ML19338F437
| ML19338F437 | |
| Person / Time | |
|---|---|
| Issue date: | 09/30/1980 |
| From: | Richardson S NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| References | |
| TASK-OS, TASK-RS-807-5 REGGD-01.008, REGGD-1.008, NUDOCS 8010200362 | |
| Download: ML19338F437 (63) | |
Text
_ _ _ _ _ _ _ _ - _ _
nro
\\
U.S. NUCLEAR REGULATORY COMMISSION
[
S OFFICE OF STANDARDS DEVELOPMENT September 1980 m
DRAFT REGULATORY GUIDE AND VALUE/ IMPACT STATEMENT Division 1 S,*****,/
t Task RS 807-5
Contact:
S. D. Richardson (301) 443-5913 SECOND PROPOSED REVISION 2 TO REGULATORY GUIDE 1.8 PERSONNEL QUALIFICATION AND TRAINING jy M
A.
INTRODUCTION g
&fh Paragraph 50.34(b)(6)(i)of10CFRPart50,"Domestiklice6singofProduc-a 9
a tion and Utilization Facilities" (Ref.1), requiresthat? applications for a wN license to operate a nuclear power plant include.nformation concerning organ-tw
.izational structure, personnel qualificationsb andare]ated matters.
Para-w3WA graph 55.10 of 10 CFR Part 55, "Operatorsh lihenses" (Ref. 2), requires that m
g operator license applications include information concerning an individual's Auu education, experience,andrelatedm'3tlebgThisregulatoryguidedescribes amethodacceptabletotheNRCgtiffgfo%complyingwiththeseportionsof the Commission's regulations with reg'a)d to the qualification and training of nuclear power plant pers' aannel_ filniTing the various functional positions gn 4
s described in the DecemberT,19J9, draft version of American Nuclear Society sa p
(ANS) Standard ANS 3.1, "QualWication and Training of Personnel for Nuclear v'
Power Plants"1 (Ref 3).
A,l.A The substantial (numbIt of changes from the first proposed Revision 2 to this guide (Task'Rh807;5). dated February 1979 have made it impractical to indicate thechanksin(themargin.
Since the issuance of the first proposed Revision 2 qualjfichtfon.j0ide1.8forpubliccomment,muchguidanceconcerningpersonnel to Regitilatory
'and training has been developed through assessment of the Three Mile' Island Unit 2 accident by various organizations.
In addition, ANSI /ANS 3.1-1978) which is. endorsed by the regulatory guide, is undergoing extensive
-revision in an effort to provide upgraded requirements for personnel qualifica-tions and training.
As a result of the incorporation of additional guidance into the revisions of ANSI /ANS 3.1 and the regulatory guide, this second pro-posed Revision 2 to Regulatory Guide 1.8 endorsing the December 6, 1979, draft version of ANS 3.1 is being issued for public comment in order to obtain addi-tional public input on the proposed regulatory guidance.
1 Copies of Draft Stanciard ANS 3.1 and preceding versions of it, as well as other ANS standards cited in this guide, are available from the American Nuclear Society, 555 North Kensington Avenue, LaGrange Park, Illinois 60525.
This regulatory guide and tha associated value/ impact statement are being issued in draft form to involve the pubile in the early stages of the development of a regulatory position in this area. They have not received complete staff review and do not represent an of ficial NRC staf f position.
Public comments are being solicited on both drafts, the guide (including any imp'tementation schedule) and the value/ impact statement. Comments on the value/ impact statement should be attrapanied by supporting ex L data. Comments on both draf ts should be sent to the Secretary of the Comission, U.S. Nuclear Regulatory f Commission, Washington, D.C. 20555, Attention: Docketing and Service Branch, by g3 Jg Requests for single copies of draf t guides (which may be reproduced) or for placement on an automatic distribution list for single copies of future draft guides in specific divisions should be eade in writing to tne U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention: Director, Olvision of Technical Information and Document Control.
'W 020n
B.
DISCUSSION 1.
DEVELOPMENT OF Gl'IDE 1.1 Impact of Events In the aftermath of the Three Mile Island nuclear plant accident (Tt11-2),
the industry, the NRC, and others have conducted a number of studies and investi-gations, and, as a result of their findings, have recommended changes in the numbers of nuclear power plant personnel now employed, and their qualifications and organization.
The principal studies have been conducted by the President's Commission on Three Mile Island (Ref. 4), the NRC Special inquiry Group (Ref. 5),
the Office of Inspection and Enfo cement Specia' Review Group (Ref. 6), the Office of Nuclear Reactor-Regulation's (NRR) Lessons Learned Task Force (Refs. 7 and 8), and NRR's Bulletins and Orders Task Force (Ref. 9).
Collectively, these studies have called for a gencral upgrading of utility capabilities for handling routine plant operations and for coping with unusual or unexpected conditions.
As might be expected, the recommendations of these diverse groups are not completely compatible; what is clear, however, is that all of these groups have called for upgrading in at least two identifiable areas:
manage-ment oversight and technical competence.
Optimum qualification and training of nuclear power plant personnel is necessary to upgrade these areas.
- 1. 2 Relationship to National Standards Effort Revision continues to existing standards for qualification and training of nuclear power plant personnel.
Based on existing knowledge and experience-in 1971, Subcommittee ANS-3, Reactor Operations, of the American Nuclear Society Standards Committee developed a standard containing criteria for the qualification and training of nuclear power. plant personnel.
This standard was approved by the American National Standards Institute (ANSI) Committee N18, Design Criteria for Nuclear Power Plants, and designated ANSI N18.1-1971, " Selection and Train-ing of Nuclear Power-Plant Personnel" (Ref. 10).
Regulatory Guide 1.8, "Per-sonnel Selection and Training," endorsing ANSI Standard N18.1-1971 was 2The recommendations of the investigating groups are collected in NUREG-0660, "NRC Action Plan Developed As A Result of the TMI-2 Accident." NUREG-0660, in Appendix E, discusses the availability of the individual investigatory reports (also see References).
2
3
. = ~
n-.
.=
~
s 3
m
'4_"
4 s8
- W-p.
- = _
~-
3:~-
[b' "y
~,
~,
~
7 4
4 fissued:linMarchj97'1bArevisionto;this!itandard'wasEsubsequently; approved-
]ibythelANS'IjBoardloffStandardsl Review:andIdesignatedANSI/ANS 3.1-1978',
f'%
p 4" Selection 1andTraining of' Nuclear Power Plant 1 Personnel"L(Ref. 11).
2InlFebruahyjl979, a[ draft Revisio_n';2"of-Regulatory GuideLI.8-(RSL80/-5) tndorsing' ANSI /ANSj3.1-1978 %as; issued for.public/commentc In May'1979, addi.-
f tional comments-ot thelarea-of;personn~el qualifications were'~-requested in-light'
_iofexperience' gained ~fromithETMI-2: accident.
Copies of all" comments receivedJ
- both on-the February 1979 draft guide and
- as a. result of the May 1979 request:
.y ifor comments were:provided to the!ANS-3 Subcommittee for their use during-l p
idevelopment of a? revision to the 1978 standard.
The' draft revision 11ncorporat -
fing upgraded r'equirementf ws approved -by, the '*;.v,.,obcommittee on December 6,
[
1979.
Draft Standard ANS 3.1..has been extensively revised in most areas of-therstandard on which comments were.re'ceived.
Public comments are now being i
solidited' on this'second' proposed -Revision 2 to Regulatory Guide 1.8 ;that endorses the r'evised standard.
l
-The significant changes incorporated-into the revised standard include f (a)_a reformulation of_Section_4,'" Qualification,".to separate the topics of:
'educat' ion,. experience, and. training -in' order: to more clearly define: personnel
) Jqualification' requ'rements; (b)~ an upgrading of a number.of specific qualifi-
.cationfrequi.rementsi particularly in:t'he--area'of' education and experience requirements;1(c) more definitive: guidance on training and retraining programs c
.,.7_.
[
uinclud.ing'_ requirements for the use_of position; task analyses to define required e
training and for.tha use(offsimulators-in'trainingandretraining-programs;;
2;(d).:a' listing,of eJditional skcificicontrol! manipulations to be performed'dur-H ing'.the retrai; ring program;.(e). requirements for corporate management certifica-
-tion of ' individuals'priorito licensing, examination by the NRC, and (f) qualifi '
cation' requirements foM individuals directing preoperational;and startup tests.
92.
'0NGOING EFFORTS"AFFECTINF GUIDE:
r 1
/
2.li NRC-P 'l'osophy-and Objectives; i:
l' I NUREG 0660,0"NRCLAction Plan? Developed As A Result of the TMI-2 Accident
J w-s.
~ f(Raf.jl2),2Ein: Chapter I,j'OperationalLSafety;"cdescribes actions intended-to substant_fally).improv'e andtemp6dsize. operational:sa_fety, an; area that has'not previously(beengiven7thefsameuregulatoryiemphasisias. nuclear _ power plant a-(y
<l
- ' %7
%-- b; p
.A
~
~
l
^
n 1_~,.
tz s
- f t
design. The actions have two complementary objectives:
(1) to reduce challenges to the safety of'the plant and (2) to ensure proper reactions to challenges that do occur.
Both of these objectives can only be achieved by requiring optimum qualification and training of reclear power plant personnel.
The reduc-tion.of challenges requires a highly qualified staf f that devotes unflagging attention to the proper operation of the plant, continuous monitoring to verify that plant operations are correctly performed, and correcting and impro<;c operations by the feedback of operating experience to appropriate personnel.
The proper reaction to challenges to the safety of the plant requires a thorough understanding of plant design and plant response to unusual conditions, as well as training in the diagnosis of these conditions and reaction to them.
Changes needed in this regulatory guide are discussed in two items of the NRC Action Plan (NUREG-0660):
Item I.A.2.6, "Long-Term Upgrading of Training and Qualifications," and Item I.B.1.1, " Organization and Management of Long-Term Improvements." Short-term actions related to personnel qualifications already taken by the NRC, as well as changes included in the December 6, 1979, draft version of ANS 3.1, " Qualification and Training of Nuclear Power Plant Personnel,"
are incorporated in this second proposed Revision 2 to Regulatory Guide 1.8.
2.2 Description c' Effor_ts As indicated in NUREG-0660, there are a number of efforts currently in progress to provide additional reviews and recommendations concerning the sub-ject of personnel qualification and training that interface with this regulatory guide.
The principal efforts in progress within the NRC on personnel qualifi-cation and training are described in Sections 2.2.1 through 2.2.8 hlow.
2.2.1 Upgrading Qualifications of Operators The NRC staff provided recommendations in Commission Paper SECY 79-330E,
" Qualifications of Reactor Operators" (Ref. 13), for upgrading the qualifications of licensed operators and senior operators through a program that includes increased training and testing in the areas of thermal-hydraulics and reactor transient response, increased use of simulator training and testing, higher passing grades on licensing examinations, increased experience requirements for operators-and senior operators, and increased emphasis on retraining and examination.
Based on Commission action on SECY 79-330E, the Office of Nuclear Reactor Regulation 4
by a letter of March 28, 1980, from H. R. Denton to all power reactar applicants and licensees (Ref. 14) set forth the revised criteria to be used by the staff in evaluating reactor operator training and licensing and established effective dates for their implementation.
Licensees and applicants were also informed in the March 23, 1980, letter of other criteria under development that would require additional staff work to produce the necessary requirements that would eventually be established through rulemaking proceedings.
Additionally, licensees and applicants were informed that Commission review in the area of operator training and qualification is continuing and may result in identifica-tion of additional criteria to be used in evaluation of operators for licensing and relicensing.
.2.2.2 Recommended Revisions to Part 55 and Part 50 The NRC staff is preparing amendments to 10 CFR Part 55, " Operators' Licenses," and 10 CFR.aart 50, " Domestic Licensing of Production and Utiliza-tion Facilities," that incorporate applicable Commission-approved recommenda-tions of SECY 79-330E and other proposed changes resulting from additional staff review of Part 55 and Part 50.
The amendments focus on education and gy training for prospective operators, requirements for simulator training for operators and operator applicants, NRC participation in requalification examinations, operator understanding of the theory behind operation of a facility, limiting extension of license expiration dates, and maintenance of operator proficiency at operating the facility controls.
The Regulatory Activities Subcommittee of the Advisory Committee on Reactor Safeguards (ACRS) has reviewed the proposed changes to Parts 55 and 50.3 Both the March 28, 1980, H. R. Denton NRR letter and the proposed rulemaking impact this proposed regulatory guide.
With respect to the March 28, 1980, letter, the short-term requirements are either incorporated in the December 6, 1979, Draft Standard ANS.3.1 or noted in the regulatory position of this regulatory guide.
With respect to Part 55 and Part 50 revisions, certain positions now included in this regulatory guide will be codified in the regulations in place of the existing general provisions of the regulations.
After publication of the "A transcript of their review dated June 4, 1980, is available for inspection or copying for a fee in the NRC Public Document Room at 1717 H Street NW.,
Washington, D.C.
5
final rule changes, Regulatory Guide 1.8 will be revised to eliminate any q
duplication.
One aspect of changes recommended by.3ECY 79-330E and applicable only to NRC that is not addressed in proposed changes to 10 CFR Part 55 or this regula-tory guide concerns NRC practices for administration of qualifying examinations for nuclear power plant personnel.
These practices include the following items:
a.
Time limits will be imposed for completion of the written operator and senior reactor operator examinations administered by the NRC.
The operator examination will be limited to 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> and the senior operator portion of the examination will be limited to 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.
b.
-The passing grade for the operator and senior operator examina-tion ~will be 80% overall and 70% in each category.
c.-
The'NRC staff will audit training programs more closely and administer all the certification exams conduct,d at the completion of the simu-lator training portion of an operator's training program.
d.
The NRC staff will administer or direct the facility to administer annual examinations as part of the licensed operator and senior operator requali-fication programs that include a written, oral, and practical (performed on a l
simulator) portion.
e.
As a condition of license application, applicants for operator and senior operator licenses will be required to grant permission to the NRC to inform their facility management of the results of their examinations.
2.2.
