50 FR 43621

Engineering Expertise on Shift

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text

50 FR 43621

Published 10/28/85

Effective 10/28/85

Commission Policy Statement on

Engineering Expertise on Shift

AGENCY: Nuclear Regulatory

Commission.

ACTION: Policy Statement on Engineering Expertise on Shift.

SUMMARY:

This Policy Statement presents the policy of the Nuclear Regulatory Commission (NRC) with respect to ensuring that adequate engineering and accident assessment expertise is possessed by the operating staff at a nuclear power plant. This Policy Statement offers licensees two options for providing engineering expertise on shift and meeting licensed operator staffing requirements.

Option 1 provides for elimination of the separate Shift Technical Advisor (STA) position by allowing licensees to combine one of the required Senior

Reactor Operator (SRO) positions with the STA position into a dual-role (SRO/STA) position. Option 2 provides that a licensee may continue to use an NRC-approved STA program. with certain modifications, while meeting licensed operator staffing requirements.

EFFECTIVE DATE: October Z8. 1985.

FOR FURTHER INFORMATION CONTACT:

Clare Goodman, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington. DC 20555, Telephone: 301/492-4894.

SUPPLIMINTARY INFORMATION:

Background

Following the accident at Three Mile Island in March 1979, a number of studies were conducted to determine why the accident occurred, what factors might have contributed to its severity, and what the industry and the NRC could do to prevent the recurrence of the same or a similar accident. These studies concluded, among other things, that a number of actions should be taken to improve the ability of shift operating personnel to recognize, diagnose, and effectively deal with plant transients or other abnormal conditions.

To addre11 these recommended improvements. the NRC initiated both short-term and long-term efforts. The short-term effort required that as of January 1. 1980, each nuclear power plant have on duty a Shift Technical Advisor (STA) whose function was to provide engineering and accident a11e11ment advice to the Shift Supervisor in the event of abnormal or accident conditions. The STA was required to have a bachelor's degree in engineering or the eguivalent and specific training in plant response to transients and accidents. The STA requirement was identified to licensees via NUREG-0578 (July 1979) and NUREG--0737 (November 1980) and was later mandated by plant-,pecific

Confirmatory Orders.

Concurrently, the NRC and industry embarked on a longer-term effort aimed at upgrading staffing levels and the training and qualifications of the operating staffs, improving the man-machine interface, and increasing capabilities for responding to emergencies. At the time the STA requirement was imposed, it was intended that use of the dedicated STA would be an interim measure only until these longer-term goals were achieved.

These long-term initiatives collectively result in an improvement in the capabilities and qualifications of the shift crew and their ability to diagnose and respond to accidents. These initiatives include shift staffing increases, training and qualification program improvements, hardware modifications, emphasis on human factors considerations, procedural upgrades, and development of extensive emergency response organizations to augment on-shift capabilities during abnormal conditions.

Draft Policy Statement

On July 25, 1983. the Commi11ion published in the Federal Reai1tar (41 FR 33781) a Draft Policy Statement on Engineering Expertise on Shift to reassert the Commission's belief that engineering and accident assessment expertise must be available to the operating crew at all nuclear power plants.

The Draft Policy Statement on Engineering Expertise on Shift offered licensees of nuclear power plants and applicants for operating licenses two options for meeting the staffing requirements of 10 CFR 50.54(m)(2) and the requirement in NUREG-0737, item 1.A.1.1 for a Shift Technical Advisor (STA). Option 2 gave them the opportunity to combine the licensed Senior Operators' (SRO) and Shift Technical Advisors' (STA) functions. Under Option 1, licensees that did not want to combine the SRO and STA functions could continue with their approved STA program in accordance with the description in NUREG-0737. "Clarification of TMI Action Plan Requirements."

Interested persons, applicants, and licensees were invited to submit written comments to the Secretary of the Commission. Following consideration of the comments, the Commission amended the Draft Policy Statement, as discussed in the following sections.

