ML16344A042

ACRS Report on the Use of the Check-Operator Concept for Licensed Reactor Operator Requalification

ML16344A042
Person / Time
Issue date:	01/15/1985
From:	Lewis H Advisory Committee on Reactor Safeguards
To:	Palladino N NRC/Chairman
References
Download: ML16344A042 (2)

Text

D850115 Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

ACRS REPORT ON THE USE OF THE "CHECK-OPERATOR" CONCEPT FOR LICENSED REACTOR OPERATOR REQUALIFICATION During its 296th meeting, December 13-15, 1984, and its 297th meeting, January 10-12, 1985, the Advisory Committee on Reactor Safeguards considered the concept of using designated representatives during the design, construction, and operation of nuclear power plants. These matters were also considered during a meeting of the Subcommittee on Quality and Quality Assurance in Design and Construction held in Washington, D.C. on September 11, 1984.

In the March 21, 1984 ACRS report on the draft NRC Report to Congress on Improving Quality and the Assurance of Quality in the Design and Construction of Nuclear Power Plants, we indicated that, "The concept of using designated representatives is worthy of further consideration."

Further, we said that, in addition to augmenting NRC resources, the use of designated representatives may be a "way of stimulating and rewarding professionalism and dedication to quality in the workplace."

Presently, the NRC administers approximately 20 percent of operator requalification examinations at approximately 50 percent of the facilities.

Since this practice was initiated in l983, it has placed a considerable burden on NRC license examination resources and has had negative impact on the morale of many licensed operators. We believe that the use of check-operators, in a manner somewhat similar to the FAA check-pilot concept, has the potential to improve the requalification process, reduce the drain on limited staff resources, and help stimulate and reward professionalism and dedication to quality in the workplace.

The pool of licensed reactor operators and senior reactor operators would provide a good, known source of qualified designated representatives who could be certified by the NRC to serve as check-operators.

These check-operators would conduct the requalification examinations.

Further, the check-operator concept could provide a controlled, limited pilot program for testing the use of designated representatives in the regulation of operating reactors.

The check-operator approach has been addressed by the NRC Staff in SECY-84-l67, "Use of the FAA 'Check-Pilot' Approach for Reactor Operator Requalification," dated April 20, l984. Although that report may not reflect accurately the FAA check-pilot practices, it can serve as an introduction to the subject. We plan to meet with the staff to discuss this in greater detail.

We recommend that the Commission give consideration to the check-

operator concept.

Additional comments by ACRS Member Glenn A. Reed are presented below.

Sincerely, H. W. Lewis Acting Chairman Additional Comments by ACRS Member Glenn A. Reed I agree entirely with the content of this ACRS letter, but consider that the following additional comments are important to clarification and encouragement of the Commissioners' consideration of the check-operator issue:

. SECY-84-l67 does not, in my opinion, clearly summarize the functioning of the FAA "check-pilot" arrangement, and is biased against the adoption of a similar arrangement for the NRC.

. An arrangement for NRC utilization of check-operators should be based on use of these check-operators at the facility (or unit) where they are licensed. Use at other facilities would have several disadvantages, one of which would be the unavailability of sufficient licensed personnel to be diverted from their home facility and from their everyday contributions to the safe operation of that facility. I consider that potential for conflict of interest can be appropriately accommodated by proper structuring.

. In my opinion, an appropriately structured check-operator program would reduce NRC overall costs of this aspect of nuclear regulation, rather than increase costs and commitments of regulatory personnel. SECY-84-l67 did not focus on the costs and commitments of the other alternatives now proceeding or under consideration.