ML19212A212
| ML19212A212 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/05/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19207B153 | List: |
| References | |
| TASK-OS, TASK-RS-901-5 REGGD-01.058, REGGD-1.058, NUDOCS 7908230484 | |
| Download: ML19212A212 (10) | |
Text
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1 Acril 5, 1979 h
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2 VALUE/ IMPACT ASSESSMENT ON OUALIFICATION OF 3
NUCLEAR POWER PLANT INSPECTION, EXAMINATI0t., AND TESTING PERSONNEL 4
SD TASK NUMBER:
R$ 901-5 5
I.
The Proposed Action 6
A.
Description 7
The Commission's Regulations require that an applicant establish 8
a quality assurance program that provides for indoctrination and 9
training of personnel performing activities affecting quality as 10 necessary to assure that suitable proficiency is achieved ind 11 maintained.
The proposed action will provide updated guidance 12 concerning the qualification of personnel who perform inspec-13 tions, examinations, and tests during fabrication, receipt at 14 the construction site, construction, preoperational and startup 15 testing, and the operation phase of nuciear power plants.
16 B.
Need for the Proposed Actinn 17 Regulatory Guide 1.58, " Qualification of Nuclear Power Plant 18 Inspection, Examination, and Testing Personnel," dated August 19 1973, provides guidance on the qualifications of inspection, 20 examination, and testing personnel and endorses ANSI Standard 21 N45.2.6-1973.
On August 31, 1978, a revised version of the 22 standard was approved by the ANSI Board of Standards Review and 1
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I was designated ANSI N45.2.6-1978.
The revision reflects 2
increased experience in the qualification of nuclear pcwer plant 3
inspection, examination, and testing personnel.
Scme confusion 4
has developed concerning the applicability of Regulatory 5
Guide 1.58 and ANSI Standard N45.2.6 to certain categories of 6
key personnel involved in preoperational and startup test _ pro-7 grams.
Current NRC guidance should be updated to reflect exper-8 ience in the application of qualification crite. ia, to remove 9
any confusion with regard to acceptance criteria, and to establish 10 an NRC position on tha approved National Standard.
11 C.
Value/ Impact of the Proposed Action p
12 Guidance on the qualification of nuclear power plant inspection, 13 examination, and testing personnel is currently contained in 14 Regulatory Guide 1.58 (August 1973) and is being used by the NRC 15 staff in the evaluation of applications for operating licenses.
16 Since the purpose of the proposed action is to provide updated 17 guidance to reflect experience with use of current guidance, to 18 remove any confusion with regard to acceptance criteria, and to 19 establish an NRC position on the approved f.ational Standard, the 20 value/ impact will be based on changes proposed to guidance con-21 tained in Regulatory Guide 1.58 (August 1973).
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1 The following is a list of the proposed changes to be made to 2
Regulatory Guide 1.58 ( August 1973) as a result of the revision 3
of the standard and the associated value/i. pact assessment for 4
each change.
(The first two changes result in the deletion of 5
two Regulatory Positions contained in the August 1973 version of 6
The last six changes concern the addition 7
or modification of Regulatory Positions included in the proposed 8
revision to the regulatory guide.)
9 1.
The revised standard expands the applicability of its require-10 cents and recommendations from personnel who perform inspec-11 tions, examinations and tests during the construction phase 12 to personnel who pcrform these activities during fabrication, 13 receipt at the construction site, construction, preoperational 14 and startup testing, and the operation phase.
Therefore, 15 Regulatory Position 1 in the August 1973 version of Regula-16 tory Guide 1.58 which expresses tnis applicability is unnecessary 17 and has been deleted from the proposed revision.
There is 18 no change in the current position of Regulatory Guide 1.58 19 and present regulatory bases will not be altered.
20 2.
In the August 1973 version of Regulatory Guide 1.58, Regu-21 latory Position 3 provides additional guidance concerning 22 the information to be included in the certificate of quali-23 fication under the category of " basis used for certification."