Comments on the Draft Policy Statement

A total of 34 responses were received

and evaluated. The public comments

related primarily to the combined SRO/

STA position. The following discussion

hishliaht• the major points raised in the

comments and the resolution of thoH

comments. A detailed analysis of all

public comments and their resolution

was also prepared. (Copies of those

letters and the detailed analysis of all

the public comments are available f.,r

public inspection and copying for a fee

at the NRC Public Document Room al

1717 H Street NW., Washington. DCJ

Of the 34 letters received. 18 includell

support for the flexibility provided by

the Policy Statement. The major points

made in the public comments were as

follows:

1. Support for the Policy Statement:

2. Opposition to combining the

functions of the SRO and the STA;

3. Opposition to a bachelor's degree

requirement for the SRO/STA position:

4. Recommendation that equivalency

to a bachelor"s degree be further

defined:

5. Concern that a bachelor's degree

requirement for the SRO/STA position

would result in a higher turnover rate

and potentially blocked career paths for

operators: and

6 Reference to a proposPd b11chclrir's

degree requirement for the Shift

Supen·isor. believed to be currently

under NRC consideration.

A general description of the majot

public comments and responses to these

are as follows:

1 Support for the Policy Statement-

Eighteen commenters favored the option offered in the Draft Policy Statement of combining the SRO and STA functions into one dual-role position. They endorsed the flexibility provided by the Policy Statement. They supported the view that it is beneficial to combine engineering expertise with operating experience.

2 Opposition to the Dual-Role SRO/STA Position-

Four individual commenlers stated

that there is a possibility that the person

in the di1al-role position would function

as an additional operator in the event of

an abnormal occurrence instead of being

u\'ailable to pr&l.!ide.the en~ineerlng and

accident asse11ment expertis1!

necessary in these circumstance·s. ln

response. the Commission notes it is the

intent of the Policy Statement that the

person in the dual-role position have

specific training in accident BBsessment

and provide that expertise during an

abnormal occurrence. The staffing level&

required by 10 CFR 50.54(m)(2). which

became effective January 1, 1984,

increased the number of operators and

Senior Operators on shift after the initial

STA position was required. This

increase in shift personnel would allow

the SRO/STA to provide both accident

assessment expertise and to analyze

and respond to off-nonnal occu1Tences

when needed. Experience has shown

that an STA. who is also an SRO. is

better accepted by the ahift crew.

Therefore. the assessment and direction

by an SRO/STA in an off-normal event

might be better accepted by the crew

than aueBSment and advice by a

separate STA.

3. Opposition to a Bachelor's Degree for the SRO/STA Position-

Se\·eral commentere felt that the

person who filled tbe SRO/STA position

should not be required ta hD\"e a

bachelor·a degree. The Commission

notes that since Nl.TREG-o731. Item

l.A.1.1, specified that the STA should

have a bachelor's degree or the

equivalent in a tcientific or engineerina

discipline, the degree requirement is not

new. Thia continun to be the

educational requirement for a dedicated

STA. However. the educational

rr.quirement1 for the dual-role (SRO/

STA) position have been chanpd to

allow the indMdual to meet one of four

educational alternatives.

4 Rccomme.1dation that F.qufrolt!11cJ to a Bachelor's Dt:gree Be Further Defined-

Many commenter& atated that the

equivalency option& were too restrictive

or req11ired clarification. In response. the

Commission notes that a bachelor'&

degree ir. engineering ia no· longer a

basic requirement but ia one of four

f!ducational alternatives. The term

"equh·alent" baa been deleted.'

Changes related to educational

alternatives are summarized below:

• Most states require a bachelor's

degree in engineering and several years

of engineering experience for an

indh·idual to sit for the Profe11ional

Engineer (PE) examination. A few atates

still allow an individual without formal

education but many years of practical

enginer.ring experience and training to

sit for the eumination. However. this

option is becoming available leH often

Hence, this alternative allows

individuals who do not have a de(!ree

but have successfully completed the PE

examination to meet one of the

educational altemattwa of Option 1.

• Other bachelor's desreea

determined to be acceptable

alternatives are a bachelor'• degree in

engineering technology from an

accredited institution or a bachelor's

degree in a physical acience from an

accredited institution. These degree

programa are acceptable provided that

they include coune worlt in the

physical. mathematical. ot: engineering

sciences. These requirements are

intended to ensure that the individuul

has substantial knowledge and

undentanding of the phyaical and

mathematical sciences and the

principles of engineering.

• The Commi11ion hu deleted the

educational alternatives that allow for

succe&&ful completion of the technical

portion of an engineering degree

program and the successful completion

of the Engineer-tn-Trainins (EIT)

examination. The Commi11ion't1

objective is to enhance engineering

expertise on shift throUBh more stringent

educational requirement& for the

indi\'idual filling the dual-role position.

