ML20079F342
| ML20079F342 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Diablo Canyon |
| Issue date: | 04/12/1982 |
| From: | Bickwit L NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | |
| Shared Package | |
| ML20079F227 | List: |
| References | |
| FOIA-83-363, TASK-AII, TASK-SE SECY-82-152, NUDOCS 8204220364 | |
| Download: ML20079F342 (4) | |
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April 12, 1982 SECY-82-152 ADJUDICATORY ISSUE (Affirmation)
For:
The Commissioners From:
Leonard Bickwit, Jr., General Counsel
Subject:
DIABLO CANYON -- CLOSING OF NEWMARK INQUIRY Discussion:
On January 27, 1982, Jim Fitzgerald and Trip Rothschild submitted a report to the Commission stating that based on their investigation they found no indication that Dr. Nathan Newmark had ever been employed by PG&E to work on me.tters relating to the Diablo Canyon facility.
They recommended that the investigation be closed.
On March 3, 1982, the Commission sent their report to the parties to the Diablo Canyon proceeding and invited comments on the matter.
The only party that responded was PG&E.
The utility stated that it had never employed Dr. Newmark on matters relating to Diablo Canyon.
OGC believes that the Commission should accept the conclusions reached by Messrs.
Fitzgerald and Rothschild.
Because the Commi.ssion sought comment on the matter, it should announce publicly its findings on the matter.
We have attached for your consideration a draft order that would serve that purpose.
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,s Leonard Bickwit, Jr.
General Counsel
Attachment:
l Draft Order Contact Copy X-43288 Been Sent to pop gwA Lo m / %
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1 Comissioners' coments or consent should be provided directly to the Office of,the Secretary by c.o.b. Monday, April 26, 1982.
Comission Staff Office coments, if any, should be submitted to the Comissioners NLT Monday, April 19, 1982, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it l
requires additional time for analytical review and coment, the Comissioners and the Secretariat should be apprised of when coments may be expected.
This paper is tentatively scheduled for affimation at an open meeting during the week of May 3, 1982.
Please refer to the appropriate Weekly Comission Schedule, when published, for a specific date and time.
DISTRIBUTION Comissioners Comission Staff Offices Secretariat t
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION COMMISSIONERS:
Nunzio J. Palladino, Chairman Victor Gilinsky John F. Ahearne Thomas M. Rcberts
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In the Matter of
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PACIFIC GAS & ELECTRIC COMPANY
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Docket Nos. 50-275 OL
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50-323 OL (Diablo Canyon Nuclear Power Plant, )
(Security)
Units 1 and 2)
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ORDER 1
Two attorneys in the. Comission's Office of the General Counsel conducted an inquiry into whether the late Dr. Nathan Newmark had been employed by Pacific Gas & Electric Company (PG&E) to work on matters relating to the Diablo Canyon facility.
In a January 27, 1982 report to the Comission, the attorneys indicated that they had found no indication that'Dr. Newmark had been so employed.
The Comission sought I
the views of the parties on their report.
The only comenter, PG&E, stated that indeed it had never employed Dr. Newmark on Diablo Canyon matters.
The Comission, after reviewing the material submitted to it, has l
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2 concluded that Dr. Newmark was not employed by PG&E on Diablo Canyon matters and has concluded its investigation of the matter.
For the Comission l
f SAMUEL J. CHILK Secretary of the Comission Dated at Washington, DC, this day of 1982.
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s, PObCY]SSUE (Notation Vote)
Aoril 12,1982 SECY-82-155 For:
The Comissioners From:
William J. Dircks Executive Director for Operations
Subject:
PUBLIC LAW 96-295 (June 30, 1980) SECTION 307(b): STUDY 0F THE FEASIBILITY AND VALUE OF LICENSING NUCLEAR PLANT MANAGERS AND SENIOR LICENSEE OFFICERS
Purpose:
To transmit to the Comissioners the results of the study regarding the feasibility and value of licensing nuclear l
pcuer plant managers and senior licensee officers and to recomend a future course of action.
Discussion:
On May 28,1981, the staff submitted a plan, SECY 81-338, describing a study of the feasibility and value of licensing nuclear power plant managers and senior licensee officers as required by Section 307(b) of Public Law 96-295.
That study included surveying other sources, i.e., NRC Inspection and Enforcement personnel, other Federal agencies that may ba involved in licensing, nuclear utility management, executive assessment professionals, companies which utilize assessment techniques, and associations which certify or license professionals.
The Division of Human Factors Safety (DHFS) contracted with Oak Ridge National Laboratories (ORNL) to perform the major portion of the study.
ORNL in turn sub-contracted a par-tion of the work to Science Management Corporation (SMC).
The DHFS staff monitored the conduct of the work and was primarily responsible for the collection of information from other Federal agencies.
A summary.of the information collected from other agencies and the ORNL/SMC report are Enclosures 1 and 2, respectively.
Contact:
J. J. Persensky, NRR 49-28249 c-
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The Cormiissioners '
The other-agency survey was conducted primarily to determine if there was a precedent for the concept
' licensing runagers either in the Government or as a requirement set by the Government in the private sector.
Early in the effort, it became evident that the respondents' lack of familiarity with the nuclear setting deterred them from making judgements on feasibility and value.
Nine agencies were contacted; two of them administered licensing programs for organizations,
only, five (the U. S. Coast Guard, Federal Communications Comission, Federal Aviation Administration, Federal Maritime Comission and U. S. Customs Service) licensed both organiza-tions and individuals, one agency (Office of Personnel Management) representative discussed the conc'ept of Government licensing requirements in general and the Senior Executive Service (SES) program and a document describing the U.S. Navy Nuclear Propulsion Program for Prospective Comanding Officers (PCO) was reviewed.
None of the Federal agencies contacted license for managerial ability and further there appears to be no Federal Government precedent for licensing managers as individuals for management positions.
However, the Federal Government's SES program and the Navy's PC0 programs do provide insight on executive development programs which might be used as a model for managerial development in the nuclear power industry. A summary of the Government agency licensing 1
programs and a description of the SES ano PC0 approaches are.
t described in Enclosure 1.
The ORNL/SMC portion of the study was to survey all of the otner sectors listed. The study consisted of 68 personal interviews; including 35 interviews with utility representa-tives,18 with NRC Inspection and Enforcement personnel,10 with individuals familiar with assessment techniques and five with professional organizations which certify or license professionals.
A discussion of the ORNL/SMC study, including sampling techqiques, interview guides, results and recommenda-tions, is presented in Enclosure 2.
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l The Commissioners,
Briefly, the consensus of the respcndents in the ORNL/SMC study was that licensing of management perscnnel as a legal requirement, administered in a manner similar to that followed in the NRC's reactor operator licensing process, would pro.-
ably be counter-productive in terms of public health and safety. However, the contractor identified a need to improve managerial and associated technical training provided to nuclear utility managerial staff.
The respondents in the ORNL/SMC study favored a certification program, administered by the utility industry, in which training programs would include a managerial training and development component. The value of managerial skills in the operation of a nuclear power plant would thus be recognized and a long-term management development program would be emphasized rather than a minimal level testing program for management competence.
The respondents were opposed to a testing program because of the perceived inability to objectively measure managerial skills.
The ONRL/SMC report indicates that NRC could provide assistance to the industry by developing guidelines and monitoring a certification program.
These guidelines could be incorporated into existing organization and management guidelines, e.g., NUREG-0731, Guidelines for Utility Management Structure and Technical Resources.
The ORNL/SMC report also states that if a certification program were instituted, it should be a mechanism for formally recognizing the capabilities of the individ
's who participate in it. Further, the program should 3
integrated with the entire personnel resource develog program of the utility and based on comprehensive job /
task analyses, both generic and plant specific.
Staff Analysis The staff concludes, based on the findings of the CRNL/SMC study and the review of other Federal Government licensing j
programs, that there is little support for the licensing of nuclear power plant management.
The feasibility of such a program is severely limited because of the technical problem i
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The Commissioners.
associated with objective measurement of managerial competence.
Though the respondents were able to identify technical and managerial requirements for their own position, much variability exists among the respondents and within the industry as a whole.
Further, the concept of developing a test to objectively and validly assess those job requirements was viewed with great skepticism.
In addition, the resources associated with developing such an assessment instrument would be excessive.
No other Federal Government program was identified which could be used as a model. The value of such a licensing program is doubtful both because of the lack of technical feasibility and the respondents' concern that a formal NRC licensing effort would inevitably focus on narrow issues.
This would place an additional regulatory burden on the nuclear industry imposed by preparation for an examination, without offering compensating benefits in assuring public health and safety.
The staff does, however, recognize that there is room for improve-ment of the managerial capabilities of nuclear power plant managers and senior licensee officers. A number of avenues can be utilitized to achieve such improvements. One possibility is the development of guidelines for a management certification project as proposed in the ORNL/SMC report. Another is to rely on the INP0 plant evaluation effort.
INP0 has developed " Performance Objectives and Criteria for Plant Evaluations" (January 1982), which is used by member utilities for self-evaluation and in INP0 evaluations of plants.
This document includes specific management areas and provides broad performance objectives against which to compare practices.
Attempts are made to identify organizational weakness, policy issues and procedural problems within a utility.
The staff will continue to monitor existing efforts and explore other avenues, such as certification and accreditation of training programs, which would lead to improved nuclear utility management capabilities.
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The Comissioners Recommendations:
We recomend that the Comission:
(1) Transmit the enclosed letter to Congress summarizing the findings and enclose the ORNL/SMC report and the summary of selected United States Government agency licensing programs.
(2)
Direct the staff to monitor existing programs (e.g. INPO) and explore other avenues to improve nuclear utility management capabilities.
Scheduling:
Comission action is requested in 60 days in order to provide the report to Congress and initiate further effort in a timely' fashion.
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William J. Dircks Executive Director for Operations
Enclosures:
1.
Summary of Sele.cted U. S. Government Agency Licensing Programs 2.
ORNL/SMC Report on the Feasibility of the Licensing / Certification of Nuclear Utility Managers and Officers 3.
Letter to Congress Ccznmissicners' ccmnents should be provided directly to the Office of the Secretary by c.o.b. Wednesday, April 28, 1982.
Commissicn staff office ccanents, if any, should be subnitted to the Ccmnissicners NLT Wednasday, April 21, 1982, with an information copy to the office of the Secretary.
If the paper is of such a nature that it requires additional time for analytical review and ccmnent, the ce=nissicners and the Secretariat should be apprised of when ccmner:ts may be expected.
DisnuBUTICN:
cewmheicners Cmmissicn Staff offices EDO EID ACBS ASIRP ASTAP
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SUMMARY
OF SELECTED U. S. GOVERNMENT AGENCY LICENSING PROGRAMS i
Nine Federal agencies were contacted to discuss their licensing programs to detemine if commonalities or parallels existed with the contemplated licensing of nuclear power plant managers and senior licensee officers.
Representatives of two of these agencies, Housing and Urban Development and the Interstate Commerce Commission, indicated that their licensing programs related only to organizations, not to individuals.
Further, they were not aware of any attempt to license individuals by their agencies. The six representatives of the other agencies, U. S. Coast Guard (USCG), the Federal Communications Commission (FCC),
the Federal Aviation Administration (FAA), the Federal Maritime Commission did dis' cuss programs concerning licensing. The U. S. Navy was also contacted regarding the Prospective Commanding Officer (PCO) training program. The infoma-tion from each of these agencies is discussed below. The question of feasibility and value were not dis. cussed in detail because of the respondents' lack of familiarity with the nuclear utility industry, l
U. S. Coast Guard The USCG program of licensing Merchant Marine personnel most closely tracks what might be a,model for licensing of nuclear utility management personnel. The Coast Guard licenses both the deck officers and the engineering crew of com-mercial vessels. The authority for licensing is Title 46 CFR 10. " Licensing of Officers and Motorboat Operators and Registration of Staff Officers," and is intended to assure minimum levels of competence and qualifications standards.
The license is based on experience, physical examination and professional compe-tency as determined by written technical examinations.
There are four levels of license 'for deck officers and the engineering crew.
Deck officers are licensed as 3rd Mate, 2nd Mate, Chief Mate and Master.
Engineers are 3rd Assistant, 2 rid Assistant,1st Assistant and Chief Engineer.
The engineering crew is primarily responsible for the power plant of the vessel whereas the deck officers are responsible for seamanship, navigation and cargo.
Currently, each level within each career requires a separate examination.
It was brought to our attention that the Coast Guard is considering reducing the examination requirements to two for each career, entry level and 1st Assistant Engineer or Chief Mate.
In addition to minimum physic.al and health requirements, entry into the licensed ranks requires a minimum of three years experience. Training is accomplished through union. Federal and State operated schools. The USCG develops, adminis-ters and scores the licensing examinations prior to issuing the license. Each increasing level of license examination tests for increasing depth and scope of knowledge and are based on analysis of the technical requirements of the job.
The Merchant Marine career path most similar to the utility management role would be the deck officer.
Deck officers are tested for items such as marine i
law, rules and regulations, seamanship, lifesaving and firefighting. Though the Master's job is primarily administrative and managerial,these skills are not testad.
s 4 Federal Communications Commission The FCC licenses both individuals and organizations (broadcast stations) under two authorities: the Connunication Act of 1930 and the International Communica-tions Agreement through the United Nations. Only individual licensing was discussed.
Individual licenses are issued to amateur radio operators and to connercial repair technicians based on examinations. The amateur licenses are in five categories ranging from " novice" to " amateur extra." The higher class licenses permit the licensed operator the use of more radio frequencies and allows use of shor,ter call signs. The examinations for amateur licenses consist of two parts, a written technical test and a telegraphy test which involves code transcription from a tape. The higher class licenses require more technical knowledge and a demonstration of greater facility at transcription.
The repair technicians for radio-telephone equipment are examined for knowledge of the technical aspects of equipment and equipment repair before a license is issued.
There are four categories of commercial licenses.
Safety Service (ship and aircraft), Standard Broadcast, Radio-Telephone, and Broadcast Endorsements.
The FCC has eliminated all examinations for commercial licenses except for repair technicians. Other commercial licenses require only a post-card registration.
The FCC representative indicated that the agency is attempting to eliminate commercial licensing requirements, but international agreements and the Communi-cations Act prevent such action at this time.
However, ligislation has been proposed to change the requirements.
Federal Aviation Administration The FAA licenses both organizations, including Air Carriers, Air Carrier Airports, Pilot Schools and Repair Stations, and individuals, including Pilots, Maintenance Personnel and Air Traffic Contro11ets. The majority of the discussion focused on individual licenses.
