reason that you're revising it, I 13 don't see that that is an issue on lessening the scope.
14 The lessening the scope had to do with the old 15 program when it was a regulatory-based program, where we 16 required a certain number of hours in the classroom and certain 17 types of content. The approach now is one of modeling the 18 program based upon performance and need, and the process is one 19 that has been endorsed by the Commission through the policy 20 statement, and I'll repeat again, to the extent you need to 21 change the program based upon feedback on your own performance, 22 that's appropriate.
23 If you would have the situation today where you 24 have an approved program that says, for example, I am going to 25 examine annually and I'm going to run through the whole program I
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4 44 1 annually, and you now want to change that to examining every 2 two years, the regulation is the basis for concluding that that i 3 is acceptable, and that is not reducing the scope. That is 4 simply. conforming to the regulation. You can do conforming 5 changes to match the ' regulation either through the 50.59 review process or, in some cases you may need to amend your 6
7 licenses. There are a few facilities in the tech specs where 8 they have commitments to operator training programs associated 9 with a staffing requirement section in Section 6 of the tech 10 specs. If you are in that category, you can submit an amendment I
11 request to the Commission for an administrative change to your (
12 tech specs to conform to the require _ments of the regulation, 13 but you may not do less if it is, in fact, a requirement in 14 your license now. You can't do less than what's in the license.
15 If it's in your approved program, you can do a 50.59 review to 16 conform to the regulation.
17 MR. COOLEY: Relative to 55.59, "It is our 18 understanding that active participation in the facility's 19 requalification program, including attending requalification 20 training and satisfactorily completing requalification 21 examinations, constitutes the basic requirements for maintaining 22 a license. Is this correct?"
23 The answer to that is yes, but in order to be 24 active, you must complete the seven eight shifts per quarter, 25 or five twelves, whichever is the case, and you must be up to FEDER AL REFORTING SERVICE INC.
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45 1 speed on your medical.
.2 The next question has to do with 55.5(b) (2) (iv) .
3 "It states that applications and correspondence should be 4 submitted to the Regi,onal Administrator. Should copies be 5 submitted to Mr. Cooley?"
6 It makes it a lot faster if you d-.
7 Question 21: "our facility will not have a 8 plant referenced simulator available for the training until 9 the first quarter of 1990. .It is assumed that operating tests 10 will consist entirely of plant walk-throughs until such time as 11 a plant referenced simulator is certified. Is this a correct 12 assumption?"
13 The answer to that is yes.
14 Relative to 55.59, "Following- "
15 MR. HANNON: Excuse me. Can I expand a little 16 bit on that answer, and where it says until such time as a 17 plant referenced simulator is certified. In the event the 18 utility were to start using that simulator to evaluate 19 candidates prior to the time at which they chose to certify it, 20 if you're using it to evaluate your candidates, I don't think 21 we'd have any problem with the examiners using it to conduct 22 operating tests on.
23 MR. COOLEY: "Following implementation of this 24 revised regulation, must an existing licensed requalification 25 program be submitted to the commission for reapproval?" ;
I i
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i 46 I 1 The answer to that is no.
c 2 The;second part of that question is: "What i l
3 is considered a continuous period?" i 4 This means for 24 months, then you start over 5 again-for another 24' months, and then another 24 months, so
'l 6 .that you'd have three requal cycles in the six-year license J 7 period.
8 Relative to 55.59 (a) (2) , "Must a facility J
9 administer annual operating tests to licensed operators prior I 10 .to the time that a certified plant referenced simulator is 11 available?"
12 The answer to that is yes. Even though it may 13 not be part of your requal program now, you have to start 14 administering an operating exam, and if you don't have a i
15 simulator, then you would give an tral exam, a walk-through type {
l 16 like we do on the plant. )
i 17 MR. RUSSELL: Let me poiDI out that this is one ]
l 18 aspect of the transition into the new rule that we are not '
i 19 going to look for everyone to have completed an operating test 20 on May the 26th, 1987, but for sure, by May the 26th, 1988, 21 overybody who's been licensed for that last year shall have 22 completed an operating test on the facility.
23 We're using a mere common sense approach, so if l
24 you submit a application for renewal for a candidate who has a 1 l
25 two-year license now, and you submit it in four months, that !
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47 1 individual may not have had an operating test, as is described 2 in the rule, because he has not been under that rule for a year.
3 We would.still renew the license and issue him a six-year 4 license. ,
5 After everyone has been under the rule for'one 6 year, we would not find that he had met the terms and conditions 7 of his license if he had not had an operating test, because 8 the operating test is to be conducted each year. So with that 9 clarification, that's what we intend.
i 10 MR. COOLEY: In other words, the last part of 11 that was: "If so, does this annual operating test consist 12 solely of the plant walk-through?", and that also goes along 13 with 55.45, all the items to do with conducting an operating 14 test have to be completed as part of that 55.45 operating test.
15 The written exam every two years is a change I
16' to your program, where your program now spells out that you 17 give an annual written exam, you will have to continue to give 18 an annual written exam unless you submit and get approved a 19 change to your requal program.
20 MR. RUSSELL: Or if you submit a certification 21 that says, "I'm accredited and I have a program that's based 22 upon a systems approach to training," and then you do candidate 23 evaluation up to two years, it could be segmented, examining on 24 certain training segments over the two years, it could be a 25 comprehensive exam, j:ither way. If you are in the process now c
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48 1 of reviewing your program to insure it's an SAT-based, it is 2 in conformance with the INPO guidelines, and you wish to amend 3 that in the near term, that would be an area that would be 3 4 a conforming change consistent with the guidance in the rule.
5 It could be done in accordance with 50.59, and you would have 6 to simply. inform us that,you are making that change.
7 I would prefer to have the simple statement, ,
8 as is contained ir, the generic letter. "We're accredited and j 9 it's SAT-base " and then you can supercede all of the detailed
.10 information in the FSAR.- I 11 MR. COOLEY: The next question: "It is. assumed 12 'that the requirements in this list supercede- " and this is 13 talking about 55.59 (c) (3) (1)- "It is assumed that the 14 requirements in this list supercede the so-called Denton letter 15 requirements. Is this a correct assumption?"
16 The answer to that is yes. l 17 The last question for Calhoun has to do with 18 simulators, 55.59 (c) (3) (v) states: "A simulator may be used 19 in meeting the requirements of paragraphs (c) (3) (i) and (3) (ii) 20 of this section, if it reproduces the general operating 21 characteristics of the facility involved and the arrangement 22 of the instrumentation and the controls of the simulator is 23 similar to that of the facility involved. Fort Calhoun will 24 continue to use the CE simulator in Windsor until the plant 25 referenced simulator is available for training. Is the CE FEDERAL REPORTING SERVICE INC. ;
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I 49 1 simulator approved for meeting the applicable requirements 2 until such time as a referenced simulator is available? The ,
I 3 same q'uestion applies to the discussion in ( 4 ) (iv) . " ;
4 The answer to that was yes, until May the 26th 5 of 1991, because this is now a part of your requal program, so 6 it will continue to be a part of your requal program until such 7 time as you get your own simulator, or other approved simulation 8 facilities.
9 (Off the record to change the tape.)
i 10 l (Whereupon, a brief recess was taken.)
11 MR. COOLEY: Okay, is everyone ready to get 12 started again? We'll start with the Diablo Canyon questions 13 and then I'll let Bob Pate do the talking for a little while.
14 MR. BOB PATE: On the Diablo Canyon questions, l
15 the first question deals with the background as it was presented 16 in the generic letter. Under background, pages 4 and 5, (a) 17 under that, "The background section states that these rules 18 supercede all current regulations for operator licenses. Does 19 this mean that all reference to NUREG 0737 is no longer 20 applicable? Also, if NUREG 0737 is still applicable in other 21 areas, are you going to publish a NUREG that supercedes NUREG 22 0737 in those areas?"
23 The answer is that no, the NUREG requirement it 24 as we applied to operator licensing will no longer apply, 25 has been superceded. However, the NUREG 0737 has not been i
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50 1 ' superceded. There's a' lot of other areas-that are covered by 2 that NUREG, and they still apply. And the last part of it, ,
1 t 3 no, we'll not issue a new NUREG that applies to the areas that 4 have not been superceded.
5 Part B. "When filing for Commission approval 6 to modify existing initial licensing and requalification {
7 training programs, 1. Can this change be submitted by filing
'8 an FSAR amendment?" The answer to that is yes.
9 "Also, what other means are available for 10 filing for program changes?"
11 Well, as allowed in the NUREG, you can just 12 write a letter and say in the lette'r that you want to substitute 13 an accredited training program, which is performance-based,.for 14 the program that you have. And so that's another way you can 15 do it.
16 The next question area is a summary of public 17 comments and final actions, and A under that is applications.
18 The first question there is: "The application section states 19 that the NRC will conduct an NRC examination 'if a candidate 20 successfully completes the training and experience requirements l 21 to be licensed as an operator.' Does this imply that an ;
22 individual must complete all training and company certification j 23 exams prior to filing an application for an NRC examination?"
24 The answer to that question is yes. That's the 25 way the regulation is now written.
, 1 FEDER AL REPORTING SERVICE INC.