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1 The revised standard inccrporates this additional gaidance 2
that was lacking in the previous version of tne standard.
3 Therefore, this Regulatory Position is unnecessary and has 4
been deleted from the proposed revision to the regulatory 5
guide.
There is no change in staff position and present 6
regulatory bases will not be altered.
7 3.
The revised National Standard states tnat it is applicable 8
to persconel who perform preoperational and startup testing.
9 Regulatory Guide 1.8 is being revised to encompass require-10 ments for personnel who perform preoperational and startup 11 testing and will provide more definitive criteria for these 12 personnel. Modifications to the requirements for the qualifi-13 cation of these personnel will be addressed in the value/ impact 14 assessment for the revision to Regulatory Guide 1.8.
Regula-15 tory Position 1 of the proposed revision to Regulatory 16 Guide 1.58 references Regulatory Guide 1.8 for the qualifica-17 tion of these personnel.
18 The value of the proposed action will be the clarification 19 of the applicability of Regulatory Guide 1.53 and Regula-20 tory Guide 1.8 to personnel who perform preoperational and 21 startup testing.
This action will benefit the NRC staff by 22 providing additional guidance for license evaluations.
This 23 action is a clarification of regulatory requirements.
The 24 additional guidance will remove any confusion concerning 4
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1 qualification recuirements of these personnai.
Since there 2
will be no change in the regulatory bases for license evalua-3 tions, the imcact will be negligible.
4 4.
The August 1973 version of Regulatory Guide 1.58 encorses 5
ASNT Recommended Practice No. SNT-TC-1A as acco: table for C
the qualification of nondestructive test persennel for the 7
test methods coverad by that document.
The proposed revi-8 sion to the regulatory guide endorses SNT-TC-1A-I975 in 9
Regulatory Position 2.
For those nondestructive examina-10 tions required by Section III and Section XI of the ASME 11 Boiler and Pressure Vessel Code, SNT-TC-1A-1975 is recom-12 mended for use in conjunction with the additional provisions 13 of the Code.
14 The proposed action results in clarification of the appli-15 cability of ASNT Recommended Practice No. SNT-TC-1A-1975 16 and the ASME Boiler and Pressure Vessel Code to personnel 17 performing nondestructive examinations and does not represent 18 a change in NRC staff or industry practice.
There should 19 be no impact.
20 5.
Regulatory Position 3 of the prcposed revision to the regula-21 tory guide addresses the compatibility of the ANSI Standard 22 N45.2.6-1978 and Section III and Section XI of the ASME Boiler 5
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I and P-essure Vessel Cade for the qualificat'an of personnel 4
2 who perform inspection, examination, and testing at nuclear 3
pcwer plants.
It is stated that ANSI N45.2.6-1978, sabject 4
to the exceptions of the regulatory position, should be used 5
in conjunction with the ASME Code where the ASME Coda does 6
not address the requirements covered by ANSI N45.2.6-1978.
7 The original version of the standard ANSI N45.2.6-1973 which 8
is endorsed by Rev. O of Regulatory Guice 1.58 did not contain 9
the Code exclusion statement and was considered applicable 10 to Code covered activities.
This new regulatory position 11 does not represent a change from present staff practice.
12 The impact should be minimal.
13 6.
The revised standard, together with Regulatory Position 5 14 of the proposed revision to the regulatory guide, de?ineates 15 the capability requirements for Level I, II, and III personnel 16 in greater detail and does not represent a significant change 17 in qualification requirements for inspection, examination, 18 and testing personnel.
The action orovides additional guidance 19 to the NRC staff and industry but does not alter present 20 regulatory bases for license evaluations.
Therefore, any 21 impact should be minimal.
22 7.
The education and experience recommendations presented in 23 the it.andard for the qualification of nuclear power plant 24 inspection, examination, and testing personnal have been 6
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revised to reflect current experience in the use of tne 2
standard.
The revised stancard also encompasses more 3
alternatives for meeting the education and experience 4
provisions of the standard.