There are four categories of pilot licenses with ratings or levels in each category. The categories are Student, Private, Connercial, and Air Transport.
The ratings in each category differentiate among the equipment type, e.g., type of plane, navigation system, engine type, etc.
The licenses are based on training requirements, written technical examination, medical examination, and check rides in the same equipment for which a license is sought. Both check rides and medical examinations are conducted periodically for certain types of pilots.
9 Repcf r technicians are licensed for specific air frames and power systems.
They must receive certified training and pass a written examination specific to the equipment type intended to be serviced.
Level and type of examination is determined by the equipment to be serviced.
Air traffic controllers are Government employees and are not actually licensed.
However, they must undergo training by the FAA, pass a written and a simulator examination, and pass a medical examination prior to assuming their duties.
Federal Maritime Comission The FMC certifies the companies which operate comercial vessels and licenses freight forwarders. The certification is economically based and requires that a bond or insurance policy is posted to protect U. S. waters against damage, e.g., oil spills. This is to assure that if the company does not repair the damage, e.g., clean-up an oil spill, then the bond or insurance can cover the Costs.
The licensing of freight forwarders is also primarily economically based. The freight forwarder represents companies with regard to the export of international cargo. The license applicant must demonstrate financial capacity, show evidence of good character in business dealings and meet certain experience requirements.
This is acccmplished primarily through provision of references and posting of a 1
bond. The FMC does investigate the individual prior to granting a license. No testing of skills or knowledge is required.
U. S. Customs Service The U. S. Customs Service licenses custom house brokers, both individuals and corporations. The cor'poration is licensed if two officers involved in super-vision are ifcensed as individuals. Brokers represent importers with regard to customs law and payment of duty on goods.
A license is granted by the Customs Service if the individual is a U. S. citizen and after a character and facility investigation and the individual passes an examination. The examination tests for knowledge of customs law, importing procedures, rates and duty, and other agency requirements.
Office of Personnel Managemer3 The OPM does not license any organizations or individuals but the OPfi individual interviewed did have an overall knowledge of licensing in the Federal Government.
The interview covered three topics: licensing of Federal employees, Federal licensing requirements in the private sector and procedures and criteria used in recruitment, selection and promotion of managers in the Government.
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As an snployer, the Federal Government requires little licensing of its employees primarily because of the strict legal guidelines imposed on licensing requirements. As a general rule, the Government requires licensing of employees only if the individual provides a service to individual citizens where the service is too critical to expect the citizen to make a rational choice regarding the competency of the employee. This primarily includes the medical professions.
Even in cases where non-Government employees who provide services to the Government must be licensed, Government enployees providing the same service need not be licensed. This includes lawyers, appraisers, barbers, etc.
In j
such cases, the Government assumes the responsibility of assuring qualifica-l tions and competency.
As regards Federal licensing ' activities in the private sector, the major examples of individual licensing discussed were the FCC, FAA and NRC. The respondent indicated that other than these, licensing appears to be directed to organizations rather than individuals.
1 Recruitment, se'ection and promotion of managers in the Government was also discussed. Assessment center techniques have been used by some agencies to select GS-14 and 15 employees as candidates for Senior Executive Service (SES) programs but costs have caused most agencies to return to standard merit procedures. The merit procedures include approval of technical and professional qualifications and approval of managerial qualifications by the agency Executive Review Board and an OPM Qualifications Review Board (QRB).
The QRB rules on whether an individual has:
- Demonstrated success in executive work
- Successfully participated in an approved executive development program
- Special or unique qualities indicating likelihood of executive success i
The SES programs are developed by each individual agency utilizing guidelines established by OPM and published in the Federal Personnel Manual (FPM) and Bulletins. The agency SES programs are reviewed and approved by OPM.
Each agency establishes an Executive Review Boaro which is responsible for development and implementing systems relating to
- Establishing qualifications standards
- Recruiting of SES candidates, including candidate development programs
- Establishing selection systems
- Handling inquiries
- Documenting merit staffing actions After an agency selects an individual for an SES vacancy, he must also be certifico by an OPM, QRB. The QR9 utilizes documents from the agency and reviews the candidate for executive qualifications in terms of competence
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. i to assume leadership responsibilities in the broad areas of:
- Integration of Internal and External Program / Policy Issues
- Organizational Representation and Liaison
- Direction and Guidance of Programs, Projects, or Policy Development
' Resource Acquisition and Administration
- Utilization of Human Resources
- Analysis and Review of Implementation and Results Achievement Once certified by the QRB, the individual retains SES reinstatement rights even if separated from Governmer.t sirvice.
Though the femal certification process is the responsibility of the OPM, each agency is responsible for the more extensive processes of recruitment, selection, development and maintenance of executives.
U. S. Navy - Prosoective Commanding Officers Program Admiral H. G. Rickover provided testimony before the House Subcommittee on Energy Research and Production on May 24, 1979, concerning the training that Prospective Commanding Officers undergo.
Prospective Commanding Officers (PCO) of all nuclear-powered submarines have qualified to serve as Engineering Officers and, therefore, have undergone all training related to that position including nuclear power school and prototype..
After selection into the PCO program, training in addition to that required of Engineering Officers is required in:
nuclear propulsion, including mechanical, fluid and electrical systems; plant materials; reactor engineering and theory; reactor' safety and chemistry; and radiological controls. The PCO is examined in each area, including two oral examinations and a final, seven and one-half hours, comprehensive examination covering all areas.
In addition, a final oral examination on reactor safety is given by a four member Naval Reactors Board.
Special briefings by senior naval officers and training in subject: that will aid the PCO in running his ship are included in addition to the technical training.
Summary of Licensing in Other Federal Agencies 3
Of the nine agencies contacted, five license individuals:
Coast Guard, FCC, FAA, Federal Maritime Commission and U. S. Customs Service.
Technical knowledge of the specific activity is the basis for the licensing exaninations in four of these five programs.
The Maritime Commission license is based on an investiga-tion of financial capabilities and previous experience. Of the programs described, the Coast Guard's licensing of deck offie:ers and masters most closely approximates the potential for licensing nuclear power plant management.
The Coast Guard license is based on technical skills rather than manaaerial abilities.
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, Two other programs described SES and PCO, might be considered models for assuring the competence of management without being based on a license. The common aspect of these two programs is the long-term development and intensive training of the individuals selected, as well as a continuing monitoring of performance and upgrading of capabilities.
The OPM representative also suggested review of a Supreme Court decision (Griggs vs Duke Power Co.) which may have a bearing on the subject of licensing of individuals.
In that case, the Supreme Court rules that Title VII of the Civil Rights Act of 1964 requires that the use of tests and diplomas as job requirements must be eliminated if they disqualify blacks at a higher rate than whites, unless the employer can show that the test or diploma bears a
" demonstrable relationship" to successful job performance.
In conclusion, through discussions with several other agencies with licensing authority of non-Government organizations and individuals, there appears to be no Federal Government precedent for licensing of managers of corporate officers for managerial abilities.
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INTER!M REPORT Accesston No.
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4 C e, e Program
Title:
Feasibility of Licensing Nuclear Ut!!!ty Managers and Officers Subject of This Occument:
Report on the Feasibility of the Licensing /Certificatien of Nuclear Utility Managers and Officers
- Project Managers:
D. Scworing (SMC)
D. Selby (CRNL) l Contributors:
D. Bowering (SMC)
D. Selby (ORNL)
O. E. Bertine (CRNL)
M. Colella (SMC)
P. Haas (CRNL)
.D. Messer (SMC)
J. Sheehan (SMC)
S. Thanas (SMC)
Cate of Occument: Decamber 17, 1981 Prepared for U.S. Nuclear Regulatcry Cammission under CCE Interagency Agreement 40-!A4-75 NRC F1n No. 50764-1 NRC Meniter:
J. J. Persensky, Division of Human Facters Safe' ty This dccument was prepared primarily for preliminary or internal use, it has not esceived full review and approval. Since there may be substantive changes, this doc:anent should not be considered final.
Werk performed by Science Management Corporation, Washington, D.C.,
under Subcontract No. 62X-35648Y with Oak Ridge National Labcratory, Oak Ridge, Tennessee, operarsd by Union Carside Corporat hn for the U.S. Department of Energy under Contract No. W-7105-eng-26.
CAK RICGE NATIONAL LABORATORY Oak Ridge, Tennessee 37830 l
ope e..d by Union Carbide Corporarion for the Deoar ment of Energy INTERIM REM RT
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TABLE CF C a2.a.a O+
EXEC:7TTT2 SCMMJutY V
1.0 INTRCCCC"!CN.
1-1 l
2.0 s m Dr MET 5cocL0cr 2-1 2.1 overview of the Methodology 2-1 2.2 Interview Sample Selection...............
2-2 2.3 Instrumentation and Data Collection 2-5 3.0 RESULTS CF THE FIELD INTERVTENS 3-1 3.1 Issue #1: Does the licensing /cartification of nuclear power plant managers and other senior licensee personnel have value in terms of public health and safety and the efficient, safe and effective operation of nuclear gewer plants?.
3-2 3.1.0 Background and General Cenuments 3-2 3.1.1 Viewpoints from the Nuclear Power Indust =y...
3-3 3.1.2 viewpoints from the NRC Inspection and Enforcement Division......
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3.1.3 Viewpoints from Profession?1 Associations and
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Societies 3-6 3.1.4 viewpoints from Management Development and Assessment Professiona3.s.
3-7 3.2 Issue 42: What job-related technical and managerial requirements can and should be included in the licensing /
certification process, and what senior licensee officers should be subject to the process?
3-8 3.2.0 Background and General Ccamnents 3-8 3.2.1 viewpcints from the Nuclear Power I.dustry.
3-9 3.2.2 viewpoints from the NRC Inspection and Enforcement Diffsion 3-14 3.2.3 viewpoints from Association Executives and Management Assessment Professionals 3-15 3.3 Issue 93: What is ths most practical and valid precess by by which the managerial and technical requirements of senior management positions could be assessed? Are there proven managerial assessment techniques (such as the assessment center approach) that could be used in the licensing / certification process?.
3-17 111
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PAGE 3.3.0 Backgreund and General Conunents.
3-17 3.3.1 Viewpoints from the r near Power Industry 3-17 3.3.2 Viewpoints from the NRC Inspection and Enforcement Division 3-18 3.3.3 Viewpoints from Association Executives and Societies..................
3-19 3.3.4 Viewpoints frca Management Development and Assessment Professicmals 3-20 3.4 Issue #4:
If a licensing / certification program is to be see in place, who should be responsible for the design and administration of the program, and if groups other than NRC are involved, what would be both their and NBC's roles in the program?..
3-22' 3.4.0 Background and General Consnants.
3-22 3.4.1
' Viewpoints frca the Nuclear Power Industry 3-23 3.4.2 V'iewpoints from the NRC Inspection and Enforcement Division 3-24 3.4.3 viewpoints from Association Executives and Management Assessment Professionals 3-25 4.0 SUletARY AND RECCMMENDATICNS 4-1 LIST OF APPENDICES APP'lNDIX As SELECTED BIBLICGRAPHY A-1 APPENDIZ B:
FIZLD INTERVOi3t GUIDES B-1 APPENDIX C:
SCMMARY OF THE BACKGROUND EXPERIENCE, T3AINING AND EDUCATICN OF THE INDUSTRY,Lws.RVIENEES C-1 l
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EXECUTIVE
SUMMARY
Secticn 307(b) of PWlic Law 96-295 directed the Nuclear Regulatory Camissicn (IRC) to undertake a s xdy of the feasibility and value of licensing... plant managers of utilizatica facilities and senio: licensee o!!1cers responsible for operatica of such facilities.
The Licensee Cualificaticna Brauch of the Divisien of Human Factors Safety in turn centracted with the Cak Ridpt National Iaboratcry (CRNL) to provide techn4M assie=ne= in completing this study. This report presents the results of GtNL's efforts, including those of its subcontrac-ter, Science Manay =4 Cocperation (SMC).
The key words in the Sectica 307(b) quotation are feasibility, value, licensing, and senior licensee officers. Feasibility as interpreted in ter:::s of whether the operation was both possible and practical. Value was addressed in terms of benefits, particularly with respect to p:blic health and safety. Cur definitien and evaluation of licanning was not limited to licensing in a narrow professional or legal sense, but rather empicyed a much broader view of the term which included such w@ as certifica-tien. The ter:n " senior limnsee officers" was left undefined, but since the position of plant manager was v 4rically defined, the study centered arcund that position and
-- ;-W one managanent level just, below and one just above it.
- be infmnaHen required to answer the questiens raised by the issue of 307(b) was acquired through interviews with A cross secticn of managers and executives in the nuclear e
p:ver industry
- 1RC inspection and enforcement 1:erscenel:
resident inspec crs, regional staff, and w t = ders staff Persens having expertise in or experience with managerial /
executive assessment and aEpraisal techniques Professional societies and other organizations which certifI' or licansa professionals.
Questionnaires and interview guides were develeged fer use in the field interviews. A total of 68 interviews were ceW *=i, ine1 Ming 31 interviews with utility Imrsonnel, i
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Aralysis of interview responses pwceeded throughout the interview phase, and team memcers frequently met informally to d4=e"a= results as the study progressed. A rurser of spcific findings began to a::exge fra this process and, as a result, it was possibla to further sharpen tha focas of particular questions. A scre formal analysis was undertaken after most of the interviews had been c:2npleted.
The consensus was that the licensing of management personnel as a
, legal requirement administered in a process =4m41=r.to that used for the SRO license is undersfrable and w::uld probably be countiu.r.cactive in terms of both public health and safety and the effective operation of nuclear sower plants. However, a need was identified for assuring that line management sarsennel possess the managerial and hachnical education, training, and experience necessary to perform their'jcbs with a high level of effectiveness.
Clearly, the belination of people from all four ww
- interviewed was to favor a certificatien program. Se value to the uY.11 ties in tezms t
of public health and safety,'it was felt, would depend upon the content of the program, the nature of the process by which the program is implananted, and the extent to which the program has implicatons for training and work forcs develognant. She general feeling was that such a certificaticn pro-gram should be develeped and administered by the utility industry itself.
Under this concept a utility's management er=4ning and develw+; program would be certified rather than an individual manager. This type of certif-ication would recognize the value of management skills in plant operation and safety and the need for 1sW.e management develegnant as opposed to minimal managerial base-line testing.