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fi 51- l 1 It goes on, then, to say: " Applications files 2 for Diablo~ Canyon Power Plant cccurs prior to completion of 3 the' individual final certification process, due to the 4 requirement'to file the application from 30.to 60 days prior l
l 5- to the exam." This will not be acceptable under the new rule.
6 Under Part B, written examinations and operating 7 tests,.it says: "The NRC clearly states that learning objectives 8 derived from job-task analyses should. form'the basis for 9 licensing written examinations and operating tests at a facility.
10 Also, that the NRC testing objectives will reflect facility 11 licensee-developed learning objectives. However, in the 12 interim, while programs are being developed and reviewed for 13 accreditation, the NRC has activities underway to improve the 14 .
content validity of NRC examinations and operating tests."
15 The question, then: "Will the NRC commit to 16 solely using the learning objectives for plants that have 17 accredited operator programs?"
18 l The answer is no, that the rule states that the 19 learning objectives will be used in part. Other things, like 20 LER's and that sort of thing will be used.
21 Under licenses, the first question: "Regarding 22 active participation, part A, the regulation for active 23 participation states that 'an individual has a position on the 24 shift crew that requires the individual to be licensed as 25 defined in the facilities technical specifications, and that the i
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52 1 individual carries out and is responsible for the duties 2 covered in that position.'"
3 Item 1 of that: "How does this rule accommodate l' 4 plants that staff up,with RO and SRO licenses on shift that 5 exceeds the technical specification minimum manning 6 requirements?"
7 The answer to that is that the rule does not 8 make any provisions.
9 The second part of that question-- ,
10 MR. RUSSELL: I'm seeing some reactions in the 11 back that indicate maybe there is not a clear understanding 1 12 to the response. If you want to.stop at a point and get an 13 expansion on a question, please just come up to the front and 14 we'll do that. I had covered before the issue of a watch 15 standard or an extra person on shift and it must be in one of 16 the positions required by technical specifications on the shift.
17 Extra licensed operators on shift, not in positions. required 18 by the technical specifications, do not meet the requirements 19 for proficiency in that position.
20 So that if you operate a single unit with three 21 reactor operators on shift, two of those individuals are in 22 positions required by the tech specs. One's usually the 23 reactor operator, the other's the balance of plan operator.
24 The third person would need to rotate into one of those two 25 positions over the course of a quarter to obtain the requisite FEDERAL REPORTING SERVICE INC.
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53 J 1 number.of shifts to maintain his license active, so he would :
l 1 2 need to sign into the logs, on occasion, to be the reactor i j 3 operator, or the balance of plant operator. So it's clear, l
4 we' hope, that you must be in the position on shift required by J J
5 the technical specifications, and additional personnel on shift 6- to perform other duties does not meet the requirement of the 7 regulation for directing the activities of licensed operators 8 for manipulating the controls.
Ron Maiser, San Onofre. I 9 MR. RON MAISER:
I 10 Would you require any additional documentation ]
l If you came out to audit, would you i 11 over and above plant logs?
12 expect some separate documents or a stack of plant logs three 13 or four years old? ,
l 14 MR. RUSSELL: The requirement is reasonable 15 records to audit that shows that the individual has performed. ) 1 16 We do not expect to be auditing in this area, however, if there l 1
17 is an event, for example, which raises questions about the- !
18 actions of the operator or potentially the proficiency of the 1
19 operator, we would clearly, in that case, go back to determine 20 whether that operator had maintained his proficiency, as is 21 required by the regulations, to have an active license. So this 22 would be by exception. There may be some portions on a routine 23 inspection basis we would look at it, but essentially, the fact 24 that the watch assignment log would be the basis for doing this.
!I 2b MR. MAISER: Thank you.
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54 1 MR. PATE: We would have to be able to look at l
2 those records, and you'd have to have them available for us to 3 look at, and whatever way that you can come up with a system 1 4 that satisfies you, t, hen the inspectors should be able to be 5 satisfied, also.
6 The question goes on: " Additionally, technical 7 specification does not address the individual's responsibility 8 for each position, except as defined in sections of page 35 9 which states that a senior operator directs the licensed 10- activities of licensed operators. Does the regulation allow 11 individuals that are filling the same job on opposite units, 12 above and beyond the minimum technical specification requirement, 13 satisfy the active participation requirement?"
14 I wasn't for sure what that question meant, but 15 if it means--
16 MR. JIM MOLDEN: I would love to explain it.
17 The real thrust of the question--my name is Jim Waldon with
.]:
18 Diablo Canyon--is since the tech specs does not identify who--
19 it says you have to have an SOL, two SOL's, one that's a shift 20 supervisor and one that's another SOL. Can you rotate that SOL )
21 position from a shift foreman position to another senior. reactor 1 22 operator position? It doesn't say who is required to fill )
23 those positions, so the complication is that if we have a senior 24 control operator who has an SRO license and he's clearly 25 directing the operator's activities, can we give him the FEDERAL REPORTING SERVICE INC.
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55 1 responsibility for the day and say the shift foreman no longer 2 nas the responsibility, because both of them hold an SRO 3 license?
4 MR. RUSSELL: The issue that you've described, 5 the individual that's on watch who is directing the activities j 6 is the individual who's in the position required by the tech 7 specs, okay. Whether he is the shif t foreman for that shift 8 because that's the. title that you use to describe other l l
9 activities or other responsibilities he may have as a shift 10 foreman, the senior operator that is there in the control room 11 who is directing how the other two operators manipulate the ]
i l
12 controls of the facility, whether it be a startup or a shutdown 13 or conduct a surveillance test or whatever it is, that individual 14 is there fulfilling the requirements of the technical 15 specifications to be supervising the activities of the licensed 16 operators and directing them. That's the position that l l
17 qualifies for the eight hours on that shift. It's independent J 18 ,of title. It goes by what he's doing,not by what his title is, ]
19 and I would hope that it would be clear through your l
20 administrative procedures as to who is in the position of 1 21 authority to direct those licensed operators, and if the shift 22 foreman is relieved and he's doing something else for that ;
i 23 shift, working on paperwork or something else, and there is 24 another senior operator in the control room carrying out those 25 duties, the tech specs don't say shift foreman. The tech specs 1
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l 56 i 1 say senior operator directing the' activities of other licensed 2 operatore. It's that position that is the one that you get 3 credit for for maintaining an active license.
4 We also had a question that came up in Region 5 II that will be in the transcript that I will describe now that 6 relates to the extra person on shift who may not be in the 7 licensed role. It is possible for that individual to complete 8 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch standing; that is, he's not in the 9 position required by the tech specs, but he's there, as long 10 as he is being supervised and his activities are being closely 11 monitored by the person who has the watch. It is conceivable 12 that he could accrue 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel watch standing and 13 be active for that quarter, based upon the 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel 14 watch standing, and not be actually in a position required by 15 the tech specs to meet the seven shifts at eight hours each, 16 or the five shifts of twelve hours each.
17 It would require, however, in that case, that 18 the responsible officer or the authorizing representative of 19 the facility certify that he has completed that, so from a 20 practical standpoint, I don't see a lot of cases where every 21 quarter you're going to be sending certifications up to your 22 on-site vice president saying, "This guy did- ", you know, the 23 ' reality is, it's easier to rotate the people through the watch 24 to maintain proficiency. The active license is intended to 25 maintain the proficiency of the people who are performing the FEDER AL REPORTING SERVICE INC.
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57 1 functions. That's the whole intent,.is that they are.
2 _ proficient'and they are doing it on a regular basis.
3 MR. HANNON: It was also discussed in Atlanta, 4- the case where we wo,uld be talking about dual licensing, and 5 if you're dual. licensed, the shift requirement can be met to 6 remain' active by standing watch on only--either one of the 7 plants, or on some combination of the plants.
8 MR. RUSSELL: You don't have to do seven eights l 9 on Unit 1 and seven eights on Unit 2 in order to be proficient 10 in manipulating.the controls. It's a total of seven on Unit 1 11 and Unit 2. ;
12 I MR. PATE: For the next question: "Are there 13 other acceptable interpretations of this rule?"
14 ; I think we just went through it.
l 15 I think the next part has also been answered, l
16 but let me read parts of it anyway. " Currently, we have 17 licensed shift STA's that share the same office with the shift 18 foreman and have relieved the shift foreman for many 19 administrative duties. The STA is extremely cognizant of control 20 room activities.
21 There are also other similar examples of extra 22 reactor operators and senior operators on shift ttat provide 23 value to the shift in excess of the technical specification 24 requirements. There is a concern that requiring individuals ;
25 to shift jobs at a high frequency to satisfy the ' active FEDER AL REPORTING SERVICE INC.
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58 1 participation' requirements may reduce safety.- Has this been 2 considered?" l 3 The answer, I believe, is yes.
4 The fourth question:- "If the number of on 5 shift licenses prohibits anyone from meeting the seven eight 6 hour per day per quarter, is amending the technical specification 7 manning requirements a necessary recourse?"
8 We don't believe that would be the intent, that 9 anyone would have to actually change their technical 10 specification to require a different number of SRO's or RO's. j ll It does require you to, as Bill was talking about, having the 12 flexibility to adjust your schedules.
13 The last question: "Does performing seven 14 eight-hour shifts within a quarter as SRO in charge of fuel 15 handling satisfy the active participation requirement for the 16 quarter?"
