ML19347E593

Ack Receipt of Comments Re SECY-79-330D.Forwards SECY-79- 330E, Requirements for Reactor Operators, Recommending Improvements in Operator Licensing Program.W/O Encl

ML19347E593
Person / Time
Issue date:	11/08/1979
From:	Collins P Office of Nuclear Reactor Regulation
To:	Bryan S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML19347E587	List: ML19347E586 ML19347E593
References
FOIA-81-131 NUDOCS 8105130087
Download: ML19347E593 (1)

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MEMORANDUM FOR:

Samuel E. Bryan, Assistant Director for Field Coordination, Division of Reactor Operations Inspection, IE FROM:

Paul F. Collins, Chief, Operator Licensing Branch, DPM

SUBJECT:

COMMENTS ON SECY 79-330D This is in reply to your memorandtsn regarding ccnnents on SECY 79-330D.,

SECY 79-3300 is an Infonnation Paper.

It was not intended to require Comaission Action. However, we appreciate the connents from Region I personnel.

Enclosed is a copy of SECY 79-330E, Requirenents for Reactor Operators that recommends sixteen actions to improve the operator licensing program.

We expect the Ccmmission action on this iten shortly.

In addition, we have initiated an RFP for a comprehensive study of the operator licensing Finally, the Lessons Learned Task Force has made several recom-b.

program.

mendations involving human factors.

We have reviewed the sixteen itens in Mr. McCabe's memo and believe each iten is being addressed, or will be addressed in a forthcoming study.

You liave my.:ssurance that we fully support Itsa 11.

.;,m.;..:' D 31 P. F. COLLINS Paul F. Collins, Chief Operator Licensing Branch Division of Project Managenent

Enclosure:

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i Admiral Hyman G. P,ickover, US!!

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.ashington, D. C. 20362

Dear Admiral Rickover:

During the i;RC discussions on the Three Nile Island investigations an:' on reactor operators, I have referred to you and to the llavy.

Attacha'd are, I believe, the references that have appeared in the.

In addition, the complete transcripts of the appropriate days press.

are c.lso attached.

As uas clear in the reactor operator meeting, I currently believe the use O-simulators would be useful for training operato:s in accident s e:;ue.:.c ss.

Absent additional information, I will be pushing for that gaining.

Since your program is obviously successful, does not use i

siculators for accident training, and involves similar equipment to that Y

in our plants, I would appreciate any information that can be provided concernir.; proper methods of choosing and training operators to handle acci:ents.

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Stello November 27,1/."f9 Shapar orsect or Tse leying SECRETARY Haller Barry MEMORANDUM FOR:

Lee V. Gossick,' xecutive KSinger Director for Operations

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TMI Inquiry Samuel J. Chilk, Secretafy FROM:

SUBJECT:

SECY-79-330E/330F - QUALI

~IO!;S OF (?0h'ER) REACTOR 1

J OPERATORS (COMMISSidliERACTIONITEM)

This is to advise you that the Commission (with all Comissioners concurring, as noted) has approved the staff's recommendations, subject to modification, as noted below:

Recomendation #1 - Senior Reactor Operator license applicants shall have 4 years responsible power plant experierce, with up to 2 years credit for academic or related technical training.Two years shall be nuclear power plant experience and at least 6 months experience must be at the plant for which he seeks the license.

All Commissioners support increasing applicar.t qualifications, and as an initial step the staff's recommendatior. is accepted.

In additica the staff is requested to prepare fer the Ccanission's consideration new requirements which would be cor.sistent with the recommendations of the Lessons Learned Task Force, NUREG-0585, Item 1.6 on page A-7.

(The Commission notes that the staff plans to provide them with additional recommendations in this and other areas in the near future.)

Commissioners Gilinsky and Ahearne would go beyor.d the staff's recommendations in these papers and NURE3-05E5.