In general, the r=---W were able to identify quite specifically what they though the technical and managerial requirements for a particular positicn should be. But they were less certain and often skeptical cf whether, or how, the managerial requirenants could be assessed in any objective manner. They were ganar=11y adanant that written tests or exami-naticms should be avoided as far as possible. The aaaaaamant-center tech-nique was identified as a pa==4h1e means cf manay---4 evaluatien, but ene which needad to be developed and aglied on a utility-specific basis.
There was general agreement that NRC inp2 would be needed for any program implemented, since NRC is the regulatory body for the nuclear power i n'"=t'I. Bowever, it was felt that NRC's role should be one of 911danca.
.NRC would set up guidelines designed to pecmote the development of the pro-gram, and would perhaps at times :nonitor the process.
It is impu.i nt to note that all four interview group expressed Sti-lesophical cpposition to further exptnsion of NRC's rem 12tary role.
Et their view the industry itself is best qualified to undertake devel-r+t and = M ai eration of a li ensing/ certification 5rogram.
It is our opinica that WC would be well advised to explore incor-potating into existing organizatica and manarA procedures (such as NCREG-0731) the necessary glidelines and procedures for certifling the qualificaticris of nuclear ower plant :nanat==ane seroonnel. Such an approach would very likely be well receivec; by the industry, and would a14=4nate the need to develop a new regulatory program.
vi l
3 Several future effcets raeded by 1RC for such a program are:
- Develcp ? tid =14 ras:
- Develop guidelines for collectien of job audit data in the industry
- Review cther cartification programs for appliah414ty
- Develop specifications which might be included in the program (criteria).
- Idetify and review av4*4ng NRC guidelines and practices related to management qtualiMcations and m=_h_ ilities (as contained in NCREi-0731 and elsewhere) for compatabilit/
with a certification program.
- Survey industry programs related to: managment requirements, assessment of management m?h414 ties, training and anagment develegnant, and evaluation cf management performance.
- Survey managment assessment, develu.-- 4, and evaluation c
practices utill:ed by other organizatiens as well as state-of-the-art techniques av=41=h1_e to mara3 - =-
specialists.
- Prepare draft certification progra guidelines based on job requirements.
- Develcp and test a draft format for the }RC review process which assures reliabilief through consistent, standardi..ed methods and i m mants.
If NCRai-0731 were chosen as the mechanism for impleanting the process, two other efferts would be caeded:
- Prepare draft ?'idatir.es covering ::aragment certification for inclusion in NCREG-0731, and evaluate consis m f of
- aragement guidelina* with guidelines for +'4ty organizations and structures.
- Prepare final 92id=14nes for utility ::enagenent to be incorpcrated into final version of NCREG-0731.
Cbviously the eventual benefits of any program will to a great extent desand on how well the program is developed in its initial stages. Any certification program put in place should be a w%nism for formally recognizing ther professional skills, abilties, knowledge, and cxperience that would qualiff managers to perfcr:n their duties in a safe and afficient manner. It should be an integral part of the entire human resources develcpment progran, i.e., recruit:nent, selection, training, and perfor-mance appraisal. Such a program should be based an a canprehensive job analysis. and the plant W ie and generic cerponents of tha certifica-tion program would 4 4 in part an that analysis.
vii
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1.0 INTRODUCTION
Section 307(b) of Public Law 96-295 (the appropriation autherief act of June 30, 19 80, for the Nucisar Regulatory r*-4 =sion) directed the Nuclear Regulatorf Commission (N3C)
"t3 undt)Ltkt G. 4.tidj Cf Z}tt f0"AIIIIf And Vgl.uS Of 2/42naiJtg... plant mdJELJFJts Of "ti?I'"tInn fGLIfi?I A Gnd sSndCh. LIALKaeL
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officrJts n.esponsible fan. ope)tation af such fG4 ?Itit.4."
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2e Licensee Qualificaticus Branch (MB) of the Division of Human Factors Safety (CEFS) was charged with responsibility for the study.
M e QB in turn contracted with the Oak Ridge National Laboratory (CRNL) to provide technical assistance in ccuplating the study.
This report presents the results of CRNL's efforts, including those of its subcontractor, Science Management Corporaticu (SMC).
"As purpose of the study was to evaluate whether the licensing of nucisar power plant managers and other senior officers responsible for nuclear pcwer plant operations is feasible and, if feasible, whether such licensing would have any value to the public, particu.larly with respect to public health and safety.
"As study was exploratory is the sense that, if both feasibility and value were demonstrated, a =cre extansive st'df would then need to be conducted to ccnfi=n preliminary results and to establish the detai's of the licensing process.
i i
Cur definition and evaluat:.cn of *1icensing" was net 13-'i ted to li:ensing is a narrow professienal or legal sense, such as that applied to senior reactor operators, medical doc ors, CPAs and professional engineers; rather, a much broader view of the ter:n was employed including the concept of certification, which would require demcastrating that individuals had achieved certain min 4== professional credentials. We chose this approach because we were also concerned with assessing the feasibilitf of achieving i
the same ends as licensing (e.g., reduction of risk to public health and safety) by :nnans other than formal licensing, such as certification.
To indicate this broader definition we have used the term " licensing /c: rtifi-ca icn" rather tan the word " licensing."
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i me key words in the law cited above are feasibility and value.
In planning and conducting the study, the word "value" was interpreted in terms of the positive and negative inpacts of licensing / certification en public health and scfety. M e emphasis here was primarily, but nct solely, on public health and safetf. Berefore, respondents were asked to ccament generally on the pcssible effects en the public, the industry, and the managers themselves.
" Feasibility" was interpreted as consisting of three sequential compocents:
(a) can a licensing process be operationalized (b) can meaning-ful tecenical and managerial criteria be developed; and (c) vhat should the licensing process be and who should administer it?
Tc ensure that studf efforts were focused en the concerns outlined above, the ICB's project officer developed a set of specific questions to define bcth the study scope and the particular areas of inquiry and analysis to be folicwed. ' Me CRNL/SMC project team then used these questions, together with pre 14=4"n f study experience, to formulate the four basic issues that the study would address, namely:
Issue #1:
Does the " licensing / certification" of nuclear power plant managers and other senior utility personnel have value in terms of public he.alth and safety and the efficient safe and effective operation of nuclear power plants?
Issue #2: What job. elated technical and managerial require-ments can and should he included in the " licensing /certifica-tion" process, and what senior utility off cers should be subject to the pescess?
Issue #3+ What would be the mest valid and practical processes l
by which the requirements, both :r nage: d and technical, would be assessed? Are there management asset, ment techniques available that could be used in the " licensing /cartification" process?
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Issue #4:
If a " licensing / certification" program is to be set in place, who should be rwsponsible for the design and ad'"4 "4 =tration of the program, and if groups e': hor than URC are involved, what would he both their and NRC's roles in the program?
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The infor: nation required to answer the questions outlined above was i
l acquired through interviews with i
f Persons having expertise in or experience with nrungarial/
executive assess:nent and appraisal techniques (a literature review was also conducted)
A cross-section of managers and executives in the nuclear power industry NRC personnel, including resident inspectors, regional staff, and personnel in the naticnal headquartars of the office of Inspection and Enforcement Professional societies and other organizations which certify or license prefersionals.
Details about the samples of interviews, as well as a discussion abou*.
the methodology employed, are provided in s' action 2.
The study results, pre-seated in Section 3, are stated in the fcz:n of findings for each of the four
- najor issues outlined abcve, with separate subsections for each of the interviewee gzeups.
Stese findings comprise syntheses of the responses.
Both :najority and minority viewpoints, opinions and beliefs are presented in Sectica 3.
In additica, some " outliers" are included, specifically those for whieft respondents provided cogent or well-conceived support.
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2.0 STUDY METHODOLOGY This section provides an cverview of the study approach and describes the methodology that was employed t.o develop and conduct the study. The overview includes a description of the development of the principal issues addressed in the field interviews and the approach to data collection and analysis which was decided upon as the meut practical.
The interview sample, the data ecliscted, the intarview guide, the 1
protccol, and the data ecliection procedures are discussed in the methodology, together with the respective rationales.
2.1 cverview of the Methor*eloo r '
me study was initiated with a series of pimnning meetings involving the NRC p.uject officer and members of the CIRII/SMC project team. Efforts focused first on the development of a precise specification of the scope of the st 2f and a definition of the specitic objectives to be achieved. For example, considerable effort was devoted to the operational definitions of "feasibilief" and "value" and to the " licensing" concept itself. Considera-tica was also given to the general subject of managerial assessment techniques, the functions and responsibilities of nuclear power plant managers and others, possible criteria for the licensing / certification process, and the relevant management pcsiticas upon which the study should focus. Based on guidance from the NRC project officer, it was decided to focus on the positien of the nuclear power plant maaager but to include cne managecent level above and below him within the range of the target positions. This approach was necessary because of the diversity in organizational structures in the nuclear pcwer industry.
mese discussions were the basis for deciding the st2/ approach, the l
data needs, the sample, the instrumentation and the field interview proce-dures to be used. Questionnaires and interview guides were developed for use in field interviews with managers in the nuclear pcwer indust:7, the Institute of Nuclear Power Cperations (*NPO), management assessment profes-sionals,.vJtc staff, and professional associations experienced in the professional 2-1
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licensing or certificatica of its :nombership.
Concurrently with the first meeting, a review of the management assessment literature was initiated, particularly with respect to the management assessment center technique.
Table 1 on the foncwing page provides a summary of the types of respondents and numbers of interviews that were conducted. Almost all of the interviews were conducted on site by two-person teams. However, a few one-person interviews were perfor:ned, and two interviews were conducted by telephone (beenuse of scheduling problems).
Se analysis of interview respcases was an on-going process throughout the interview phase, and team moders met f_wtly on an informal basis to discuss resulta. nrough this process, a number of specific findings began to emerge, and as a result it was possible to furthar sharpen the focus of particular questions. A more fc:: mal process of analysis was undertaken after most of the interviews had been completed. After 4 ' 4 tial centent-analysis was completed, a 2-day review meeting was m d e.ed to share inter-view results and highlight the major points in the respondent opinions, resolve any contrary results, and identifI' the range of opinions that should be expressed in the *4ndings.
It is i:nportant to note that there was consensus among the team :neders on virtuany an essential points.
4 In the fonowing sections the sample of respondents interviewed, the data conected, the data conection instr monts (interview guides), and the field procedures are discussed.
2.2 Interview Sample Selection ne methodologf caned for obtaining the views and opinions of persons from several different groups:
Utility managers because they were the focus of the study and would be the subjects of the licensing /cartificacien process 2-2
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Utilitf corporate exec.:tives as representatives of the industry and because they too : night be included within the the scope of the process Representatives of INPO because of their knowledge of the industry and because DIPC aight bs called upon to assist in or to develop and = ^4n4stor the program.
NBC personnel because of their knowledge of nuclear power plant cperations, the regulatory process, etc., as well as the fact that NRC vould be a prine candidate for adminster-ing or at least :nonitoring any licensing / certification program that night be developed Professional societies and associations, preferably in fields concer=ed with public health and safety, in which licensing or certification of professionals is.@d Users and practitioners of :nanagement development and
= v gement assessment techniques, including specifically users of such techniques in the power industry.
Se approach selected to obtain the necessary -information for perseas representing these groups was that of face-to-face inter-riews. This approach was selected over the alternatives 'of questiew=4 =m : nail-outs and telephone inter-riewing because it would prov2.de an intes.riewer with the opportunity to explore topics in greater detail, as well as to stimulate respondents to provide support and rationale for their views.
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2e decision to conduct face-to-face interviews resulted, however, in the need to restrict intarviews to selected samples in each of the target groups.
mis was necessary because of the limited resources available and the tight schedule. me approaches employed to select the sample in each of *he group are described briefly below.
Tr'te. Nut!.za.t Pcwen. Indu.sttu I
Secause of resource limitations, a target of conducting inter riews in 8 utilities with nuclear plants was established. This, it was felt, would provide a sufficient cross-section of industry views, since three to four interviews per plant we 1 planned (representing several levels of management. )
me issue then became that of establishing the particular utilities and plants that should be Psited.
2-3
To ensure the selection of a representative cress section, we first foraclated a set of selection cr:.teria applicable to both activities and plants. ':he more important of these were to ensure the inclusion of:
At least one large multiplant utility A spread between small and large utilities and plants Several single-plant utilities At least one plant located in close prox =nitf to a large metropolitan area A range of managerial and funt.tional organizational structures Both BWR and PWR plants Age (vintage) representation Geog::aphical dispersica.
A prs 14=4=7 sazqple of utilities and plants was selected using the criteria listed above. Several "bacic-ups" were also identified for use' in tLe event of scheduling difficulties.
Int.stviewee. Samcf.e. fn.cm NRC inscec. tion and Enfo,tezment 12ivision It was decided that the NE sample should cens!.st of resident inspectors at the plants included in the utility sample, plus representatives (three to four persons) from all of the regions in which interviews were conducted.
It was left to the Regional Directors to nominate the individual interviewees.
The basic NE sample'was augmented with a mall sample of four persons frem the headquarters offices of the office of Inspection and Enforcement, including its Director.
Usen and P.tactit.icnen af %xnageme.n.t Assessmen,t Techniones i
Ma selection of organhations and persons in this category was based on a combination of professional knowledge and experience resident in the project team, the literature review that had been conducted at the onset of the study, and referrals by the initial group of persons interviewed.
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Two samples were required in this category:
companies (preferably utilities) that employ management assessment techniques, and professionals in the field who provide such services.
For example, personnel from two utilities who are respcnsible for the development and implementation of training and personnel assessment programs were interviewed. They currently use a number of assesmnant approaches and employ the services of assessment center professionals to assist them.
In addition, we interviewed persons fr=m one of the leading proponents of the use of management assessment techniques in business and industry, including the assessment center approach.
I P.tofessional. Societ.Les and Associations several professional societies and associations that are involved (directly o'r indirsctly) in the licensing or certification of professionals were kacwn to the project team, and others were identified during the literacure review.
A =4"4=-
sample of three such organisations was established, 'sith provision for expansion in the event results of the initial interviews indicattd,that this would be desirable.
2.3 I'nstrument'ation and Data Cellection Prior to initiating interviews, interview guides were developed for use by project staff in leading the discussion with interviewees.
Each of these guides (except those used for other associations and societies, which l
were organizational 1r specific) went through at least two itare.tiens.
Copies of the interview guides that were developed are included in Appendxx B.