5 Concern that a Bachelor's Degree Requirement Would Result in a Higher Turnover Rate and a Potentially Blocked Career Path for Shift Employees-

Several commenters expressed

concern that degreed individual& would

leave for other poaitiom in the plant.

contributing to a hish turnover rate on

shift. Another concern of commenten

was that career paths to tlie senior

operating positions would be bloc:kcd

for those indh:idullls without degrees. In

response, the Commi&Sion notes that

individuals may move to other positions

within the utility. However. this can be

viewed as desirable since ii would

increase the number of employees with

valuable operating experience in o!he1

posi lions a I the u tilily.

The only positions which mar not l>C'

available for individuals without a

degree would be the STA or the SRO/

STA position. The career path lo olhe·

senior operating positions remains

available.

6. Reference to a Proposed Bar.l1elm .. s Degree Requirement for the Shift Supervisor-

A few commenters on the Federal

Register notice toolt the opportunity to

comment on whether & b!lchelor"&

degree should be required for specific

positions in the operating staff of

nuclear power plants. and in particular.

for the Shift Supervisor's po11ition.

The Final Policy Statement on

Engineering Expertise on Shift does not

addre11 the i11ue of requiring a degrt:e

for the Shift Supervisor. Early in 1984.

the staff conaidered a "Proposed

Rulemakina Concerning Requirements

for Senior Managera" in SECY-M-106.

This proposed rulemaking would hi.ve

required that an additional degreed.

SRO-lice~ individual be assigned to

each shift of a nuclear power plant-who

would be responaible for manqerial

direction of all plant functions including

chemistry, health phyaics, maintenance.

operationa. secwity. aDd technical

services. Following aeveral meetings

"•Ith the staff and industry

representatives, the Commission

concluded that this proposed rulemaking

was not warranted: therefore. it wa& not

approved. One of the primary base& for

the propoaad senior manager rule v.-11s

the need to provide engiaeering

expertise to the shift crew. which is ;,l&o

the primary objective of this PoliCl'

Statement.

Developmmt al Final Policy Statement

As a result of the analysis of public

comments, the Commission clarified the

educational alternatives of the dual-role

(SRO/STA] position. The revisions to

the Draft Policy Statement resulted in

SECY-&1-355. a draft Final Policy

Statement on Engineering Expertiae on

Shift.

The main difference between the

Draft Policy Statement and SECY-M-

355 concerned tbe educational

qualifications for the dual-role position.

The Draft Policy Statement required. of

the person filling the dual-role poaition.

a baccalaureate degree in engineering or

related sciences or one of three

equivalents to the degree. SECY-84-355

required a bachelor'• degree in

engineering from an accredited

institution or one of five 1tcceptable

altematives to the engineering degree.

The staff met with the CommiBBionera

on November 5, 1984, to discuss SECY-

84-355. As a result of that meeting, the

Commissionera directed the staff to

coordinate the Policy Statement on

Engineering Expertise on Shift with the

Nuclear Utilitiea Management and

Human Reaourcea Committee

(NUMARC). Another draft Final Policy

Statement, SECY-85-150, was the result

of the CommiBBionera' direction. staff

analysis. rasolution to public comments,

and staff coordination with NUMARC.

The majority of the Commission

approved a veraion of the Policy

Statement in SECY-85-150 with change•

In the educational alternatives.

Furthermore. the Commiaaion haa

deleted an item from SECY-85-150.

which allowed for college-level training

instead of formal college education for

the dual-role position. The objective of

the Commission is to enhance

engineering expertise on ahift throush

more atringent educational requirements

for the individual filling the SRO/STA

position. The educational alternatives in

this Final Policy Statement require a

bachelor'• degree in engineering,

engineering technology. or physical

science from an accredited institution.

or a PE license obtained through

succeuful completion of the PE

examination.

Finally, although this Final Policy

Statement includes an option which

allows for the continued use of the ST A

position, as did the Draft Policy

Statement. the former encourases

licensees to work towards having the

STA asaume an active role in shift

activities.

While it is the Commission's

preference that licensees move toward

the dual-role (SRO/STA) position,

continuation of an approved STA

prosram remains an acceptable option.

The Commission acknowledae• that

some licensees may prefer the dedicated

STA position for a number of reasons.

The Commission also recognizes the

advantages or integrating the

qualifications and training of the STA

into the licensed operating staff.

The separate views of Commi11ioner

Thomas M. Roberts on this Policy

Statement follow;

I am in .a11reement with the majority'•

Intent that operators lhould be -u trained

and qualified lo perform their dutie1.