Specifically they would give primary responsibility for c:ntrcl room operation to a person who has at least an engineering ce:ree, has passed the exar for licensed operator, has at least 5 years experience in the nuclear power business, and at least one year of experience as an assistant engineering officer in some area of a nuclear plant.

Recommendation #2 - Modify " hot" training programs and require 6 months experience as a licensed reactor operator for senior operator applicants.

The Commission prefers to increase the tite re:u' red as an operator to 12 months, as opposed to the 6 man h recuirement recommended by the staff.

The staff's basic recc :mendation is accepted; however,12 months experience is tc be rec.uired.

Chairman Hendrie and Commissioner Kennedy did.oc agree with the 12 month experience stipulation.

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SEP 121979 MEMORANDUM FOR:

H. R. Denton, Director, Office of Nuclear Reactor Regulation FROM:

Robert B. Minogue, Director, Office of Standards Development

SUBJECT:

QUALIFICATION OF REACTOR OPERATORS Your paper SECY 79-330E, dated July 30, 1979, recommends to the Commission improvements in the opirating licensing program.

I recognize that these recommendations, which reflect many comments and suggestions discussed among NRR and SD personnel during preparation of the paper, are first steps in a long-term program to upgrade operator proficiency and are not intended to identify and address all areas of concern nor, as your paper points out, are they intended to provide final word on subject areas which are covered.

As you note on page 2 of SECY 70-330E, we are in the process of revising Regulatory Guide 1.8, " Selection and Training of personnel" and have requested additional public comment in view of the Three Mile Island (TMI) accident.

Together with a special Federal Register Notice, these additional public comments have been solicited by a special mailing to more than 5,000 persons on the Division 1 Regulatory Guide Distribution List.

The cognizant standards committee of the standard endorsed by R. G.1.8, ANS-3, is also revising its standard to reflect the experience learned from TMI.

The ultimate resolution of the issue of qualifications of reactor operators should take into account this broad-based public review and the effort of the national consensus standards committee in this area.

Any decisions made by NRC should be considered interim decisions pending this broader review.

Recognizing that this is a complex subject that has been escalated to a very high level of importance as a result of the TMI-2 accident, I believe that SD views in this area should be identified now for resolution during our on-going work to improve operator competency.

I am also aware of the efforts of the utility industry to establish an Institute for Nuclear Power Operations (INPO) which I support and which has the potential for instituting improve-ments in many of the arees of our concern. As of now, our observations are as follows :

1. We should require licensee management to become more involved in the training and qualification of operating personnel.

Because of its paramount importance to safety, top management at each utility must become involved with operator competency in detail.

I believe at a relatively early stage we should identify, require and enforce the necessary levels of management involvement in our standards, licensing, and enforcement actions.

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To:

H. R. Denton SEP 121970 2.

We should provide for keeping track of operator errors by operator name or coded symbol.

Every operator error should be traceable to the name or coded symbol of the operator responsible and this information should be used for training, requalification or license suspension or revocation.

3.

As a fundamental part of the operator training program, we should ensure that there is a detailed look into what is being taught trainees.

Preferably, this detailed look should be independent of the normal process for reviewing and approving operator training and requalification programs, and should concentrate on reviewing texts, schematic diagrams, lesson plans, workbooks, assignment sheets, and other tools essential to proper training of personnel.

This review either should be done by NRC personnel or NRC sponsored personnel or, possibly, by INPO with NRC oversight.

In any event, it should be a thorough, critical review to ensure adequacy of training.

4.

If the recommendation in SECY 79-330E is adopted, reactor operator instructors would be required to hold senior operator licenses. Although 2

this would help in assuring that instructors have the required technical competence, we need to ensure that the instructors are also competent in 1

the art of instructing and have the experience to impart their knowledge with authority.

Nith regard to the proposal in SECY 79-330E to deputize utility people as 5.

NRC part-time examiners, called " Check Senior Operators", we believe that certain limitations should be imposed on their use.