Crganimation-specific instruments were developed for use in interviews with representatives of professional societies and other I
organizations in which professionals are licensed or certified.
Nuc.leat Power indusCtu inte/wiew Gilde f
I A semi-structured interview instrument was developed for use in guiding interviews with persens in the nuclear pcwer industry (including INPO).
It included:
2-5
A personal information summary to record key educational and work experiences of the interviewees Questions regarding key wctk experiences, training and managerial attributes /capabilitias that the interviewees felt were essential or desirable requirements for the job A section designed to de* amine the orientation of the position (i.e., with whom the manager dealt most f.wtly)
A questionnaire that was used to obtain each interviewee's opinion, ideas, perceptions and comments about the value and nature of licensing or its alternatives.
Se questions and prompts i'scluded in the guide were developed around the four basic issues listed in Section 1.0.
Soy were designed to provide facts (e.g.
how do managers spend their time and with whom do they interact how frequently, etc.), as well as opinions (e.g., with respect to the value of licensing).
t It is important to emphasize that the instrument was used as a guide and that the questions were not asked in a serial manner. Also, promising lines of inquiry were pursued in the discussions, even whon these had not been addressed en the instrument.
All but two intarviews were conducted face-to-face, on-sita, by a two-person interview team. Cne persen acted as the interviewer, whereas the second recorded respenses and ensured that all t= pics mre covered.
Nuc. twt Regtdztaltu Cow.iui.on int.ettui.ac Gaide.
I m e instrument used to guida discussions with NRC personnel was similar to that used for interviews with nuclear power industry managers and executived.
However, heavier emphasis was placed on the potential benefits and disadvantages of licensing or certification, the adequacy of the existing processes for plant licensing, who should develop and i
administer such a program, etc.
2-4 N
Ussts and Pnctifinnets of Sfc.ncalment Assessment
- The interview guides that were used for discussicas with both users and practiticcars focused on uses of management assessment, the techniques involved, where their use is most/least appropriate (both jobs and att=i-butes), benefits and disadvantages, possible legal or ethical probelms, etc.
Respondents were also briefed on the organization of nuclear power plants and provided with an everview of the results being obtained with respect to how power plant managers spend their time, essential and desirable management knowledges. skills and attributes, etc.
May were then asked a series of questions to elicit their views on the appropriateness, feasi-bility,and value of employing management assessment techniques in the nuclear pcwer industry.
Insttuments for Use fa)L int.Ltvians widt Re.wtesenttives af Socie'ie.s cxa A440c.cz.e<.ana at Wnct PerSono aste U ceM4Ed. c.t Cot 4<.4.ca nous were three basic cbjectives in madneg interviews with persons in this category. specifically, we wanted to obtain An understanding of the process and techniques used for licensing or car ification in that profession me interviewees' views of licensing /cartificatica, l
including the benefits / disadvantages, who they believe should be responsible for
- a4 =tration, etc.
Meir views (after a briefing on nuclear power plant organization and management) as to the value and feasibility of licensing / car 4 84 cation, as well as any alternative approach t!utt they might suggest.
2-7
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_L 3.0 RESULTS OF THE FIELD INTERVIEWS In the introduction to this report, we stated the four basic issues around which the questions posed to responoonts in the field interviews and telephone disettssions were framed. In this section of the report, we have sunsaarized the opinions of those interviewed on each of the issues in question.
Se format chosen to present them is the narrative discussion.
Majority opinions are presented together with key minority opinions and outliers that : night be considered important despite their deviation from the general viewpoint.
-nespondents warr. generally willing to discuss the issues at length, and consequently there was quite a diversity of detailed opinica collected on them. Clegrly, it would not be usiful in such a short and exploratory study to attempt to present all nuances of cpinica surrounding each issue.
Rather, we have content-anc.lyzed the responses to highlight the major points about which there were consistent opinions; where consistency was absent, we have exercised judgment ?.hout which majer points to include in the discussion and have also tried to represent the range of opinions encountered where it is useful.
f clearly, the inclination of people frca all four groups interviewed was to favor a certification program ovqr legal licensing.
Furthe Are, they felt that the value to public health and safety would depend upon the content of the program, the nature of the process by which it is implemented, and the extent to which the program had implications for training and workforce development. M ere was indication, suppersed by evidence presented in later sections of this report, that the respondent group favored some form of self-developed and self-ar*ministared certifica-tien program. 2 e respondants' opinica regarding the role of NPC in such a situation is discussed later in this report.
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P 3.1 Issue #1r Dees the "licensine/cortifieation" of nuclear oower olant 9
_nanagers and other senior licenree eersonnel have value in tez:ns of public healr.s and safety and the efficient. safe and effective operation of nuclear ;cwor 71 ants?
3.1.0 Background and General Comments mis issue obviously aims at the kernel of the proposed licensing /
certification of management personnel - its perceived impact on public health and safety.
De interviewers did not provide respondents with the linkage between safety and managerial competence, but rather allowed them to consider the question without prompting and then conducted probing discussions around the points raised. More was, however, a preceding discussica of licensing and certifica' tion in order to expand the concept beyond the existing Reactor Cperator (RO) and Senior Reactor Cperator (S20) licensing process, which is technical in nature, emphasizes cognitive knowledge, and has no management component.
Discussion of the value of licensing / certification of senior management personnel was hampered by diffictilties in identiff* ing.who (i.e., what positions) were to be the subjects of the licensing process.
It was clear that there was great diversity among utilities, and even among nuclear plants in the same utility, in terms of the job functions associated with what initially appear to be comparable positions. mere is no standard organizational structure through which the nuclear facilities are I
cperatad, ard this also made the clustering of responses in terms of
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specific positions more difficult. For this reason, we have resisted the tamptation to separate the respendants into position categories in the analyses.
P With the utilities personnel, and to some extent Jith NRC perscnnel also, we encountered considerable skepticism.marding the feasibility of defining valid management criteria, and even more doubt regarding tne ability to measure management capabilities in a valid and reliable way. mis 4
mada discussion of the first issue - the value of licensing / certification -
somewhat difficult and.W that respondents be asked to suspsnd their doubts and presuppose that it was possible to do so.
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3.1.1 viewecints fre:n the Nuclear Power Industry Mero was a clear consensus that the licensing / certification of j
management personnel, if conceived as a legal requirement in the same way as the 5140 licenses, is undesirable and would probably be countas. productive i
in terms of both public health and safety and the safe and effective opera-I tion of nuclear power plantr.
Despondents felt that senior management personnel are already burdened and their time is li:aited; any additional regulation which took them away from their duties on site would threaten their ability to f"1"d 11 their responsibilities adequately and thus threaten the safe operation of the plants.
One possible advantage (which the respon-dents perceived as being heavily outweighted by the disadvantages) was the possible positive impact it might have on the industry's public image, but even that was considered very uncertain.
Dere was, however, support for the concept of certification if indeed some process for record - g and -W.ng fm-nat professional credentials of senior managerial personnel were to be put in place. Certification was seen to differ from the licensing concept in that it would not be con-ceived as a privilege that could be granted or withheld at the yelitics of a legal ragulatory body; rather it would be viewed as evidence that the holdars had attained certain =4"4-s*mm mW.s of professional ability, a
skill and accomplish:nent that are considered necessary to effectively discharge the requizamar ts of their positions.
m ars were some respondents who rejected the notion of placing any additional regulatory requirements on senior management personnel beyond those already present is the periodic management reviews perfor:ned by NRC on a utility-wide basis. D ese individuals felt that the current process provides NRC with the necessary leverage fcr achieving the desired objectives of licensing.
nose who favored the certification approach offered the following reasons for their viewpoint:
screening would be improved for all utility management positions, thereby increasing the calibre of all key decision-making management personnel 3-3
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The certificatica requirements would serve to help define job.@ements and standards upon which man-power development, manpcwer p1=an4"g and training pro-grams could be based, thereby improving the calibre of future managars.
The certification process, if appropriately publicized, would help to promote greater public confidence regarding the safe operation of nuclear power facilities.
The supporters of certification were at pains to point out, however, that their support precuppcsed that a careful jcb analysis of the positions to be certified would be performed to define cri* aria and set both general and plant-specific requirements, and that' these would go beyond the ANSI /ANS 3.1 senadards currently under review, particularly in the area.of training.
Further, their support would also depend on the nature of the process and procedures that would be employed to impian=nt the prc 6.s.
v A minority of rescondants wno oppose both licensing and certification raised the following objections Sta basic goal of enhanced public health and safety would not be served in any way and could be jeopardized, as stated earlier.
Current NRC inspections of the utilities are adequata to control and regulata managers by auditing utility manage-ment as a whola without additional regulatory requi wents The <-n14hre of management personnel would not be improved in that the self-interest of utilities is currently directed toward identifying, training and selecting the best people available.
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There might be a tandancy on the one hand to set sinimum c=iteria to cover the diversity of the industry, which might fail to distinguish among different calibres of personnel and impede selection on the basis of merit s
by setting the sundards'that tend to be over-broad. On the other hand, there might be a tendancy to set very date.iled, j
idealistic or impractical requirements which few could meet, j
thereby discouraging or excluding otherwise qualified people.
j
'f It should be pointed out that even thosa persons oppo:jd to licensing o
i and/or car-4 #4 cation were nevertheless able to identify quite specific job l
l qualifications and perfomanes requirements that they considered either i
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essential or very desirable (discussed below under Issues 2 and 3). Weir central point was not that perscnnel qualifications and pesitica requirements were not c: cculd not be estab1inhed, but that there were alternatives
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available that could achieve the same goals without the need for further regulation, such as self-policing management t==4ning programs, or profes-sional certification by the indust =y itself.
3.1.2 Viewcoints from the NEC Inscaction and Enforcement Division me majority of those interviewed, while opposing legal licensing, did see a need for scae kind of certification process for the industry.
Car-tification was seen as a process wherein standards would be established for formal professional credentials to ensure that managers had met certain minimum standards of both education and emperisace.
mese respondents who favered certificatica over licensing cited the following reasons in s 4 port:
me certification precess wculd provide a means of screening individuals who enter into utility management to ensure that potential managers have the necessazy aH 1i=
and abilities.
Certification would provide a consistent approach to qualifying individuals in management positions by defining job requirements and standards.
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Certification would both improve the safetf of the utilities and improve the public's perceptica of their interest in safety in operating nuclear pewer stations.
A minority favored the licensing of utilities rather than individuals.
nese respondents believed that by using this approach the NRC would be able to exsreise a greater degree of control over utility management (which is also precisely why others strongly cppesed this approach). Under this concept, the utility would be licensed with a qua'i'ied management personnel
" team" as authorized users under the license.
i caly a small minority of NRC personnel expressed a posi:1ve attitude toward the concept of licensing of nuclear power utility managers (as a process similar to that used in acquiring an 530 license).
mose respon-dents who did favor licensing did so because they felt enat direct health l
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and safety benefits would result frca requiring personnel to be more effective
'and responsible and that licensing could prenote this. Licensing of indi-vidual managers was also perceived as a means of assuring the public of the qualifications of nuclear power utility management.
Finally, there were a few individuals who saw no need for either licensing or certification.
cbjections were based on the fo11cwing grounds:
There is an already existine review precess for utilities whereby NRC can det amine which utilities are performing up to standard and which are not.
Management is'too difficult to quantify. Technical skills may be necessary for' the team but not for'avery individual.
I1 censing / certification is too prescriptive, and would prevent utilities frca developing worJcable staffs.
Licensing /cer*4"4 cation could result in falso confidence in the efficacy of the process.
3.1.3 viewcoints from Professimal Cr-a4zations and Sccieties Professinnal association executives typically reject the notion of licensing by government in favor of self-=^4"4 =tered certification programs.
Cne or=a4 *= tion contacted, the American Institute of Cer*4 ** ed Public Accountants, does requLre certification by a state board of accountancy as a requirement for membership. Another, the National Society of Professional Engineers, ^^4"isters a certificaticn program for engineering teciusicians, although architects and engineers are presently licesed by state boards in all 50 states.
i No associatica executive contacted expressed a pcsitive attitude toward legal licensing of senior nuclear power plant managers, although
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several did not feel they had sufficient informatior. to legitimately comment on the idea. An executive with an association that =^4"*=ters an ac==editation pregram for its members felt perronally that licensing nuclear plant managers would probably Icwer standards by focusing solely I
on NRC's concern with technical safety as cpposed to covering a wide range
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of both technical and, managerial requirements. Sto interviewee supported 3-6
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this contention by cc= paring the :nanagement of U.S. airports to those in Canada where airports are owned and operated by govern:nent persennel. He claimed that U.S. airport management was far superior to c=a=dian :nanage-ment and that U.S. airport operating costs were much lower.
While association executives had no ccennent or were opposed to licensing of nuclear plant managers, the consensus favored scnu form of self-devwloped and self-=^4nistered certificat: ion program. Although thase interviewees did not k.new enough about nuclear plant management to specify the content of a certification program, most felt that :nanagement capacilities as opposed to technical kncwledge should ccustituta an impor-tant di:nension of the program. Hypothesized benefits frca a certification program included more efficient and safer plant operation tnrough enhanced
- nanagement, increased public assurance that plant managers are well Tsalified for the positions they hold, and an upgrading of u**1*tf management in general.
Several association and socioty representatives er;ressed st=eng opinicas in favor of professional "self-poHedag" (including voluntary, non-sandatorf accreditation or certificatien by the organi-= tion) as a means of i:nprov::.ng professine=' 4==, upgrading know1* ige and shills, and generally enhancing the profession's stature.
3.1.4 Vieweoints f cm Manacement Cavelcement__and Assessment Professionals Executives involved in persennel and organizational development generally held views s4=4'=" to those of persons from professional societies, albeit they exprassed stronger positicus on the negative consequences of licensing and the desirabilitf of self-a*4"4 =tered certification.
"he :nost common negative positica expressed by interviewees whose responsibilities presently include management training and development was that licensing would be an additional burden on the nuclear industry with no correspcnding benefits either to safety or real managerial ecmpetency.
Formal licensing by NEC, they felt, would inedably focus on narrow l
l 3-7
-l technical issues where plant managers were already qualified. The critical areas of concern are :nanagerial and interpersonal skills where plant
- nanagers, because of their technical backgrounds, are often deficient. Mere appropriate and beneficial to both the public and the utility, they felt, would be a cairtification process based on a tr=4 inny and development program for management personnel. Under this concept, the utility's managerent training program would be certified rather than the individual manager. This type of certification would recognize the value of management skills in plant operation and safety, the general lack of emphasis en such skills in the training of many plant managers, and the need for ongeing, long-term :nanage-ment development as opposed to a =4n4==1
==n= y ial base-line testing.