17 The answer is yes. That SRO now would have, in 18 effect, a SRO license limited to fuel handling, and you would 19 have to keep records to show that if you're going to use him as 20 a fuel handler.
21 MR. RUSSELL: Let me clarify that. I'm not sure 22 what the intent of the question was, but if you have a senior 23 operator, and you administrative 1y determine that he is only i 24 going to handle and supervise activities associated with fuel 25 handling, in that case, it only takes one shift to be active FEDERAL REPORTING SERVICE INC. ,
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59 1 for that function of supervising handling of fuel. That can 2 be handled administratively by the certification by the 3' responsible officer that puts it into the file for that 4 individual and mainta,ining it on site. I don't want you to 5 send in and request to amend the guy's license to limit it to 6 fuel handling only. He was originally licensed based upon an 7 unrestricted license. He was examined for it.
8 However, prior to him returning to active 9 status, he would necessarily perform 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of parallel 10 fwatchstandingwithanothersenioroperatorinthecontrolroom, 11 and then at that point in time, you would have another 12 certification on file by the authorized representative of the 13 facility that says this guy's now ready to go back and stand i
14 licensed duties, unrestricted, in the control room. So that 15 the rule is clear, that it's eight hours for fuel handling, 16 and then the other shift requirements are for mode one operations 17 at power, for example.
18 MR. PATE: Let me expand on it a little more, 19 though, also. If you'ye talking about the guy has a SRO and 20 that's all he did was fuel handling, but say you were down for 21 six weeks and during that time he did his eight hour eight--or !
22 seven eight-hceur shitt.s during that six weeks, then he's still
- 23. a active SRo. Ce's not just a fuel handler, because he's met
( 24 the requireme'ts. Only if you had him as a fuel handler for ;
I 25 some extended time beyon6 the quarter, then you would have a l l
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1 60 i i problem meeting the quarter requirements.
2 MR. HANNON: I'm still not sure it's clear, 3 that if I have a fuel handling restriction on an SRO license, 4 for that guy to be considered an active fuel handler, he must 5 meet the same seven--
6 MR. RUSSELL: No. Only one for fuel handling.
7 MR. HANNON: No, that's to get--that's to 8 regain currency, to regain proficiency. We discussed this last 9 night.
10 MR. PATE: Okay; right.
Il MR. HANNON: He still, in order to be active, 12 even if he's got a fuel handling restriction, he does have to 13 meet the same requirements as a regular SRO. The only 14 difference is to get him to regain his proficiency, he only 15 needs to stand one eight-hour shift under instruction.
16 MR. MOLDEN: What is the other instruction; 17 what is he doing under instruction?
18 MR. COOLEY: Another fuel handler.
19 MR. RUSSELL: He's on a paralle) watch with 20 another SRO.
21 MR. COOLEY: That is certified as a fuel handler.
22 In other words, he has'to stand a parallel watch with a SRO 23 who is an active fuel handler at that time.
24 MS. SHANKMAN: Or an active SRO, full-time SRO.
25 MR. COOLEY: Or an active SRO that can be used FEDER AL REPORTING SERVICE INC.
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61 1 as a fuel handler if he's got an active license. See, there's
)
2 a special license--there's still a special license for fuel 3 handlers.
4 MR. FjOLDEN: The problem is standing the shift 5 foreman's license does not prepare this person to go out and 6 handle fuel, and I don't understand how doing one watch under 7 instruction does that, how that can guarantee that he's going 8 to be a safe person in charge of fuel handling.
9 MS. SHANKMAN: But we're talking about an SRO 10 llimitedtofuelhandling, not an SRO with an unlimited license 11 here.
~12 MR. COOLEY: So if a guy has an SRO license 13 and he's an active SRO, he can be used as an SRO with no other 14 duties to handle fuel, or be the supervisor in charge of fuel I
15 handling, with no other duties. If he's a senior with a 16 limited license, he's in a different category, because he can't 17 be used as an SRO. So any active SRO could be a fuel handler 18 senior, but if he is an active fuel handler and then he doesn't 19 handle any fuel for awhile, or for some reason he doesn't use 1
20 his. license, then he has to only stand one watch, or one 21 eight-hour shift with an SRO who is an active SRO, or an SRO ,
1 22 with a limited fuel handler, and then he has met that {
23 certification again, i l
24 MS. SHANKMAN: The only adjustments we've made l 25 in the rule for fuel handlers are that, in order to become i
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1 active, they only have to stand one parallel shift, which would 2 make it much quicker and easier than the 40 parallel shift,_and 3 that the requal program is limited only to those aspects of the 4 plant operation to which their license is limited, i 1
5 MR. PATE: Under applications, how to apply, 6 the first question: "When filing an application, the facility 7 is required to provide evidence that the applicant has 8 successfully completed the facility licensee's requirements 9 l to be licensed as an operator or senior operator.
10 Part of the training program is not complete 11 prior to filing the application for the license due to the 12 requirement to file an application 30 to 60 days prior to 13 the examinations. This has been acceptable in the past due 14 to the statement on the application above the facility 15 representative signature. It states that: 'The individual has 16 or will have completed by the time of the examination all the
' Will this continue to be an acceptable 17 required training 18 approach under the new rule?"
19 No. The answer is no, that it will not be j 20 continued. The application will be revised to remove the 21 words "or will have".
22 Questions?
23 UNIDENTIFIED SPEAKER: Bob, could you repeat i
24 that, please? l 25 MR. PATE: Sure. The question is, "Will this I
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63 1 continue to be an acceptable approach under the new rule?"
2 The answer to that question is that no, it will not be an 3 acceptable approach because the application which now--which 4 was quoted as saying he has or will have completed the training i
5 by the time of the exam, will be removed. Those words, "or 6 will have" will be removed. The new Form 398 will have that I
7 revision. l 8 MR. RUSSELL: More importantly, the Commission 9 has stated in the rulemaking that the authorized' representative 10 ' certifies that the individual has completed. It's not a future 11 completion, and we don't want to get into situations, well, at I
12 ; the time I signed it I thought he was going to complete, but 13 he didn't. I mean, it's completed. That's the clear meaning 14 of complete, not to be done in the future. I am certifying it's 15 l complete, standard Webster dictionary definition of complete.
16 MR. COOLEY: One of the items under 55.31, 17 Item No. 4, which says " provide evidence that the applicant 18 has successfully completed the facility's license requirement 19 to be licensed as an operator or a senior operator."
20 MR. RUSSELL: So that the old issue where you 21 used to submit them in advance, saying that the guy, you know, 22 you'd submit it and then you'd give him an exam and some of 23 those guys have failed the exam and you withdraw the application 24 at the eleventh hour, we're not going to see that any longer, 25 because at the time you submit the application, the candidate i
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64 I
I will have completed and, in all respects, be ready.to be {
i 1
2 examined by the NRC. It's not conditional. It's not based upon )
3 something that's going to happen in the future. The 4 responsible officer has certified to the NRC that in all
- j 5 respects that candidate is ready to be licensed,.and that the l 6 necessary programs are complete, and it should eliminate the l- 7 kind of problems that we've had on qual cards in the past, 'with 8 some enforcement actions that have been significant, with 9 confusion over whether the training program has to be complete 10 or not complete.
11 It's very clear in the regulation, must be-12 complete. So those words on the 398 are being revised to be 13 consistent with the requirements of the regulation.
14 MR. PATE: The next question, still under i I
i 15 applications, "The Examiner Standard, Section ES-109, lists the 16 eligibility requirements for licensed operators and senior-17 licensed operator applicants. one of these requirements is 18 that each individual spends three months on shift as an extra 19 man, under the supervision of a licensed or senior licensed 20 operator."
21 Under that, the first question, A: "Is this 22 requirement still in effect?"
23 Well, first I have to qualify it that it's not 24 a requirement. The Examiner Standards doesn't have requirements )
i 25 in it. However, it is consistent with our past practice, and FEDER AL REPORTING SERVICE INC.
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65 I it's consistent with the Reg Guide which--1.8, which endorses l b I
2 ANSI 3.1-1981.
3 The B part of that: "Where does this 4 requirement come from, given that it is not addressed in 10 CFR I l
5 55, and that the new revision is proposed to supercede the
]
6 previous requirements?"
7 This is consistent with our past practice for
)
8 determining eligibility, and it will be continued in ES-109.
9 The facilities can ask for a waiver and it will be considered.
l 10 The next question, still under applications: )
}
11 "The facility is required to provide evidence that the applicant 12 has successfully manipulated the controls for a minimum of five. ]
13 significant control manipulations, which affect reactivity or 14 power level. Is it acceptable to perform the same significant ,
15 manipulation five times?"
This was addressed in one of the previous I 16 17 questions. While it meets the rule, it's not the intent of the I
18 rule, and if, in fact, this is being done we would expect that i 19 in the application, that the comment sections do make it clear 20 that his five manipulations are all the same manipulation. !
f 21 The next part goes to written examinations and 22 operating tests. The first part addresses Part 55.41, written 1
23 examinations for operators. The question: "Part 55.41 content j 24 does not specifically address the licensed operator candidates 25 need to know technical specifications, yet the examiner standard, I
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i 1 Section ES-201, discusses the need to know technical 2 specifications."