First, they should be carefully selected by the utility employer and the NRC to ensure that only the most experienced and knowledgeable individuals perform this task.

Secondly, they should not examine operators of their own utilities when acting as an NRC " Check Senior Operator". And thirdly, they should be used only as part of a team which is headed by an individual from the NRC.

6.

10 CFR Part 55 presently allows waivers of reactor operator examinations.

Because such waivers give the appearance of a degradation of the requirements, I believe that we should look closely at this practice to confirm that there have been no abuses and to reassess whether the practice is worthwhile.

7.

SECY 79-330E provides a recommendation regarding the required performance of casualty drills on simulators.

In addition, we need to require the performance of casualty drills of a type which the simulator cannot handle --

i those which affect more than just the control room.

In addition to emergency planning drills and fire drills, we need to reqtire sufficient j

casualty drills run on the actual plant to ensure that the operators are 4

trained to handle casualty action outside of the control room.

Perhaps this can be accomplished by requiring that sufficient time be allocated l

each quarter so that all the operating personnel receive the necessary training.

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.To:. H. R. Denton -

SEP 121979 i'

8. As a result of the TMI-2 experience, more reliance will be placed on simulators. Thus, NRC should become more involved in assuring that the simulators accurately reproduce conditions of the plant for which the operator is being trained and that the simulators are being used effectively for such training.

It may be wcrthwhile to contract for detailed simulator checkout based on actual plant parameters measured during acceptance test l

programs.

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9. With regard to the use of part-time examiners,we believe that there is an argument for the use of part-time examiners who have recent nuclear power plant experience rather thari obtaining such examiners from universities l

'and national laboratories with no power plant experience.

It also may be helpful to assign technical personnel from the various NRC technical branches to periodically examine licensed reactor operators from the utilities in the technical area of expertise of the NRC person.

10. Under the present operator licensing system, the NRC conducts no further examinations after the initial license exam since follow-up requalification exams are performed by the licensee. We should consider examining the licensee orally in detail at least every two years in such subjects as thermodynamics, heat transfer, fluid flow, fluid systems, instrumentation and control and reactor protection.

Not only would this provide a strong l

basis for continued confidence in operator performance obtained.directly by NRC, but would also provide a strong incentive for all reactor operators to maintain their necessary skills.

We recognize that the resources required for this effort would have to be examined to determine the t

feasibility and suggest that the " Check Senior Operators" (see item 5) coelo be used to supplement NRC personnel in this effort.

il.10 CFR Part 50.55 presently requires that only one licensed operator or senior operator be present at the controls during operation of the faciiIty.

This same section also requires that a senior licensed operator only be readily available on call (not present at the facility). This senior operator is required to be present at the facility during certain conditions such as start-up and approach to power.

We need to upgrade our require-ments to ensure that the number of personnel on watch, including those required to be in the control room, are sufficient to handle casualties and other abnormalities.

In this regard, we have received specific recom-mendations. with regard to watch manning in response to our request for j

public comments on Regulatory Guide 1.8, " Personnel Selection and Training".

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Many of the foregoing observations suggest an attention to d9 tail beyond current practice and which require resources which are not currently assigned to this work.

However, I believe that if we are to make significant progress

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in upgrading reactor plant operation, such redirection and reallocation of resources must be done if we are to provide the necessary assurance that accidents i

such as that which occurred at TMI-2 will not recur.

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To:

H. R. Denton SEP 121979 In addition to the SD views expressed above regarding qualifications for reactor operators, a member of my staff, M. S. Medeiros, has provided additional views which, in some cases, are at variance with the SD views.

His views are enclosed for your consideration.