Onsite and Offsite Managerial and Technical Organizations The NRC staff has under development criteria for onsite and offsite managerial and technical organizations, including a radiological protection organization, that will provide assurance of the safe operation of the plant during normal and abnormal conditions and the capability necessary to respond to unusual or unexpected situations.
A contractor, Teknekron Research, Inc.,
was selected to assist in the development of criteria listed above.
Teknekron submitted its final report to the NRC in May 1980 (Ref. 15).
Task I.B.1.1, " Organization and Management of Long-Term Improvements,"
and Task'I.B.1.2., " Evaluation of Organization and Management Improvements of Near-Term Operating License Applicants," of NUREG-0660 describe the criteria development. effort for technical and managerial organizations.
Task I.B.1.2
'is a first step in the development of criteria described in Task I.B.1.1.
As 6
+
described in Task I.B.1.2, near-term operating licensee applicants, as part of the license application review process, are being required to comply with the findings and requirements generated in an NRC interoffice review of licensee organization and management. 'The review is based, in part on an NRC document entitled " Draft Criteria for Utility Management and Technical Competence" (Ref. 16).
The first draft of this document was dated February 25, 1980, however, the document continues to change with use and experience in ongoing reviews.
The document addresses the organization, resources, training,.and qualifications _of plant staff and management (both onsite and offsite) for routine operations and accident conditions.
The criteria developed for use in evaluation of operator license applicants, as modified by experience from interoffice review of near-term operating license applicants, will form the basis for the final criteria to be developed in accordance with Task I.B.1.1 of NUREG-0660.
The criteria reference Regulatory Guide 1.8 and ANS Standard 3.1 with regard to qualifica-tions of nuclear plant personnel filling the various functional positions described in ANS Standard 3.1.
Regulatory Guide 1.8 will be implemented in conjunction with the recommendations of Task I.B.1.1 of the NRC Action Plan
~s j (see Section D of this guide, Implementation).
2.2.4 Onsite " Independent Safety Engineering Group" Each near-term operating license applicant as a part of ongoing license application review is being required to establish a group, commonly referred to as the " Independent Safety Engineering Group," that is independent of the plant staff, but is. assigned onsite to perform independent reviews of plant operations activities and to evaluate operating experiences at nuclear power plants.
Commission Information Paper SECY-80-242 (Ref. 17) describes the relationship of the proposed " Independent Safety Engineering Group" to other organizational entities such as the Plant Operations Review Committee.
The
" Draft Criteria for Utility Management and Technical Competence" (see Item 2.2.3 above) addresses the qualifications of the onsite independent safety engineering group by referencing Section 4.7 of the December 6, 1979, Draft Standard ANS 3.1.
7
2.2.5 Shift Technical Advisors As described in Task I. A.1.1 of NUREG-0660, the NRC is requiring that a technical advisor to the shift supervisor be present on all shifts.4 Although minimum training requirements have not yet been specified for shif t technical advisors presently occupying such positions, shift technical advisors should enhance the accident-a,sessment function at the plant.
B.y January 1, 1981, shift technical advisors will be required to have a technical education, which is of_the quality of courses taught at the college i sel and includes about 60 semester hours in basic subjects of engineering and ience; specific training in the design, function, arrangement, and operation af plant systems; and train-ing in the expected response of the plant and instruments to normal operation, transients, and accidents, including multiple failures of equipment and operator errors.
Commission Information Paper SECY 80-243 (Ref. 18) addresses the sub-ject of shift technical advisors, including a summary of experience yequired, duties to be performed, and the number of shif t technical advisors required onsite.
The qualifications of shift technical advisors as addressed in this regulatory guide are the ame as those specified in Commission Paper SECY 80-243 The Commission was inform i in this paper that the Institute of Nuclear Power Operations (INPO) has recently forwarded to NRR for comment a copy of an INP0 document, " Nuclear Power Plant Shift Technical Advisor--Recommendations for Position Description, Qualifications, Education and Training" (Enclosure to SECY 80-243), and that the NRC staff had the document under review.
This review may lead to revi sion to this regulatory guide with regard to shift technical advisors.
2.2.6 Comparison of NRC, Commercial, and Naval Procedures for Qualification of Personnel In early 1980, Basic Energy Technology Associates, Inc. (BETA), completed a study for the Office of Nuclear Reactor Regulation that outlined the results
- Requ >ements for the Shift Technical Advisor were contained in H. R. Denton and D. G. Eisenhut NRR letters to operating plant licensees on September 13 and October 30, 1979; applicants for pending operating licenses on September 27 and November 9, 1979; and applicants for pending construction permits and licensees of plants under construction on October 10 and November 9, 1979.
Copies of these letters are available for inspection or copying for a fee in the NRC Public Document Room at 1717 H Street NW., Washington, D.C.
8
of a comparative reviaw of current NRC requirements, commercial nuclear power plant practices, and the Naval Nuclear Propulsion Program procedures for the selection, training, and qualification of personnel involved in nuclear power plant operation and maintenance.
The results of the BETA study entitled " Power Plant Staffing" are documented in NUREG/CR-1280, BETA-103 (Ref. 19).
Public comments were requer.ted on tnis study..The' BETA study, when comparing the majority of practices, used the provisions outlined in ANSI N18.1-1971 and did not consider later versions of the standard.
The BETA study will be con-sidered when developing future revisions to this regulatory guide.
2.2.7 Requirements for Licensing of Operators The NRC staff has awarded a contract to Analysis and Technology, Inc.,
for a study of requirements for operator licensing.5 The scope of the work should result in recommendations for (a) the means to be employed for selection and training of nuclear power plant personnel and the degree to which the NRC should be involved in the process, (b) the means to be employed to evaluate the effectiveness of training programs, including who, by job description, should be licensed, (c) the methods to be emp'oyed to ensure continued competency of plant
~ 3
(
)
personnel and the degree to which the NRC should be involved in the methods, (d) the methods to be employed for maintaining a highly motivated and dedicated work force, and (e) the means to be employed for rapidly requalifying presently licensed operators to meet the proposed new,equirements.
Task I.A.2.6, "Long-Term Upgrading of Training and Qualifications," of NUREG-0660 provides a descrip-tion of planned NRC actions related to this contract study.
After staff review of the study has been. completed, the staff will provide recommendations to the Commission and subsequently factor Commission decisions on the recommendations into a regulatory guide or a regulation.
2.2.8 Planned NRC Accreditation of Training Institutions As described in Task I. A.2.7, " Accreditation of Training Institutions," of NUREG-0660, the NRC staff is conducting a study of procedures and requirements for NRC accreditation of training institutions.
A Commission Information Paper on this subject should be completed by late 1980.
The NRC staff will also
)
6Since the study is in progress, its recommendations are not yet available, a
9
(
prepare a Commission paper examining various NRC approaches to accreditation of training institutions.
Staff action on this later effort shocid be completed by January 1982.
3.
ANTICIPATED REVISION TO GUIDE With regard to the interface of this proposed regulatory guide and the other efforts described in Section 2.2 above, this version of the regulatory guide is a first step b a comprehensive process of upgrading the training and qualifications of operations personnel.
Some of the regulatory positions may be eventually superseded by more comprehensive long-term changes (e.g., changes ta NRC egulations) in the area of personnel qualification and training; however, t.he e pos tions are expected to be consistent with the long-term changes.
i This regulatory guide is being issued at this time in order to solicit public comment on changes thus far made.
The draft standard, ANS 3.1, endorsed by this guide las not yec been approved as an American National Standard, but permission nas been granted by the American Nuclear Society to use the December 6, 1979, draft revision of the standard with the proposed regulatory guide redsion. during the public review and comment period.
Comments received l
on the draft standard will be transmitted-to the ANS-3 Working Group that is developing _the standard in addition to being given consideration by the staff for inclusion in the regulatory guide.
Since the standard and the guide are being developed in parallel, comments.can be resolved, as appropriate, by modification to either the standard or the guide or both.
~
C.
REGULATORY POSITION
)
i The requirements included in Draft Standard ANS 3.1 dated December 6, 1979, are acceptable to the NRC staff for complying with the pertinent require-ments of the Commission's regulations for qualification and training of personnel in the operations organization subject to the following exceptions and supple-ments.
(The discussions in Appendix A r lated to Regulatory Position 2.3.1 about
-Shift Supervisors and in Appendix B related to Regulatory Position 2.7 on Shift Technical 'Aavisors should be considered with those positions.)
O l
10
i I
1.
GENERAL:
EXCEPTIONS AND SUPPLEMENTS
_1.1 Pertinent Standards and Endorsing Guides Throughout the draft standard, other documents required to be included as part of this standard are identified at the point of reference.
The specific applicability of these standards listed in the draft standard has been addressed in the latest revision of the following regulatory guides:
Regulatory Guide-ANSI Standardi 1.17 N18.17 1.33 N18.7 1.134 N546 In addition, the NRC has issued for comment Draft Guide RS 110-5, " Nuclear Power Plant Simulators for Use in Operator Training," dated July 1980, endorsing the March 24, 1980, draft version of American Nuclear Society Standard ANS 3.5,
,ps
" Nuclear Power Plant Simulators for Use in Operator Training."1 1.2 femporary Personnel Replacements 1.2.1 Field-Specific Experience Section 3.1 of Draft Standard ANS 3.1 discusses the use of personnel who may not meet the requirements of the standard to fill positions as temporary replacements.
Temporary personnel should not be used as replacements for periods exceeding 1 month.
Additionally, temporary personnel replacements should have experience in the field of the individual for whom they are serv-ing as replacements.
1.2.2 Training When an individual is hired to temporarily function as a plant employee, such as for contracted services, evidence of previous education, experience, and training should De provided and reviewed by the appropriate professional-technical group leaders.
The appropriate group leaders should then determine
l the content for that individual's training, including plant-specific training.
i i
As a minimum, each individual should receive " General Employee Training" (see Section 5.4 of ANS 3.1).
11 l
1.3 Definition of " College-Level Education" Throughout the standard, the term " college-level education" is used to describe the quality of the education to be completed; i.e., courses completed should be as demanding as those offered at the college level.
This term should be construed to mean course work satisfactorily completed (e.g., finished with a grade at t' 70% level) at or conducted by a college or university with curricula accredited by a nationally recognized agency such as the Accredita-tion Board for Engineering and Technology (ABET /ECPD).6 Additional guidance 7 will be developed by the NRC.
The on accreditation of training institutions NRC intends to establish alternative means of accreditation of training pro-grams, after'which, course work completed under such programs may be acceptable.
1.4 Interim Regulatory Positions Related to Anticipated Rules Section 1 of Draft Standard ANS 3.1 states that the NRC and other regula-tory agencies promulgate egulations applying to many aspects of the design, construction, and_ operation of nuclear power reactors and that ANS 3.1 shall I
not take precedence over any such regulation.
As indicated in the Section B
" Discussion" of this guide, the NRC staff is preparing amendments to 10 CFR Part 55 and 10 CFR Part 50 that relate to subjects addressed by ANS 3.1.
Listed below are exceptions taken to the standard to provide for consistency with the anticipated amendments.
The proposed amendments to 10 CFR Part 55 and 10 CFR Part 50 are undergoing review prior to publication for public comment.
The positions listed below should be regarded as interim regulatory positions pending issuance of final amendments to 10 CFR Part 55 and 10 CFR Part 50.
a.
Section 4.3.1 of Draft Standard ANS 3.1 requires as part of the experience requirements that a senior operator have 6 months of experience as e licensed operator.
Except in cases where personnel are taking cold NRC senior operator examinations, a senior operator should have 1 year of experience as a licensed operator at the plant for which the senior operator license is requested.
6The Manual of Evaluation Procedure of the Engineering Accreditation Commission may.be obtained from the Accreditation Board for Engineering and Technology (ABET /ECPD), 345 East 47th Street, New York, New York 10017.
7The' term " training institutions" includes colleges, universities, other named four year schools of higher learning, and technical schools that offer courses of the quality and at the level of comprehension usually taught in colleges.
12
b.
Sections 4.3.1.2 and 4.5.1.2~ require that the competency of license applicants-for senior. operator and operator licenses be certified by corporate management prior to endorsing the applicant for licensing by the NRC.
This certification should be performed by the highest level of corporate management responsible for plant operations (for example, the Vice-President for Operations).
Additionally, ~ documented evidence of this certification should be submitted with the license application and this documentation retained for at least as
'long as that individual is employed at the plant or. by the organization that operates the plant.
c.
Section 4.3.1.2, in discussing education requirements, states that a senior operator shall have a high school diploma plus the equivalence of thirty (30) semester hours of college-level education (450 classroom or instructor-conducted hours) in mathematics, reactor physics, chemistry, mate-rials, reactor thermodynamics, fluid mechanics, heat transfer, electrical and reactor control theory.
In lieu of this provision, a senior operator should hold a high school diploma or general education development certificate and have had a minimum of 60 semester hours of college-level education in technical subjects such as mathematics, reactor physics, chemistry, materials, reactor thermodynamics, fluid mechanics, heat transfer, and electrical and reactor control theory.
d.
Section 5.2.1.3.1 requires that, as part of the operator training program, candidates shall observe operating practices in the control room.
As a minimum, an operator license applicant should have received 3 months of shift training with no other concurrent duties at the facility for which the applicant seeks a license. =During this training, the applicant, under the observation and control of a licensed operator, should ha.e manipulated the facility controls and performed duties that would be performed by a licensed operator.
As a minimum, a senior operator applicant should have received 3 months of shift _ aining with no other concurrent duties at the facility for which the applicant seeks a license.
During this training, the applicant, under the observation and control of a li,:ensed senior operator, should have supervised the manipulation of the facility controls and performed duties that would be performed as a licensed senior operator.
e.
Section 5.5.1, in discussing retraining of licensed personnel, states that a simulator shall be used to fulfill portions of the retraining 13
program.for those evolutions where the simulator is capable of simulating con-tinuously and.in real time plant operations of the referenced facility.
Pro-posed amendments to Part 55 are expected to contain requirements for nandatory simulator training for both new license applicants and requalification of operators and senior operators.