3.2 Issue #2: Miat ich-related technical :nanagerial requirements can and should be included-in the licensing / certification precess, and what senior licensee officers should be subiect to the erecess?
3.2.0 Background and General Comrunts no questions fr-="1=ted to address. this issue hypothesized that seme form of licensing / certification program wecid be set in pla e, although what form it might take and what its content might be were allowed to rammin undefined.
Respondents were asked to give their opinions on the managerial iand technical qualifications and accoup14 hat that they thcught shculd be demonstrated by :nanagers to hold senior management positicus. They were asked about the background experiences, trai ing and education that they considered were 4 4==
requirements, and those managerial attr:.butes managers should possess to be able to successfully discharge the respon-sibilities. of their position. They were also asked to identify those management levels or specific positions which they thcught should be subject to the licensing / certification process.
i In general, the res W aats were able to identify, quite specifically, what they thought the te^a4-=1 and managerial ~requi.wts should be: how-ever, they were less certain (and often skeptical) of whether, or how, those l
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.. _7 requirements could be assessed in any cbjective manner, with the exceptien of technical knowleden.
They were generally adamant that written tests or exa:sinations should be avoided as far as possible.
3.2.1 Viewooints frem the Nuclear Pcwer Industr/
Generally, it was thought that the plant =anager's role and those of cther senior officials, both above and below the plant manager, were more managerial than technied and that any licensing program should recognize this.
Most respondents referred to ANSI standards of experience, trai..ing and education when asked to recommend requirements, particularly those for plart managers. Most felt that, while the sn nd eds were generally acceptable, they were not sufficiently targeted on de individual pcsition requirements, par icularly in the area of training: mere detail was thought to be needed. There were varied orinicas on the degree requirements in ANSI /ANS 3.1, and many felt that scre flexibility was required to acccm-
=odate the exceptional person who did not meet the standards. Mest felt that the degree requirement waa probably unnecessary belcw the plant manager level. They also felt it likely that future managers would have a degreer i.e., that tne passage of time and the maturity of the industry would take cars of any degree requirements felt to be necessary.
.i Some respondents pointed cut that to dichotemize teMc5L1 and managerial skills and abilities was a false distinction in that managerial activity and decision-making ultimately intelved the technical nature of the plant, par-ticularly under high-stress situaticas (decisions regarding outages, for. example).
Technical skills, knowledge and abilities were thenght to become increas-ingly i:::portant as One moved dcyn the organisation from the plant managar.
Above the plant manager at the corporate level in the nuclear chain, maragement attributes became increasingly important as management activities mcved =cre tcward pinnn b g, resource develcpment and organisatien.
There was, however, some variation of opinien regarding the level of technical ability that positions above the plant manager required.
Cne Vice President of Nuclear Ceerations asserted that not only was he involved quite deeply in the technical subject matter of his suberdinates bu'c that he actually made important tech-1 nical decisions that required specific scientifi; and engineering knowledge.
,.._.-v---
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r This was an exception, but it underscores the differences between utilities in terms of the functional responsibilities and behavior of people in apparently similar positions.
one aspect of this issue is the question of the organization level at which " senior licensee officers" should be included in the licensing /
certification process. Respondants, however, in some cases extended their responses beyond senior management to the organizatica as a whole. Ths opinions are summarized on two levels:
(1) for senior managerin1 positions only and (2) for all positions, plant-wide, both managerial and technical.
If there was a trend at c11 in terms of managerial personnel,it leaned toward the opinion that the highest levul included should be the plant manager or that person on-site with the highest decision authority (1:i some cases the vice President for Nuclear Operations may be located at the plant sita rather
,than at headquarters). There was some opinice on the part of the corporate level managers that the process should reach as high as the senior vice President for Nuclear Operations, or whoever is the senior nuclear officer, particularly if the licensing program is a professional certification program with training implicaticas rather than a legal, regulator / raguire-ment. Very few of those interriewed at the plant level felt there was a need to extend the process to the corporata level.
Most felt that the top superviscr/. level (Superintendant of Cperations, Superintendent of Technical Services, etc.) was probably the lowest level at which managerial personnel should be certified, although there were some who extended this all the way down to first-line supervisers. There was also some feeling that not' aR supervisors at the top level need to be included, but that the focus should be on operations and maintenance mainly and possibly technical services.
q Again, it was pointed out that this would vary because of the differing organizational structures ancag the ueM ities and the different functional.wibilities assigned to positions.
When asked about non-management positicas, respondents felt that some form of certification was ap5.repriaca down at least to the engineer level, al tough obviously below line management positions such licenses would involve technical skilss and abilities almost exclusively.
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Below are the major points s"-=*ized in terms of the managerial knd technical requiremants:
Managerial Recuirements Plant managers, corporate managers and other line managers should have a minimme of several years' experience in the nuclear power industry, depending on the individual and the positions previously held.
(M4 4-=
estimates ranged from 1-2 years to as many as 4-5 years,largely depuding upon the amount of additional experience in fossil plants.)
Some'of the nuclear experience should be in the particular plant or utility in which the== nager will or does work.
There was some variation regarding how much experience in the electrical power industry in general (either fossil or nuclear) was necessary for the plant manager; the range was anywhere from a =4"N= of 5 to 15 years.
Many persons cited ANSI 3.1 s*=ndards as the appropriate criteria.
Vice presidents were seen to.@e longer periods of experience in the nuclear power indust =7, as all st=essed that nuclear operations differed greatly from those of fossil plants.
Plant managers and executives above them should have experience supervising large numbers of staff (more than 20 persons at least).
Mcbility through a number of key areas of clant operaticas was sann to he a necessary career route for plant managers, par-ticularly operations and maintenance (although one manager is a health physicist), since mobility provides a broad unders*mding of plant systems and the interrelatedness of the many functicnal units in the plant's orgtnizatica.
More than their fossil counterparts, nuclear plant managers should have a good knowledge of the government regulatory process and how plant operations relates to this procesa.
The need for experience and training in areas such ac public relations and labor relations varied from plant to plant, depending on the functional responsibilities of the positicas in questien as defined in the organization.
Scme respondents considered that labor relations experience and ability was essential wnile others saw it as a desirable attribute but not a critical one because such a function was assigned to others quite frequently..
j Virtually all interviewees expressed the opinien that management trai ing was an essential prerequisite for senior management personnel. Most fsit that such t=aining programs already existed in their organi=aH nns to acconnodate this need or were in Gvelopment.
This opinion was expressed in both large and smail i
I 3-11
utilities.
(All of the utilities visited in the course of this study have conunitted resources to management training prog.ams.
It should be pointed out that this study did not assess the management programs per se, and we cannot make any judgments regarding the quality of the different programs.
However, at least one utility hcs shown its serious recogni-tion of the importance of management t h.g by its ccm-mitment in terms of donars per year for this aspect.)
T!)e utilities felt that (a) they were already addressing the felt need for management tr=44 7, both general and industry /
utility-specifier (b) they are doing so in a variety of vays but not necessarily solely through a formal degree program; and (c) their programs of traf ning and education are *Mered to the industry's needs, which they feel is the most effective course of action.
Although a general opinion was not evident, it w'as suggested on several occasions that certification requirements should examine some plant-specific aspects of the jch. For exangle, managers should % strate a sound knowledge of the management systems at both the plant and corporate levels. The impli' cation of this (and one that was occasionally expressed) was that the possi-bility of certifying the managers on the specific plant (just as operators are) should be considered.
2 The background experience, training and education described above can be readily assessed through a records review in met instances or through techniques such as oral board interviews or peer reviews. However, mest felt that it would be difficult to define the behavioral at*dbutas of mandgers which contribute to successful managerial performance on the job, and to objectively measure them.
For example, au respondents stressed the impor-tance of humen-relaticas skins and team building. How to incorporate such an at-dbute in a ce=tification p:wgram is a difficult question to answer, and would require a more data.tled study.
Those management attributes considered essential to *J.e plant manager's job were An underse=nd47 of the management team approach and an ability to function as part of such a team Strong p1=nn4ag abilities t
Good public relations skins A commitment to, a knowledge of, and an ability in work-l force development, including :nanpower planning, human resource development, and related skills.
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Most interviewees felt that the Senior managers should have progressed on at leest a 5-10 year career path through the ranks. Major utilities with established nuclear programs maintained that this was a fait acecmpli v
and thus unnecessary for anyone to monitor or regulate in any way.
l Technical Recuirements I
Few respondents felt that indepth technical knowledge in specific scientific and engineering disciplines was a requirement of positicas at the plant unager level and above.
Rather, persons at these levels need to have demonstrated a solid understanding of the technical consequences of the systems in their plants, mus, a broad technical knowledge of the technology involved, cutting across the different functional areas they must manage, should he demonstrated. The main points of respondents' opinions were:
A formal academic degree. in science or engineering was generally censidered desirable. Ecwever, it was thought that the licensi:uy system should be flexible enough to accommodate the exception.
Thus some form of equivalency should be incorporated, but it should have very rigorous standards and not merely reflect, say, years on the job.
Although interviewees agreed that senior managers (exempting supervisors of cperations perhaps) should not be required to hold or have held an operater's license, a number of perscus felt that cey should have undergone the training programs leading to such licenses.
Such t=aining, it is felt, provides a goed understanAi g of what is involved in the operation of the plant, which was censidered essential.
Few felt that it was l
necessa=y to have had actual experience as an operator.
Several did say eat some shift management experience might be desirable, however.
Systems training, educatien and experience was considered highly desirable in the senior managers' bac~ grounds.
Specific in-depth traini ng in special areas such as fire protection was not thcught to be necessary, but managers should be able to danenet:ste an understandir af the rela *4an=h4ps of all aspects of plant operation to healt ad safety concerns, and the systems available to them in addre_
- them. Many persons stressed that a plant manager's responsibility is to set policies requiring such awareness all the way down the organiention and that he shculd actively monitor the organization to ensure that these policies were in effect.
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i 3.2.2 t7ieweoints frem the NRC _Inscection and Enforcement Division l
te views expressed by the majori:y of interviewees from the Nuclear Regulatory Commissien wer> surprisingly similar to the consensus positions frca persons in the nucimar power indust =y.
However, NRC staff placed more emphasis on the technical requirements of the positions. Utility managers emphasized i
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that their jobs were more heavily oriented toward management skills and abilities. Se exceptien to this ns the common opinica held by NRC and utility personnel interviewed that it was de11rable for managers to have cbtained SRO license trening at some time, which is largely techa4 r-=1 in nature. 3cch g cups felt that while the license need not be main *hd (should notl, the SRO traini g would be helpful to the plant manager.
A very small minorit/ of NRC staff felt that it should be a requi;*nent.
When NRC permannel were asked to cite those requirements that should be included in a licensing or cartification process for someone at the plant manager level, there was a clear consensus on the =cet important managerial and tech-nical skills. All respondents cited supervisory experience as a necessary requirement; however, the nusber of years of prior experience suggested varied fram 2 to as many as 10 years. Almost all respondents agreed that prior technical experience in the nuclear oower industry, plus experience in a variet/ cf positicas in the power industry, were also requi.wts that shculd he addressed in a licensing / certification. process. Conversely, previous exper-ience in the areas of public relations, govemmental relations, and negotia-tiens and labor rslations were viewed by the majorit/ of NRC interviewses as being desirable but not mandatory.
Regarding education and training, almost everycae agreed that a degree in engineering or in a 'hard" science was apcropriate, with tha stipulation j
that allowances had to be mada for those individuals who have the knowledge without the formal degree. Traini 7, partic.21arly in the area of crisis management, was viewed by all respondents as being desirable but difficult if not impossible to provida. Virtually all NRC personnel expressed the i
belief that plant managers should receive special training in a rarierf of sanagement disciplines, but few persons were willing to go ao far as to say that this shculd be a requirement. Many NRC staff expressed the belief that the kncwledges and skills that would be developed through special training would have had to have been r'=mmn=trated at lower levels of *.he 3-14 L.
organizatsen in order for a manager to have advanced. Ecwever, a vocal minority teck st==ng exceptien to this position.
Bere was sc=a reluctance on the part of many NRC personnel to address the specific managerial attributes and knowledge that plant managers and others should possess. Most were willing to agree that nuclear power plant managers probably did spend in the range of 60-80 percent of their time on managerial and =d=M *trative vis-a-vis technical matters. A number of these l
persens cbserved.
- hat-the distribution. of managers' ti=a was unlikely to previde guidance with respect to the criticality of their varioue technical and managerial respcasLSilities.
3.g.3 viev=eints fr:m Association Executives and Manacement Assessment a
Professicnais ne almest==1 versal opinion among association executives and management assessment professionals, both in and out of the nuclear indust =y, is that licensing - er their preferred cptien, voluntary certification -
should focus en maragerial skills. These @d'i= include interperscnal relations, decision-making, ce=="ndcations, resource management, team bnii M g, leadership, and a wide variety of others which are generic to management in almost any envircement.
htervd.swees frca these groups were not c=ncerned abcut technical skills which they tended 'a consider of secend.ary i=cortance.
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People interviewed fr m cutside the nuclear utilit-f industry were not familiar with nuclear plant organ M tional structures and functional respen-sibilities and had no opinion on who should he included in a licensing program.
Since they were opposed to licensing, utility training and persennel executives involved with management development also would not j
express an opinion about who should be licensed. When the focus of discussion changed frca licensing to certification, several of these executives felt that a management development program should be applied to all levels of utility management, from the plant level to the corporate level.
The exact conduct of a management training and development program established to meet certification.@ements wculd depend on three fasters:
he overall cr:anina ional and functional structure of the utility, position requirements and career paths, and the u nagerial strengths and weaknesses 3-15
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of each manager. As described by one utility tr*ining directer, the l
organizational structure and each managerial position should be analyzed l
to identify managerial skills requirements, and managers should he assessed based on those. M u nts. Where areas of weakness were identified, a specific training and development progrra would be established and carried l
out. Managers wculd be reassessed en a regular basis *a track the progress of the developmet.t program and to revise the pr%.m as needed. Certifica-tien of the mancgement development program would involve an outside review i
(by INPO, NRC, or an assessment professional) of (1) the organization and position analysis, (2) the management assessment program, (3) the manage-ment and its i=plementation training pr%s.m, and (4) the system of management reassessment and training program igrovement.