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p R. B. Minogue, Director Office of Standards Development

Enclosure:

Additional Views Concerning Reactor Operato.- Qualification CONTACT:

M. S. Medeiros, Jr.

443-5913 cc:

L. V. Gossick, EDO (w/ encl.)

E. G. Case (w/ encl. )

D. B. Vassallo (w/ encl.)

D. J. Skovholt (w/ encl.)

P. F. Collins (w/ encl.)

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ENCLOSURE: NO. 1 MEMORANDUM FOR:

R. B. Minogue, Director Office of Standards Development SED ' 91970 FROM:

M. S. Medeiros, Jr.

Reactor Systems Standards Branch Division of Engineering

SUBJECT:

ADDITIONAL VIEWS CONCERNING REACTOR OPERATOR QUALIFICATION The views expressed in your September 12, 1979 memo to H. R. Denton are those I hold except for the following:

1.

Unlike your memo, I have difficulty recognizing the SECY paper recommendations as merely or mostly first steps - - - that more detailed, substantive, and complete work is underway.

I accept as accurate the statement on the first page of the SECY paper that the recommendations made are the result of a detailed review.

Consequently, I view the SECY paper as seriously deficient for failing to address fundamental issues identified by your memo, especially items 1, 2, 3, i

i and 4, and I do not see in the SECY paper the commitment to identify those measures and redirections that will be needed if the upgrading program is to have meaningful and lasting results.

2.

While I agree with the SD observation that our upgrading effort should incorporate public reviews and the work of national consensus standards conunittee ANS-3, I see little evidence to date suggesting that ANS-3 is interested in tackling the fundamental issues identified in the SD memo as necessary to upgrade operator training in a meaningful way.

i Therefore, since I view this subject an urgent one requiring prompt action, I would start immediately, in houce, to define, in detail, what is needed to assure ourselves and the public that the operators j

really understand the plants they are operating.

l 3.

The idea of deputizing utility people as NRC part-time examiners called l

" Check Senior Operators", as proposed in the SECY paper, is a fundamental error that should not be allowed to take root even under the circumstances mentioned in the SD memo.

It is difficult enough for a Government field employee to represent the Government to industry instead of vice versa; recognizing human nature, it is unrealistic to expect a utility employee, being paid by the utility, to properly represent the Government's interests.

In fact, we would probably be better off with the resulting lesser number of bona fide government examiners; at least, we then would not create an opportunity to be lulled into false conclusions.

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R. B. Minogue 4.

Similarly, while I am in agreement with the basic idea expressed in item 10 of the SD memo, use of utility people as proposed would do little to correct an existing basic deficiency which is to depend almost entirely upon the utility industry to set training standards and verify titair performance as we now do.

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flay 14,1979 SECY-79-330 For:

The Commissioners From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:

Executive Director for Operations

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Subject:

PLANT SUPERINTENDENTS AND ASSISTAN cPE NTENDENTS WHO HOLD, OR HAVE HELD, OPERATOR LICENSES

Purpose:

To inform the Commission regarding the number of plant superintendents and assistant superintendents who have current operator licenses and how many were licensed in the past.

Discussion:

In a memorandum from Samuel J. Chilk to Lee V. Gossick dated April 30, 1979, NRR was requested to inform the Cormission regarding seven items relating to procedures for qualifying reactor operators.

Item 3 of the memorandum requested that we determine how many plant superintendents and assistant superintendents have current operator licenses and how many were licensed in the past.

We have conducted a survey of the 70 nuclear power plants with operating licenses at 48 sites and have obtained the following information.

One hundred and seven individuals are employed as plant superintendents or assistant plant superintendents.

Sixty individuals (56%) have senior operator licenses in effect.

Saventeen individuals (16%) have had a senior operator license at the facility where they are presently employed.

Ten individuals (9%) have had senior operator licenses at other nuclear power plants. Twenty individuals

Contact:

P. Collins, NRR 492-7486 p 7f06JoO330 e7

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2-(19%) have not been licensed.

However, all of these individuals have nuclear power plant experience and have participated in compichensive training programs.

Coordination:

This action has been coordinated with the Office of the Executive Legal Director.

