ML20127B627
| ML20127B627 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML20127B630 | List: |
| References | |
| FOIA-85-345, TASK-PII, TASK-SE SECY-84-167, NUDOCS 8405180003 | |
| Download: ML20127B627 (8) | |
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f April 20, 1984 y
lg SECY-84-167 (Information)
For:
The Comissioners From:
William J. Dircks Executive Director for Operations
Subject:
USE OF THE FAA " CHECK-PILOT" APPROACH FOR REACTOR OPERATOR REQUALIFICATION
Purpose:
To provide the Commission with a report on the concept of obtaining industry participation in a " check-pilot" approach to the requalification of reactor operators.
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Discussion:
At the request of the Commission, the staff has explored the concept of obtaining industry participation in the application of the FAA check-pilot approach to the requalification of reactor operators at nuclear power plants.
The enclosed report discusses the FAA Check-Pilot System as l
it is currently administered for recertification proficiency checks. Since the pilots of larger commercial aircraft are most analogous to reactor operators, the report focuses on the FAA system for those pilots.
The report discusses the differences between the FAA-airline industry regulatory relationship and that of the NRC to the nuclear industry. A legal analysis will be performed on the
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statutory authority for conducting a mandatory, nationwide check-operator program.
The analysis would have to be integrated with the evaluation of any trial program that may be conducted.
At present, it appears that legislation would be preferable for NRC to conduct a mandatory, nationwide program. OLB is continuing its efforts to investigate requalification program alternatives and, as noted in the Human Factors Program Plan, long-term efforts to explore new strategies for licensing.
The staff is including the FAA check-pilot concept as an option in the long-term investigation of alternative operator licensing examination
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strategies.
Contact:
D. Beckham, NRR QI x24868 g*
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The Commissioners A preliminary draft of a check-operator program is also enclosed. This program would be further investigated and could be conducted in one Region on a trial basis. The program would be for requalification operational tests only. Although NRC has the authority to conduct a trial program with the gratuitous help of sor; of its licensees, other concerns must be appropriately resolved, such as the development of special examiner standards and check-operator guidance before program implementation.
If further investigation suggests the need for a trial program, the region selected to conduct such a program would have to redirect approximately one full-time professional and a half-time support person to conduct the trial program for the requalification examination effort or have additional support made available. Additional resources would also be needed to develop guidance and standards and to evaluate the trial program.-
Preliminary contacts with industry sources have been made on the check-operator concept. Several concerns have been raised, including the level of effort required by industry and the shortage of experienced operators. The fea'sibility of obtaining industry support will be studied as part of the integrated industry response to the human factors issues.
sdC)liamJ.Dircks l
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Wil Executive Director for Operations
Enclosures:
1.
A Discussion of FAA Check-Pilot Type Program for the Nuclear Industry 2.
Draft of Check-Operator Program
Enclosura 1 A DISCUSSION OF FAA CHECK-PILOT TYPE PROGRAM FOR THE NUCLEAR INDUSTRY t
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I.
INTRODUCTION f
l The Commission, in the " Staff Requirements Resulting from Review of the l
FY 1985/1986 Budget," has asked the staff to explore the feasibility of
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obtaining industry participation in a FAA type check-pilot approach to the qualification and requalification of reactor operators. A check-operator program offers the potential for more direct participation in the requalification of licensed reactor operators than at present.
Currently, while all qualification examinations are conducted by NRC, only by conducting a direct audit of requalification programs does NRC obtain detailed information about the effectiveness of requalification training programs and the proficiency level of reactor operators. The l
check-operator program, on the other hand, would provide NRC with direct sources of information by having an NRC approved individual administer the annual requalification operator test. Moreover, this system could be implemented and expanded as necessary without a concomitant increase in the number of NRC employees or contractors.
The FAA check-pilot system is based on the FAA system of designated i
representatives. A check-pilot is a private person who represents the FAA for the purpose of conducting the required recurrent proficiency checks of certified (licensed) pilots. The person conducting the check is a certified pilot, thus the tenn check-pilot. The FAA uses designated representatives to conduct certification and recertification operating tests of pilots. This review concentrates on the system used for proficiency checks of airline transport pilots because an airline transport pilot is. most analogous to the licensed operator at a commercial nuclear power plant. Airline transport pilots are rated on large (over 12,500 pounds) commercial airplanes.
Pilots-in comand have responsibility for large, revenue producing equipment similar to the role of a senior operator. The pilot in comand also has a second in command and other crew members. Moreover, the second in comand, the flight engineer, and the navigator must also be certificated and have recurrent proficiency checks.
II.
FAA AND THE CHECK-PILOT APPROACH A.
The FAA Check-Pilot System In 1958 in response to several midair crashes, Congress enacted the Federal Aviation Act, which created the Federal Aviation Administration with the power to regulate air commerce, including civil and military operations within the U.S., in the interest of safety and efficiency.
FAA administers a complex system in which everyone directly involved in the operation, maintenance and direction of airplanes is required to have a valid FAA certificate with appropriate ratings.
Included are pilots, flight engineers, navigators, aviation mechanics, air traffic controllers, aircraft dispatchers and parachute riggers.
In addition, FAA certifies both
. pilot and mechanic schools and the instructors who teach in these institutions. Since 1959, FAA has closely inspected airline crew operations. Current requirements for pilots of aircraft over 12,500 lbs. include recurrent training and proficiency checks after initial certification. Pilots in comand are required to have proficiency checks every six months; other airline transport pilots are' required to be checked annually.
The legislation establishing the FAA authorized the Administrator to delegate certain functions to private persons.