Licensees should provide, to the extent pos-sible, for' simulator training.
2.
QUALIFICATIONS:
EXCEPTIONS AND SUPPLEMENTS 2.1 Limited Number of Exceptions to Required Qualifications Section 4.1 discusses a case-by-case evaluation of an individual's qualifi-cations when the individeil does-not meet those stated in the standard.
Accept-ance of an individual's qualifications based on this type of evaluation should be reserved for exceptional cases.
Exceptions for individual qualifications should not exceed 5 percent of all the positions covered by this standard on a per unit basis without prior NRC staff approval.
Exceptions should not be used for the positions of plant manager, operations manager, radiation protection manager,8 or shift supervisor.
In those cases where exceptions to requirements of the standard are used, the evaluation that justifies any such exceptions should be documented and that documentation retained for at least as long as that individual is employed at the plant or by the organization that operates the plant.
2.2 Managers 2.2.1 Plant and Technical:
NRC Certification Sections 4.2.1 and
.2.4 discuss certification at the plant or at an appro-priate simulator as a qualification requirement for the positions of plant manager and technical manage..
This certification should either be conducted or approved by the NRC staff.
"The title " red ation protection manager" is used by many licensees to describe the person reponsible for the radiation protection program; other titles are equally a.;ceptable.
I 14
( _ u-a.
12.2.2-Maintenance:
Educatic. Requirements Section 4.2.'3 discusses the education requirements-for the maintenance manager.
The recommendatic.T for the maintenance, manager to-have nondestructive
-testing' familiarity, craft knowl'e Q e,.and an'understan' ding of electrical, pressure vessel,*and piping codes and stan'dards should be construed as a-
_ requirement.
-2.2.3 Radiation Protection:
Training and Experience 2.2.3.11: Minimum Formal Training.
Sectior. 4.4.4a. requires that the Radia-tion P_rotection_ Manager have some formal training in radiation protection.
. Topics.to be, included ~in this training should include as a minimum, personnel dosimetry, air sampling, shielding; radiological biology, and radiation protec--
tion' instrumentation.
2.2.3.2 1 Certification'and Experience.
In general, an individual who is certified.by the American Board of Health. Physics in accordance with the " Power Reactor Health' Physics Certification Program" dated November 1978-is considered as having met the requirements specified in Sectioa 4.4.4 of the draft standard for the Radiation-Protection Manager 8 provided that the individual has spent-a minimum of 2 of the 6 years immediately preceding application 'or certification in a position of supervisory capacity in a health physics pr6 gram for an operating nuclear power. plant.
2.2.3.3 Experience Requirement.
Section 4.4.4 states that the Radiation Protection Manager shall have 4 yea.s of. experience in applied radiation protec-tion and that at least 3 years shall-be in applied radiation protection work in a nuclear facility dealing with radiological problems'similar to those encountered in nuclear. power plants.
Additionally, the 4 years of experience in applied radiation protection required by.the draft standard should be professionalslevel experience and the 3 years of experience at a nuclear facil-~
ity_should_ include supervision of the activities of radiation protection
-technicians.
-2.3 TShift Supervisors
- 2.321' Education Requirements
'Section'4.3.1.1 discusses the requirements for qualification of shift
. supervisors (pe_rson.in charge of-shift operations).
In lieu of the education p
15 -
p
requirements of the standard, the shift supervisor should have at least a Bachelor of Science degree that includes at least 60 semester hours in mathe-matics, reactor physics, chemistry,. materials, thermodynamics, fluid mechanics, heat transfer, end electrical and reactor control theory.
(A discursion of the education requirements for shift supervisor is included as Appendix A to this regulatory guide in an additional effort to obtain public input in developing this position.
Specific comments on Appendix A are invited.)
2.3.2 Corporate Certification of Candidates In order to ensure greater management involvement in the selection of thift supervisors, certification of the competency of shif t supervisor candi-c3tes should be performed by the highest level of corporate management respon-sib b for plant operations (for example, the Vice President for Operatioris).
This certification should be documented and the documentation retained for at least as long as the individual is employed at the plant or by the organization that operates the plant.
2.4 Professional-Technical Group Leaders 2.4.1 Instrumentation and Control and Chemistry and Radiochemistry:
Experience Requirements Sections 4.4.2 and 4.4.3 contain experience requirements for the leaders of the instrumentation a:4 control professional-technical grour and chemistry and radiochemistry professional-technical-group.
Consistent with the experience requirements of the standard for the leader of the reactor engineering group, the experience for those individuals discussed in Sections 4.4.2 and 4.4.3 should be 4 years of professional-level experience, 2 years of which should be in instrumentatics and control or cherpistry and radiochemistry, respectively.
Included in this experience should be 1 year of nuclear power plant experience as required by the draft standard for these positions.
2.4.2 Chemistry and Radiochemistry:
Cred t of Training Toward Experience Section 4.4.3 allows 1 year of credit toward nuclear power plant experience for a chemistry and radiochemistry training program.
In order to ensure that any such training program cannot be used to fulfill the requirement of the stand-ard for the chemistry and radiochemistry group leader to have 1 year of nuclear 16
~
' licensing' prior to initial 3 fuel loading may require special additional con-
- siderations,.particularly withKrespect;to experience.
"(1)/ Shift Supervisor (person in charge.of; operations on shift at-the
- station) - Shift Supervisors should have at least a Bachelor of Science degree or= equivalent training and experience in engineering or the related,physicalfsciences. ~ The Shift Supervisor should'also hold'a
- senior reactor ~ operator's-license (issued under new proposed require-ments defined below) and have served as a reactor operator for one.
year or senior reactor operator'for six months.
In establishing o
equivalency withra Bachelor of-Science degree, consideration should be given not'only to formal courses-in engineering and related i
' sciences, but also to education in the liberal arts.
It is recommended
'that the use of the equivalency to a Bachelor of-Science degree;be f
ex'ercised to only a limited degree and that most shift supervisors hold degrees.
It is also recommended that shift supervisor qualifica-tions include leadership training and experience.
"(2) Senior Reactor Operator (e.g.,. shift foreman in a multi-unit station) -
l Senior Reactor h erators should have at least the same general technical education and specific training in transient and accident response-characteristics of nuclear power plants as recently articulated for,
-the_ shift technical advisor. Additional-recommendations.for upgrading senior reactor operator. qualifications -are identified in the Commission
' Paper SECY 79-330E on. Qualification of Reactor Operators."
In comparing proposed Regulatory Position '2.3.1 and the recommendations of the Lessons-Learned Task. Force it should be noted that the Lessons-Learned Task Force recommended-(1) that shift supervisors have~at least a Bachelor of Science
, degree,or equivalent training and experience in engineering or_the related physical sciences and (2) that the shift supervisor also held a senior reactor operator ( 'icense issued under r 4 requirements proposed by the Lessons
~
. Learned Task Force (senior ; reactor operators should have at -least the 'same general technical education and specific training'in transient and accident response l characteristics of nuclear power plants. as -ecently articulated for 25-4
,4
the shift technical. advisor).
The provision af this regt.latory position for 60 semester hours of technical education is derived from the general technical education requirements for shift technical advisors (see Appendix B to this guide).
Proposed Regulatory Position 2.3.1 is more stringer.t than the position the Advisory Committee on Reactor Safeguards (ACRS) may deem necessary.
The l
Advisory Com'ittee on Reactor Safeguards in its report cf December 13, 1979,*
to Chairman Ahearne on the Lessons Learned Task Force Final Report (NUREG-0585) stated'that it gave-general-support to the recommendations related to personnel qualification and training; however, the ACRS also provided the following com-ment concerning qualifications of shift supervisors.
"The ACRS believes that, although a broader technical background should be required of Shift Supervisors, it may be neither necessary nor practical to require that all Shift Supervisors have a Bachelor of Science Degree.
The Committee recommends that the NRC define its criteria for ' equivalent training and experience in engineering or the related physical sciences.'
The ACRS
' believes that a training program tailored to the requirements of reactor operation, possibly of less than four years duration, may provide a practical
(
alternative to a formal degree program.
The Committee believes that the NRC Should dc9 ne the scope and duration of a training program that may be con-sidered as an _ acceptable alterr.ative to a degree curriculum."
The differences between the comment of the ACRS and proposed Regulatory Position 2.3.1 will be discussed in Section 3 of this appendix when addressing the alternative education requirements for shift supervisor that could be l
considered.
Prior to that discussion, recommendations or comments of other groups on qualification requirements for shift supervisors are presented.
2.
RECOMMENDATIONS AND COMMENTS FROM OTHER GROUPS The Report of the NRC Special Inquiry Group (NUREG/CR-1250) recommended that the NRC should require every licensee to hire a cadre of graduate engineers knowiedgeable in reactor engineering and physics and that each A
Document is available for inspection or copying for a fee in the NRC Public Document Room at 1717 b Street NW., Washington, D.C.
{
26
g engineer be provided with training in specific characteristics of the plant, W
with special emphasis on integrated plant response and transient behavior.
The Special Inquiry Group further recommended that the utility should be required to. deploy on every shift at least one such engineer as supervisor whose qualifications as shift manager, not as an " advisor," have been examined by the NRC.
Basic Energy Technology Associates, Inc. (BETA), in its report to the NRC on power plant staffing (NUREG/CR-1280) discusses the differences in NRC, commercial, and Naval practice for shift supervisors. to this appendix is an excerpt from the BETA report concerning shift supervisor qualifica-tions.
The BETA report recommends that a new position entitled " Shift Engineer" be created.
The " Shift Engineer" would be a degreed engineer who would normally function within the technical organization but is sssigned to the Operations Manager to provide shift engineering coveragc.
The LETA report also ndicates that the " Shift Engineer" should have the power and responsibility to direct the shift supervisor in the event of an emergency.
If the " Shift Engineer" has the power and responsibility to direct the shift supervisor and is licensed as a senior reactor operator with extensive D
operating experience, then the difference between the BETA recommendation and the proposed regulatory position is more related to organizational requirements than to qualification requirements of the " person in charge of operations on shift."
Teknekron Research, Inc., in its report to the NRC on utility management and technical resources recommended the shift supervisor have a bachelor's degree in engineering. to this appendix is an excerpt from the Teknekron report concerning shift supervisor qualifications.
While the above recommendations, for the most part, have been supportive of proposed Regulatory Position 2.3.1, the Atomic Industrial Forum (AIF) had reservations about such an approach.
!.' the February 1980 Report to the AIF Policy Committee on Follow-Up to the Three dile Island Accident by the AIF Working Group on Action Plan Priorities and Resources, it was stated: "The requirements for a B.S. degree could have adverse effects on plant safety in that it probably would result in a higher turnover rate for these positions, thus reducing experience in this position at most plants industry wide.
The turnover is expected because the person is likely to consider himself over qualified for the usual daily operations; he would not be gaining professional 27
satisfaction.
There would be no risk reduction attributable to the degree.per l
se because it is assumed that he has sufficient fundamental education in the proper engineering discipl bes.
If this requirement is implemented, risks from plant operation will increase due to personnel turnover.
It is suggested this item be reviewed with a consideration toward ine"?asing requirements for funda-mental education, but not requiring a degree."
Proposed qualification requirements for the shift supervisor are also included in the December 6, 1979, Draft Standard ANS 3.1, " Standard for Quali-fication and Training of Personnel for Nuclear Power Plants." This draft revision of ANS 3.1 states, in Section 4.3.1, that the educational requirements for this position'are a high school diploma plus the equivalence of 60 semester hours of college-level education in specified technical topics.
3.
ALTERNATIVE EDUCATION REQUIREMENTS A wide variety of opinion exists concerning education requirements for shift supervisors.
A discussion of proposals for education requirements for shift supervisors is provided below in an attempt to define the issues invclved I
and to foster public comment an these issues. While the requirements related to nuclear power plant experience are not addressed in the following discussion, the importance of extensive in plant experience for shift supervisors cannot be over emphasized.
Alternative education requirements for shift supervisors include the following:
Alternative 1: Require as a minimum a high school education.
Aiternative 2: Require a high school education plus a specified number of college-level technical courses.
Alternative 3: Require a high school education plus a specified number of col'ege-level courses in technical subjects as well as courses in humanities and social studies such as written and oral communication, applied psychology, political science, and economics.
l 28
Alternative 4: Require a Bachelor of Science degree in engineering or a related physical science.
'Alternctive 5: Require a Bachelor of Science degree in engineering or a related physical science that includes a specified number of courses in technical subjects as well as courses in humanities and social studies such as written and oral communication, applied psychology, political science, and economics.
The following discussion explains why Alternatives 1, 2, and 4 are deemed unacceptable and conpares the acceptability of Alternatives 3 and 5.
Alternative 1 (high school diploma) is unacceptable.
In particular, the technical complexity of supervising the operation of a nuclear power plant requires an education' exceeding that demonstrated by a high school diploma.
The <iemands of present practice for operator and senior operator training exceed this requirement (i.e., while a shift supervisor may have only a high school diploma, completion of the senior operator training program requires education beyond the high school level.)
Alternative 2 (high school diploma plus completion of a specified number of college-level technical courses) is also unacceptable.
While this alterna-tive qualifies a supervisor to deal with technical areas, it does not provide a broad-based education in nontechnical subjects such as management, leadership, and written communication that is necessary to-deal with many of the nontechnical responsibilities of tha shift supervisor, particularly, supervision of plant personnel.
Alternative 4 (Bachelor of Science degree in engineering or a related physical science) is also' unacceptable.
There are some Bachelor of Science (B.S.) degree programs that do not meet the education requirements for a shift supervisor.
Although an engineer holding a B.S. degree would have completed many of the subjects considered necessary'to qualify as a shift supervisor, having successfully earned a degree in engineering does not ensure knowledge of such specific areas as fluid mechanics and reactor control theory.that is necessary to the shift supervisor.
The remaining discussion will be limited to a discussion of Alternatives 3 l
and 5.
Proposed Regulatory Position 2.3.1 (Alternative 5) is selected as the 29
optimum choice because it quantifies the required technical courses as 60 semester hours in mathematics, reactor physics, chemistry, materials, thermo-dynamics, fluid mechanics, heat transfer, and electrical and reactor control theory. Alternative 3 does not quantify the number of technical courses required.