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.q SECY-79-330A May 29, 1979

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For:

The Commissioners From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:

Executive Director for Operations

Subject:

A STATISTICAL PROFILE OF LICENSED OPERATORS AND SENIOR OPERATORS AND A STATISTICAL PROFILE OF COMMERCIAL AIRLINE PIL0TS, AND MERCHANT MARINE ENGINEERING PERSONNEL

Purpose:

To inform the Commission of the results of a survey to determine a profile of operators and senior operators and the comparison of this profile with a profile of people in other regulated industries.

Discussion:

In a memorandum from Samuel J. Chilk to Lee V. Gossick dated April 30,1979, NRR was requested to inform the Commission regarding seven items relating to procedures for qualifying reactor operators.

Item 2 of the memorandum requested that we should determine by suitable statistical sampling of available records, an estimate of the years of operating experience for currently licensed operators and Lenior operators, and, if possible, provide the information separately for the reactor plants designed by each of the major NSSS vendors. Also, we were requested to provide a comparison of licensed reactor operators (age, educatic,nal level, salary) with people in other regulated industries with similar responsibilities (e.g., air traffic controllers, commercial airline pilots, etc.).

We eviewed the information contained in individual dockets of lic.:nsed individuals employed at nine sites with three sites having dual units.

Three units at two sites were GE NSSS, five units at three sites were Westinghouse NSSS, two units at two sites

Contact:

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s gne12,1979 SECY-79-330B For:

The Commissioners From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:

Executive Director for Operations

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Subject:

Operator Emergency Response Training Required by Other Agencies, Using Simulator Training

Purpose:

To inform the Commissioners regarding how other agencies approach training for unanticipated accident sequences and operator re-sponses, by using system simulators, and to make recommendations for the NRC operator licensing program.

Discussion:

In a memorandum from Samuel J. Chilk to Lee V. Gossick dated April 30,1979, NRR was requested to inform the Commission regarding seven items relating to procedures for qualifying reactor operators.

Item 1 of the memorandum requestea that we contact other agencies to determine how operator emergency response training is conducted and the use made of system simulators in such training.

Item 1 further requested that recommendations for the NRC operator licensing program be proposed.

l We have held discussions with the U. S. Navy, Federal Aviation Administration, National Aeronautics and Space Administration and American Airlines.

The following is a brief description of the training and retraining requirements specified by each l

organization.

It identifies how, and to what extent, simulators are used in the training programs.

It also discusses the methods used for establishing and maintaining the competency of the operators.

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UNITED STATES NUCLEAR REGULATORY COMMISSION WAsHIN G' TON, D. C. 20555 July 2, J 97g g

The ComlNFORMATION REPORT ror:

From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:

Executive Director for Operations

Subject:

RESULTS OF EXAMINATIONS ADMINISTERED TO LICENSED OPERATORS AS PART OF THE REQUALIFICATION PROGRAM

Purpose:

To inform the Concission of the results of examinations admin-istered to licensed operators in facility administered requal-ification programs.

Discussion:

In a memorandum from Samuel J. Chilk to Lee V. Gossick dated April 30,1979, NRR was requested to inforn, the Commission regarding seven items relating to procedures for qualifying reactor operators. This response pertains to items 4 and 5 of the subject letter which requests testing results during the licensed operator requalification programs which are in effect at all operating facilities.

This information was obtained from facility responses to IE Bulletin 79-10, Requalification Training Program Statistics, dated May 10, 1979.

Responses have been received from all operating facilities (47 sites, 66 units).

Data was obtained for the last four annual requal41'34? ion examinations or less than four exam-inations if a facility had not administered four examinations.

Fifty-fcur facilities had administered four annual examinations, seven facilities had administered less than three examinations.

The total number of written examina. ions administered was 250 operator examinations and 250 senior operator examina-tions.

Each of these examinations was administered to all the licensed individuals at their, facility.

The da:s indicates that 25 licensed operaters at 15 sites failed a written examination.