However. this policy. by requirina that an

Individual have both an SR.O license and a

BS degree in enaineering or related ICience or

have passed the PE examination prior to

assuming the combined STA/SRO duUe1,

places inordinate confidence In "academic"

credentials. Strinldns)y abaent frolll lhe

policy are the apecif"ic aldlla or abilitiel

needed to perform tbote duties. Thaa. lhe

Commiaion bu pMtpoaad the quution of

what those skill• should be and bow they

should or could be achieved and

demonstrated. This leave1 me no choice but

to vote qainat the modificatio111 proposed to

the Polley Statement on Engineering

Expertise on Shift. By eliminatiq alternatives

to a bachelor's degree for lndividual1 wtlo

would otherwile occupy the dual role. the

Commi11ion would be ignoring the

compellina arguments made in public

commenta and the staff'• proposal for

nexibillty. We would be impo1lna our

solution without addre11ina the benefltl that

will be eliminated by not allowing ftexlbility.

Thia leaves the utilitiet with little incentiYe to

change from the current poaitlon. which 11

allowed by Option 2. Since a majority of the

CommiNion haa already determined that

improvement from the current program -1d

be desirable, the Commiuion 1hould provide

aome 111echani1m to move toward

Improvement. The proposed 1tatement, 11

modified. does not provide that mechanism,

and we provide no justification for overrldtns

the 1taff's evaluation of the beneftts that the

ftexibility would bring.

Policy Statement

The Commission continues to 1tre11

the importance of providing engineerina

and accident aue11ment expertise on

shift. In this Policy Statement, "accident

assessment " means immediate actions

needed to be taken while an event is in

progress. This policy Statement does not

reqllire any changes in the fonnal

education and training of operators and

Senior Operators not expected to fill the

dual-role SRO/STA position.

The intent of this policy pclance may

be satisfied by either of the optiona

described below. The Commiaaion

prefers a combined SRO/STA position

(Option 1). In addition. in the long term,

the Commission would prefer that the

STA be combined with the Shift

Supervisor in the dual-role position.

Either Option 1 or Option 2 may be

used on each shift. A utility may uae

Option 1 on some ahifta and Option Z on

other shifts, or may uae the same option

on every shift. If Option 1 ia used for a

st1ift, then the separate STA position

may be eliminated for that ahifL

Option 1: Combined SRO/STA Position

Thia option ia aatiafied by •uisnins

an individual with the following

qualif1Cationa to each operatina abift

crew ea one of the SRO. (preferably lhe

Shift Superviaor) required by 10 CFR 50.st(m)(2)(i):

a. Licensed as a senior operator on the

nuclear power unit(s) to which aasigned.

and

b. Meets the STA training criteria of

NUREG--0737, Item I.A.1.1, and one of

the following educational ahemativea:

(1) Bachelor'• degree in engineerill8

from an accredited institution:

(2) Prof eaaional Engineer's licenae

obtained by the aucceasful completion of

the PE examination:

(3) Bachelor'• degree in engineering

technology from an accredited

institution. including course work in the

physical mathematical. or engineering

sciences; or

(4) Bachelor's degree in a physical

science from an accredited institution.

including course worlt in the physical.

mathematicaL or engineering sciences.

Option 2: Continued Use of STA Position

Thia option is 1Btisfied by placing on

each shift a dedicated Shift Technical

Advisor (STA) who meets the ST A

criteria of NUREG-G787, Item I.A..1.1.

The ST A should a11ume an active role

in shift activities. For example, the STA

should review plant logs. participate in

shift turnover activities. and maintain an

awareness of plant configuration and

status.

Licensee proposals different than the

two options described above will be

considered by the staff on a caae-bycue

basil. To eliminate the STA

position. a licensee of an operating

reactor should apply for a modification

to its license and an applicant for an

operating license should modify its Final

Safety Analysis Report to reflect

elimination of the STA position and a

commitment to provide a required SRO

on shift with the qualifications

described in Option l above.

NRC will accept a utility'•

modifications if it finds that tbe proposal

meets the intent of this Policy

Statement. NRC will review. on a caaeby-

caae basis. multi-unit sites with duallicenaed

SRO• to ensure that an

adequate number of licensed staff are

available and that engineering expertise

can be provided when needed. It is the

intent of this Policy Statement to ensure

that engineering and accident

aueaament expertiH is possessed by

the plant operating staff.

Dated at Washlnpin. DC. on this 22 day or

October. t985.