When considering technical courses, two questions are readily identifiable.
First, is the number of courses and the area of their. coverage sufficient?
Since the number of technical courses required for a Shift Supervisor in Alter-native 5 is the same as that required for a shift technical advisor (Regulatory Position 2.7), the course requirement appears to be acceptable.
Second, should the requirement stipulate that the courses be taught at an accredited college or university? The level of instruction of the courses is required to be beyond the high school level. Therefore, the only practical way, pending accredita-tion of technical training institutions other than 2-or 4 year accredited colleges or universities, to specify the required level of instruction is to provide that such instruction be satisfactorily completed at or conducted by an accredited college or university.
The technical education requirements of Alternatives 3 and 5 are consistent, but the nontechnical education requirements of Alternatives 3 and 5 differ.
It is expected that the nontechnical liberal arts curriculum requirement of Alternative 3 would consist of a minimum of 20 semester hours conducted at or j
by an a
- dited college or university in such courses as psychology, management, j
leadership, sociology, and other liberal arts courses thereby providing a broad-based education.
This broad-based education would equip a shift supervisor to deal with many of the nontechnical responsibilities of the position such as communicating with shift personnel and providing leadership for shift activ-ities.
Completion of the required 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of technical courses and estimated 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of nontechnical courses amounts to 80 semester hours or approximately 75% of the work necessary to obtain a degree.
Completion of only an additional 40 to 50 semester hours would be required-to obtain a college degree.
It is expected that an individual who completes 75'f, of the work necessary to obtain a degree would likely complete the remainder.
Therefore, realistically, there may be little difference between Alternatives 3 and 5.
A college degree indicates a level of accomplishment and self-discipline that-helps produce self-confidence in an individual and helps establish leadership qualities necessary to a shift supervisor.
The wide exposure of 30
O f
~
~
' the1individua11tc both1 technical and liberal-arts courses' provides a more well-1 rounded' education.than exposure ~tn.only technical courses;that could improve a tsh'ft supervisor'sLability to direct shift operations activities.
~
'A degree is' based on a well-thought-out. curriculum with required courses-
~ integrated'and dovetailed to ' complement one another in a consistent manner:in
, order to equip'a person-to consider problems and make. decisions in a construc-
~
.tiv'e waylin a particular field. Without such planning, 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, or anyfother required'ncaber of cou.*ses, is taaningless--it could be a hopeless hodgepodge of-unintegrated and only vaguely related information.
Therefore, Alternative 5 with.its degree requirement ir urobably the best choice.
.4.
IMPLEMENTATION The Lessons Learned Task Force.in its final report 1(NUREG-0585) recommended a phased program to take. place within1the next 5 years for-. upgrading the quali-fications of shift supervisors and senior reactor operators. 'Whether training of,present personnel is1 upgraded or degreed engineers are introduced into the
-training program, it is' expected that it would take a minimum of 5 years-to fully respond.to the upgraded requirements stated in-Alternatives 3 or 5.
A program of upgrading the-qualifications of individuals now employed as shift supervisors at operating plants should be initiated by the utilities to ensure that these individuals possess the necessary technical competence and
. management skills to adequately-perform their-jobs.
Due credit should be given shift supervisors for demonstrated ability'to perform'their duties.
The quali-
-fications of. current shift supervisors and the utility's. program for upgrading-qualifications for shift supervisors should be reviewed on a case-by-case basis 1by the Office of Nuclear Reactor Regulation at the time of renewal-of the shift supervisor's senior operator: license.
In1 implementation of the regulat'ory~ position on shift supervisors, con--
sideration will;need to_be given to the AIF cencein that such a position may cause a high turnover-rate and thereby adversely. affect plant safety.
31!
9 3
-w
-.., ~... - -.
- m. to Appendix A EXCERPT FROM NUREG/CR-1280, " POWER PLANT STAFFING" VI.
SHIFT SUPERVISORS i
A.
Definitions In the context of this review, shift supervisors will be considered licensed senior reactor operators (SR0's) and wiil-be compared with Engineering Officers of the Watch (E00W's).
An Engineering Officer of the. Watch (E00W), insofar as a nuclear ship is concerned, is an officer who has been selected, trained, qualified, and designated as a nuclear trained officer.
He has been qualified as an E00W in his ship by hit Commanding Officer.
He is the senior officer on watch in the engineering plant of the ship.
All persons on watch in the engineering plant report to him.
He is responsible for the operation of the plant, its safety, emergency action and anything going on in the plant.
He directs all operations.
8 B.
NRC Requirements for Shift Supervisors NRC requirements for eligibility, training, qualification and requali-fication of shift supervisors are contained in ANSI N18.1-1971 and NUREG-0094.
These requirements are summarized in Table 1 of this report.
C.
Industry Practices for Shift Supervisors As in the case of operators, civilian industry practices generally follow the NRC requirements.
However, as previously indicated, ANS 3.1-1978 and proposed Revision 2 to Regulatory Guide 1.8 are used even though not required. All of the comments made in Section V.B of this report concerning industry problems with operators equally apply to the case of shift supervisors.
D.
Navy Practices Before a naval officer can qualify as an Engineering Officer of the Watch (first-line operating supervisor) on a nuclear ship he will have met the following requirements:
e
'32
licensing prior to initial fuel loading may require special additional con-siderations,.particularly with respect to experience.
"(1) Shift Supervisor (person in c3arge of operations on shift at the station) - Shift Supervisors shoula have at least a Bachelor'of Science degree or equivalent training and experieace in engineering or the related physical sciences.
The Shift Supervisor should also hold a senior reactor operator's license (issued under new proposed require-me-+s defined below) and have served as a reactor operator for one
-year or senior. reactor operator for six months.
In establishing equivalency with a Bachelor of Science degree, consideration should be given not only to formal courses in engineering and related sciences, but also to education in the-liberal arts.
It is recommended that the use of the equivalency to a Bachelor of Science degree be exercised to only a limited degree and that most shif t supervisors hold degrees.
It is also recommended that shift supervisor qualifica-tions include leadership training and experience.
"(2) Senior Reactor Operator (e.g., shift foreman in a multi-unit station) -
Senior Reactor Operators should have at least the same general technical education and specific training in transient and accident response characteristics of nuclear power plants as recently articulated for the shift technical advisor.
Additional recommendations for upgrading senior reactor operator qualifications are identified in the Commission Paper SECY 79-330E on Qualification of Reactor Operators."
In comparing proposed Regulatory Position 2.3.1 and the recommendations of the Lessons Learned Task Force it should be noted that the Lessons Learned Task Force recommended (1) that shift supervisors have at least a Bachelor of Science degree or_ equivalent training and experience in engineering or the related physical sciences and (2) that the shift supervisor also hold a senior reactor operator's license issued under new requirements proposed by the Lessons Learned Task Force (senior reactor operators should have at least the same general technical education _and specific training in transient and accident response characteristics of nuclear power plants as recently articulated for 25
the shift technical advisor).
The provision of this regulatory position for 60 semester hours of technical education is derived from the general technical education requirements for shift technical advisors (see Appendix B to this guide).
Proposed Regulatory Position 2.3.1 is more stringent than the 70sitio:1 the Advisory Committee on Reactor Safeguards (ACRS) may deem neces. ary.
Tne Advisory Committee on Reactor Safeguards in its report of December 13,199,*
to Chairman Ahearne on the Lessons Learned Task Force Final Report (NUREG-0585) stated that it gave general support to the recommendations related to personnel qualification and training; however, the ACRS also provided.the following com-ment concerning qualifications of shift supervisors.
"The ACRS believes that, although a broader technical background should be required of Shift Supervisors, it may be neither necessary nor practical to require tnat all Shift Supervisors have a Bachelor of Science Degree.
The Committee recommends that the NRC define its criteria for ' equivalent training and experience in engineering or the related physical sciences.'
The ACRS believes that a training program tailored to the requirements of reactor i
\\
operation, possibly of less than four years duration, may provide a practical l
alternative to a formal degree program.
The Committee believes that the NRC should define the scope and duration of a training program that may be con-sidered as an acceptable alternative to a degree curriculum."
The differences between the comment of the ACRS and proposed Regulatory Position 2.3.1 will be discussed in Section 3 of this appendix when addressing the alternative education requirements for shift supervisor that could be considered.
Prior to that discussion, recommendations or comments of other group:: on qualification requirements for shift supervisors are presented.
2.
RECOMMENDATIONS AND COMMENTS FROM OTHER GROUPS The Report of the NRC Special Inquiry Group (NUREG/CR-1250) recommended that the NRC should require every Ticensee to hire a cadre of grarfuate engineers knowledgeable in reactor engineering and physics and that each n
Document'is available for inspection or copying for a fee in the NRC Public Document Room at 1717 H Street NW., Washington, D.C.
26 s
enginear be provided with training in specific characteristics of the piant, with special emphasis on integrated plant response and transient behavior.
The Special Inquiry Group further recommended that the. utility should be required to deploy on every shift at least one such engineer as supervisor whose qualifications as shift manager, not as an " advisor," have been examined by the NRC.
Basic Energy Technology Associates, Inc. (BETA), in its report to the NRC on power plant staffing (NUREG/CR-1280) discusses the differences in NRC, commercial, and Naval practice for shift supervisors. to this appendix is an excerpt from the BETA report concerning shift supervisor qualifica-tions.
The BETA report recommends that a new pocition entitled " Shift Engineer" be created.
The " Shift Engineer" would be a degreed engineer who would normally function within the technical organization but is assigned to the Operations Manager to provide shift engineering coverage.
The BETA report also indicates that the " Shift Engineer" should have the power and responsibility to direct the-shift supervisor in the event of an emergency.
If the " Shift Engineer" has the power and responsibility to direct the
~
shift supervisor and is licensed as a senior reactor operator with extensive operating experience, then the difference between the BETA recommendation and l
the proposed regulatory position is more related to organizational requirements than to qualificat ion requirements of the " person in charge of operations on shift."
Teknekron Research, Inc., in its report to the NRC on utility management and technical resources recommended the shift supervisor have a bachelor's degree in engineering. to this appendix is an excerpt from the Teknekron report concerning shift supervisor qualifications.
While the above recommendations, for the most part, have been supportive of propcsed Regulatory Position 2.3.1, the Atomic Industrial Forum (AIF) had reservations about such an approach.
In the February 1980 Report to the AIF Policy Committee on Follow-Up to the Three Mile Island Accident by the AIF Working Group on Action Plan Priorities and Resources, it was stated: "The requirements for a B.S. degree could have adverse effects on plant safety in that it probably would result in a higher turnover rate for these positions, thus reducing experience in this position at most plants industry wide.
The turnover is expected because the person is likely to consider himself over 9
qualified for the usual daily operations; he would not be gaining professional 27
satisfaction. There would be no risk. reduction attributable.to the degree per se because it 'is assumed that he has sufficient fundamental education in the I
proper engineering disciplines.
If this requirement is implemented, risks from plant. operation will increase due to personnel turnover.
It is suggested this item be teviewed with a consideration toward increasing requirements for funda-mental education, but not requiring a degrer "
Proposed qualification requirements for the shift supervisor are also included in the December 6, 1979, Draft Standard ANS 3.1, " Standard for Quali-fication and Training of Personnel for Nuclear Power Plants." This draft revision of ANS 3.1 states, in Section 4.3.1, that the educational requirements for this position are a high school diploma plus the equivalence of 60 semester hours of college-level education in specified technical topics.
3.
ALTERNATIVE EDUCATION REQUIREMENTS A wide variety of opinion exists concerning education requirements for shift supervisors.
A discussion of proposals for education requirements for shift supervisors is provided below in an attempt to define the issues involved and to foster public comment on these issues.
While the requirements related I
to nuclear power plant experience are not addressed in the following discussion, the importance of extensive in plant experience for shift supervisors cannot be over emphasized.
Alternative education requirements for shift supervisors include the following:
Alterna' ve 1: Require as a minimum a high school education.
Alternative 2: Require a high school education plus a specified number of college-level technical courses.
Alternative 3: Require a high school education plus a specified number of college-level courses in technical subjects as well as courses in humanities-and se;ial studies such as written and oral communication, applied psychology, political science, and economics.
l 28 s
3 x.
y',
2,
~
m
+
x iAlternative4:] Req'uire'E;BachelorofSciEnce~degreein-engineeringora
^
.related physical science.
. 2 m
_AlternativeSIRequireiaBachelorof; Science-degreeinengineeringora~
1 2
~
}
1related2 physical science that includes'a'specifie'd number:
y of course'sTin 'techritcal ?subjActsias well. as courses.in f
Th'umanities and sodial studiesJsuch 'as written and oral 1
~
communication, appliid psychology,' political science, and 4
- economics.
)Thefollowingd'iscussion~ explains.whyAlternatives1,2,and4'aredeemed
~
^
.unacceptab1e and compares the acceptability:of Alternatives 3 and 5.
~Altsrnative 1-(high' school diploma) is unacceptable. 'In particular, the itechn'ic51' compjexity of supervising-the. operation' of a nuclear power plant requires:aneducation.exceedingthat~demonstratedbyahihhschooldiploma.
' The demands of present practice for ' operator-and senior operator. training' exceed-this requirement-(1-e., while a shift supervisor may have only a high school
- ' diploma,. completion of-the' senior operator training program requires education
.beyond the'high-school level.)'
1 Alternative ~-2c(high' school ~ diploma plus'completic<n of a~specified number
- of college-levs1 technicallcourses)'is also unacceptaole. While this alterna-.
d
~
'tive. qualifies' a~. supervisor lto-deal with technical areas, -it does not provide
' abroad-basededucation?innontechnicalfsubjectssuchasmanagement, leadership, i
and written communication thatlis:necessary to deal with many of the nontechnical
'responsibilitiestof the: shift-supervisor, particularly, supervision of. plant personnel.
? Alternative-41(Bachelor of._ Science degree in engineering or a relat'ed physical j
science)11sialso1 unacceptable.'.There are some Bachelor of Science (B.S.). degree.
l 7 programs [thstidoSot'meetthe: education _requirementsforashift" supervisor.