-3 Actually, Susan, if you would--there's two more.
'4 Let me' read the rest,of it. Susan will answer this question.
5 The first part of that question: "What is the reason'for 6 this difference?", and the second part is: "Is ES-202 correct 7 in its application for technical specification knowledge?"
8 MS. SHANKMAN: I think we've gone over this 9 and' stated this morning, pointed out those sections of 41 that 10' really do hark to the technical specifications, and the thrust 11 of our work on technical specifications, because there's !
12 another follow-on question about the Westinghouse Owner's Group, 13 we expect that operators will use technical specifications as i i
14 appropriate'to their job, and a reactor operator, those items d 15 five, and clearly says how we expect them to know limiting l 16 conditions; particularly those things that they should recognize 17 and communicate to the SRO in a timely manner.
18- The same thing goes for the SRO. We don't _l l
'19 expect SRO's to be engineers unless they are hired by the ~l j 20 facility to be an engineer, also, and review technical 21 specifications. So to require job performance in your systematic 22 evaluation, plus our catalog should give you a clue.to the.
23 level of specificity, and you can't be anymore direct than that.
24 We intend to revise the examiner standards to give our examiners 25 better guidance. Pight now, I think it's not as clear as it FEDERAL REPORTING SERVICE INC.
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67 1 could be, but the required job performance is the key, and 2 if, for some reason, you feel you use technical specifications-3 differently'than.we:can interpret it, you should call that to 4 the Region's attention and discuss'it long before the exam 5 occurs.
6 MR. MOLDEN: Actually, the only point of the 7 . question is there's clearly a line item for the SRO, and 8 there's' clearly not a line item for the RO.
9 MS. SHANKMAN: Right. Well, Item 5, then, of 10 41 is an expansion. i 11 MR. RUSSELL: There is clearly a difference.in 12 what we expect an SRO to be able to do by virtue of directing 13 the activities of others. He must be knowledgeable'of all 14 Iaspects of license conditions. He approves work, work orders 15 -and other things, which require a knowledge of technical 16 specifications beyond the set of those tech specs which relate 17 to the knowledges under the reactor operator written exam.
18' So if you look at the knowledges related to tech specs, and 19 you start with'those subject areas, it does not cover the entire 20 scope of tech specs.
21 For the SRO, because of his role in assuring 22 on the back shift conformance to all of the Commission's rules, 23 regulations and standards, and because he's directing those 24 activities, we expect him to know those. Whether he knows the 25 bases for them or not, and whether he can approve TCN2 changes FEDERAL REPORTING SERVICE INC. l DENVER. COLORADO I
68 1 on the back shift by way of an administrative procedure change 2 that meets the intent. those things go directly to job-related 3 knowledge. We don't expect him to be able to develop a bases 4 'for a requirement on his own.- We expect him to understand what 5 the requirement is, and be able to carry it out. That's the b difference that we tried to articulate in these two sections.
7 An Ro doesn't have to know about approving surveillance, yet 8 surveillance are covered in the tech specs. An RO does need 9 to know about. limits on operation of the plant, as they relate 10 to the list of items under the written examination.
Il MR. PATE: The next question goes to Part 12 55.43, written examinations, senior operators. It says: "Part 13 55.43 does not specifically address emergency plan implantation.
14 This is addressed in Part 55.45. Will the senior operators 15 continue to be asked to classify events, given a specific 16 scenario, into four categories (UE, Alert, SAE, GE) from memory 17 on the written examinations?"
18 The answer is yes. Item 5 of the seven that 19 are included in that part of the regulation, of the seven 20 additional things that the SRO's have to know beyond what the 21 RO's have to know, addresses the assessment of facility 22 conditions and selection of appropriate procedures during 23 normal, abnormal, and emergency conditions, and there's where
)
24 it comes from. ]
l 25- The next part of that question, still going to l
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.1 written examinations: " Senior operators are required to know l
2 ; the facility operating limitations in the technical I 3 specifications and their bases." Question A, "If and when 4 the Westinghouse Owner's Group complete development work and 5 gains acceptance for the technical specification MERITS 6 program, this will vastly increase the bases section of 7 technical specification."
8 The subpart question on that, then: "Will the 9 NRC position change regarding the requirements to know the 10 technical specification bases if this new program is 11 implemented?"
12 The answer is no, as Susan indicated earlier.
13 MR. RUSSELL: We hope that as we implement 14 improvements to tech specs--which up until last Friday I was 15 {responsiblefor,andunderthereorganization, I passed to 16 someone else--but having been actively involved in getting a 17 Commissi:n policy statement out, we hope that the size of the 18 tech specs are reduced substantially as a result of this 19 program, and that we do a better job in the technical 20 specification bases of describing the why's associated with 21 the limits and the underlying assumptions that relate to them.
22 We hope that in the ..ong run, if we do a 23 reasonable job of developing those, that we will better define i
the knowledge that a senior operator should have related to the 24 25 technical specifications and their bases. I don't expect that i
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l l l t l l 70 j l 1 1 the volume of the bases is going to generate out to several l
l 2 three-inch notebooks full of stuff. It should be a signifi- .
3 cantly reduced subset of what's contained in the TSAR. !
4 Hopefully, it will be crisp, to the point, and directed to 5 what the guy needs to know to operate his job. We are a long 6 ways away from that. We are going to move into it slowly.
7 It's going to require a topical report submission and an approval 8 by the staff before it can be implemented on a plant-specific 9 basis. We will be looking at generic bases, and there will be 10 opportunity for utilities, through the development process, to l 11 comment on that, and I'm hoping that everybody being cognizant I
12 of this issue, will assure that we do the right thing when 13 it's finally done.
14 Our intent is not to add superfluous information 15 to the operator or senior operator job to examine him on it.
16 It needs to be related to his job, and if it's superfluous, 17 then that means an j thing you don't currently find in a catalog, 18 that's fair game for having that question thrown out on appeal.
19 We've done that in the past.
20 MR. PATE: The next question: "Will the NRC 21 be changing any of the eligibility requirements for taking the 22 SRO exam discussed in Examiner Standard, as a result of 23 implementing 10 CPR 55? This question is being asked in light 24 of the fact that 10 CFR 55 supercedes previous regulations.
25 Specifically: A, will the NRC require one year of experience I
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l 1 as an.RO prior-to entering the. training program for an SRO?
2 ANSI 3.1-1981 requires a minimum of six months." ,
3 Well, first of all, the answer is yes, except 4 that if a facility hAs an accredited program and a certified 5 simulator, then that requirement goes away anyway, it becomes 6 part'of your accreditation program. And when the ANSI 3.1 7 becomes effective, then it would go t'o six months even if you 8 don't have an accredited program.
9 MR. RUSSELL: Hold it, Bob.
10 MR. PATE: What?
Il MR. RUSSELL: That's one of the exceptions in I2 the Reg Guide that we took exception to.
13 MR. PATE: The six months is?
14 MR. BUSSELL: Well, six months--it is in the 15 Reg Guide in the regulatory position on page five, where it 16 explains the application process, and what we're talking about 17 is an SRO with prior experience--the total experience has to be 18 the same, but it's six months at the' facility for which he's 19 seeking a license, so you can substitute other experience to 20 lead up to-the total, but it is six years at that facility, or 21 six months at that facility.
22 11R . PATE: That's Position E. It still requires 23 a year, you mean?
l 24 MR. RUSSELL: He still has to meet the total I
25 experience requirements based upon experience possibly at other FEDER AL REPORTING SERVICE INC.
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72 1 facilities, or through other mechanisms, but he must have at 2 least six months experience at that facility. For instance, 3 if you look at the NUMARC commitments that were contained in 4 Generic l Letter 84-16, which go to how you count' experience and 5 'how much credit you give for a reactor's time, or time in a l 6 like facility, licensed as a ,ommercial reactor operator, we 7 believe that the regulatory position in endorsing ANS 3.1 is 8 consistent with that generic letter and industry commitment.
9 We are not adding anything more than what was committed to back 10 ,in May of 1984, in 84-16. That's the basis for the exceptions i
11 Iin the regulatory position section in Reg Guide 1.8, which 12 becomes effective one year following publication for all 13 licensees. It's effective today for anyone who was in the 14 i Fipeline as of the time of the Generic Letter 84-16.
15 MR. PATE: Okay, the second part of that
- 16. question, I believe Bill just answered, but we'll answer it 17 again. "Will the NRC continue to accept one year as a Navy 18 reactor operator, engineering watch supervisor, et cetera, 19 as meeting the one year reactor operator experience requirement, 20 if one year remains as a requirement?"
21 The answer is yes; no change in there. :
22 The next question goes to Part 55.45, operating j 23 tests. "Part 55.45 contains a new evaluation criteria which 24 requires an individual to demonstrate the applicant's ability 25 to function within the control room team as appropriate to the FEDER AL REPORTING SERVICE INC.
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l 73 1 assigned position, in.such a way that the facility licensee's 2 procedures are adhered to and that the limitations in its !
3 license and amendments'are not violated."
4 Part, A of that--let 's see , John, I guess we 'll ;
5 ask you to respond to this. Do you find the question there?