5 Regulatory Position 6 of the proposed revision to the 6
regulatory guide states that a commitment to comply with 7
the regulatory guide will mean that the education and 8
experience recommendations of the standard will be 9
followed.
10 The value to the NRC staff should be reduced effort in deter-11
. mining the acceptability of various alternate proposals 12 submitted by applicants.
The revision of the education and 13 experience recommendations reflects current experience in 14 the use of the standard and does not represent a significant 15 change in the regulatory basis for license evaluations.
16 Therefore, the impact should be minimal.
17 8.
The revised standard includes a statement that personnel 18 not meeting the requirements of the standard may be used in 19 data-taking assignments or in plant or equipment operation 20 provided these personnel are under supervision by a qualified 21 individual participating in the test.
To p event possible 22 abuse of this authorization, Regulatory Position 7 of the 23 proposed revision to the regulatory guide states that 7
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1 personnel involved in inspections, examinations, or tests 2
ho do not meet the requirenents of the standard should have 3
sufficient training to ensure an acceptable level of com-4 patence in the performance of their activities.
5 The value to incustry will be the ability to utilize lesser 6
trained personnel for those tasks which require little formal 7
training.
This proposed action will not represent a significant 8
change in present NRC staff practice.
There should be no 9
impact as a result of this position.
10 9.
An impr.rtant concept that is not addressed directly in ANSI 11 N45.2.6-1978, ANST Recommended Practice No. SNT-TC-1A-1975, 12 or the ASME Boiler and Pressure Vessel Code is that occupational 13 radiation exposures should be maintained as low as is reasonably 14 achievable (ALARA).
To provide guidance in this area, Regulatory 15 Position 8 of the Yroposed revision to the regulatory guide states f
16 that inspection, examination, and testing personnel who may be 17 exposed to radiation fields during their activities should receive 18 instruction in radiation protection and safety.
19 The value of the proposed action will be to provide increased 20 awareness of the ALARA concept.
Present practice within the 21 industry should not be effected.
Therefore, the impact to 8
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1 industry should be minimal.
Since the proposed action does 2
not represent a change in NRC staff position, there will be 3
no impact on NRC staff, 4
II.
Technical Approach 5
This section is not applicable to this value/.'mpact statenent since 6
the proposed act'<a is an update of previously issued guidance.
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III. Procedural Approach 8
Since the propused action is an update of information contained in an 9
existing regulatory guide, the only appropriate procedural alternative 10 is a revision to the existing guide.
11 IV.
Statutory Considerations 12 A.
NRC Authority 13 This guide would fall under the authority and safety requirements 14 of the Atomic Energy Act.
In particular, under 10 CFR Part 50, 15 Appendix B, which requires that the quality assurance program 16 provide for indoctrination and training of personnel performing 17 activities affecting quality as necessary to assure that suitable 18 proficiency is achieved and maintained.
19 8.
Need for NEPA Assessment 20 The proposed action is not a major action, as defined by 10 CFR 21 51.5(a)(10), and does not require an environmental imoact statement.
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1 V.
Relationship to Other Existing or Proposed Regulations or Policies 2
Regulatory Guide 1.8, " Personnel selection and Training," contains 3
reco.mendations for the selection and training of nuclear pcwer p:aat 4
personnel.
Regulatory Guide 8.10, " Operating Philosophy for Main-5 tainina Occupational Iadiation Exposures As Low As Is Reasonably 6
Achievable," contains qualification and training recommendations for 7
plant personnel for implementing the ALARA concept.
The guidance of 8
the proposed action will be consistent with the guidance furnished in 9
these Regulatory Guides.
10 VI.
Summary and Conclusions 11 A proposed revision to Regulatory Guide 1.58, " Qualification of Nuclear 12 Power Plant Inspection, Examination, and Testing Personnel," has been 13 prepared.
The proposed revision endorses, with certain exceptions, 14 ANSI N45.2.6-1978.
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