~
V a.
~
.\\
- Although an) engineer holding a5B.S. degree.would have completed.many.of the
- subjects; considered'necessary to" qualify as.a shift:s.upervisor,:having successfully fearned::a degreejin engineering does:Lnot nsure knowledge of such specific areas-
~-
g asifluid: mechanics and reactor; control theory that:is necessary to the shift
~
.,.v.
~
M_
jsupervisor. 3 s
+
~.
JThe" remainingLdiscussion;willl be limited to:a discussion of Alternatives 3 -
Jand5[(PropossdlRegulatoryPositior'23.1(Alternative 15)'is. selected:asfthel a
1
,5
.<(
I a
1 7,
x s
+ *
\\
l' V
,;3
.sg
~
x
-} }f a
- pn
, ; n_.
~
7 7
LW% y ;,,
- jys g
l optimum choice because it quantifies the. required technical courses as 60 semester hours in mathematics, reactor physics, chemistry, materials, thermo-dynamics, fluid mechanics, heat transfer, and electrical and rr.ctor control theory.
Alternative 3 does not quantify the number of technical courses required.
When considering technical courses, two questions are readily identifiable.
First, is the number of courses and the area of their coverage sufficient?
Since the number of technical courses required for a Shift Supervisor in Alter-native 5 is the.ame as that required for a shift technical advisor (Regulatory Position 2.7), the course requirement appears to be acceptable.
Second, should the requirement stipulate that the courses be taught at an accredited college or university? The level of instruction of the courses is required to be beyond j
the high school level.
Therefore, the only practical way, pending accredita-tion of technical training institutions other than 2-or 4 year accrediteu colleges or universities, to specify the required level of instruction is to provide that such instruction be satisfactorily completed at or conducted by an accredited college or university.
1 The technical education requirements of Alternatives 3 and 5 are consistent, but the nontechnical education require'ents of Alternatives 3 and 5 differ.
It is expected that the nontechnical lit ual arts curriculum requirement of J
l Alternative 3 would consist of a minimum of 20 semester hours conducted at or by an accredited college or university in such courses as psychology, management, l
leadership, sociology, and other liberal arts courses thereby providing a broad-based education.
This broad-based education would equip a shift supervisor to deal with many of the nontechnical responsibilities of the position such as j
communicating with shift personnel and providing leadership for shift activ-ities.
Completion of the required 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of technical courses and estimated 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of nontechnical courses amounts to 80 semester hours or approximately 75% of the work necessary to obtain a degree.
Completion of only an additional 40 to 50 semester hours would be required to obtain a college degree.
It is expected that an individual who completes 75% of the work necessary to obtain a degree would likely complete the remainder.
Therefore, realistically, there may be little difference between Alternatives 3 and 5.
A college degree indicates a level of accomplishment and self-discipline that helps produce self-confidence in an indiv' dual and helps establish leadership qualities necessary to a shift supervisor.
The wide exposure of
{
30
the individual to both. technical and liberal arts courses provides a more well-rounded education'than exposure to only technical courses that could improve a t
i shift supervisor's ability to direct shift operations activities.
A degree _is based on a well-thought-out curriculum with' required courses integrated and dovetailed to complement one another in a consistent manner in
.~ order to equip _ a person to coraider problems and make decisions in a construc-tive way in a particular field. Without such planning, 60 hot:rs, or any other required number of courses,-is meaningless--it could be a hopeless hodgepodge of unintegrated and only vaguely related information. _Therefort, Alternative 5 with its degree requirement is p ubably the best choice.
4.
IMPLEMENTATION The Lessons Learned Task Force in its final report (NUREG-0585) recommended a' phased program to take place within the'next 5 years for upgrading the quali-fications of shift supervisors ano senior reactor operators. Whether training cf present personnel is upgraded or degreed engineers are introduced into the training program, it is expected that it would take a minimum of 5 years to fully respand to the upgraded requirenents stated in Alternatives 3 or 5.
A program of upgrading the qualifications of individuals now employed as shift supervisors at operating plants should be initiated by the utilities to ensure that these individuals possess the necessary technical competence and management skills to adequately perform their jobs.
Due credit should be given shift' supervisors for demonstrated ability to perform their duties.
The quali-fications of current shift supe / visors and the utility's program for upgrading qualifications for shift supervisors should be reviewed _on a' case-by-case basis by the Office of Nuclear Reactor Regulation at the time of renewal of the shift i
i t
superv sor s sen or opera or-license.
-In implementation of the regulatory position on shift supervisors, con-sideration will need to belgiven to the AIF concern that such a position may cause a high turnover rate and thereby adversely affect plant safety.
l 31 i
I
-u
-s t
h
?
to Appendix A EXCERPT FROM NUREG/CR-1280, " POWER PLANT STAFFING" VI.
SHIFT SUPERVISORS A.
Definitions In the context of this review, shift supervisors will be considered licensed senior reactor operators (SR0's) and will be compared with Engineering Officers of the Watch (E00W's).
An Engineering Officer of the Watch (E00W), insofar as a nuclear ship is concerned, is an officer who has been selected, trained, qualified, and designated as a nuclear trained officer.
He has been qualified as an E00W in his ship by his Commanding Officer.
He is the senicr officer on watch in the engineering plant of the ship.
All persons on watch in the engineering plant report to him.
He is responsible for the operation of the plant, its safety, emergency action and anything going on in the plant.
He directs all operations.
G B.
NRC Requirements for Shift Supervisors NRC requirements for eligibility, training, qualification and requali-
, tion of shift supervisors are contained in ANSI N18.1-1971 and NUREG-0094.
These requirements are summarized in Table 1 of this report.
j C.
Industry Practices for Shift Supervisors As in the case of operators, civ.ian industry practices generally follow the NRC requirements.
However, as previously indicated, ANS 3.1-1978 and proposed Revision 2 to Regulatory Guide 1.8 are used even though not required.
All of the comments made in Section V.B of this report concerning industry problems with operators equally apply to the case of shift supervisors.
D.
Navy Practices Before a naval officer can qualify as an Engineering Officer of th:
Watch (first-line operating supervisor) on a nuclear ship he will have met the following requirements:
I 32
l 1.
He will have entered into the Navy's nuclear power program by applying (volunteering) and meeting the following requirements:
a.
Age requirements:
no older than 27 years of age.
l b.
College graduate (4 year curriculum) having successfully completed one year of calculus through differential and integral calculus, and one year of calculus-based physics.
c.
Physically qualified.
d.
Meet requirements of moral turpitude sufficient to be granted an appropriate security clearance.
e.
Have been interviewed in Washington, D.C. headquarters of tne Department of Energy's Deputy A.sistant Secretary for Naval Reactors.
These interviews consist of at least three individual interviews by senior technical staff personnel and the Deputy Assistant Secretary himself.
In about two-thirds of the cases, written examinations in math and physics are administered during this interview period.
f 2.
The Navy acquires its officers for the nuclear program through three sources:
U.S. Naval Academy, NROTC colleges, Nuclear Power Officer Candidate (NUPOC) program.
Officers selected for the nuclear program from D
the NUPOC program must attend the Navy's Officer Candidate School (0CS) for 16 weeks.
3.
Successful completion of the Navy's 6 months Nuclear Power School (NPS),
This course teaches basic theory relating to nuclear power at a higher level than that taught to enlisted personnel.
All instruction is conducted in the classroom.
4.
Successful completion of a 6 months practical course of instruc-tion at one of the Navy's 8 nuclear prototype plants.
Students will have actually " qualified" on the plant.
During this phase, the officer will qualify on all enlisted watch stations in addition to qualifying as an E00W.
5.
Will have been assigned to a nuclear powered ship and will have
" qualified" on that ship's plant.
This takes about 9 months and involves the following:
a.
A basic engineering qualification (BEQ) course which, in addition to,being a review of course material covered at NPS, covers basic reactor plant theory and application to the specific plant installed on his ship.
33
b.
A watch qualification program involving standing watches under instruction throughout the plant.
c.
The watch qualification program also involves completion of each item of a watch qualification guide by obtaining signatures, usually several hundred, that he has demonstrated, through discussion, actual prac-tice, or written tests his knowledge and ability.
j d.
He will be given a final comprehensive written examination and a series of oral examinations.
He must be given his final oral examina-tion by the ship's Commanding Officer.
6.
This entire program, from the time he enters the Navy as an officer until he stands his.first E00W as a qualified watcl stander is about 2 years.
E.
Differences and Recommendations for Shift 5.upervisors 1.
Difference:
E00W's are naval officers selected into the program through a I
tough but well-defined system.
Quality input is maintained even to the sacrifice of quantity.
High standards of performance are instilled from the first moment of selection and are emphasized throughout the training
{
program.
Each candidate knows he has a 5 year commitment.
He may fail, but he can not quit.
The training program is structured so that all stu-dents must work hard to succeed. No one, regardless of his background or intelligence, can just breeze through.
Standards for passing or failing the courses are clearly defined and enforced without waivers.
There is every incentive to finish the courses and finish them well.
There is no incentive to " drift alorg".
He is constantly examined as to his under-standing and retention of knowledge.
His examinations are orals or essay written.
There are not true or false or multiple choice examinations.
There is no self pace teaching.
His training is competitive and he knows i t.
The higher his relative standing, the better chance he has of select-ing his duty station.
His prototype instructors are qualified and experi-enced operators, many of whom are sea-returnees.
His rewards are ample:
a.
Recognition in the form of special bonuses whiin are sub-stantial.
l 34-
b.
Pride in being part of a small, elite group of officers who have successfully passed through the most difficult program the Navy has to offer.
c.
A sure path to future, better-than-average promotion if he continues satisfactory performance.
d.
The prospect of a select civilian career if he elects to resign at the end of his commitment.
e.
Knowledge that he is an integral part of the nation's number one major deterrent to war.
In the civilian nuclear industry a shift supervisor comes from two sources.
He can either be prcmoted up from the ranks of an operator, or he can be brought in directly from outside and made 3 shift supervisor without passing through the job as an operator.
In eiths-case, his selection, training and qualification generally follow that of an operator but with greater experience required.
All of the comments provided in Section V of this report relating to differences and recommendations have direct applicability to shift supervisors.
However,- there are two additional differences that should be
}
highlighted which are unique to the shift supervisor and the E00W.
The one difference has been discussed in the various reports and studies emanating from the Three Mile Island accident and has to do with the proper manning of the control room.
NRC has already issued interim requirements on the stationing of a Shift Technical Advisor in the Control Room.
Recommendations:
Our recommendation is to create a new position entitled " Shift Engineer".
He would be a degreed engineer who would normally function within the technical organization but is assigned to the Operations Manager to provide shift engineering coverage.
This position is created for the following purposes and reasons:
a.
If it is assumed that the requirements for becoming a shift supervisor (senior reactor operator) remain such that he need not be an experienced engineer (college graduate type), then there exists the need f9r such a person on shift who can make engineering judgments.
This would be the function of the Shift Engineer.
D 35
b.
The possibility exists to change the requirements for a shift supervisor such that he must be a college graduate engineer.
This alternative was not selected because it would close off an advancement path for reactor operators. While some may consider this to be a minor issue, the reviewers, based on their Navy experience, do not.
The civilian nuclear power industry must be able to provide an attractive career path for reactor operators or else face the prospect of heavy turnover or lower quality applicants.
c.
There is also the suggestion that the position of Shift Engineer be filled only when a shift supervisor is act an engineer, or that the Shift Engineer position be an interim measure until such time as all shift supervisors meet the engineer eligibility requirements or their equivalent.
We do not agree with this approach.
Regardless of whether or not a shift supervisor is an engineer, there should always be present in the control room an engineer whose primary interest, background and experience is technical in nature.
d.
The functions of the Shift Engineer would be as follows:
(1) He acts as a technically qualified observer to plant operations.
(2) He has the power to order the niant put into a safe condition in the event of an emergency.
(3) He does not report to the Shift Supervisor--he is an independent observer similar to the NRC inspector on shift.
However, he has the power and responsibility to direct the Shif t Supervisor in the event of an emergency or accident.
(4) He has the wherewithal to contact appropriate technical personnel to obtain technical assistance, thus allowing the Shift Supervisor to focus his attention on plant operation.
(5) If, during the course of normal operations, it is discovered that a given procedure requires modification, the Shift Engineer has the responsibility to resolve the problem, correct the procedures in accordance with approved methods, and to provide the results to the Shift Supervisor for his accomplishment.
The Shift Engineer would be a licensed Senior Reactor Operator e.
and will have had operating experience as outlined in Table 2 of this re,nort.
36 to Appendix A l
EXCERPT FROM V0L!ME I, " UTILITY MANAGEMENT AND TECHNICAL RE50VRCES,"
i THE TEKNEKRON RESEARCH, INC., REPORT
- 1. 5 ONSITE MANAGEMENT RESOURCES One man must be in charge of the plant at all limes.
Since in the normal work-week, the Plant Manager can be expected to be onsite less than 25% of the time, the Shift Supervisor has short-term onsite management responsibility (in the absence of the Assistant Plant Manager).
(The accession of management responsibility by the Plant Manager or his designee in the event that the long-term resources should be called upon is discussed in Section 2.3.)
The Shift Supervisor is the single most important resource in the event of an accident.
Not only is he solely responsible for any hands-on operations performed on the system, but he must also be the " intellectual leader" of the team.
He must be able to evaluate and act upon the technical input supplied by individuals on his onsite team and by his offsite resources.
He mu:,t also be able to coemunicate essential information to the long-term resources if and I
when they arrive onsite.
It is essential that he be thoroughly familiar with the plant, that he be exceedingly well trained (and retrained;, and that he command the respect of his colleagues.
Although this is a stringent requirement, it is not possible to overemphasize the importance of this individual in an accident situation.
With the foregoing in mind, and recognizing that the Shift Supervisor is equivalent to the Plant Manager when the latter is absent, we recommend the following minimum qualifications for tne Shift Supervisor:
1.
A bachelor's degree in engineering 2.