'!he certifica-tion process would be designed to ensure that the management development program was in place and regularly and systematically applied and updated.
It was pointed out by several assessment professicnals (practitioners and users) that the managerial requirements of nuclear plant managers and other superviscr7 positions could be systematically identified and defined using existing task analysis and assessment' techniques, and dat managers could be tested and judged based on those requ1_ w ts.
The general feeling, hcwever, was that the specification of requirements and the assessment of managers was more app. y. late in the context of training and development rather than a single " pass-fail" decision. From this perspective, managerial 1
certification is seen as a process rather than an event and certification is program-related rather than manager-specific.* The objective would not be to ensure that plant =anagers meet *4 4==t.m zirements, since this is ciready done through the scrmal selection process, but that plant managers were i= proving their managerial car. abilities. This is a movement beyond the
"=inimum requirements" approach to a more developmental concept.
- Cur impression is that anny of the NPP managers and NRC staff who were inter-l viewed would ccacur fully with this view. In retrosoect, it is now clear that a cumber of persons " grappled" with this concept but were unable to ar:Le late ic.
a e
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3.3 Issue 43: What is the mest practical a.:id valid process hv which the manacerial and technical recuirements of senior manacement posit.icas cculd be assessed? Are there preven manacerial assessment technicues (such as the assessment center acpreach) that could be used in tne licensine/cartificatien procacc7 3.3.0 Backcround and General comments Cne of the difficulties encountered in addressing dis question was the tendency for respondents to think in terms of licensing / certification as de granting of a piece of paper - a " ticket" - en the basis of a written test, that is, as a result of a process similar to that employed in SRO licensing.
It was frequently necessary to pull respondents back to the broader alternatives trem the more narrow dsfinitien i= plied by the written testing procedure.
- is was done when it appeared to the interviewer that the respondent was indeed respending en the basis of a procedure that was ecaceived as being s4"4 7 ar o SRC licensing. Nevertheless, it is not clear to what extent this tendency en the part of interviewees may have confounded responses in terms of de intent of the questions.
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- 3. 3.1 71ewecin s from the Nuclear Pcwer Industrf o
g.
Mcst respondents indicated that their epinions en how the licensing pr gram should be implemented and the precedures mest appr=priate to assess
=anagerial qualifications.and competencies would depend on the content of the program and the cri aria that were established. Nevertheless, the respondents were quite firm en a number of points about the procedures that should ng be used, and there was consensus on the general approach dat shculd be empicyed.
"he major points were:
i
- dritten tests of technical or managerial knowledge should be avoided.
Such tests were considered to be usually unrelated to effective job performance.
Current NBC magement assessment precedures applied through the management review preesss were already adequate to identify management problems.
Perhaps some greater spe::ificity or targeting of the evaluations to specific positions could be ac:. mplished, but by and large it was felt that the appropriate mechanism is already in place.
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An overwhelming :najority of respondents considered that the :nost l
i practical and relevant approach to licensing or certifying :nanage-
- nent personnel would be through a process involving one or several of the folicwing: oral heard interviews, record and background reviews, testimnny of significant past supervisors and peers, peer review panels comprised of other persons in the same positions, and/or some plant-specific simulation exercises that would avamina knowledge of the particular plant operations and utility organi=ation.
i C'extificatica should take place on entry to a position and should not necessarily be repeated, although a requirement for periodic l
" refresher" training eculd he included. Any precess that required the :nanagers to be taken away or distracted frem their duties at the plat for inordinate periods of time was to be avoided at all ecsts. Managers arm already extremely burdened it was felt, and the pay-off for such distractions was li'<aly l
to be marginal in terms of ani an< ed public health and saferf.
I t
With respect to the first point above, :nost individuals rejected testing
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(including use of assess:nent centers) because they are convinced that is is in-(
possible to cbjectively ":neasure" or assess managers in any field, much less thei c cwn, through testing, and they are highly skeptical about any c1=4mm to the contrary, i
3.3.2 viewcoints frem the NRC Inseection and Enforcament Divisien i
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There was greater diversity in the views of the NRC personnel who were interviewed than in de industry groups,. and a clear consensus did not eme.ge on any key points.
?cr example, although NRC staff were generally as skeptical as industrf ahcut the value, effectiveness and validitf of unagerial assessment, a larger proportion were wi111ng to suspend their disbelief and "assu:na that valid techniques could be developed." Despite l
dis caveat, however, a substantial :tajority of the interviewees were still cpposed to written exami.utions.
l Those individuals who thcught that written avaminations would be a valid part of the licensing / car-d '4 cation process tended to focus this :nethod 1
of testing on specific knowledge of nuclear engineering principles and technical i
systems and in-depth knowledge of plant-specific technical specifications. This group tended to see licensing in ter:ns od tetnical rather than =anagerial skills, even though they agreed that at the senior :nanage:nent pcsitions the emphasis of the job was heavi?y en :nanagerial rather than technical activities r.nd responsibilities.
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t Many NRC interviewess advocated a process involving a ccucinaticn of' o
cral testing by an established review board and procedures to ensure that certain nisiv.cn educatica and experience standards are : net.
It shculd be noted, however, that every persen interviewed favored the notics of equivalency.
Aldough establishing s*=ndards was felt to be desirable, inest felt that rigid standards would he unfair to at least a minority of perscas who, although perhaps not :neeting the standards, were nevertheless fully qualified to =anage nuclear power staticus.
One idea dat was suggested in one of the regions was the establishment of a federally-funded nuclear safety school. The schcol wculd cencentrate on non-technical areas such as nuclear regulations and progra:ns, which are fccused en the :nanagerial roles of utility :nanagers. pericdic attendance wculd be required by plant : managers and others, with no certification or licensing involved.
Mixed opinions were expressed on de questica of whether the cu=ent NRC manage:nent review process (as it scw exists or strengdened in some way) is an adequate alternative to licensing or certification of :nana,gers. Sc:na felt that -de two precesses (the present review process and a licensing er certificatics pregram) shculd be M 4-=d.
i 3.3.3 viewecints ' rem Asscciatien 7.xecutives and Scciaties All cf the professienal associations contacted employ a ceabination of pr=cedures to assess requirements fer certification.
Typically, these includa scme ecmbinatica of educatien, experience and demcastrated abilit/ to j
carry cut the respcasibilities of the profession.
In the case of the Institu.e fer Management Censultants, certificatica requires a college degree, 5 years of direct experience, attendance at a 3-day training program, the sulmissica of written essays describing several specific censulting techniqces and their applicatica, and an oral av=mfnation by a panel of three senior cenaulting practitioners.
The American Associatien of Airport F.xecutives has a s md tar set of procedures which include sulmissica of a d
lengthy desis as well as oral and written e---4-=tions, and which % es 3 years of direct experience in airport :nanagement.
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All of the assceiation and assessment interviewees agreed that licensing /
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certification re@ments for plant managers should focus on managerial skins and consequently could not be " measured" or satisfied simply by demon-i strating some concination of education and experience since these factors are unsatisfactory predictors of managerial perfm nmer-e.
Rather, as with the association programs, they felt that other measures of managerial competence should be applied.
l 3.3.4 viewcolsts from Manacement Ceveloement and Assessment Professier=1=
In addition to the procedures more cczm:culy used (and listed' above under 3.3.3) such as oral and written tests and/or presentations, etc., a growing number of businesses and organizations. have turned to the assessment center techniquw l
as a method of =anagement assessment. As described by the president of the largest assessment center in the U.S., the assessment center technique involves a five-step process:
I A systematic analysis of the tasks (.6maments) of a position or set of positions The org=nhation of these tasks into ccamen categories caned dimensicas (a fem of behavioral factor analysis)
The identification of the skins necessary to carry out these tasks The develcyment of s1=ulations where these skins are called for The assessment of how managers (or managerial candidates) i' perform in these simulations.
The assessment center technique places managers in a series of simulations, each designed to tap specific skins required by a management position.
The manager's performance in these simulations is viewed and evaluated by a panel of assessors specifically trained to weigh skin and performance levels.
As verified by a review of management science literature, the assessment l
l center technique has gained wide acceptance during the past 13 years.
First e
developed at American Telephone and Telegraph Company, the assessment cantar technique is currently uM 14 =d by a large number of the " Fortune 500" companies in the U.S., as well as major companies and orgarizations world-wide.
s A review of the literature reveals two key reasons for the increasing
)
use of the assessment center technique for placement, premetion and diagnosis of persennel in business and indust:f. Cne reason is that the assessment center technique seems to provide a more chjective and reliable measure cf management ability than the more traditional assessment techniques such as paper 'asts and interviews. Byham *sas compared traditional selection precesses a=d the assessment center and found a higher degree of consistency among the assessor ratings from among test scores or the results of multiple interviews.
In a more statistically based analysis, Morse and Wagner found significantly higher correlations between assessment cantar =easures than becween respenses to paper *asts.
In Eddition to this issue of reliabilief, a review of nwgement science litsrature also reveals a strong belief in the practical validir/ of the assessment center technique.
Such v= W 4:7, hcwever, is less substantiat'ed and is based primarily on tas1d dmi* on hcw well it works by busiress executives who use the assessment cantar technique.
Indeed, no rigercus methodological study was f'ound that clearly demonstrated that the assess-
=ent center tahique actually predicts better managers.
In essence, the technique has gained widespread acceptance =ecause (a) it pr=vidas an internally censistent =sthod o* evaluating managers and (b) many practitioners, users, and others believe that' it wczks. A selected bibliography of literature en =anagement assessment and the assessment center appr:ach upcn which these c=nc1:siens are b'ased in presented in Appendix A to this report.
.IWilliam Byham, " Helping Managers Find the Besc Candidate for the ;oh with Assessmenc Canza: Techniques," T:sining, Vol.16, No. 11, Nov. 1979 2;chn Morse and Francis Wagner " Measuring the Process of Managerial E!!ac-i tiveness," Academy of Management: :ournal, Vol. 21, No.1a 1975 3Richa:d X:sincsici and William strickland, "Arsessmenc Centers - Valid cr Mersly ?:escient?", Perscnnel Psychology, Vol. 30, 50. 3r Auc'.:mn 1977.
3-21
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A number of nuclear and non-nuclear u*d 14 ties currently use the assessment.
center technique for pime===nt and career development of entr/ and mid-level personnel. Assessment practitioners and assessment professionals ameng the utilities contacted were unable, however, to identify any utility currently using the assessment center technique as the basis for f*114 g plant and
'other senior manager positions; but all agreed thts the assessment center technique could be used for licensing / certification at this level. This technique was viewed by all interviewees as far superior to written tests or even licensing / car *4 "4 catica based on some education-experience formula.
l If the assessment-center concept were adapted for use in licensing /
certification, and the five-step precedure described earlier wer a followed, plant manager and other supervisory positions would be systematically
{
- analyzed to de*=~4"= managerial components and corresponding skill requirements; management candidates would then be assessed through use of multiple simula-tiens viewed by multiple assessors. Licensing would be based on a satis-factory rating by the assessors on all of the skill Ad== ions. Assurance that licensing.Wes had been met could be achieved by usi' g NRC n
personnel as assessors, through use of NBC approved assessment professionals as assessors (semewhat like third-party inspectors) or through NEC review of assessment center records including, as one practitioner pointed out, videotapes of the simulations and assessment proceedings.
3.4 Issue 44:
If a licensine/ certification erocram is to be set in place, who shcuid be rescensible for the design and administration of the l
erh am, and if croups ofher than NBC ars involved, what wculd be both their and N3C's roles in' the crocram?
l 3.4.0 Backereund and General Comments Interviewees were offered a number of choices as to who shculd ad=d"4 eter a licensing / certification pr% m. mese included:
ne NRC A special accrediting agency set up for the purpose i
A universitf A private group or concern Indust:/ t!u ough, for example, INPO A professional society.
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s As discussed belew, se'nral interviewees offered other suggestions, i
such as tne utilities themselves (with or without audit /menitoring by NRC and/or DGO).
l l
3.4.1 viewecists frem the Nuclear Power Indust:V i
Most respondents felt that the indus:ry or its representative organin-tions should conduct and =d=4"4 *ter a licensi.g or certification program if l
such a program were to be set in place. DGO was the overwhelming choice of nuclear pcwe plant managers and others as the ora =a4'= tion dat was probably most appre:priate. Approximately two-thirds of the interviewees selected l
DiPO as their first choice, but there was a strong, vocal minority thst was cpposed to DGO. Also, much of the support for DGO cars be +=-=mized es lukewarm at best; a number of psrscus felt that DGO was simply the least cbjectionable among the possibilities because it was an indust:f organizatien.
Cypesitica to DIPO involved two principal concerns.
First, many people (including many who favored DGO's leadership in licensing) felt that it lacked the internal capabilities for developing such a program. Second, some individuals felt dat such a role could compromise DTPO in meeting de goals and cbjec.ives that have been established for it.
Conversely, however, several persens felt that the selection of CIPO would enhance its image and strengden its role as both a spckesman and ser' ant of the industr1 They felt dat ce nuclear pcwer industry needs a strong self.% tang pre-fessional crganization and that this would strengthen DGO's role in this
- regard, i
A few persens roccinnended that the utilities themselves aMnister I
the program, several suggested NRC,and about an equal number favored some organizaticn (undefined) other than those on the list. On the other hand, i
there was streng opposition to NRC in this role by well over half the industry pecple interviewed.
l 3-23
s Cppositio 3 NRC was basically on two grounds: philosophical opposi-i lr tien to an increase in the scope of NRC's responsibilities and the belief that NRC lacks the resources to properly ar8 minister such a program, even if it l
were developed by a qualified cutside group or oca4'= tion.
I me *4nA4ngs outlined above must be viewed in the context of the indust =y's general opposition to licensing er certification. As discussed previcusly, most industry managers and executives would prefer to see guidelines caly.
3.4.2 viewocists frem the NRC Inspecticn and Enforcement Divisien I
A clear majority of the NRC personnel who were interviewed ctrongly opposed NRC =^4"4 =tration of a licensing program other than pc: haps in i
a monitoring and audit role. Most of this group felt that such a role should not have a legal or regulatory basis. The n'inority that i.'avored NRC administration tended to believe that such a program should be operated through NRC's regional offices rather than from headquar.ars.
l Cppcsi**m to NRC's =^4"4stration of the program invariably involved several of the follcwing concerns:
1 Belief that NRC lacks the resomcas to develop and properly =d-'4"4 *ter such a program PM N acphical cypositica to f mther expansion of NRC's regulatory =cle, particularly en the manarJement side of the uH '4 ty business Se feeling that NRC's participation would place an imprimatur en the program that was not warranted: that is, the belief that NRC's administratica could place it in an untenable positica in the futura in the event of utility " problems" due to mis-management.