This number of failures recre-

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sented 1.4% of the total nunber of operator written examina-tions administered.

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2 Also, the data indicated that 28 licensed senior operators at 15 sites failed a written examination. This number of failures represented 1.2% of the total number of senior operator written examinations administered. An overall grade of 70% or greater is a passing grade on both the operator and senior operator examinations.

Requalification programs require accelerated training if an individual has an overall grade of less than 70% on the annual written examination. The data indicated that 25 li-censed operators and 26 senior operators successfully completed accelerated training programs.

Two senior opirators were not given accelerated training since one individual was trans-ferred to an unlicensed position and one terminated his empl oyment.

The written examinations are divided into seven or more categories depending upon each facility's philosophy and any individual scoring less than 80% in a category is required to attend lectures on that subject.

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The data indicated that 62.9% of the operators and 50.6%

of the senior operators had at least one category or more below 80% and therefore were required to attend lectures.

Of those required to attend lectures, the minimum number of lectures attended per individual was one to a maximum of 11.

The average number of lectures attended per indiv-idual was less than two.

The requalification programs require a systematic observa-tion and evaluation of the perform'ance and competency of licensed operators and senior operators including evaluations of actions taken cr to.be taken during actual or simulated abnormal and emergency conditions.

Normally, this evaluation consists of an oral examination administered by designated facility station supervisory personnel.

Accelerated train-ing is required if an individual is evaluated to be unsatis-factory.

The data indicated that three licensed operators and one senior operator received an unsatisfactory rating on the performance evaluation, and therefore receive' accelerated training.

• =

COORDINATION: This paper has been reviewed by the Office of the Executive Legal Director, which has no legal objection.

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/ Office of Nuclear Reactor Regulation DISTRIBUTION:

Commissioners Commission Staff Offices Exec Dir for Operations Secretariat 1

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_Ju_ly 5, l979 SECY 79-3300 For:

The Commissioners From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:

Executive Director for Operation subject:

COMPARISON OF THE NAVY AND NRC/ INDUSTRY TRAINING AND REQUALIFICATION PROGRAMS

Purpose:

To provide the Commission with information on the Navy's nuclear training and requalification program and a compar-ison of the NRC license program to that of the Navy.

IntroJuction:

In a memorandum from Samuel J. Chilk to Lee V. Gossick dated April 30, 1979, NRR was requested to inform the Commission regarding seven items relating to the proce-dures for qualifying reactor operators.

Item 6 of the memorandum requested that we obtain informa-tion from the Navy on their training and requalification program and compare the NRC licensing program to that of the Navy.

A summary comparison is given below. provides a more detailed description of commercial power reactor training programs regulated by the NRC.

provides a more detailed description of the Navy Nuclear Propulsion Training Program.1 Summary:

A comparison of the Navy and the NRC/ commercial programs indicate the following points:

(1) Selection of Personnel Commercial - Applicants for reactor operator and senior operator licenses hired by the utility come from (1) conventional plants throughout the utility, (2) government operated nuclear reactors, and (3) new hires off-the-street.

Both the operator and senior 1/

Navy program as described in a statement of Admiral H. G. Rickover, USN, Naval Nuclear Propulsion Training Program Before The Committee on Science And Technology-United States House Of Representatives, May 24, 1979.

Contact:

P. F. Collins, NRR 492-7486 7foBMD 15

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July 30, 1979 For:

The Comeissioram From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation Thru:

Executive Director for Operations

Subject:

QUALIFICATIONS OF REACTOR OPERATORS

Purpose:

To obtain Commission action regarding improvements in the Operator Licensing Program.

Category:

This paper covers a major policy matter. Resource estimates, Category 1, preliminary.

==

Introduction:==

In a memorandum from Samuel J. Chilk to Lee V. Gossick dated April 30, 1979, NRR was requested to conduct a thorough review of current NRC requirements and guidance to licensees fer qualification of reactor operators.