6 Okay. Part A of that: "Is this intended to be evaluated using 7 the manipulation criteria addressed on the operating examination 8 report contained in ES-301 which covers: 1) follows procedures; 9 2) observes and checks instrumentation; 3) dexterity and feel 10 for console operations, or will this evaluation be addressed 11 in a future revision of ES-301?"
12 MR. HANNON: I think, if you remember, when we 13 were discussing the revision to 157 form, when we were looking 14 at the page D that had the--there was a two part, two-page Part 15 1 with the simulator and one without the simulator, one of'the 16 competencies there that is being evaluated is directly related I
. 17 to this item, and it goes to the communications within the 18 icontrol room team, and the candidate's ability to work with the 19 team in a team approach to carrying out the plant's procedures.
20 So yes, it is being addressed in the operating 21 test, and as indicated this morning when we discussed the 157 22 part.
23 (Off the record to change the tape.)
24 MR. PATE: The next question goes to Part 55.53, 25 conditions of license, and here we discuss again the active and i
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1 inactives on the 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, and the position.of the RO in the l'
2 refueling position, or refueling restriction on his SRO license.l i.
3- I believe we've answered all that, and so we'll skip on to the f
4 next one.
5 The next one, the question goes to Part 55.57, 6 renewal of license. "The NRC will renew a license if the 7 applicant meets the requirement and medical requirements- "
8 excuse me, let me read that again, "The NRC will renew the 9 license if the applicant meets the requalification and medical 10 requirements and there is a continued need for the licensee to 11 operate the facility. What criteria will the NRC use to 12 determine if the continued use of a license is required?"
13 l That is up to the facility.- They define who 14 needs a license and who doesn't. !
15 The next question goes to the medicals. The 16 first question: "Is the medical- ", let me see, John, maybe 17 I should ask you to respond to these next two?
18 MR. HANNON: Refer to Susan on that.
19 MR. PATE: Oh, Sue? Okay.
I 20 MR. RUSSELL: Let me go back and supplement the 21 last answer, just to make sure it's clear, j 22 MR. PATE: Okay.
23 MR. RUSSELL: We do have a few positions, 24 operations superintendent, if that title is used, that requires )
1 25 a license. Clearly, you need to have an operations FEDERAL REPORTING SERVICE INC.
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1 superintendent because it's in the license conditions in the 2 . tech specs, and clearly, that individual must be licensed.
3 so there's a case where we're not going to leave the determina-4 tion of need solely up to the facility.
You either have to have 5 that individual be licensed, or propose another individual to 6 take over the position.
7 We do intend for need to be based solely on the 8 economic decision on the part of the utility. We have indicated 9 that the requal training will ue done the same for people on 10 shift as off shift. If you are willing to put the person in a 11 training program, on the equivalent of a one and five or a one 12 and six rotation that's off shift, you can afford that 13 commitment of time, then that's the facility's decision as to 14 {howmanylicensestheyneedandwhethertheindividualhasthe l
15 time to.put into requal training.
16 There's no longer any testing out, exemptions 17 from requal training. It's on a continuing basis, so the 18 issue is one, we believe, of economics, and you should decide 19 how many you need, and the Commission has stated that it 20 believes that more licenses are preferred; that is, the more 21 people you have licensed, the more people that understand 22 operations, the better position you are in to support the 23 operation of the facility. More people are staying current 24 with changes in the plant and what's going on, and we feel that 25 that is advantageous. It's one of the things that we look at l
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1 76 1- closely, but it is solely a utility decision. Do you need that 2 particular individual to have a license? And if you answer !
3 that question yes, and you say you have a need', there is no 4 .further review by the NRC of need.
5 Similarly, if you say you don't need it anymore, 6 that's a condition under which the license automatically 7 expires. So you, as a facility owner, control who has licenses 8 on your facility.
9 MS. SHANKMAN: The medical questions ask must 10 you submit a 396 form for every license application, and the 11 answer is yes, but the revised 396, so the detailed medical 12- information only has to be submitted when you are requesting a 13 conditional license.
14 The second question is about NRC: "Will it 15 be acceptable if the licensee designs and implements a modified-16 Form 396 to include acceptance criteria required?" You can use 17 that for the refort that you want to have on file. You can 18 modify, and if you want to work with others so you have the same ;
i 19 one at several facilities, that would be a good idea to have an 20 industry form, but in terms of our submittal, the 396, as 21 revised, is what we want to see, and supporting evidence can be 22 submitted however you want to submit it. ,
l 23 MR. HANNON: There was a reldted question on 24 whether or not if one wanted to, they could take the forms, )
1 I
25 regardless of which one we're talking about, the 398, the 396, l
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77 1 any of them, and reduce them down in size so that they could 2 be produced by some sort of word processor, and that's fine.
3 As long as it's the exact same content, you can produce these 4 forms locally if you,want, but it has to have exactly the same 5 content.
6 MR. PATE: That's all the questions that go to 7 the rule. Now we'd like to address the ones that go to the 8 simulator.
9 MR. MOLDEN: Before you do that, I have one I 10 desire to ack. I understand that the authorized representative, '
11 or who is the authorized representative for a facility is i 12 changing. We currently go to our general office as the person 13 that signs. I'd like to know more about that.
14 MR. RUSSELL: We will accept, as the authorized 15 representative, the senior individual on site responsible for 16 operations. Some companies have a vice president on site, 17 some have a site manager. Others choose to have it be done at 18 a higher level, and send it off site to the corporate office, ;
19 and do that. That is acceptable to us. It is also acceptable 20 to be done on site. If, within your company, you choose to have 21 it be done at the general offices off site, at the vice 22 presidential level, above operations on site, that's your l 23 choice. We will accept it from the authorized representative 24 who is the senior person on site responsible for operations.
25 It need not be the same authorized representative who requests FEDERAL REPORTING SERVICE INC.
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license amendments under Part 50, okay, and there has been some 2 l confusion on that in the past. !
3 There is, under the facility license, only one 4
authorized representative; generally somebody on the corporate 5 level, a senior vice president, if he is the authorized 6 representative for the facility, he signs license amendment 7 requests, makes other certifications. We will accept, for Part 8 55 licensing, the senior man responsible for operation on site.
9 The plant manager is an example.
10 MS. SHANKMAN: I want to call attention to 11 something on the 396 form, it's on the 474 and it_will be on the 12 398. 'Above where that signature appears, there is now a 13 statement which has always been implicit, but now it's explicit, 14 .that any false statement or omission in this document, including ,
15 attachments, may be subject to civil and criminal sanctions, 16 and then the person signing it, the statement says: "I certify, 17 under penalty of perjury, that the information in this document 18 and attachments is true and correct." And so that's, I think, l
19 why we're adjusting it so that the site person will be closer l
20 to the information and is going to sign this, and we have to be ,
J 21 absolutely sure.
22 With the medical, we're particularly concerned 23 that that person is certifying that the ANSI standard has been 24 given to the physician, and th'. the physician has read it and
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( t 1 MR. PATE: Okay. The next question has to do 2 i with the simulatc/t. . Jerry will answer those questions.
3 MR. RUSSELL: Before we go on, if there is 4 somebody that has to leave to catch a plane and you've got a 5 question we haven't answered, just pass the question up and we 6 . will answer it and put it into the NUREG when it's published.
7 MR. JERRY WACHTEL: Okay. On page 3, Section C 8 deals with simulation facilities, and Item 1 under that regards 9 performance testing. Question A says: "Is the list of 10 malfunction tests, required by Part 55.45 on the simulator, 11 limited to the malfunctions listed in ANSI /ANS 3.5-1985, 12 Section 3.1.2?"
13 And the second part.of that question asks: "Is 14 the 25% malfunction testing requirement developed from this 15 list?"
16 The answer to the first'part is no,.as we 17 described before. Performance testing includes not only the-18 malfunction tests shown in Section 3.1.2 of the standard, but 19 also those applicable items from the appendices to the standard, 20 and of course, the provisions of 55.45 (a) , and the 25% per year 21 which refers to performance testing, which includes the 22 malfunction testing as a subset of that, applies to the list 23 that I just mentioned.
24 Question B asks: "Does the NRC continue to 25 endorse the requirement in ANSI /ANS 3.5-1985 to perform annual FEDERAL REPORTING SERVICE INC.
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- 1. operability tests? If so, should th'is be part of the 25% i 2 testing, or should it be done annually?"
3 And I think we touched on that earlier as well.
4 The answer is yes, we continue to endorse Appendix B on 5 operability testing, and as the standard requires, this must be 6 done annually. This is not a part of the 25% performance i
7 testing. )
l 8 Question C asks: "Due to the extensive use of.
9 the simulator for training, there may be times that meeting the 10 25%. performance testing requirements within twelve months of the 11 last set of tests is not possible. What is the allowable t
12 time table tolerance regarding this situation?"
13 And I'll add to that Question D, which asks:
14 "Is it permissibic to perform 50% testing in one year and no 15 testing in the next year, as long-as 100% testing occurs every 16 four years?"
The regulation provides, in 55.45 (b) (4) (vii) r 17.