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m, Se view that the industrf, itself (e.g.
through DGO) was best qualified to under ake development and administration of such a program.
Scme felt that this would help to "professienali=e" the industrf.
- t should be emphasized that most of those cyposed to a formal role for NRC in this process had also been cpposed to licensing and, for the most part, to certification as well. Mest of these persons also expressed their opposi-tion to NRC's =M"4_stration of the program rather forcefully.
- However, there was far less confidence and conviction when attention turned to who then should e N adster de p. g m.
Nevertheless, a clear majority cited CIPO as the crg=a4'= tion that should be responsible.
Some made this recom-
- rrndation because they felt that DTPC has (a) the respect and support of the industrf, (b) a good " handle" on the problems faced by the industry, and/or (c) the management and t e ndc=1 skills to administer the program. Others disagrsed with these views but felt that assigning the program to OTPC would help to raise its stature, and dat the necessarf technical resources re uired to develcp and run -de p m.
could he acquired.
t Se minoritf view that NRC should =M"4 ster such a program was based en the fc11cwing rationale:
i I
NRC is the regulator / bcdy for the nuclear power industry and, therefore, = M 4 stration of such a program is a ' ~
- ssponsibilit/ that it cannot ignore.
l Sere is far mere knowledge about the nuclear power indust:f l
(both industrf-wide and plant-specific) resident in the NRC than in any other organization, which makes it the loc ical choice to develop and administer such a program.
Only NRC has the " muscle" (i.e., the necessarf legal /regulaterf authe__d rf) to ensure that such a program would work.
3.4.3 viewcoints from Association Executives and Management Assessment Professionals l
None of the associations exec 2tives interviewed felt that NRC was the proper bcdy to administer a licensing program for plant managers, and all spcke in favor of a certification program administered either by an indust,-
associatiet or by the utilities thec.selves. Although several respondents l
3-25
felt NRC should provide guidance and review of the requirements and procedures of a certification program, they differentiated this from NEC control and i
a '4"#'t Stion.
n The view against licensing by NRC came from the following perspectives:
General philosoph.l. cal bias against government licensing Belief that NRC does not have the apprcpriate perscnnel and resources to conduct a management (as opposed to technical) licensing pregram i
Belief that the assessment center technique should constitute a major component of a licensing p. w and that tM.s "achnique should be developed and applied on a utility-specific basis.
Although there was general agreement regarding the need for input from NRC into specification of requi.wts and review /audiu of application of l
licensing precess, there was not a consensus on who should ad=4"4 stor the pr= gram, i.e., each utility or & u*"
- ty association. In pu tic..lar, the question had little relevance for assessment center practitioners who felt that either CTPC (or scme other orgarrizatien) or the utilities *hamaelves c=uld administer the program.
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i 4.0
SUMMARY
AND RECOMMENDATIONS i
2.e answers to the four basic questions presented in the introducticn to this report are now considered in terms of our "best judg=ent" regarding the censensus of the resperses to the survey.
The first questien was concerned with evaluating the potential value of a lic=a=4ng/ certification program. The ene clear-cut opinion amcng nuclear 1:dustry manat=- s, NItc staff, and :nanagement develegment and training sped =14e= in and out of the nuclear industry was that atC should not license, in a legal sense, nuclear plant managers. It was the consensus that fer:nal licensing by NitC would inevitably focus en narrow technical i=="==, r1adne a =4-=hle burden on the nuclear inch:stry without effering ecx::pensating benefits either in safety imprevement or real
- ana?=Hal cangetanc1
. Houever, many i=terviewees did idar+4 *y a need for setting scme mini:mm standards of managerial educaticn, training, and exW.ence, with-vasis en de mindng and experience requirements. Such s-h ds, if pecperly develoged, were felt to effer positive value in achieving the goal i
of assuring de efficient, safe, and effective operaticn of nuclear pcwer Plants. Most people interviewed felt that these standards could be a m14=d through sema sort cf "certificatien" program, t.5x: ugh the exact nature of the certification program was not wellu = fin =d.
We cencur with these opinions. We do not feel that a for:nal " single-event" licensing pru.:ess similar to that used for wd.ac1 roan operators would be effective. However, based en specific interview ccanents and i
opinions for:ned during the course of this study, we do agree that sane for:n of certificaticn would help to ws.de u*d14ty management quali*ication and establish sane level of consistancy throughcut the industrf.
It is our epinian that the certification process should focca m the management 4-1
. = -. -.;.. :. ;.-
_... a
- -=4"ing program rather than en the individual manager. Bis type of cer*4#4 cation wculd recognize the value of management skills in plant operations and safety and the need for engoing, long-term manage-m developnent as opposed to =4n4==1 managar4=1 base-line testing.
S e second gn==*icn was concorred with 4 dan *4+ying the job-related l
technical and :nanagerial requirements needed to serve as a basis for any elpe of review process. In general, the rg---A=iti were able to identify, i
i quite specifically, what they tbcught were the technical and :anagerial requir e s for their own positicas. Ecwever, they were quick 64 point l_
cut that the requirements abould probably differ frcm one position to another and frcan ene utility to another. Berefore, it was felt that the l
requirements should probably be tased on sit... A c job / task analysis.
l 21s wculd ensure that the educatien, ezpariance, and tr=4_ning requirements a*=1'y fit the needs of each individual job and each utilief.
l l
Cur experience in visiting scme of the utilities would lead us to 1
agree with these statanants. Utilit/ or=n4= tienal structures differed, l
and even at different plan *? within a utilief the job +2r=&=ristics were not ala ys the same. Sus a cer*4#4 cation program relying en si* w 4"4_c job /tasx analysis would tend to encourage staadardizarien while pecnitting inh ar.3 individual u*d'ities the flexibilief reamary to deal with
/
site-specific variations.
De third question was ccomenad with how the managerial and technical attributes could be aanmaand. Most r=- -- LM indicated that their,
l cpinions en this issue would 9 -2 on the content of the program and the criteria es*=hl*=hai.
Nevertheless, the res;-#--OtE were quite fi=n cn a number of points that need to be assessed. Rese were dier msed in the body of the report.
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Despite mny differir.g ideas on specific details, there was consensus i
on the general approach that should be empicyed. S e interviewees felt that written tests of technical or :nanagerial knowledge should be avoided.
Such tests were censidered to be &=11y unrelated to effective job perfor: nance. An overwh=1=+=J :najority of rg-x-%ts felt that the : nest practical approach to aaa===4*g abilities would be through a process which imrolved an oral interview with a peer review board (cmprised of other persons with recent or current experience in the same position) and/or sane I
plant-specific exercises that wculd examine knowledge of plant operatiens and utiliti cesan4= tion. 2ose interviewees familiar with amasament center technicues felt that such t W 4Tc.es could be very useful as part of j
the exercises to evaluate abilities.
Cne of the points raised by al:nost ov gm was that their job was pri:sarily ::anagerial is nature.
- Info $: nation collected during our literature review of :nanagernent assessment tW4ry.es has clearly shown that written examinatiens are not the bes: :neans of :neasuring :nanagenent abilities, although they might be used to assess sane teeMiM kncwledge.
Ecwever, if the exan:s were perfer:ned outside of the utility, :nanagers would prcbably associate these tests with operator examc, which they do not think adequately :anasure abilities. 21s could result in significant oppositien to x.ch testing. Bus we would again agree with the interview es that formal written testing chould be avoided whenever possible.
2 e fourth gna
- ion was concerned with identiff ng who should be i
re+- 24 hie for the design and akiniatration cf any type of :nanagement review. Most rg-y un felt that if any program were to be set in place, l
the individual utility or representative utility or W rions should conduct and ^^4"4 *er it. It was felt that the industry itself was best
~
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-7 7_____
qim144'ied to mdertaku devah -- m and adminieraticn of such a program.
I In acMiticn, it was felt that IRC's endorsement cf a self-goU.cing policy could promote a feeling of professionaHm in the iriustry which could do mere teward WJ.ing ' :cwledge and skills taan could government s
regulaticn.
There was some agreement regarding the need for intx:t frein IRC since
)RC is the regulating bcdy. However, it was felt that BRC's regulatcry i
role was to assure the develegnant cf management skills raca==ary fe:: safe plant ogentien but not to define hcw they should be develegd.
Wbile rescensibility for the safe operatiota of nuclear power plants rests with the nuclear ihf, and while it is clearly in the interest of utilities to recruit and retain higWty manag= ret persennel, the level of attenticn, structures and pecendures, and rescurces that utilities have ccma:itted to management developent varies widely acress the nucinar irxiustry. It is mn=4*=t with !ac's regulatory role and responsibilities, therefers, for the IRC to develop miA=14n.es for: nuclear plant management that w4'1 both previde a framewcek fce indust:f practices related to manamiPhilities and also provide the NRC with a basis for evaluating these practices in terms of public health and safetI.
If at all possible, rather than develop a new regulatory pregram IRC would be well advised to explore the capacity of tPs existing crganizatica and management assessmere. Erocedures (e.g. IUREG-0731) to 2 m --hte procedures for monitoring the management capbilities of plant managers and~
cthers. Such an approach is likely to be favorably received by the ira L.f.
It is cur opinicn that NRC ahm1 A explore the possibility of i
inco# rating guid=H-for management develegant in the overall framewcek established by }UREG-0731.
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The stamaries of t:ho responses to the four questiens have to sane extent, defined a pessible certificatica progran, which cculd be cutlimd as fo11cw:
- NRC would defim, posadhly through !EREG-0731, guidal 4 les for the 4
industry (1:x!ividual utilities and/cr a representadive cesan4* ton) to eshh14e its own trogram(s) fcr develegnent of necessary management skills.
- Industry would perfccm job / task analysis of positions to identiff skill needs.
- Ld:stry would then see that Irograns are develcred to assure that the necessary educatien, training, and experience is m 11ad.
i
- I:x! cst:f wca.11d devels sera type of review process to see that the needsi are being met.
- !aC w:cid examine de overall industry prcgran to assure that NRC guidelihes are being followed.
Chvicusly there are many pssible variations for each step cutlined.
Ecwever, it was the opinicr1 of the majoritf interviewed, as well as our cwn, that no action should be taken if NRC is not receptive to a program alcng these general lines. A majority of the utilities interviewed have 7
already reccgnired the need for 1,0M maragement training and have developed er are in de process of developing good management training programs. Mcat interviewees felt that any program which had a higher level cf involvement by NRC than outlined above would likely have a negative impact on the programs now in existence.
4-5
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-=
2.
If, en the other band, NRC wculd like to purme a progra alcag the lines o*1%ad above, the 1::plicatiens for future efforts by NRC (not in any particular ceder) are:
Develop guideliras:
Develcp 9'id=14ms for collection of job-audit data in the industry
- Review other certification pecw ams for applicability j
- Develop apae4*4caticas which might be included in the program (critaria).
Identify and review av4+4ng NRC guidelines and practices related to anagement qm141'icatiens and caph414 ties (as cc*a4nad in EREM731 and elsawhere) fcr c:mq:ntability with a car'"4 cation prcgram.
i Survey industry progras related to: unagment j
requirements,=====ar=st of managment carb414 ties, j
training and managment deveh
---m-, and evaluation of 1
management perfer:: lance.
Survey manam i a===aamant, devel w i, and evaluatica practices *4'4 ed by other cr-Ations as well as state-of-the-art techniqces available co managst specialists.
Prepare draft certification program 92id=1 4== based on
[
job requir d ts.
Develop and test a draft format for the NRC review process which assures reliability threwL a:nsistent, standardized m thods and irstruments.
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i If IEREG-0731 were chcsen as the mechanism fee i=pleenting the process, 1
t:wo other efferts which would be needed are:
'
- Prepare draft ?lida'ims covering maragenent certificaticn for inclusion in NCREG-0731, and evaluate consistency of anagment ?!id=14nes with Fid=14n== for utility cesanistiens and structures.
- Prepare firal 9tidalims for utility maragment to be incorporated into final versicm of N:5ElG-0731.
It sbculd.be noted that the eventual bar.efits of any program will to a great exte.*:t depend en how well the program is developed in its initial stages. Acf certificatien program put in place should be a mechanism for fermally reWag the professional skills, abilities, knowledge, and experience that g='i'I anage_m to perfers their duties in a safe and efficient mrmer. It should be an integral art cf the entire human E
rescurces develcpment program, i.e., recruitment, selecticn, traird.ng, and perfer=ance apprai==1 Scch a program =hm'd be based en a ecmprehensive
'l jcb analysic, and the plant-specific and generic ccmpetents of the industry-wide certificaticn program wculd depend in part en that analysis.
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APPENDIX A SECCTTD BIBLICG7APHY e
t l
p l
n
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APPENDIX A SEIZva B::3LICG*/APTl i
Alavander, Lar:7 "An Exploratory Study of the Utilization of Assessment Canter Results," 3-=A==y of Management Journal, Vol. 22 No. 1 (1979).
Allen, Peter and Stephen Rosenberg.
"Foz:nulating viable Cbjectives for Manager Perfer: nance Appraisal," Personnel Journal, Vol. 57:
No. 11 (1978).
"Getting a Managerial Perfamnt-* Appraisal System Underway -
the New York City Experience," Public Administratica Review, No. 4 (1980).
Bennett, D. and M. I.a;:gford.
"Ecw to Measure Managers," Manacement Teday (1979).
~
Scwonder, 3.
"S e Research Manager and His Roles," Society of Resear=h Ad= W =crators, Vol. 12:
No. 1 (1980).
' Byham, William.
" Helping Managers Find the Best Candidate for the Job with Assessment Center Techniques," Training, Vol. 16:
No. 11 (1979).
Child, Jchn.
" Factors Associated with Managerial Ratings of Supervisor /
Perfc =ance," Jcurnal of Manacement Ste. dies, Vcl.17:
No. 3 (1980).
Civil Sezrice Ccamission.
" Federal Executive Guidelines and noir Impacts on Assessment Canter Methods."
Clark, S omas and Joseph Hedstrem.
"Hcw to Evaluate I.E's," Indus-d al Engineering, Vol. 9:
No. 12 (1977).
{
- emski, Joel.
"Uncarcainty and Evaluation Based on Controlled Perfor: nance,"
Jcur.al of Acccunting Research, Vol.14:
No. 2 (1970).