It I

was further requested that their training and qualifi-cations for off-normal and accident conditions should be particularly addressed. Finally, the staff was requested to review licensee practices for training and testing of operatort.

The memoranm also requested information on seven specific items.

This' Aformation has been provided in separate information papers, SECY 79-330 through SECY 79-3300 and

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in a memorandum from H. X. Shapar to Commissioner Bradford dated April 24, 1979.

On May 15, 1979, GA0 issued a report to Senator Schweiker regarding the Operator Licensing Program. The report did not mac.e any recommendations for changes to the program, but raised several questions regarding the program. This paper will also address those questions.

Discussior; We have conducted a detailed review of the Operator Licensing Program. The results of the review, answers to the questions raised on the GA0 report and options to the present program are addressed in Enclosure 1.

The purpose of this paper is to summarize the results and present our recommendations for your consideration.

Contact:

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P.F. Collins, NRR 49-27486

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9102 SECY-79-330F_

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11, 1979 Sectember s'

.. COMMISSIONER ACTION __

For:

The Corrnissioners Frem:

Harold R. Denton, Director, Office of Nuclear Reactor Regulation Executive Director for Operations. EM h @

Thru:

Subject:

QUALIFICATIONS OF REACTOR OPERATORS purcose:

To provide a supplement to the Comission Action Paper, SECY 79-330E, dated July 30, 1979, on the above subject. The supplement covers information for implementation and rule-making decisions for all recomendations.

• Cateoorv:

This paper covers a major policy matter. Resource estimates, Category 1, preliminary.

On July 30, 1979, SECY 79-330E was submitted to the Discussion:

Comissioners and contained (16) recomendations complete with various options to improve the Operator Licensing Program, in response to Samuel J. Chilk's request to Lee V. Gossick, dated April 30, 1979.. That report considered the principal type of facility, i.e., nuclear power generating reactors, for which licensing of operators is required.

Recomendations for the time required to implement each of the (16) SECY-79-330E recomendations are addressed in.

Also, this enclosure provides staff proposals concerning implemention steps and whether rulemaking amend-ments or changes are required and/or desirable.

The infor-matien in Enclosure 1 is based on approval of the recommenda-tions in SECY-79-330E anc ':his paper.

is :a:er an:' SECY-79 'i30E are cu rently scheduled for a oriefing at =

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December 21, 1979 SECY-79-330G For:

The Comissioners From:

Harold R. Denton, Director Office of Nuclear Reactor Regulation M f F(

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Executive Director for Operations

Subject:

SECY-79-330E/F - QUALIFICATIONS OF (PCWER) REACTOR OPERATORS

Purpose:

This is in reply to the memorandum from S. J. Chilk to L. V. Gossick dated November 27, 1979. The memorandic indicated the Comission's approval of the subject paper, with modifications.

The purpose of the memorandun is to inform the Comission of the actions we are taking regarding four items, as requested in the memorandun.

Discussion:

(1) The staff is requested to provide the Commission with further recommendations in the area cf Recomendation #1. Specifically, the recomendations of the Lessons Learned Task Force, NUREG-0585, Item 1.6 on page A-7 should be included. The additional require-ments recomended by Chaiman Ahearne and Comissioner Gilinsky should be considered and discussed.

The Comission considers this a priority matter that should receive the staff's prompt attention.

Task I.A.2 of the Draft Action Plan addresses increasing the education and experience requirements for senior operators and shift supervisors over a period of five years that take into account re:omendation 1.6, NUREG-0585 and address the recoc:nendations of Chairman Ahearne and Comissioner Gilinsky.

(2) The staff is requested to promptly proceed with the imple-mentation of those recomendations approved by the Comission.

The staff should provide a revised implementation schedule reflecting the authorized recocr.endations.