18 and (b) (5) (vi) that performance testing be done approximately 19 25% per year on a continuing four-year cycle. The goal is to 20 ensure that ongoing testing and upgradi.ng of the simulator, j 21 and to assure that the simulator is maintained on a consistent 22 basis with the status of the plant. You must present to us, 23 on Form 474, your performance testing schedule. To the extent 24 that it must deviate from 25% per year, if it must deviate, you 25 need to let us know just what those deviations are and we will ,
I
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i 81 1 have to evaluate it, essentially, case-by-case. We're not in a
? position to give you an allowable table of tolerance for 3 deviations from 25% per year, but I think it's safe to say that 4 performing 50% in one year, and no tests in the next year 5- wouldnotmeet.the[ntentof.theregulation.
6 And let me clerify here that we really don't 7 want to see the minutiae of your performance testing schedule, 8 which tests are to be run on which days of which months. We're 9 looking at an annual, an annualized 25% per year basis,-and i
10 that's the block of time in which we would like to see your 11 Performance testing scheduled, and any changes that may need I
12 ltobemadetothat schedule, you need to tell us about, based 13 lonthatannualblock.
I I
14 Let me go'to Question E. " ANSI /ANS 3.5-1985 15 requires that performance tests be conducted in the event a 16 design change results in a significant simulator configuration I
17 or performance variation. What is the NRC's definition of 18 significant?"
19 We would use, as an operational definition of
- 20. the term significant, any change to the simulator or its models 21 or software that might cause the results of performance tests 22 that you conduct to fall outside the acceptable performance 23 criteria, which are set within the standard itself. As a point 24 of information, the standard does not define the term 25 significant, and for an official definition, or an official FEDERAL REPORTING SERVICE INC.
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82 1-clarification, you.need to seek guidance from ANS itself.
2 It's possible that this definition will be clarified in the next 3-revision to the standard, but unless and until it is, we will 4'
use our operational, definition of that term as I just described.
5 Question 2 says: "Regarding simulator 6
certification of ' reference plant' simulators,'since the NRC 7
has not published its guidance on assessing simulator adequacy, 8
is it advisable for utilities to apply for certification prior 9 to this being published?"
10 !
of course, the answer is that that guidance is l 11 now available. !
12 There are' continuing questions on simulator 13 certification that appear on page 9 of this' submittal. Let me 14 start with--let me make sure here.
15 MR. PATE: Start with Item 2 on the top of the 16- page.
17 MR. WACHTEL: Okay, yeah, Item 2 on the top of 18 page 9. "Regarding certification submittal to use a plant 19 reference simulator in accordance with Part 55.45 (b) (3) (iii) 20 60 days prior to the proposed conduct of NRC operating tests."
21 Question A: "Is this 60-day submittal, prior to 22 proposed NRC examinations independent of the 46-month l
23 requirement to submit a certification for use, as addressed in l 24 (b) (2) (iii) ?"
25 The answer to that is no. The 60-day submittal FEDER AL REPORTING SERVICE INC.
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is the one that must be made no later than 46 months after 2 the effective date of the rule. It is not independent. That L 3- 60 days is 60 days prior to four years after the effective date j l
4 of the rule. That's where the 46-month period comes in.
5' Question B is not applicable because it is based L i 6 on the different answer to Question A, and Question C: "Are 7 100%-of the performance tests required to be performed prior 8 to initial certification submittal to the NRC, or is an 9 established schedule and completion of 25% of the tests 10 sufficient?"
11 The answer, as I think we covered before, is i
12 that 100% of the performance tests are-required prior to your '
13 submittal of the certification, or of an application for 14 approval.
15 Question 3: "Regarding decertification of a 16 plant reference simulator: A, what process will be used to 17 decertify a simulator? 1) Will an NRC examiner be able to 18 decertify a simulator based on his observations of simulator 19 performance during an NRC exam?"
20 We covered that this morning as well. The 21 answer is no, an examiner will not be able to decertify a 22 simulation facility based upon his observations. He will 23 report those observations to the NRC, and we may choose that 24 information to go out and perform an audit or an inspection, 25 and that leads into Question 2.
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84 i 1 "Will an NRC certification team be sent to i 2 the facility to conduct a simulator performance audit, using l 3 the new simulator certification criteria?"
4 The answer is essentially yes. The NRC staff 5 will be the ones to conduct the review and the inspection.
i 6 It will be a two-phase process, an off-site review, followed 7 by an on-site inspection, if necessary, and only as a result
- 8. of that inspection might certification be removed, as a last i
9 resort.
10 I think that's it on those. (
11 MR. RUSSELL: It's even more important--a 12 certification is not removed as a result of an inspection. It's i i
J 13 removed as a result of failing performance tests which are 14 required by the regulation. Through the inspection we conduct i i
15 performance tests where we audit the ability of the simulator ]
f 16 to perform as described in the performance tests that you 17 submitted. So, in fact, if the machine does not work and we J l
18 find that it doesn't work through an inspection, the criteria 19 is still the failure of a substantial number of performance 20 tests, such that you cannot perform a meaningful operating test 21 as described in the regulation.
22 So that the conclusion is based upon the 23 requirements for the operating test, not just on failing some You have to fail performance j 24 fraction of the performance tests. 1 25 tests, but it's got to be a substantial enough number of l l
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1 performance tests that it impacts on the ability to conduct an 2- NRC. operating examination. So one performance ~ test failure 3 does not necessarily mean that the simulator would be~
4 decertified. It_has to be a gross enough set of failures that 5 .you can't conduct a test.
6 MR. PATE: The last set of questions we want 7- to look at in this submittal would be under requalification, 8 The first question there: "Regarding NRC administration of 9 requalification exams, it states that the NRC will conduct a 1
-10 six-year renewal exam on a random basis. Will the utility be 11' able to establish its own schedule and. selection of people to 12 insure the exams are conducted with minimal impact on the plant)'
13 The answer is no.
14 The second part of that question: Will the NRC
'15 be increasing the number of exam visits to each site to 16 accommodate the additional exam requirements?"
17 Again, the answer is no. We will be having two 18 trips a year per facility, and will try to incorporate the
, 19 exams with those trips.
20 MR. RUSSELL: His "no" was only with respect to 21 you choosing when and who. We will try to minimize the impact 22 on the facility. To the extent we can, we will try and 23 coordinate replacement exams and requalification exams on 24 approximately the same cycle. We are not interested in creating 25 artificial pertavasions (phonetic) which raise anxieties, and FEDER AL REPORTING SERVICE INC.
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i 86 i 1 it is likely that you will have dialogue back and forth with 2 both regions prior to their issuing a 90-day letter scheduling i 3 when they're coming to conduct exams. This is the practice 4 today.
5 Also, the randomness, our intent is to-take a !
6 look at the pool of six-year licenses that you have on site at. l 7 the time we go to administer the exam. We will select from 8 those individuals that have six-year licenses first. We will 9 also look at candidates who have not yet been examined by the 10 NRC, before we would look at candidates potentially a second 11 time around. That is, if an individual had been examined one 12 year and on a six-year license, we would consider the other 13 candidates first before going back to that candidate. So the 14 guy is not going to be on a random basis of potentially having !
15 his number come up three years in'a row or three examinations-16 in a row. That's not the intent. l 17 I should also clarify that for the purposes of 18 evaluating the facility program, we will still be selecting 19 candidates to be examined to judge the quality of the 1 20 continuing training program, some of you are involved in a 21 pilot program now. Recognize that the rule permits facilities 22 which we feel have satisfactory programs, to certify to us that 23 the necessary operating tests and written comprehensive 24 examinations have been completed. The mechanism that the staff 25 uses to obtain confidence in that program, right now, is being i
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-1 tried on a pilot basis, called the Pilot Requal Program, where 2
we evaluate the.' examinations that you develop, use a parallel 3 grading technique, et cetera.
4' That issue is not yet resolved with the 5
commission. . I must go back to the commission at the end of 6
May, give them the report on that result, and then we will 7
decide whether we continue to use the pilot program for ;
8 !
evaluating utility programs or not, or whether we will go back i 9
to randomly selecting operators, other operators to get a 10 sufficiently.large sample to judge the continuing training i 11 program.
12 So that's an ongoing effort. Many of you are 13 involved in it, and we'll be interested in your feedback, and 14 well as the feedback from the regions, which is due to me in May, 15 and I expect to get a Commission paper down in about June on 16 that result.
17 MR. PATE: One more question on requal. "Part 18 55.59 states that in lieu of accepting the certification by i
19 facility licensee that the licensee has. passed written i
20 examinations and operating tests administered by the facility l 21 licensee, the Commission may administer comprehensive 22 requalification written examinations and an annual operating l 23 test. Will this testing take the same form and frequency as 24 the previously established 20% testing at 50% of the utilities 25 in the Region?"
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2 except it'll now be about 16% of the operators at all h 3 {
facilities in the region every-year.
4 That's the last question from this submittal.
5 MR . ' HANN ON : I'd like to expand a little bit 6 on the answer to that on the requal exam, the form of it.
7 You can anticipate that the operating test will resemble the 8 operating test that would be given for an initial candidate, i
9 but the written exam would be geared directly to the job 10 performance. The written exam is going to have to be 11 operationally-oriented.
12 MR. MOLDEN: I understand what you said, but 13 already, with the six-year. exam process, you have to examine l
14 16% of the candidates. The question is, are you going to 15 examine on another basis, like the pilot program, an additional 16 number of candidates? '
17 MR. RUSSELL: Well, let me address it now in 18 transition, because I think that's where we are. Ultimately, 19 we'll get to a steady state where everybody's got six-year 20 licenses, and with the examining process being the way it is, 21 we would shift to examining approximately 16% of the licensed 22 operators, total, each year, and that's what we're budgeted for.