Two yects of operating experience at a nuclear power plant 3.
One year of experience at the specific nuclear plant to be operated (which can be satisfied by pre-operational testing) 4.
An NRC Senior Operator's License 5.
Four years of supervisory experience The nuclear plant experience satisfies one of the criteria under the col-lective technical qualifications given in Table 3.
We feel strongly that Shift D
37
Supervisors should have this operating experience "under their belt." Addition-ally, the Shift Supervisar
,..,old have some leadership experience.
A quantifi-cation of this experience a judgmental. We have adopted the four years of supervisory experience qualification from the recommendations of the ANSI Com-mittee (ANS-3.1) for
.,'lant Manager.
The degree requirement (B.S. in Engineering) is a deviation from the col-lective qualifications of the onsite technical resources given in Table 3.
Although we are committed to the recommendeu collective technical resources presented earlier, we also support this requirement in the category of manage-ment resources.
In our judgment, the degree wili orovide the Shift Supervisor with additional depth, aaturity, problem solving abilities, and respect that cannot be equated to simple technical requirements.
The degree will also provide the Shift Supervisor with the basic equivalent course work in many of the areas of expertise cited earlier, as well as the foundation to master most of the others.
As a final note, we strongly recommend that the Shift Supervisor possess the Transient Analysis experience discussed earlier and in Chapter 4.
e e
38
a APPENDIX B
}
CRITERIA FOR SHIFf TECHNICAL ADVISOR (AN EXCERPT FROM NRR SEPTEMBER 13, 1979, LETTER TO ALL OPERATING POWER PLANTS)
In developing the recommendath..' for the Shift Technical Advisor, the Lessons Learned Task Force concentrated on the two functions that needed to be provided, namely, an accident assessment. function and an operating experience assessment function.1 The proper performance of these functions requires the provision of certain characteristics described in the following paragraphs.
A.
Accident Assessment Function 1.
General Technical Education The technical education of at least one person in the control room under off normal conditions should include basic subjects in engineering and science.
The purpose of this education is to aid the operator in assessing unusual situations not explicitly covered in the current operator training.
The following is a tentative list of areas of knowledge that are considered to l
i be desirable:
Mathematics, including elementary calculus Reactor physics, chemistry and materials Reactor thermodynamics, fluid mechanics, and heat transfer l
Electrical engineering, including reactor control theory These areas of knowledge should be taught at the college level and would be equivalent to about 60 semester hcurs.
Although a college graduate engineer would have many of these subjects and more that would not be essential, some engineers might be deficient in a few of these specific areas, e.g.,
reactor physics. 'Although the time to teach these subjects to a licensed senior reactor operator could be as short as two years, depending on the scope and content of the subjects, the selection of a graduate engineer would likely be a more rapid means of fulfilling this characteristic.
9 IThe staff has accepted the assignment'of these two functions to two separate groups at the prerogative of individual licensees.
59
s 2.
Reactor Operations Training All persons assigned to duties in the control room should be trained in a
the details of the design, function, arrangement and operation of the plant systems.
This training is necessary to assure that the meaning and significance of instrument readings and the effect of control actions are known.
A licensed operator or supervisor of an operator would not be required to have further training in order to fulfill this characteristic.
A graduate engineer not previously licensed or trained as an operator or senior operator would require cdditional training in order to fulfill this characteristic.
3.
Transient and Accident Response Training In addition to the training in normal operations, anticipated transients, and accidents presently required of operators and senior operators, one person in the control room under off normal conditions should be trained to recognize and react to a wide range of unusual situations including multiple equipment failures and operator errors.
This training should not be limited to written j
procedures or specific accident scenarios, but should include the recognition of symptoms of accident conditions such as complex transient responses or inadequate core cooling and possible corrective actions.
The purpose of this training is to broaden the ability for prompt recognition of and response to I
unusual events, not to modify the instinctive, rapid procedural response to transients and accidents provided by reactor operators.
The training is required in recognition of the fact that real accidents inherently are initiated and accompanied by unusual and unexpected events.
The training is also to emphasize need to focus on the essential parameters that indicate the status of ;,he core and the primary coolant bo. ndary.
This additional training would t ue up to a year to accomplish for a po ;on not already experienced in nuclear plant transient and accident analysis or evrluation.
Both inexperienced graduate engineers and currently licensed operators vould require additional training to fulfill this characteristic.
4.
Detachment from Operations The plant response assessment function requires a measure of detachment from the manipulation of controls or immediate supervision of operators.
This is intended to provide the perspective and the time for assessing plant conditions and advising on appropriate operator actions.
It has been called a safety monitor characteristic.
Currently only three operators would normally be in the control room'at the time an unusual event occurred, and it is allowed that at I
40
i He will have entered into the Navy's nuclear power program by applying (volunteering) and meeting the following requirements:
a.
Age requirements:
no older than 27 years of age.
b.
College graduate (4 year curriculum) having successfully completed one year.of calculus through d;fferential and integral calculus, and one year of calculus-based physics.
c.
Physically qualified.
d.
Meet requirements of moral turpitude sufficient to be granted an appropriate security clearance.
e.
Have bee. interviewed in Washington, D.C. headquarters of the Department of Energy s Deputy Assistant Secretary for Naval Reactors.
These interviews consist of at leart three individual interviews by senior technical staff personnel and the Deputy Assistant Secretary himself.
In about two-thirds of the cases, written examinations in math and physics are administered during this interview period.
2.
The Navy acquires its officers for the nuclear program through three sources:
U.S. Naval Academy, NROTC colleges, Nuclear Power Officer Candidate (NUP0C) program.
Officers selected for the nuclear program from I
the NUP0C program must attend the Navy's Officer Candidate School (OCS) for 16 weeks.
3.
Successful completion of the Navy's 6 months Nuclear Power School (NPS). This course teaches basic theory relating to nuclear power at a higher level than that taught to enlisted personnel.
All instruction is conducted in'the classroom.
4.
Successful completion of a 6 months practical course of instruc-tion at one of the Navy's 8 nuclear prototype plants.
Students will have ually " qualified" on the plant.
During this phase, the officer will qualify on all enlisted watch stations in addition to qualifying as an E00W.
5.
Will have been assigned to a nuclear powered ship and will have
" qualified" on that ship's plant.
This takes about 9 months and involves the following:
a.
A basic engineering qualification (BEQ) course which, in addition to,being a review of course material covered at NPS, covers basic reactor plant theory and application to the specific plant installed on I
his ship.
33
b.
A watch qualification program involving standing watches under instruction throughout the plant.
c.
The watch qualification program also involves completion of erb item of a watch qualification guide by obtaining signatures, usually al hundred, that he has demonstrated, through discussion, actual prac-tice, or written tests his knowledge and ability.
d.
He will be given a final comprehensive written examination and a series of oral examinations.
He must be given his final oral examina-tion by the ship's Commanding Officer.
6.
This entire program, from the time he enters the Navy as an officer until he stands his first E00W as a qualified watch stander is about 2 years.
E.
Differences and Recommendations for Shift Supervisors 1.
Difference:
E00W's are naval officers selected into the program through a tough but well-defined system. Quality input is maintained even to the sacrifice of quantity.
High star.dards of performance are instilled from the first moment of selection and are emphasized throughout the training l
program.
Each candidate knows he has a 5 year commitment.
He may fail, but he can not quit.
The training program is structured so that all stu-dents must, work hard to succeed.
No one, regardless of his background or intelligence, can just breeze through.
Standards for passing or failing the courses are clearly defined and enforced without waivers.
There is every incentive to finish the courses and finish them well.
There is no incentive to "cirift along".
He is constantly examined as to his under-s+,anding and retention of icnowledge.
His examinations are orals or essay written.
There are not true or false or multiple choice ey ainations.
There is no self pace teaching.
His training is competitive and he knowc it.
The higher his relative standing, the better chance he has of select-ing his duty station.
His prototype instructors are. qualified and experi-enced operators, many of whom are sea-returnees.
His rewards are ample:
a.'
Recognition in the form of special bonuses which are sub-stantial.
I 34
b.
Pride in being part of a small, elite ;roup of officers who have successfully passed through the most diffictIt program the Navy has to offer.
c.
A sure path to future, better-than-average promotion if he continues satisfactory performance.
d.
The prospect of a select civilian career if he elects to resign at the end of his commitment.
e.
Knowledge that he is an integral part of the nation's number one major deterrent to war.
In the civilian nuclear industry a shift supervisor comes from two sources.
He can either be promoted up from the ranks of an operator, or he can Le brought in directly from outside and nade a shift supervisor without passing through the job as an operator.
In either case, his selection, training and qualification generally follow that of an operator but with greater experience required.
All of the comments provided in Section V of this report relating to differences and recommendations have direct applicability to shift sucervisors.
However, there are two additional differences that should be I
highlighted which are unique to the shift supervisor and the E00W.
l The one difference has been discussed in the various reports and studies emanating from the Three Mile Island accident and has to do with the proper manning of the control rcom.
NRC has already issued interim requirements on the stationing of a Shift Technical Advisor in the Control Room.
Recommendations:
Our recommendation is to create a new position entitled " Shift Engineer".
He would be a degreed engineer who would normally function w%nin the technical organization but is assigned to the Operations Manager to provide shift engineering coverage.
This position is created for the following purposes and reasons:
.a.
If it is assumed that the requirements for becoming a shift supervisor (senior reactor operator) remain such that he need not be an experienced engineer (college graduate type), then there exists the need for such a person on shift who can make engineering judgments.
This would ba the function of the Shift Engineer.
35
b.
The pnssibility cxists to change the requirements for a l
shift supervisor s Jch that he must be a college graduate engineer.
This alternative was not selected because it would close off an advancement path for reactor operators.
While some may consider this to be a minor issue, the reviewers, based on their Navy experience, do not.
The civ'lian nuclear power industry must be able to provide an attractive career path for reactor operators or else face the prospect of heavy turnover or lower quality applicants.
c.
There is also the suggestion that the position of Shift Engineer be filled only when a shift supervisor is not an engineer, or that the Shift Engineer position be an interim measure until such time as all shift supervisors meet the engineer eligibility requirements or their equivalent. We do not agree with this approach.
Regardless of whether or not a shift supervisor is an engineer, there should always be present in the control room an engineer whose primary interest, background and experience is technical in nature.
d.
The functions of the Shift Engineer would be as follows:
(1) He acts as a technically qualified observer to plant operations.
l (2) He has the power to order the plant put into a safe condition in the event of an emergency.
(3) He does not report to the Shift Supervisor--he is an independent observer similar to the NRC inspector on shift.
However, he has the power and responsibility to direct the Shift Supervisor in the event of an emergency or accident.
(4) He has the wherewithal to contact appropriate technical personnel to obtain technical assistance, thus allowing the Shift Supervisor to focus his attention on plant operation.
(5) If, during the course of normal operations, it is discovered that a given procedure requires modification, the Shift Engineer has the responsibility to resolve the problem, correct the procedures in accordance with approved methods, and to provide the results to the Shift Supervisor for his accomplishment.
e.
The Shift Engineer woulc be a licensed Senior Reactor Operator and will have had operating experience as outlined in Table 2 of this report.
I 36
a to Appendix A I
I EXCERPT FROM VOLUME I, " UTILITY MANAGEMENT AND TECHNICAL RESOURCES,"
0F THE TEKNEKRON RESEARCH, INC., REPORT 1.5 ONSITE MANAGEMENT RESOURCES One man must be in charge of the plant at all times.
Since in the normal work-week, the Plant Manager can be expected to be onsite less than 25% sf the time, the Shift Supervisor has short-term onsite ma % ement responsibility (in the absence of the Assistant Plant Manager)..('ine accession of management responsibility by the Plant Manager or his designee in the event that the long-term resources should be called upon is discussed in Section 2.3.)
The Shift Supervisor is the single most important resource in the event of en accident.
Not only is he solely responsible for any hands-on operations performed on the system, but he must M so be the " intellectual leader" of the team.
He must be able to evaluate and act upon the technical input supplied by individuals on his onsite team and by his offsite resources.
He must also be able to communicate essential information to the long-term resources if and I
when they arrive onsite.
It is essential that he be thoroughly familiar with the plant, that he be exceedingly well trained (and retrained), and that he command the respect of his colleagues.
Although this is a stringent requirement, it is not possible to overemphasize the importance of this individual in an accident situation.
With the foregoing in mind, and recognizing that the Shift Supervisor is equivalent to the Plant Manager when the latter is absent, we recommend the following minimum qualifications for the Shift Supervisor:
1.
A bachelor's degree in engineering 2.
Two years of operating experience at a nuclear power. plant 3.
One year of experienco at the specific nuclear plant to be cperated (which can be satisfied by pre-operational testing) 4.
An NRC Senior Operator's License 5.
Four years of supervisory experience The nuclear plant experience satisfies one of the criteria under the col-lective technical qualifications given in Table 3.
We feel str,?ngly that Shift 9
37
Supervisors should have this operating experience "under their belt." Addition-ally, the Shift' Supervisor should have some leadership experience.
A quantifi-cation of this experience is judgmental. We have adopted the four years of supervisory experience qualification from the recommendations of the ANSI Com-mittee (ANS-3.1) for the Plant Manager.
The degree requirement (B.S. in Engineering) is a deviation from the col-1ective qualifications of the onsite technical resources given in Table 3.
Although we are committed to the recommended collective technical resources presented earlier, we also support this requirement in the category of manage-ment resources.
In our judgment, the degree will provide the Shift Supervisor with additional depth, maturity, problem solving abilities, and respect that cannot be equated to simple technical requirements.
The degree will also provide the Shift Supervisor with the basic equivalent course work in many of the areas of expertise cited earlier, as well as the foundation to master most of the others. As a final note, we strongly recommend that the Shift Supervisor possess the Transient Analysis experience discussed earlier and in CMpter 4.
)
l 38-
APPENDIX B C_RITERIA FOR SHIFT TECHNICAL ADVISOR (AN LxCERPT FROM NRR SEPTEMBER 13, 1979, LETTER TO ALL OPERATING POWER PLANTS)
In developing the recommendation for the Shif t Technical Advisor, the Lessons Learned Task Force concentrated on the two functions that needed to be provided, namely, an accident assessment function and an operating experience assessment function.1 The proper performance of these functions requires the provision of certain cher.icteristics described in the following paragraphs.
