Information Notice 1997-67, Failure to Satisfy Requirements for Significant Manipulations of the Controls for Power Reactor Operation Licensing

Failure to Satisfy Requirements for Significant Manipulations of the Controls for Power Reactor Operation Licensing

ML031050127
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	08/21/1997
From:	Slosson M M Office of Nuclear Reactor Regulation
To:
References
IN-97-067, NUDOCS 9708150270
Download: ML031050127 (8)

UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-OpO1August 21, 1997NRC INFORMATION NOTICE 97-67: FAILURE TO SATISFY REQUIREMENTS FORSIGNIFICANT MANIPULATIONS OF THE CONTROLSFOR POWER REACTOR OPERATOR LICENSING

Addressees

All holders of operating licenses for nuclear power reactors except those who havepermanently ceased operations and have certified that fuel has been permanently removedfrom the reactor vessel.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alertaddressees that operator license applicants are required to perform at least five significantcontrol manipulations on the facility for which a license Is sought (Section 55.31 (a)(5) of Title10 of the Code of Federal Regulations [10 CFR 55.31(a)(5)]). Licensees have erred on theinterpretation of the requirements of this section of 10 CFR Part 55. It is expected thatrecipients will review information for applicability to their facilities and consider actions, asappropriate, to avoid similar problems. However, suggestions contained in this informationnotice are not NRC requirements; therefore, no specific action or written response isrequired.

Description of Circumstances

Operator license applicants are required to provide evidence that they, as trainees, havesuccessfully manipulated the controls of the facility for which an operator or senior operatorlicense is sought. At a minimum, applicants must perform five significant controlmanipulations which affect reactivity or power level on the facility for which the license issought (10 CFR 55.31(a)(5)). Controls as defined in 10 CFR 55 are apparatus andmechanisms, the manipulation of which directly affects the reactivity or power level of thereactor. Licensees have erred on the interpretation of what constitutes a significant controlmanipulation.During a review of operator license applications for the Pilgrim facility, NRC inspectorsdetermined that the requirements for operator and senior operator applicants to perform atleast five significant control manipulations on the facility were not satisfied. The Pilgrimlicensee incorrectly assumed that a single 30 percent decrease in power with recirculationpumps was equivalent to three 10 percent or greater power reductions and counted this asthree of the five required significant control manipulations. The licensee contacted otherlicensees regarding the practice at their facilities and reported that there was a wide range ofinterpretations by the other licensees contacted. I I_pDp4 rceq -01 1101'2¢Q05020Hills r, .'Y 4 IN 97-67August 21, 1997 The NRC administered examinations to the individuals but did not issue operator licensesuntil the facility submitted revised applications and provided details of how the applicantssatisfied the requirements to perform the required significant control manipulations. Asdocumented in "Pilgrim Examination Report 50-293/97-006 and Notice of Violation,"(Accession No. 9707290261), dated July 18, 1997, the NRC determined that a violation ofNRC requirements had occurred because two applicants had not completed the fivesignificant control manipulations required by 10 CFR 55.31 (a)(5) in an acceptable manner.DiscussionBefore 1987, the operator license application required the licensee to certify that theapplicant had learned to operate the facility and also to provide the details of the training andexperience of the applicant. A 1987 NRC rule changed the requirement to provide the detailsof the applicant's training and experience and requested instead a simple check mark in theboxes on the application form (NRC-398) to indicate that the applicant has successfullycompleted an Institute of Nuclear Power Operations (INPO) accredited operator trainingprogram that is based on a systems approach to training, and that a certified simulationfacility is used in the operator training program.During rule making, the nuclear industry requested clarification of the phrase "leamed tooperate" (Federal Register Vol. 52, No. 57 Wednesday, March 25, 1987, page 9456) andNRC added 10 CFR 55.31 (a)(5) to specify the minimum number of control manipulations thatthe applicant had to conduct on the facility.Examples of significant control manipulations are contained In Regulatory Guide (RG) 1.8,Revision 2, "Qualification and Training of Personnel for Nuclear Power Plants."Paragraph C.1.h. of RG 1.8 states in part that:Control room operating experience ...should include manipulation of controls of thefacility during a minimum of five reactivity changes. Every effort should be made tohave a diversity of reactivity changes for each applicant. Startups, shutdowns, largeload changes, and changes in rod programming are some examples and could beaccomplished by manually using such systems as rod control, chemical shim control,or recirculation flow.Additional examples of significant control manipulations include, but are not limited to, itemsA-F of 10 CFR 55.59(c)(3) (on-thejob training for requalification):