23 We are presently budgeting, and as a goal, 24 supposed to be examining 10% of the licensed operators at all 25' facilities, and do that on a sampling basis of 20% of the FEDERAL REPORTING SERVICE INC.
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1 operators at the facility every other year.- That's a budget 2 -assumption. That's a direction from the Commission.to me, and 3 a direction from me to the five regions. We haven't met that t t
4 goal yet, for the last three years running. We have done less 5 than 10% of the licensed operators in the U.S. for a number of 6 different reasons.
7 We're in the process-of transitioning from that 8 program into the six-year license, with doing the exams at the
-9 facilities at approximately 16% per year. The transition 10 process and how we obtain confidence in the facility program 11' is the subject of the pilot program evaluation that's going on
-12 now that I need to provide answers to the Commission on in May 13 or in June.
14 I am anticipating and I'm hoping that the
.15 results of the pilot program would be support for a continuation 16 of that effort, and not immediately moved into examining 16%
17 of the operators every year, or 32% of the operators every 18 other year, but that's a function of how well the pilot program 19 goes, and how much confidence we get in the facility's ability 20 to examine themselves.
21 We had some experiences with the early pilot ]
i 22 program where operating tests were not being conducted. My l J
23 feedback was provided to all the participants. We had some i 1
24 cases where, in fact, training was conducted, performing l I
25 practical factors to meet the Denton Letter requirements, instead j l
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l 90 1 of conducting an operating test where you evaluated the i 2- candidate's performance. On certain practical factors he was 3 able to, for instance, perform it incorrectly three times, and j
4 if on the fourth time he did it satisfactorily, that was 5 checked off and it was determined to be acceptable. We are I
6 now talking about an examination, and that examination being !
l 7 given annually, and we need to develop confidence in both the ]
8 non-simulator operating tests for those plants that don't ]
9 have them yet, and confidence in the operating tests, plant 10 walk-through simulator tests for those facilities that have 11 them. ,
I 12 I am hopeful that we can generate that 13 confidence through a process that's similar to the pilot 14 program. If we cannot, then we will continue to conduct our 15 own examinations to gain confidence in the utility's programs, 16 and the track record to date for the last calendar year and 17 the calendar year before, we have had approximately 25-30% of 18 the facilities evaluated fall into the category of unsatisfactory q 19 or marginal continuing training programs. They were not 20 maintaining a level of knowledge that was needed, and the 21 people were not current on changes in facility design procedures l i
22 and operating experience and events.
23 That's what we need to see, and until such l
24 time as we start having some successes and the track record l l
25 changes, there is going to be a pressure to continue examining. {
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I 93 1 So right now, the first--we've had some cases that have been l l
2 very positive, and we've also seen the first example where a l I
3 utility has failed a large number of their own candidates under i 4 'the pilot program. ,Lemerick, in their examination of their 5 operators under the pilot program approximately two weeks ago, 6 had six out of twelve senior operators fail. It was an area 7 that was found to be weak. It related to procedures and how j l
8 they were doing it. It was emergency procedures associated {
9 with ATWS event, and they found some holes which they are now 10 in the process of correcting.
11 I characterize that as a success, because it i 12 shows me that the industry process of evaluating themselves is 13 working, and that feedback is going back into the program, and 14 things are being corrected where deficiencies exist. It did 15 take the NRC going in and conducting examinations on ATHS 16 to find that out. That's the kind of successes we need to start 17 seeing. Find your own problems and fix them, and let us stand
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18 on the sidelines and watch. That's the mode I want to get into, 19 and I hope we get there in the near future, and I'll see what I
20 feedback I get that's being done in all the regions now. I'm i I
21 waiting for that written feedback by the end of May, and then 22 I have to put that into a response to the commission, and then 23 I have to get commission approval for how I redirect the program.
i 24 So that's a question mark that's still up in the air.
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25 MR. COOLEY: The next group of questions that l 1
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I have from South Texas, I think, have essentially all been 2 answered and asked.
3- MR. RUSSELL: South Texas agree-with that?
4 UNIDENTIFIED SPEAKER:
Yes.
5 MR. COOLEY: So I think we can probably go to 6 the open questions.
7 MR. RUSSELL: If someone has questions that 8
they want addressed at this time, feel free to come up to the l 9 mike or, if not, we're ready to call it a day. All those in 10 favor of calling it a day, rest your questions. ,
11 MR. PHILIP BARELY: I'm Phil Barely from Public !
'12 Service Company of Colorado, and I presently--we have a program 13 where we have licensed maintenance people as senior reactor 14 operators limited to fuel handling. My question is, to what 15 extent will this new rule--to what extent is it going to apply 16 to us, since in the comments preceding the rule and some things 17 like that, there's mention that this is not being covered, i 18 it's going ~to be covered as it is currently being done. We 19 have several questions that pertain to that, such as i
20 requirements for a simulator. !
i 21 Presently, for the past 14 years, as long as 22 we've had SRO's limited to fuel handling, we have not been i
23 required to give operating exams. Our annual recall exam is a '
i 24 written exam only. I 25 MR. RUSSELL: For a license which is conditioned I
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to fuel handling only, the testing and requalification program 2
should be' appropriate to the license as it's conditioned.
3 He is not permitted to operate the facility. You would not be l
4 required to give him an operating test, as is described in the 5 regulation. So that the. limitations are as appropriate, and 6
that's why we commented earlier.that a person who has a license 7- where the company subsequently chooses to limit it to fuel i 8
handling, we don't see it would be in the company's interest to .1 9
amend the license to limit it to fuel handling only. They can 10 do that through the administrative process of just keeping him Il current for handling fuel, but not current and active with 12 respect to manipulating the controls.
13 MR. EARELY: As far as a simulator, what type 14 of--what are we looking at as a simulation facility for 15 strict 1.y fuel handling types?
16 MR. RUSSELL: It would not be required for fuel l 17 handling only. It would be required for the f acility, though.
18 MR. JOE GASPER: Joe Gasper, from Fort Calhoun.
19 A further question on that, we had a concern on restoration of l
20 a inactive license es a full-scope SRO license, and we wanted )
1 21 to use that individual for fuel handling during refueling.
22 Would that individual as a full-scope license have to go through 23 the 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of concurrent duties, or just eight hours of 1
24 concurrent duties? l 26 MR. RUSSELL: Your second is correct, it would l FEDERAL REPORTING SERVICE INC.
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94 1 only.take eight hours under parallel watch with a person whose i 1
2 license is active, whether that's another licensee limited to !
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3 fuel handling only, or it's a senior reactor operator, that's 4 all it would take. -
5 MR. GASPER: Okay. Thank you.
6 MR. DAN PACKER: Dan Packer, Louisiana Power and 7 Light. You mentioned earlier, Susan, about a training program 8 for the examiners on writing terminal--the learning objectives.
9 How is that program being instructed; who's teaching that?
10 MS. SHANKMAN: Okay. Shelly Spielburg (phonetic)-
11 and I; mostly Shelly. I started several years back working on 12 writing multiple choice questions, and then Shelly has been )
13 doing a one-week training session. She's done it in all the
)
.14 regions, and'she's repeated it twice at headquarters for those 15 examiners that weren't employed at the time that she did it in 16 the regions. She also went to each of the contractors and did 17 a one-week training session, in which they took learning 18 objectives and converted them into testing objectives and 19 practiced writing testing objectives. ;
20 MR. RUSSELL: We've shared that information, 21 also, with INPO and we've had INPO staff come up and participate 22 and take the materials back with them, and so the information 23 that we're using with respect to developing examinations is 24 avai]able to you all through INPO, or even through the staff if j l
l you want to request it.
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MR. PACKER: Would you say it's going to change 2
I the way the exams are now, largely an essay-type; most of them ,
3 are.
4 MS. SHANKMAN: Well, first of all, the exam 5
standards right now requires that you have only 25% of the exam 6
be multiple choice, and 50% short answer, and 25% longer' answer, !
7 and I don't see that that standard is going to change 8 significantly.
I 9
One of the--well, you know we're working on the 10 issue of the generic exam, and if that--that prototype exam 11 will be all multiple choice for theory and component operation.
12 I don't know, I think that the Region 4 examiners have all been 13 through the training, so I think that there has already been a 14 change.
-15 MR. COOLEY: Somewhat. But we're not--nothing :
16 in the future calls for us to go to more than what's in the !
17 standards right now, for two reasons--
18 MS. SHANKMAN: Yeah.
19 MR. PACKER: It's been a long time since we've 20 had an exam, so...
21 MR. COOLEY: Manpower is one constraint that 22 we're still fighting. It takes a lot of up front time to 23 develop these multiple choice-type questions, good multiple ,
24 choice-type questions, so I don't see any change towards that 25 in the near future.
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MR.- COOLEY: Essay-type' questions. !