A.
Accident Assessment Function 1.
General Technical Education The technical education of at least one person in the control room under off normal conditions should include basic subjects in engineering and a
science.
The purpose of this education is to aid the operator in assessing unusual situations not explicitly covered in the current operator training.
D The following is a tentative list of areas of knowledge that are considered to be desirable:
Mathematics, including elementary calculus Reactor physics, chemistry and materials Reactor thermodynamics, fluid mechanics, and heat transfer Electrical engineering, including reactor control theory These areas of knowledge should be taught at the college level and would be equivalent to about 60 semester hours.
Although a college graduate engineer would have many cf these subjects and more that would not be essential, some engineers might be deficient in_a few of these specific areas, e.g., reactor physics. Although the time to teach these subjects to a licensed senior reactor operator could be as short as two years, depending on the scope and content of the subjects, the selection of a graduate engineer would likely be a more rapid means of fulfilling this characteristic.
D 2The staff has accepted the assignment of these two functions to two separate groups at the prerogative of individual licensees.
39-
2.
Reactor Operations Training i
All persons assigned to duties in the control room should be trained in the details of the design, function, arrangement and operation of the plant systems.
This training is necessary to assure that the meaning and significance of instrument readings and the effect of control actions are known.
A licensed operator or supervisor of an operator would not be required to have further training in order to fulfill this characteristic.
A graduate engineer not previously licensed or train:d as an operator or senior operator would require additional training in order to fclfill this characteristic.
3.
Transient and Accident Response Training In addition to the training in normal operations, anticipated transients, and accidents presently required of operators and senior operators, one person in the control room under off normal conditions hould be trained to recognize and react to a wide range of unusual situation-ncluding multiple equipment i
failures and operator errors. This training st,ild not be limited to written procedures or specific accident scenarios, but inould include the recognition of symptoms of accident conditions such as comp ex transient responses or inadequate core cooling and possible corrective actions.
The purpose of this l
training is to brotden the ability for prompt rnognition of and response to unusual events, not to modify the instinctiv", rapid procedural response to transients and accidents provided by reac+sr operators.
The training is required in recognition of the fact that real ac.ider,ts inherently are initiated and accompanied by unusual and unexpecter' events.
The training is also to emphasize need to focus on the essential par'. meters that indicate the status of the core an't the primary coolant boundary.
This additional training would take up to a year to accomplish for a person not already experienced in nuclear plant transient and accident a.. lysis or evaluation.
Both inexperienced graduate angineers and currently licensed operators would require additional training to fulfill this characteristic.
4.
Detachment from Operations The plant response assessment function requires a measure of detachment from the manipulation of controls or immediate supervision of operators.
This is intended to provide the perspective and the time for assessing plant conditions and advising on appropriate operator actions.
It has been called a safety monitor characteristic.
Currently onl, three operators would normally be in the control room at the time an unusual event occurred, and it is allowed that at I
40
5.2 Upgrading Qualifications of Operators The NRC staff is preparing amendments to 10 CFR Part 55, " Operators' Licenses," and 10 CFR Part 50, " Domestic Licensirg of Production and Utiliza-tion Facilities," that incorporate applicable Commission-approved recommenda-tions of SECY 79-330E and other proposed changes resulting from additional staff review of Part 55 and Part 50.'
The Regulatory Activities Subcommittee of the Advisory Committee on Reactor Safeguards has reviewed the proposed changes to Part 55 and Part 50.
Both the March 28, 1980, H. R. Dentca, NRR letter and the proposed rulemaking impact this proposed regulatory guide.
With respect to the March 28, 1980, letter, the short-term requirements are either incorporated in the December 6, 1979, Draft Standard ANS 3.1 or noted in the
, regulatory position of this regulatory guide.
With respect to Part 55 and Part 50 revisions, certain positions now included (see Regulatory Pcsitions 1.4a-e) in this regulatory guide will be codified in the regulations in place of the existing general provisions of the regulations.
After publication of the final rule changes, Regulatory Guide 1.8 will be revised to eliminate any duplication.
I 5.3 Onsite and Offsite Managerial and Technical Organizations The NRC staff has under development criteria for onsite and offsite managerial and technical organizations, including a radiological protection organization, that will provide assurance of the safe operation of a plant during normal and abnormal conditions and the capability necessary to respond to unusual conditions.
A contractor was selected (Teknekron Research, Inc.)
to assist in the development of criteria listed above.
Teknekron Research, Inc., submitted its final report to the NRC in May 1980.
Task I.B.1.1, " Organization and Management of Long-Term Improvements,"
and Task I.B.l.2., " Evaluation of Organiza* ion and Management Improvements of Near-Term Operating License Applicants," of NUREG-0660 describe the criteria development effort for technical and managerial organization.
Task I.B.l.2 is a first step in the development of criteria described in Task T.B.l.1.
As described in Task I.B.l.2 of NUREG-0660, near-term operating license applicants, a's part of the license application review process, are being required to comply
)
with the findings and requirements generated in an NRC interoffice review of 49
i licensee organization and management.
The review is based, in part, on an NRC document entitled " Draft Criteria for Utility Management and Technical Competence."(
The first draft of this document was dated February 25, 1980, however, the docu-ment continues to change with use and experience in ongoing reviews.
The docu-ment addresses the organization, resources, training, and qualifications of plant staff and management (both onsite and offsite) for routine operations and accident conditions.
The criteria developed for use in evaluation of operator license applicants, as modified by experience from interoffice review of near-term operating license applicants, will form the basis for the final criteria to be developed in accordance with Task I.B.1.1 of NUREG-0660.
The criteria reference Regulatory Guide 1.8 and ANS Standard 3.1 with regard to qualifications of nuclear power plant personnel filling the various functional positions described in ANS Standard 3.1.
Regulatory Guide 1.8 will be imple-mented in conjunction with the recommendations of Task I.B.1.1.
5.4~ Onsite "Independeat Safety Engineering Group" Each near-term operating license applicant as part of ongoing license application review is being required to establish a group, commonly referred to as the " Independent Safety Engineering Gr*up," that is independent of the plant staff, but is assigned onsite to perfora independent reviews of plant operations activities and to evaluate operating experiences at nuclear power plants.
Commission Information Faper SECY-80-242 describes the relationship of the proposed " Independent Safety Engineering G-oup" to other organizational entities such as the' Plant Operations Review Committee.
The " Draft Criteria for Utility Management and Technical Competence" (see Item E.3 above) addresses
-the qualifications of the onsite independent safety engineering group by referencing Section 4.7 of the December 6, 1979, Draft Standard ANS 3.1.
5.5 Shift Technical Advisors As described in Task I.A.1.1 of NUREG-0660, the NRC is requiring that a technical advisor to the shift supervisor be present on all shifts.
Although minimum training requirements have not yet been specified for shift technical advisors presently occupying such. positions, shift technical advisors should enhance the accident assessment function at the plant.
By January 1,1981, l
i r
50
shift technical advisors will be required to have a technical education, which is of the quality of courses taught at the college level and includes about 60 3emesters hours in basic subjects of engineering and science; specific trainicg in the design, function, arrangement, and operation of plant systems; and train-ing in the expected response of the plant and instruments to normal operation, transients, and accidents, including multiple failures of equipment and operator errors.
Commission Inf6cmation Paper SECY 80-243 addresses the subject of shift technical advisors, ind eding a summary of experience required, duties to be l
performed, and the number of shift technical advisors required onsite.
The qualifications of shift technical advisors as addressed in this regulatory guide are the same as those specified in Commission Paper SECY 80-243.
The Commission I
was also informed in this paper that the Institute of Nuclear Power Operations (INPO) has recently forwarded to NRR for comment a copy of an INP0 document,
" Nuclear Power Plant Shift Techical Advisor - Recommendations for Position i
Description, Qualifications, Education and Training" (Enclosure to SECY 80-243),
and that the NRC staff had the document under review.
Further discussion with l
INPO may lead to revision of this regulatory guide with regard tc shift technical advisors.
D 5.6 Comparison of NRC, Commercial, and Naval Procedures for Qualification of Personnel In early 1980, Basic Energy Technology Associates, Inc. (BETA), completed a study-for the Office of Nuclear Reactor Regulation that outlined the results of a comparative review existing NRC requirements, commercial nuclear power plant practices, and the Naval Nuclear Propulsion Program procedures for the l
selection, training, and qualification of personnel involved in nuclear power plant operation and maintenance.
The results of the BETA study entitled " Power Plant Staffing" are documented in NUREG/CR-1280, BETA-103.
Public comments l
were requested on this study.
The BETA study, when comparing the majority of practices, used the provisions outlined in ANSI N18.1-1971 and did not consider later versions'of the standard.
The BETA study will be considered when develop-ing future revisions to this regulatory guide.
D 51
5.7 Requirements for Licensing of Operators 1
The NRC-staff has awarded a contract to Analysis and Technology, Inc.,
for a study of requirements for operator licensing.
The scope of the work should result in recommendations for (a) the means to be employed for selection and training of nuclear power plant personnel and the degree to whit.h NRC should be involved in the process, (b) the means to i,e employed to evaluate the effectiveness of training programs, including who, by job description, should be licensed, (c) the methods to be employed to ensure continued competency of plant personnel and the degree to which the NRC should be involved in establish-ing the methods, (d) the methods to be employed for maintaining a highly moti-vated and dedicated work force, and (e) the means to be employed for rapidly requalifying presently licensed operators to meet the proposed new requirements.
Task I.A.2.6, "Long-Term Upgrading of Training and Qualifications," of NUREG-0660 provides a description of planned NRC actions related to this contract study.
After staff review of the study has been completed, the staff will provide recommendations to the Commission and subsequently factor Commission decisions on the recommendations into a regulatory guide or a regulation.
5.8 Planned NRC Accreditation of Training Institutions As described in Task -I. A.2.7 of NUREG-0660, the NRC staff is conducting a study of procedures and requirements for NRC accreditation of training insti-tutions. A Commission Information Paper on this subject should be completed I
by late 1980.
The NRC staff will also prepare a Commission paper examining various NRC approaches to accreditation of training institutions.
Staff action on this later effort should be completed by January 1982.
5.9 Operator Emergency Response and Organization of Personnel Two other efforts interface with this Regulatory Guide to a lesser extent than the efforts described above.
In February 1980, the staff issued for interim use and comment, NUREG-0654/ FEMA-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear l
52
I Power Plants."* NUREG-0651 was desicned to provide a common-reference and W
interim guidance for State and local governments and nuclear facility opera-tors in the development of emergency response plans and preparedness in support of nuclear power plants, as well as to provide guidance to Federal agency per-sonnel.
In effect, the thrust of NUREG-0654 is to ensure adequate preparedness planning for protection of the populatic o around nuclear power plants.
As a part of this emergency preparedness planning, however, NUREG-0654 necessarily addresses the emergency response capability of the nuclear plant operators.
In particular,Section II.B of NUREG-0654 sets forth proposed criteria for the onsite emergency organization of the nuclear plant considered to be necessary to adequately support the plans for offsite response in the event of an accident at the plant.
Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation),"
4hich endorses, with exceptions, ANSI Standard N18.7/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase of duclear Power Plants" (see Regulatory Position 1.1), is being revised to update quality assurance program requiren.ents for the operational phase of nuclear power plants.
Regu-latory Guide 1.33, while not addressing qualification requirements for plant personnel, addresses organizational requirements.
l Both of these efforts, NUREG-0654 and Regulatory Guide 1.33, by addressing staffing and organizational considerations have a potential for impacting Regula-tory Guide 1.8.
With regard to the interface of this proposed regulatory guide and the other efforts described above, this version of the regulatory guide is a first step in a comprehensive process of upgrading the training and qualifications of operations personnel.
Some of the regulatory guide positions may be eventually displaced by more comprehensive long-term changes (e.g., changes to NRC regulations) in the area of personnel qualification; however, these posi-tions are expected to be consistent with the long-term changes.
ANUREG-0654 (FEMA-REP-1) is available at current rates through the Government Printing Office Sales Program, Distribution Services Se: tion, Division of Technical Information and Document. Control, U.S. Nuclea? Regulatory Commis-sion, Washington, D.C. 20555 or from the National Technical Information Service, Springfield, Virginia 22161.
I.
53
6.
SUMMARY
AND CONCLUSIONS A draft revision to Regulatory Guide 1.8, "Selec* ion and Training of Personnel," should be prepared.
The draft revision should endorse, with certain exceptions dnd supplements, the December 6, 1979, Draft Standard
- ANS 3.1.
(A discussion of proposed regulatory positions in second proposed Revision 2 to Regulatory Guide 1.8 is provided in the attachment to this "alue/ impact statemen'.)
i I
e 54
Attachment to Draft /Value Impact Statement RATIONALE FOR REGULATORY POSITIONS 1.
Regulatory Position 1.1 addresses the applicability of documents referenced in Draft Standard ANS 3.1.
Regulatory Position 1.1 als.o provides information on a regulatory guide being prepared on nuclear power plant simulators for use in operator' training.
This position has been provided, as is customary ir many regulatory guides, to assist the user of the guide in determining the applicability of referenced documents.
2.
Regulatory Position 1.2.1 takes exception to Section 3.1 of the draft version of ANS 3.1 concerning personnel temporarily filling positions owing to absences of the principal.
The standard permits the use of temporary personnel replacements for a period not to exceed 3 months.
The regulatory position l
states that temporary personrel should not be used as replacements for periods exceeding 1 month.
The 3-month period allowed by the standard is too long to be considered temporary.
If the principal is replaced for a period greater than 1 month, the replacement should not be considered temporary and qualifications of the replacement should be subject to the provisions of Section 4 of the standard.
Since' temporary absences normally do not exceed one month, the position should not result in impact on licensees. _The provision exists in the standard te recognize that a principal may be temporarily absent.
The regulatory posi-tion should result in maintaining a consistent level of staff qualifications.