IN 97-67August 21, 1997 A. Plant or reactor startups to include a range that reactivityfeedback from nuclear heat addition is noticeable and heatuprate is established.B. Plant shutdown.C. Manual control of steam generators or feedwater or both during startupand shutdown.D. Boration or dilution during power operation.E. Significant ( 10 percent) power changes in manual control or recirculationflow.F. Reactor power change of 10 percent or greater where load change isperformed with load limit control or where flux, temperature, or speed control ison manual (for HTGR).As defined in 10 CFR 55.59(c)(3)(E), a 10 percent or greater power change is considered tobe a significant control manipulation. Additional clarification was provided in NUREG-1262,"Answers to Questions at Public Meetings Regarding Implementation of Title 10, Code ofFederal Regulations, Part 55 on Operators' Licenses," dated November 1987, which wastransmitted to all licensees on November 12, 1987, as an attachment to Generic Letter 87-16(Accession No. 8712030029). Some of the guidance included in NUREG 1262 is reiteratedbelow; licensees should refer to NUREG 1262 for additional details.The situation in which an applicant performs a 30 percent change in power in a shortperiod (i.e., on the same shift) with no diversity of controls would be evaluated as onesignificant control manipulation. The situation in which an applicant reduces powerfrom 100 percent to 95 percent and then increases power from 95 percent to100 percent would be evaluated as one significant control manipulation.The situation when an applicant performs a 50 percent change in power in a shortperiod of time with diversity of controls (recirculation flow and control rods, orchemical shim and controls rods) can be evaluated as two significant controlmanipulations. The situations when an applicant reduces power by 10 percent thenholds there for performance of other work or testing and then later in the shiftincreases power by 10 percent can be evaluated as two significant controlmanipulations.Diversity of significant control manipulations on the plant are expected; however, it isnot required. If the applicant does not have experience in diverse significant controlmanipulations, this fact should be noted in the comments section of NRC form 398.

.IIN 97-67August 21, 1997 I -AttachmentIN 97-66August 20, 1997 LIST OF RECENTLY ISSUEDNRC INFORMATION NOTICESInformation Date ofNotice No. Subject Issuance Issued to97-66 Failures to Provide 08/20/97 All holders of oDeratiria licensesSpecial Lenses forOperators UsingRespirator or Self-Contained BreathingApparatus DuringEmergency Operationsor construction permits fornuclear power and non-powerreactors and all licensed reactoroperators and senior operators97-65Failures of High-Dose-Rate (HDR) Remote After-loading Device SourceGuide Tubes, Catheters,and Applicators08/15/97All high-dose-rate (HDR)remote afterloader licensees97-6497-6397-6297-61Potential ProblemsAssociated with Lossof Electrical Powerin Certain TeletherapyUnitsStatus of NRC Staff'sReview of BWRVIP-05Unrecognized ReactivityAddition During PlantShutdownU.S. Department ofHealth and HumanServices Letter, toMedical Device Manu-facturers, on theYear 2000 Problem08/13/9708/07/9708/06/9708/06/97All U.S. Nuclear RegulatoryCommission medical tele-therapy licenseesAll holders of OLs or CPsfor boiling water reactorsAll holders of OLs or CPs*for nuclear power reactorsAll U.S. Nuclear RegulatoryCommission medical licensees,veterinarians, and manu-facturers/distributors ofmedical devicesOL = Operating LicenseCP = Construction Permit

