Information Notice No. 97-67: Failure to Satisfy Requirements for Significant Manipulations of the Controls for Power Reactor Operator Licensing

                                 UNITED STATES
                         NUCLEAR REGULATORY COMMISSION
                         WASHINGTON, D.C.  20555-0001

                                August 21, 1997

                               POWER REACTOR OPERATOR LICENSING


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


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

Description of Circumstances

Operator license applicants are required to provide evidence that they, as
trainees, have successfully manipulated the controls of the facility for which
an operator or senior operator license is sought.  At a minimum, applicants
must perform five significant control manipulations which affect reactivity or
power level on the facility for which the license is sought (10 CFR
55.31(a)(5)).  Controls as defined in 10 CFR 55 are apparatus and mechanisms,
the manipulation of which directly affects the reactivity or power level of
the reactor.  Licensees have erred on the interpretation of what constitutes a
significant control manipulation.

During a review of operator license applications for the Pilgrim facility, NRC
inspectors determined that the requirements for operator and senior operator
applicants to perform at least five significant control manipulations on the
facility were not satisfied.  The Pilgrim licensee incorrectly assumed that a
single 30 percent decrease in power with recirculation pumps was equivalent to
three 10 percent or greater power reductions and counted this as three of the
five required significant control manipulations.  The licensee contacted other
licensees regarding the practice at their facilities and reported that there
was a wide range of interpretations by the other licensees contacted.

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The NRC administered examinations to the individuals but did not issue
operator licenses until the facility submitted revised applications and
provided details of how the applicants satisfied the requirements to perform
the required significant control manipulations.  As documented 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 of NRC
requirements had occurred because two applicants had not completed the five
significant control manipulations required by 10 CFR 55.31(a)(5) in an
acceptable manner.


Before 1987, the operator license application required the licensee to certify 
that the applicant had learned to operate the facility and also to provide the
details of the training and experience of the applicant.  A 1987 NRC rule
changed the requirement to provide the details of the applicant's training and
experience and requested instead a simple check mark in the boxes on the
application form  (NRC-398) to indicate that the applicant has successfully
completed an Institute of Nuclear Power Operations (INPO) accredited operator
training program that is based on a systems approach to training, and that a
certified simulation facility is used isted clarification of the phrase
"learned to operate" (Federal Register Vol. 52, No. 57 Wednesday, March 25,
1987, page 9456) and NRC added 10 CFR 55.31(a)(5) to specify the minimum
number of control manipulations that the applicant had to conduct on the

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 the facility during a minimum of five reactivity changes. 
      Every effort should be made to have a diversity of reactivity changes
      for each applicant.  Startups, shutdowns, large load changes, and
      changes in rod programming are some examples and could be accomplished
      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, items A-F of 10 CFR 55.59(c)(3) (on-the-job training for

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      A.    Plant or reactor startups to include a range that
            reactivity feedback from nuclear heat addition is
            noticeable and heatup rate is established.

      B.    Plant shutdown.

      C.    Manual control of steam generators or feedwater or both
            during startup and shutdown.

      D.    Boration or dilution during power operation.

      E.    Significant (�10 percent) power changes in manual control or
            recirculation flow.

      F.    Reactor power change of 10 percent or greater where load change is
            performed with load limit control or where flux, temperature, or
            speed control is on manual (for HTGR).

As defined in 10 CFR 55.59(c)(3)(E), a 10 percent or greater power change is
considered to be a significant control manipulation.  Additional clarification
was provided in NUREG-1262, "Answers to Questions at Public Meetings Regarding
Implementation of Title 10, Code of Federal Regulations, Part 55 on Operators'
Licenses," dated November 1987, which was transmitted 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 reiterated below;
licensees should refer to NUREG 1262 for additional details. 

      The situation in which an applicant performs a 30 percent change in
      power in a short period (i.e., on the same shift) with no diversity of
      controls would be evaluated as one significant control manipulation. 
      The situation in which an applicant reduces power from 100 percent to 95
      percent and then increases power from 95 percent to 100 percent would be
      evaluated as one significant control manipulation.

      The situation when an applicant performs a 50 percent change in power in
      a short period of time with diversity of controls (recirculation flow
      and control rods, or chemical shim and controls rods) can be evaluated
      as two significant control manipulations.  The situations when an
      applicant reduces power by 10 percent then holds there for performance
      of other work or testing and then later in the shift increases power by
      10 percent can be evaluated as two significant control manipulations.

      Diversity of significant control manipulations on the plant are
      expected; however, it is not required.  If the applicant does not have
      experience in diverse significant control manipulations, this fact
      should be noted in the comments section of NRC form 398..                                                            IN 97-67 
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This information notice requires no specific action or written response.  If
you have any questions about the information in this notice, please contact
one of the technical contacts listed below or the appropriate Office of
Nuclear Reactor Regulation (NRR) project manager.


                                    Marylee M. Slosson, Acting Director
                                    Division of Reactor Program Management
                                    Office of Nuclear Reactor Regulation

Technical contacts:  Brian Hughes, NRR          John Pellet, RIV 
                     301-415-1096               (817) 860-8159
                     E-mail:       E-mail:

                     Donald Florek, RI          Thomas Peebles, RII
                     (610) 337-5185             (404) 562-4638
                     E-mail:       E-mail:

                     Mel Leach, RIII
                     (630) 829-9705

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