3.
Regulatory Position 1.2.2 is intended to provide practical guidance on
-how the standard should be applied to contractor personnel.
The proposed regulatory position 'does not take exception to 46 3.1.
While Section 1,
" Scope," of the standard states that the standard is-limited to personnel
.within the owner organization, the definition of owner organizatic states
-that contracted personnel are included in the owner organization.
Thus j
contracted personnel are within the scope of Draft Standard ANS 3.1.
55
4.
RHulatory Position 1.3 defines the term " college-level education" that is used throughout the standard.
It states that " college-level education" is construed to mean course work satisfactorily completed (i.e., finished with a grade at the 70% level) at or conducted by a college or university with curri-cula accredited by a nationally recognized agency such as the Accreditation Board for Engineering and Technology.
The regulatory position is provided to establish a norm for the provisions of ANS 3.1 dealing with " college-level education" requirements and is intended to describe the quality of the educa-tion to be completed.
Case-by-case reviews of educational programs conducted at nonaccredited training institutions pending additional guidance on accreditation will require additional regulatory staff review.
The regulatory position indicates that the NRC intends to establish alternative means of accreditation of training programs and that course work completed under such programs may become acceptable.
College-level education is specified in terms of semester hours of college-level subjects.
To ensure that there is no misunderstanding as to the meaning of a college credit hour, the following example is repeated from Dr. Miller's letter of May 21, 1980, to Mr. H. Denton on this subject.
Dr. Miller, Chairman, Nuclear Engineering Program of Ohio State 'Jniversity, states:
"There appears to be some misunderstanding as to the meaning of a college credit hour.
Specifically the 60 semester hours of college level subjects specified for senior operators in fact implies approximately 900 classroom hours.
However, college instructors normally assume they will be assigning approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of work outside the classroom for every hour in the classroom.
As a consequence, 60 semester hours implies approximately 2700 hours0.0313 days <br />0.75 hours <br />0.00446 weeks <br />0.00103 months <br /> of work for the average student. Obviously, students of superior ability will complete them in fewer hours and vice versa." The NRC staff agrees with Dr. Miller's comments con-cerning the meaning of a college credit hour.
Therefore, 60 semester hours (representing approximately 2700 hours0.0313 days <br />0.75 hours <br />0.00446 weeks <br />0.00103 months <br /> of work for the average student) was selected as the established norm for judging education requirements.
5.
Regulatory Position 1.4 lists exceptions taken to ANS 3.1 to provide for consistency with the anticipated amendments to 10 CFR Part 55 and 10 CFR I
56
h Part 50, which are presently undergoing NRC review prior to publication for F
public comment.
6.
Regulatory Position 2.1 provides guidance on use of the provisions of-Section'4.1 of ANS 3.1 for conducting case-by-case evaluation of an individual's qualifications when the individual does not meet those qualifications stated in the standard.
Although it was recognized in the development and review of the draft version of ANS 3.1 that there may exist situations where individuals could become qualified for a position based on factors other than those included in the standard (i.e., education, experience), this position recognizes this situation should be the exception rather'than the rule.
This position will result in fewer deviations from the requirements of the standard.
Additionally, this position helps ensure that such deviations are not used for a number of specific plant. positions that are responsible for overall plant safety.
This regulatory position, if not initially applied with caution, could have a significant impact on licensees.
A phased implementation of the standard and the regulatory guide is necessary so that a high turnover rate of personnel does not ensue that might adversely affect the safe operation of a plant.
The D
position most significantly affected by upgraded qualifications is that of shift supervisor. Appendix A to this regulatory guide provides a detailed discussion of shift supervisor qualifications-including recommendations for implementation.
As indicated in the implementation section of the regulatory guide, the regulatory guide will be applied in conjunction with Task I.B.1.1, "Organiza-tion and Management of Long-Term Improvements," of NUREG-0660.
Task I.B.1.1 provides for licensee submission by May 1981 of a plan for implementing the NRC requirements for upgrading of management and technical resources whether or not an effective active guide on personnel qualification has been issued by that date.
Thus, the impact on each licensee will be determined on a case-by-case basis.
Once fully. implemented, this regulatory position should provide assurance of a consistent level of staff qualifications.
7.
Regulatory Position 2.2.1 provides limitations concerning acceptability of certification of plant managers and technical managers at the plant or at an appropriate simulator as 'a condition of qualification.
It states that this I
certification should either be conducted or approved by the NRC staff.
This 57
~
regulatory position provides for regulatory staff involvement in the certifica-
{
tion process since the provision of.the standard for such certification is intended as an alternative to holding a senior operator liccnse.
The position should not significantly impact licensees; however, NRC staff time will be required in. conducting or approving certification examinations.
8.
Regulatory Position 2.2.2 states that the recommendation of the standard for the maintenance manager to have nondestructive testing familiarity, craft knowledge, and an understanding of electrical, pressure vessel, and piping codes and standards should be construed as a requirement.
These qualifications t e essential to the performance of the_ duties of a maintenance manager.
The most significant impact of this position may be that the provision of the standard is very general and application of the general requirement may not be applied uniformly.
This could result in additional staff review time.
9.
Regulatory Position 2.2.3.1 presents the minimum formal training a radia-tion protection manager should receive while Section 4.4.4 of ANS 3.1 states
{
only that a manager must receive formal training.
This position further clarifies the intent of a similar position contained in the first proposed revision of Regulatory Guide 1.8 issued for comment in February 1979.
10.
Regulatory Position 2.2.3.2 specifies that a certified (ABHP) health physicist's experience be in a position of supervisory capacity in a health physics program for an operating nuclear power plant because the NRC staff does not believe that a health physicist who has no such experience should qualify as a radiation protection manager.
11.
Regulatory Position 2.2.3.3 has been added to provide clarification that the 4 years of experim"e required by the standard for the Radiation Protection Manager should be above the technician level and that the 3 years of experi-ence at a nuclear facility required by the standard should involve directing the activities of radiation protection technicians.
The provision for 3 years of experience directing the activities of radiation p otection technicians is consistent with the first proposed revision of Regulatory Guide 1.8 issued for comment in February 1979.
The' provision that 4 years of experience be above
~
D the technician level when coupled with the provision for 3 years of experience directing the activities of radiation protection technicians represents only a minor modification of present staff practice and is consistent with the require-ment for 4 years of professional-level experience for other group lead 0rs.
12.
Regulatory Position 2.3.1 addresses qualifications of shift supervisors.
See Appendix A to the guide for a detailed discussion of this regulatory position.
12.
Fegulatory Position 2.3.2 provides for corporate management involvement in the' certification of the competency of shift supervisor candidates and for documentation of such certification.
This provision is similar to the provi-sions for certification by corporate management of the competency of operators and senior operators.
To ensure proper conduct of training programs and qualification of plant personnel, corporate management of each licensee should establish a definitive pr.sence and involvement in the selection, training, and qualification of opera-tions personnel.
Such a provision should have minimal impact or licensees.
This particular position is responsive, in part, to one of the subitems of Task I.B.1.1, " Organization and Management of Long-term Improvements," of NUREG-0660.
14.
Regulatory Position 2.4.1 makes experience requirements for onsite pro-
'fessional-technical group leaders more consistent than past guidance.
The regulatory position is self-explanatory.
The overall experience rcquirements for ted.nical group leaders should be more consistent.
15.
Regulatory Position 2.4.2 is self-explanatory.
The standard contains a potential. loophole that could allow the position of chemistry and radiochemistry group leader to be filled without the person having had nuclear power plant experience.
In order to ensure-that this situation will not be permitted, the equivalence of the training program to experience should be allowed only to a maximum of 6 months.
16.
Regulatory' Position 2.5 states that training for the Training Coordinato:
D should include the training required by Section 5.4, " General Employee Training,"
59
of ANS 3.1.
This type of training is required by ANS 3.1 for other pro.essional-q technical group leaders and such training is appropriate for the Training Coordinator.
17.
Regulatory Position 2.6 takes exception to the requirement of Section 4.4.7.2 of ANS 3.1 that " Instructors who provide instruction on the simulator shall hold a senior operator license for a similar unit (PWR, BWR, HTGR) or have been certified at an appropriate plant simulator...." The proposed regulatory posi-tion is consistent with the staff recommendation approved by the Commission that training center and facility instructors who teach systems, integrated responses, transient, and simulator courses should demonstrate their competence to NRC by successful completion of a senior operator examination and should participate in appropriate requalification programs to ensure they are cognizant of current operating history, problems, and changes to procedures and adminis-trative limitations (see Commission Paper SECY-79-330E).
This provision was contained in the March 28, 1980, letter from H. Denton to all power reactor applicants and licensees.
18.
Regulatory Position 2.~/ netes that the requirements of Section 4.4.8 of Draft Standard ANS 3.1 concerning Shift Technical Advisor qualifications are i
not consistent with the requirements for the Shift Technical Advisor previously forwarded to all applicants and licensees.
(Dates of letters to licensees and applicants are indicated in the proposed regulatory position.) The proposed regulatory position states that the previously issued requirements are included as Appendix B to the guide ar.d should be followed.
The proposed regulatory position provides for consistency with present staff practice.
19.
Regul&to.'y Position 2.8 is an amplification of the requiremei.ts contained in Sections 5.3.4 and 5.4 of the standard for training programs for raoiation protection technicians.
The guide position should be helpful in establishing the conte'nt of the training program for radiation protection technicians.
The guide position does not represent a significant change from the more general provisions of Draft Standard ANS 3.1.
20.
Regulatory Position 2.9 states that training in accordance with Section 5.4,
" General Employee Training," should be provided for the " Engineer-in-Charge" 60
independent of whether this is an onsite or offsite position. ~ General employee D
training is provided to all persons regularly employed in a nuclear power plant.
Such training is essential for the " Engineer-in-Charge" since this person is to provide additional services to the plant beyond those provided by the opera-tions organization professional-technical personnel.
It cannot be envisaged that such a person can successfully perform his or her required duties without training in the subjects covered in Section 5.4 of Draft Standard ANS 3.1.
21.
Regulatory Position 3.1 states that a position task analysis should be performed for all operations personnel in which the tasks performed by the person in each position are defined, and the required training, in conjunction with education and experience, is identified to provide assurance that the tasks can be effectively performed.
For many positions described in Draft Standard ANS 3.1, a position task analysis is a requirement of the standard.
This proposed regulatory position is consistent with Task I.A.2.2, " Training and Qualifications of Operations Personnel," of NUREG-0660.
NUREG-0660 states that the Office of Nuclear Reactor Regulation will issue a requirement by October 1,1980, for each licensee to review its training progran for all opera-I tions personnel, including maintenance and technical personnel and to justify the acceptability of training programs on the basis that these programs provide sufficient assurance that safety-related functions will be effectively carried out.
NUREG-0660 states that the preferred method of fulfilling this provision is a position task analysis.
In the February 1980 report to the AIF Policy Committee on Follow-up to the Three Mile Island Accident by the Working Group on Action Plan Priorities and Resources, it was indicated that tasks analyses of positions were worthwhile end should be pursued jointly by the NRC and INPO, with INP0 performing task analyses for those positions that are generally used industry wide.
The working group also provided the following additional comments:
"These analyses would be conducted by professionals and include recommendations for qualifications and training needed for a particular position.
Each utility would then evaluate in a similar manner any unique position in their
' organization-not addressed in the INP0 study.
These 61
studies by INP0 should be completed by early 1981 and would greatly reduce individual utility costs.
" Evaluating positions affecting safe operation other than the licensed operators to ascertain that their training and qualifications are adequate has considerable merit.
It would introduce no plant safety hazards and would have a small degree of positive effect on reducing overall risks if a need for additional training is identified.
The cost for a utility-unique analysis would be an unnecessary use of resources for each utility at an aggregate cost which is large."
The NRC staff agreed with the AIF working group comments and revised NUREG-0660 to state that the task is amenable to a generic approach in which INPO could perform task analyses of those positions generally used throughout industry and each utility could evaluate in a similar manner any unique posi-tion in its_ organization not covered by the INPO study.
l 22.
Regulatory Position 3.2.1 incorporates Task II.B.4, " Training for Mitigating Core Damage," of NUREG-0660 as a proposed regulatory position.
The Commission on February 7, 1980, approved this item in conjunction with other "Near-Term Operating. License Requirements" (see Table A.1 of NUREG-0660) as being necessary to implement before full power operation is permitted for near-term operating license applicants.
Task II.B.4 of NUREG-0660 states NRR will issue a require-ment by October 1,1980, for licensees to develop a training program by January 1, 1981, and imples.
+he training program by April 1,1981.
The AIF Worki g 'roup on Action Plan Priorities and Resources stated that the inclusion of tt:is item in the periodic retraining prog mm will increase its potential for effectiveness.
23.
Regulatory Position 3.2.2 incorporates-Task I.A.2.5, " Plant Drills," of NUREG-0660 as a proposed regulatory positien.
Task I.A.2.5 indicates that requirements for conduct of plant drills will be issued by January 1981 and that drills will begin at operating reactors by July 1, 1981.
Operating G
62
licensee applicants will begin drills by July 1, 1981, or before operating license issuance, whichever is later.
l The AIF Working Group on Action Plan Priorities and Resources indicated plant walk-throughs and drills would be effective in training.
24.
Regulatory Position 3.2.3 takes exception to Section 5.5.1.3.1 of Draft Standard ANS 3.1 concerning criteria for requiring a licensed ir.dividual to participate in accelerated requalification.
This proposed regulatory position was included to provide consistency with instructions that were included in the NRR H. R. Denton letter af March 28, 1980, to all reactor applicants and licensees.
I 63
I UNITED STOTES I
-l NUCLE AR REGULATORY COMMISSION WASHINGTON, D. C. 20555 -
u.s. nucle A R nacuLaTony OFFICIAL 8USINESS cou MassioN PEN ALTY FOR PRIVATE USE.8300 L
J l
)
i i
120555008386 2 SNDIDAQ1QA US NRC SECY PUBLIC DOCUMENT ROOM BRANCH CHIEF j
WASHINGTON DC 20555 2
e G