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Contact:

P. F. Collins, NRR 492-7486

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The Comissioners Implementation of the SECY-79-330E recommendations as modified, is addressed in Tasks I.A.1 through I.A.4 of the Draft Action Plan that is scheduled for Comission consideration beginning December 19, 1979.

(3 ) Chairman Ahearne's coments of the utilization of simulators vs prototypes should be addressed.

We are presently proceeding to issue RFP-RS-NRR-80-ll7, A Study of the Requirements for Operator Licensing.

As part of this study, we have requested a detailed review of plant training vs simulator training. The final report is due July 31,1980.

It is our understanding that Admiral Rickover replied to Chaiman Ahearne's letter on December 14, 1979 regarding this subject. Hi.i concerns will be considered with the recomendations of the study.

(4 ) Since a majority of the Comission, Chaiman Ahearne and Commissioners Kennedy and Bradford have indicated a desire to extend Comission approval of the training of non-licensed power plant. personnel in functional positions which would affect the safe operation of the plant, (e.g., management, maintenance and other technical personnel) the staff should proceed expeditiously with the development of new or upgraded training program requirements for these positions for the Comission's consideration.

RFP-RS-NRR-80-117 includes a study of non-licensed personnel duties and training. The RFP requires a recomendation regarding NRC involvement in these programs, including licensing.

In addition, Task I.A.2 of the Draft Action Plan requires licensees to start their own review of all facility traininc programs and upgrade them within one year.

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Harold R. Denton, Director t

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DISTRIBUTION l

Comissioners Comission Staff Offices Exec Dir for Operations ACRS Secretariat

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u February 9, 1981 C 0 R R E C T I O N N O T I C E I

i TO ALL HOLDERS E

SECY-81 PROPOSED RULEMAKING, " QUALIFICATION OF REACTOR OPERATORS" (RULEMAKING---AFFIRMATIOM)

PER THE REQUEST OF THE EXECUTIVE DIRECTOR FOR OPERATIONS, PAGE 9 0F ENCLOSURE A 0F THE SUBJECT PAPER IS REVISED IN ACCORDANCE WITH THE ATTACHED EDO MEMORANDUM.

ATTACHMENT:

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SECRETARIAT 1

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UNITED STATES

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February 6, 1981 MEMORANDUM FOR:

Samuel J. Chilk Secretary FROM:

T. A. Rehm Assistant for Operations /EDO

SUBJECT:

CORRECTED PAGE - SECY-81-84 Attachd is corrected page 9 to Enclosure "A", referenced 3

paper above. The word "as" has been added at the end of line 19, and the marginal line has been extende'd the entire page.

. A. Renm Enclosure As stated l

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t-s' in some cases, a number of alternative proposals are still under considera-1

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tion by the Commission.

Advantages of using the high school diploma as j

the educational requirement, as proposed, include the fact that in addi-tion to skills, the high schcol diploma documents an individual's motiva-tion and self-discipline necessary to complete a comprehensive educational program and not just to pass a single examination.

Similarly, although a Bachelor of Science degree that includes at least 60 semester hours of specific technical subje' cts is being proposed as the education requirement for the senior operator, the alternative of requiring only a specific

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number of semester hours of college level courses, but not necessarily completing a degree program is also being evaluated.

Again, although this alternative may represent a viable technique for increasing the

. technical competence of senior operators, a Bachelor of Science degree serves as a measure of the individual's initiative to complete a compre-hensive educational program.

Such motivational qualities are consistent with the strengthenirg of the cadre of highly trained and highly dedi-cated professional reactor operations personnel.

Related to this con-sideration is the expectation that utility management will look for individuals with degrees and experience as senior reactor operators a_s_

candidates for more senior positions in the nuclear portion of the company.

Such opportunities #or advancement should serve as enticement for individuals with degrees to serve on shift work.

'O The type of simulator required to be used to conduct training would

.also be specified.

Provisions hav: been included in the proposed amend-ments for the Commission to approve alternative typas of simulators, t

9 Enclosure "A" l

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