IN 97-XXAugust XX, 1997 This information notice requires no specific action or written response. If you have anyquestions about the information in this notice, please contact one of the technical contactslisted below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.Marylee M. Slosson, Acting Dir ctorDivision of Reactor ProgramWianagementOffice of Nuclear Reactor egulationTechnical contacts: Brian Hughes, NRR John Pellet, RIV301-415-1096 (817) 860-8159E-mail: bxhl@nrc.gov E-mail: jlp@nrc. vDonald Florek, RI Thomas P les, RI1(610) 337-1585 (404) 56 638E-mail: djfl@nrc.gov E-mailf pnrc.govMel Leach, Rill(630) 829-9705E-mail: mnl@nrc.govAttachment: List of Recently Issued N Information NoticesDOCUMENT NAME: G:1CDP1lN9pX7A.BXH*See previous concurrence /To receive a copy of this document. Indicate hI the box: *C -Copy without attachmentlenclosure E -Copy with attachment/enclosureN' -No copy 4 AOFFICE HOLB/DRCH ' HOLB/DRCH PEC &NAME BHughes:rc/bh RGallo Cpet'rone kc-haffteeDATE 08/06/97*, 08/07/97* 08/)cf/97 08/ #( /97(A) DRPM11slosson08/ /97UV-VILIAL KtLUUV LUFY'y9'Y% 1VI

IN 97-XXJuly XX. 1997 This information notice requires no specific action or written response.you have any questions about the information in this notice. please c act(one of) the technical contact(s) listed below or the appropriate ice ofNuclear Reactor Regulation (NRR) project manager.Jack Roe. Acting rectorDivision of Rea or Program ManagementOffice of Nuc ar Reactor RegulationTechnical contact(s): Brian Hughes. NRR/HOL(301) 415-1096E-Mail: BXH1@NRC. VDonald Florek, egion I Thomas Peebles. Region II(610) 337-158 (404) 562-4638E-Mail: DJ @NRC.GOV E-Mail: TAP@NRC.GOVMel Leac .Region III John Pellet. Region IV(630) 29-9705 (817) 860-8159E-Mai. MNL@NRC.GOV E-Mail: JLP@NRC.GOVAttachment: List of Recen y Issued NRC Information Notices*See previous concurrenceTo receive a copy of this document. Indlicate In the bo C -Copy without attachment/enclosure E -Copy with attachment/enclosure 'N' -No copyOFFICE HOLB/DRCH TECH/EDITOR l PECB/NRR DRPM/NRRNAME BHughes:rc/bht. RGallo'f DCalureA d AChaffee JRoeDATE 08/06/97* 08 /97 07/08/97* 08/ /97 08/ /97 I ..INFORMATION NOTICE FORMATThis information notice requires no specific action or written res onse. If youhave any questions about the information in this notice, please ntact (one of)the technical contact(s) listed below or the appropriate fice of NuclearReactor Regulation (NRR) project manager.Marylee M. osson, DirectorDivision Reactor Program ManagementOffice Nuclear Reactor RegulationTechnical contact(s): Brian ghes, NRR/HOLB301- 5-1096E- 11: BXH1@NRC.GOVonald Florek, Region I Thomas Peebles, Region II610-337-1585 404-562-4638E-Mail: DJF1@NRC.GOV E-Mail: TAP@NRC.GOVMel Leach, Region III John Pellet. Region IV--- --- ----eS no o a63U-829-9/UbE-Mail: MNL@NRC.GOVE/-MaJU-iJb GE-Mail: JLP@NRC.GOVAttachment: List of Recently Issued NRC Information NoticesTo receive a copy of this document, hIdicate hi the box: 'C -Copy without attachmentlenclosure WE' -Copy with attachment/enclosure 'N" -No copyOFFICE HOLB/DRCH I HOLB/DRCH I TECH/EDITOR I PECB/NRR I DRPM/NRR l lINAME BHughes:rc/bh RGallo DCalure4UPP AChaffee MSlossonDATE 08/6 /97 08/ /97 08/ /97 08/ /97 07/ /97OFFICIAL RECORD COPYIssue Date: 03/21/94E20-50720, Exhibit 20