4 MS.,SHANKMAN: Right.
5 MR. PACKER: We have seen-more of them.
6 MS. SHANKMAN: Yeah, the list so many, and s ,
7 describe in a short paragraph. J 1
8 MR.. PACKER: Looking at the 55.45, Item No. 13 I h
9 on teamwork, how will that be evaluated in the operating test? 1 10 You know,.we'may get to a point one day, we've got 60 licenses 1 11 on.our site, where we're only running two or three person i 12 classes. We'may be a ways away from that, but then of the two' 1
- 13 candidates, and you've got to do an operating test and then 14 evaluate.them from a team' standpoint, how'they operated as a ]
'15 team, 'l f
16 MS. SHANKMAN: With 60 licenses, and you don't 17 think you'll have enough to do a shift evaluation?
18 MR. PACKER: No. I'm talking about the '
19- . operating test itself, when you have to evaluate one single 1
20 candidate on how he reacts and interreacts with the team.
21' MR. RUSSELL: You could put some licensed I 22 operators on the team with him, and we would just put an 1
!. 23 examiner with the individual that's standing for the exam. ]
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24 MR. COOLEY: Have one of your instructors 25 standing there, like we have in the past.
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'l MR. PACKER: We don't have a simulator. 1 0 2 MR. COOLEY: You've never had any. simulator 3 exEms, and we've done that quite a bit. If there's'only'two l 4 guys, somebody stands in and he just can't take an active role 5 and tell-the other people.what to do. He does what the shift 6, supervisor tells him to do, but he can't give hints to the f, A p people taking the exam.
8 MS. SHANRMAN: Should I:go to this control now?
h4 - .
9 MR. COOLEY: That's been done before.
10 MR. PACKER: In 55.57 in renewal, in looking at s
[
-) , 11 past performance, and one of the things you said earlier was s-12 that an NRC letter or a letter of reprimand might be part of 9 3,
{., . s ,
, 13 what you'd evaluate, a letter of reprimand.specifically from the y- 14- NRC, or one from the site'itself?
15 MR. RUSSELL: Good point. M.rst, the company 16 certifies that the individual has performed in accordance with
's 17 the terms and conditions of his license, and that has been 18 satisfactory. That is for you to. determine how that performance
-19 has been, through whatever mechanisms you want to use; whether 20 it be performance evaluations,. ether information that_you'have 21 in your company files related to that individual.
22 ,
With respect to the NRC review, we would make
~23 our review based upon two things: One, the certification from L 'O 2'4 the company; and two, any official enforcement actions taken 25 against the individual which are in his official docket file. i FEDERAL REPORTlWG ShMVICE IWC. ;
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I l-98 1 It does not include information which has not been formally i 1.
2 transmitted to the individual under his license, and it must l
'3 be a completed action. The fact that an individual is under 4 investigation by the NRC does not result in something going 5 into his file. It only goes into his file when we complete 6 an enforcement action and he receives a letter, " Dear Licensed 7 Operator, Contrary to the requirements, terms and conditions of 8 your license on such-and-so date, you did XY and Z," and it's 9 a. formal notification, and there is guidance as to what may be 10 permitted in.the docket file and what is not, and essentially, 11 anything in the docket file of the NRC is information which can 12 be--has already been presented to that candidate, whether it i
13 be an examination grading report result, or it be an enforcement 14 action, he would have it.
15 MR. PACKER: On the. training program approval, i
16 if you have an accredited program and you certify that you're 17 doing a SAT process, that's one method. You also listed under 18 that item, implementation of INPO 86.025 as another approach..
19 MS. SHANKMAN: That's really the same.
20 MR. PACKER: It's really the same?
21 MS. SHANKMAN: Because 96.025 is the SAT 22 approach, so...
I 23 MR. PACKER: Okay. Then would that be all 24 aspects of that, or being that it's a guideline--
25 MR. RUSSELL: Let me clarify it.
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The accreditation process has a hierarchy of l 2 documents. The' top level requirements are what are called 3 ' objectives. You must meet the intent of the objective in order -
4' to be accredited, a,nd those are contained in INPO 85.002. The 5 commission has reviewed those, and we have endorsed-the INPO 6 accreditation objectives and criteria as meeting a systems 7 approach to training. There are twelve, I believe, objectives. 1 8 Under the twelve objectives, for each one are 9 a number of criteria, that.if you meet those criteria, you also 10 meet the objective, but the opposite is not always the case.
Il That is, you may not meet one criteria, but you still may meet 12 the intent of the objective through some other mechanism. The 13 criteria and objectives are described in a document, and that's 14 used for accreditation and that's what you go through and do 15 your self-evaluation against.
16 subordinate documents to that are guideline 17 documents. There are guidelines for licensed operator training.
18 There are guidelines for maintenance training. There are 19 guidelines in other areas. One guideline is a guideline for 20 continuing training for licensed operators; it's been recently 21 issued. That guideline gives information both on content, of 22 what is appropriate for a continuing training program, and it 23 describes process by how you evaluate and feedback information 24 from plant operations, performance evaluations back into the 25 process. It's based upon a TSD process.
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1 You cleary do not have to cross all the t's and 2 dot all the l's of everything that's in that guideline. That 3 guideline, however, constitutes an acceptable method of 4 implementing a performance-based, SAT-based continuing training l
5 program that the staff would find acceptable, and which INPO 6 has found acceptable.
7 The next level below that are good practices, j 8 There are some--
9 (Off the record to change the tape.)
10 MR. RUSSELL: The next level below guidelines 11 are good practices. Those are things which INPO has seen 12 facilities do that it worked particularly well for a facility, 13 and they have provided guidance on those. So there is clearly 14 a hierarchy scheme.
15 What we have concluded is,.if you are accredited, 16 we believe that you understand what the objectives are, and how 17 criteria are used, and what the process is for developing a 18 systems approach to training. We think that that understanding, 19 along with the guidelines that are contained in the recent INPO 20 continuing training document, provide an adequate basis for 21 you to do a review of your own programs and develop it, and 22 certify to us that your program is, indeed, based upon a 23 systems approach to training.
24 We believe that, clearly, there are two final 25 parts to that. One, you need to look at the tasks that are FEDER AL REPORTING SERVICE INC.
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.( l relevant to the job, decide which ones are appropriate to train 2 on on a continuing basis, based upon such criteria as 3 importance of the task to the safety function and frequency of 4 performance. Clearly, emergency procedures would fall into 5 that type of category. shift relief and turnover would be 6 outside of that category, such that your continuing training 7 program would not address shift relief and turnover, but it may 8 address emergencies.
9 If you've operated continuously at steady 10 state for the entire period of time between outages, you would 11 not necessarily have performed startups and shutdowns of the 12 plant. In that case, you may want to fold the startup and 13 shutdown into the continuing. training program, and do that on
~14 a simulator.
15 It's that type of flexibility, and reviewing 16 and determining the content of the program which I feel is the 17 most important attribute of the change to the regulation, which 18 gives you the flexibility to tailor that program to the needs 19 of the job incumbents, and to bring them up to a comparable 20 level to what's been done with the initial training programs 21 through the INPO accreditation. That's the process we think 22 should be followed. It doesn't mean that everything has to be 23 done in 85.026 with respect to simulator training, or 85.025 24 with respect to continuing training. Those are guidelines, and 25 you really need to address the issues as to how much of that FEDER AL REPORTING SERVICE INC.
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102 1 should be.followed or done with INPO, not with the staff. We 2 are not in the. position of reviewing and determining what 3 constitutes INPO' requirements. We want to move out of that.
4 We will provide our , comments to INPO should we see problem areas 5 for INPO to address generically with the industry. We do not 6 want to'get into the mode of providing guidance to individual a 7 utilities on how much of an INPO document needs to be followed 8 before the staff would accept a certification. That's for you-9 and INPO to work out.
10 MR. PACKER: That addresses my concern. Have.
11 you piloted 157 at all, or any practice with that at all?
12 MR. HANNON: The new 157 will be available for 13 use after May 26, and it will be getting piloted in use on the 14 job. We'll be revising it as necessary, based on the feedback 15 we get after it becomes applied.
16 MR. PACKER: Thank you.
17 MR. RUSSELL: We had one good question that 18 was submitted, and unfortunately, the people have already left, 19 but I want to cover it because it's an important issue.
I 20 The question is: "If a licensee determines he 21 is out of conformance with the INPO-accredited training 22 program, is that reportable to 10 CFR 50.72, pursuant to 23 10 CFR 50.72 and 50.73?"
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- c 1 to get back into conformance. It may be reportable to NRC if 1'
2 you have certified that someone is a graduate of an accredited
.3 program and he has completed the program, and then you find the t -
4 you.have not implemented the program adequately. In that 5 instance, you may have a reporting requirement to NRC, but it'is l 6 not under the LER reporting system, prompt reporting to the 7 incident center. i 8 MR. COOLEY: That's all I have.
9 Thsnk you all.
MR. RUSSELL:.
10 (whereupon, the meeting was concluded at 11 4:30 p.m.)
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1 CERTIFICATE 2
This is to certify that the attached proceedings before: .
3 .
UNITED STATES NUCLEAR REGULATORY COMMISSION 4
5 In the matter pf: Final Rule Making 6
7 Denver, Colorad At , DATE: April 14, 1987 8
was held as herein appears, and that this is'the original ,
9 transcript thereof for the file'of the Department.
10 11 4/L Wd r!
13 , OFFICIAL REPORTER 14 15 ,
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