Cuvall, Scmas and Evan Becker.
" Housing Management Acc=editation: A Plan of Action," Journal of Housing, Vol. 31: No.11 (1978).
I A-3
~
~
Frits, Roger.
" Rate Yourself As A Manager," Association Manacement, Vol. 32:
No. 8 (1980).
Geisel, Jerry.
"Cartify Risk Managers: No Way Say the Pros," Business Insurance, Vol.11:
No. 8 (1977).
Goodman, Claire.
"Idantifying Managerial Potential: An Alternative to Assessment Centers," Personnel, Vol. 57:
No. 3 (1980).
Hays, Janet.
"A Model of the Successful Manager," American Manacement Associatien (1979).
Howard, Ann.
"An Assessment of Assessment Canters," Academy of.unacement Journal, Vol. 3 (1979).
Kerrner, Ea:cid.
" Evaluation Techniques in Project Management," Journal of Svstems Manacement (1980).
Klimosici, Richard and ' William Std ekland. Assessment Canters - Valid or Merely Prescient," Personnel Pcveholocy, vol. 30:
No. 3 (1977).
Knart, Allen.
"New F:entiers for Assessment Centars," Personnel, Vol. 53:
No. 4 (1976).
Morris, Terry and Laura Ilcisin.
""he Assessment Cantar: A New Way to Test Management Capability," Bank Administration, Vol. 56:
No. 6 (1980).
Morse, John and Francis Wagner.
" Measuring the Process of Managerial Effectiveness," >=,8=w of Manacement Journal, Vol. 21:
No. 1 (1978).
Newland, Chester.
"Perf=r: nance Appraisal of Public Admi.dstrators:
According to *dhat Criteria?" Puolic Personnel Manacement (1979).
i Nickols, Fred. "Findi: q the Bottom-Line Payoff for Training," Training and Develocuent Jour g, No. 54 (1979).
CSHA.
" Development of a Cargification Process for Construction Supervisors."
f A-4
cP e
Reeser, Clayton.
" Executive Performance Appraisal - A View From the Top,"
Personnel (1975).
Shalcnan, Richard and Ray Rcherts, "An Evaluation of Management Effectiveness,"
Universiw of Michican Business Review, vol. 29: No.1 (1977).
Steers, Richard.
"When Is An Organization Effective?" Creanizatien Dva.amics, Vol. 5 No. 2 (1976).
7111areud, Morey.
"I:nproving Managerial Perfczmance," Personnel Journal, vol. 56:
No. 2 (1977).
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O 3-9
i Merican Asseeistien cf Air ert I:tecutives (.tAuf Cculd you please provide me with an ev'e: view of de AAAZ's testing j
and certification p:cgram.
SPEC *?!C C T *CNS 1.
Is accreditation sandatory for the managers of airpcets maged by the Federal government.
.l 2.
Is any effort being made with the Feds (e.g., the FAA) to make ac=reditation a ccndition for being an.ai. port manager?
A-major airpcet manager?
3.
Is there one exam er several versions?
When and how is it updated? To what extent is the. exam the same f:cm one year tc the next? If quite similar, dcasn't that give the repeater an advantage?
i 4.
Ecw are test questiens develcped (what's de peccess)?
What criteria are used?
Ecw are they validated?. Are the examinert given de answers?
In what form are day, particu-larly for de essay questions?
i 5.
Are principals - and more important - practices and proclams
- eated in the examinatien? If so, how are they handled (i.e.,
via essays, shert-answers, multiple chcica)? And/cr are day handled in the cral interview? How?
6.
cces the test (or the interview) go beycnd knowledges?
That is, do you attempt te address behavic:11 traits?
If so, how?
If =ct, why =ct and do you think that it wculd (a) ce desirable te do so and (h) feasible?
l 3-10 1
1 l
1 SMC.MANAGEMEN"7tCHNOLOGY
~ -. -
7.
T.nsuring that a tes: is cbjectively-designed and " fair" is always a pechlem, and de difficul:tes are even greater with interviews.
Scw have these problems been addressed?
8.
If one were to attempt to " validate
- the tests (in de sense-that a psychelegist would use), i: wculd be necessary em demonstrate in some way thsti the test questiens represented both all and only the most important aspects of :erfermance en the job.
First, would you say that the AAAE's tes: dcas this and, socced, how*would ycu descastrate it?
9.
The average nucle.ar pcwer plant empicys quite a number of persons in a number of didfarent areas including both licensed and unlicensed. Reacent ccm cperators are of course licensed; unlicensed persennel include engineers, technical support and maintenance persennel, technicians and QC inspectors, and others. Core is also a plant manager who runs everything en a day-to-day basis.
He also functions as an " emergency" direc-ter.
In other words, he is the * " bess" including having respcasibility and authority ever the licensed personnel. What meri: do ycu see in licensing managers? What kinds of technical difficulties would you foresee?
10.
It's been suggested that we are actually dealing with a spectrum et possible approache.1 with accreditatica at one end, I
scmething that we might call certification in the middle, and licensing at de other extreme. Wculd ycu make these kinds of distinctions? If ac, would you see the requirements (i.e., the cesprehensiveness and difficulty) increasing as one seved
- cward licensing?
j 11.
Would you furnish us with a copy of cne of de tests?
- 12. Cne of the basic p chless involved in licensine plant managers is tha: the criteria vic whien nuclear pcwer industry manage-ment measures (and een rewards) individual ecmpetency and I
performance are a great deal different than those used by the l
NRC.
Ce latter is only a subset of the former, and cne can l
easily suggest conditiens in which utility cwnership concerns would sericusly conflict with NRC's objectives.
We're also dealing with a situacien in which utility management "secres" managers en a continuum er scale ranging, perhaps, f:cm unacceptable to pocr to fair and en up, whereas the NRC deals wi-J a broader concept of accountability that emphasizes public safety.
"*he r e fore, its decisien process is really binary -
that is, TES cr NC in terms of licensing.
In an accredita:ica peccess, one can attempt to address bcth concerns independently or separately, with the view that they're both crit:. cal dimensions of the whole jch.
3-11 SMC.MANAGEME.NTT.ECHNOLOGY
Your industry has a similar dichcecmy with *=anagement con-carns' en the one hand and public safety issues en the ether.
Oces your accreditatica pecgram emphasire or til: in either direction? If so, hew much? Why? Wculd you offer a perscnal cpinica (acc for attribucien) at ec whether the NRC shculd focus sclely on safety issues, cc whether it shculd take a broader view?
13.
- o you have any general guidance for us in terms of licensing?
For example, shculd we phase such a pe Mram in gradually, making it a little bit more difficul: each year and, if sc, ever q
what length of time? Shculd peer review he used or shculd the NRC take the lead? Why? Is there ancther appecach ycu'd favor instead?
4 14.
Also, Ecw :cuch input to the develcyment of certificatien precedures and tests do you feel that industry shculd have? NRC cfficials? Academia? The public? The managers themselves?
- 15. wculd you effer'any suggesticus, ccaments, guidance, etc., in cicaing? Ice example, is there anyone else in the AAAE =c whcm we shculd speak.
In other asscciations ce sectors, etc.?
t 3-12 i
l SMC-MANAGDfENTTECHNOLOGY
1 Cctcher 9,1981 NATICNAL SCCIETY CF PROFESSICNAL INGUIEEPS 2029 K Street, N.W.
Washington D.C.
(202) 463-2300 Mr. Milten Lunch:
Mr. John Antri:n e
e-e e
1.
Could we begin with your providing me with an overview of *de two programs:
A&E licensing and the certification program?
2.
PE licensing is a state fJr.ction. What is the NSPE's role in this:
Review tests? Monitor? Assist? Sa:ne for certification.
3.
Are there any states where pes are not given?
B-13
4.
Without naming states, would you contrast the poorest *:o the best programs?
)
Provida numbers.
Ditto for cer:ification.
5.
Is there one exam or seversi versions in a state? When and how are they updated? To what extent are the exams the same from one year to the next?
How do you ensure " fairness" frca year to year? If quite similar, dcasn't that give the repeater an advantage?
6.
How are test questions developed (what's the precess) ? Whats cf teria are used? How are they validated? In what form are they?
l t
7.
Are principles - and l acre important - practices and problems treated in the avami9ation? If so, how are they handled (i.e., via essays, short-answers, :m21tiple choice) ? Are oral interviews used anywher27 l
3-14
,.--m
v 8.
Does the test go beyond knowledges? That is, do you attempt to address behavioral traits? If so, how? If not, why not and do you thi.*dc that it would (a) he desirable to do so and (b) feasible?
9.
Insuring that a test is objectively-designed and " fair" is always a problem, and the difficulties are even greacer with interviews.
How have these problems been addressed? Have there been any legal challenges?
10.
If one were to attempt to " validate" the tests (in the so.sse that a psycholo-gist would use), it would be necessary to demonstrate in come way that the test questions represented both all and only the : nest impcrtant aspects of cerformance, on the jch.
First, would you say that the PE tests do this and, second, how would you demonstrate it?
11.
The average nuclear power plant employs quite a number of persons in a number of different areas, some licensed and :nost unlicensed.
Reactor recm operators are of course licensed; unlicensed personnel include engi-neers, technical support and maintenance personnel, technicians and CC inspectors, and others.
There is also a plant manager who rans everfehing on a day-to-day basist he has a number of high level management people under him.
In other words, he is the " boss" including having responsibil-ity and au-Jiority over the licensed personnel.
What :nerit do you see.in licensing managers? What kinds of technical difficulties would you foresee?
3-U
(
l i
12.
We are actually dealing with a spect=m of possible approaches with accredi- -
tation at ene end, something that we might call certification in the middio, and licensing at the other extreme. Would you make these kinds of distine-tions? If so, would you see the requiraments (i.e., the comprehensiveness and difficulty) increasing as one moved toward licensing?
13.
Many of the pecple in the NP industry with whom we've spcken favor accredi-tation. What would you see as the potential benefits of such an approach?
The disadvantages?
I 14.
Cne of the basic problems involved in licensing plant managers is that the critaria with which nuclear pcwor industrf management measures (and then rewards) individual competency and performance are a great deal different i
than those used by the NBC.
Cne can easily suggest conditicas in which utilirl cwnership concerns would sericusly conflict with NRC's objectives.
We're also dealing with a situation in which utility management " scores" managers en a continuum or scale ranging, perhaps, f=cm unacceptable to poor to fair and on up, whereas the NEC deals with a broader concept of accountshility that emphasicas public safet*/.
Therefore; its decision l
process is really binarf - that is, YES cr NO in terms of licensing.
In l
an accreditatica process, one can attempt to address both concerns indepen-dently or separately, with the view that they're both critical M mensions of the whole job.
J I
i 4
1 i
i i
3-1C l
1 1
i
l h
15.
The professienal engineering co=cmnity has a sisillar dichotomy with " manage-ment cence:ns" on the one hand and public safety issues on the other.
Ioes your accreditation program emphasize or tilt in either direction?
If so, how much? Why? Would you offer a personal opinien (not for attribution) as to whether the NRC should focus solely on safety issues, or whether it shculd take a broader view?
(
16.
Do you have any general guidance for us in terms of licensing? For example, should we phase such a program in gradually, makiug it a little bit more I
difficult each year and, if so, over what length of time? Should peer review be used or should tha NBC take the lead? Why?
Is-ther ancther approach you'd favor instoad?
(Mention INPC).
17.
Also, how much int:t to the development of certification procedures and tests do you feel that indust:/ should.. ave? NRC officials?
Ac=A==4 a?
The public?
S.e managers themselves?
18.
Would you offer any suggestiens, censnents, guidance, etc., in closing?
For example, is there anyone else in t.he NS7E to whom we should speak?
In other asscciations or sectors, etc.?
3-17
y.
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Dear Mr. Speaker:
On June 26, 1981, the Nuclear Regulacory Commission submitted a status report in response to Public Law 96-295, Section 307(b). That law required NRC to study the feasibility and value o' licensing plant managers and senior licensee f
officers responsible for the operation of nuclear power facilities.
The status report indicated that the staff had been directed to expand their efforts through interviews with persons knowledgeable in the areas of management assessment, licensing and nuclear operations. The study has been completed and we are hereby transmitting the reports.
Briefly, the results indicate that the costr of a formal licensing program appear to outweigh the potential benefits as related to public health and safety. We would, therefore, advise against such a licensing program.
The staff conducted a survey to determine if there was a precedent for the concept of licensing ma'nagers either in the Government or as a requirement set by the Government on the private sector.
Nine agencies were contacted; two of them (Housing and Urban Development and Interstate Commerce Comission) administer licensing programs for organizations only, five agencies (U. S.
Coast Guard, Federal Comunications Comission, Federal Aviation Administra-tion, Federal Maritime Comission and the U. S. Customs Service) license both organizations and individuals, and one agency,0ffice of Personnel Management) representative discussed the concept of Government licensing requirements in gene.'al and the Senior Exer.utive Service.
Also the U. S.
Navy Prospective Comanding Officers program was reviewed.
None of the Federal agencies contacted license for managerial ability and further there appears to be no Federal Government precedent for licensing managers as individuals for a management job.
0 3
.2-Oak Ridge National Laboratories (ORNL) and their subcontractor, Science Management Corporation (SMC), performed a survey study of NRC Inspection and Enforcement personnel and private sector personnel familiar with management assessment and the nuclear industry. The study consisted of 68 personal interviews; including 35 interviews with utility representa-tives,18 with NRC Inspection and Enforcement personnel,10 with individuals familiar with assessment techniques and five with professional organizations.
A thorough discussion of the ORNL/SMC study, including sampling techniques, interview guides, results and recommendations, is attached.
Briefly, the ORNL/SMC study team found that a formal licensing requirement, administered in a manner similar to that followed in the NRC administered reactor operator licensing process, would probably be counter-productive in terms of public health and safety-primarily because the ' additional regulawry burden would take time away from regular duties. Also, the respondents we adamantly opposed to a testing program because of the perceived inability to objectively measure managerial skills.
We recognize the need to improve nuclear utility management capabilities and will continue to monitor efforts by the Institute for Nuclear Power Operation to achieve this goal.
Staff has also been directed to explore other avenues, e.g. increase training, to ensure management capabilities.
Based on the weight of the evidence accumulated, the staff reconsnends against the establishment of a NRC' licensing requirement for nuclear power plant managers and other senior licensee officers.
However, we intend to continue to pursue other means of assuring and improving management competen,ce.
Sincerely, Nunzio J. Palladino
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