Under Section 314 of the Federal Aviation Act, the Administrator can delegate authority; Sections 602-605 identify the areas which can be delegated. The FAA has established-the basic requirements for " representatives of the Administrator" under 14 CFR 183. Specifically, 5183.23 delineates the activities of pilot examiners.
In the late 1970s, the increasing number of proficiency checks required for commercial airline pilots, and the limited number of FAA examiners available, resulted in an increased use of designated air carrier airman examiners, commonly referred to as
" check-pilots." These check-pilots are designated by the FAA to function for the Administrator in conducting the required recertification proficiency checks of airline transport pilots. FAA continues to conduct the initial certification examinations for airline transport pilots.
How the Check-Pilot Program Works The FAA has established guidelines and standards for qualification, selection, authority, responsibility and supervision-of check-pilots.
Qualification and Selection Check-pilots are selected by the FAA from nominations.
Generally, the " holder of a certificate," an airline, nominates pilots to be used at that airline to perform proficiency check rides of its pilots.
An outstanding record and well recognized performance as a pilot are required. Of ten the person nominated is well known to the FAA and has gained respect within the airline as a pilot.
The ratio of one examiner per twenty pilots is average, although as low as one to five may exist.
Check-pilots are selected by the FAA Air Carrier District Office in whose geographical area the examiner will operate. At a minimum, by regulation (9121.411), a check-pilot must hold a pilot certificate and must be rated to serve as a pilot in command of the particular airplane type; have satisfactorily completed the appropriate training phases for the airplane, including recurrent training in order to serve as a pilot in command; and have satisfactorily completed the appropriate proficiency or competence check as well as the applicable check-pilot initial and transition training.
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. Training, Supervision and Renewal The designated check-pilot performs under the same requirements, instructions and procedures applicable to FAA employees conducting the same proficiency checks.
The indoctrination and training for a prospective designated examiner is similar to that of a newly assigned FAA inspector. The prospective examiner may be given tests by an FAA inspector or be observed while being tested by.another examiner or designated check-pilot.
If the prospective examiner does not exhibit sufficient knowledge, ability and skill required for his particular certificate or rating and satisfactory knowledge of FAA evaluation and grading standards as well as the Examiner's Handbook, he will not be designated. An FAA air carrier operations inspector will observe the prospective check-pilot conduct, evaluate, grade and critique a minimum of one full test prior to designation.
The designation is made annually, and each examiner is evaluated by an FAA inspector prior to renewal.
In addition, examiners must attend FAA training each year as well as maintain the rating and certificate for which they perform proficiency checks.
FAA field personnel monitor check-pilots and provide guidance and counsel, as necessary.
The principal operations inspector for the airline and other field office personnel reviews the work of check-pilots through spot checks and annual operations reviews.
Check-Pilot Activities Under FAA regulations, airline transport pilots must satisfactorily complete an annual proficiency check. Check-pilots conduct the proficiency checks. These checks include procedures and maneuvers-set forth by the FAA and consist of emergency procedures in circumstances such as missed approaches, failed engines, and hazardous weather conditions.
The proficiency checks (14 CFR 121.441) are usually conductec in an FAA-approved simulator. Simulator checks are supplemented by actual flight checks in which at least two landings are made in the airplane for which the pilot is being qualified.
The check-pilot may give additional training to the pilot during the conduct of the proficiency check, may have the pilot repeat any maneuvers and may stop the proficiency check.
Pilots must satisfactorily complete their proficiency check to continue flying.
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. 8.
Conflict of Interest and Other Concerns With Check-Pilot Program NRC staff interviewed FAA inspectors at FAA Headquarters, in the Field Office of the Southern Region and training managers / check-pilot coordinators at Delta and Republic airlines. A select group of pilots was also interviewed from Braniff, TWA and Delta. All interviewees acknowledged that conflict of interest was a concern in a system in which designated check-pilots served their own employer, e.g., Delta check-pilots conducted proficiency checks for Delta pilots.
The major control of conflict of interest problems appears to be in the large number of pilots and, therefore, the large number of proficiency checks conducted. For example, Delta has approximately 4,000 pilots.
In addition, although a check-pilot must be a line pilot with a current rating, the check-pilot may also be a member of the training staff or pilot without a current medical certificate. Therefore, the check-pilot is not likely to conduct proficiency checks of persons with whom he flies; that is, the check-pilot is not likely to be a co-worker or a friend of the pilot being examined. An additional balance to the check ride is the FAA enroute crew check conducted at least once a year for every crew.
Another concern with the check-pilot program is the level of examining skill of check-pilots. By regulation (14 CFR 121.411) check-pilots must complete special training prior to conducting proficiency checks. This training is -approved by the FAA and includes proper evaluation of pilot performance.
By regulation, the training includes detection of improper and insufficient training, personal characteristics that could adversely affect safety, the appropriate corrective action in the case of unsatisfactory checks as well as the approved methods, procedures and limitations for performing the required normal, abnormal, and emergency procedures in the airplane. At Republic, for example, check-pilot initial and ground training takes eight hours.
Check-pilots are also given flight training and training on the operation of the appropriate simulator. Check-pilots attend periodic meetings to discuss check-pilot procedures and policy. This training has the added effect of promoting check-pilots as a select group with special skills which not only set them apart as excellent pilots, but also as leaders with the ability to judge the performance of others. Moreover, an FAA inspector observes the prospective check-pilot giving an examination prior to designation.
The benefit to the check-pilot is that of being regarded as an example to one's peers. Often check-pilots feel it is an honor to serve. Some airlines provide cash or benefits to : heck-pilots; however, most persons interviewed indicated that pride and management recognition are the incentives to. serve.
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. III. CONSIDERATIONS FOR NRC/ NUCLEAR INDUSTRY Current NRC/ Nuclear Industry Considerations All initial qualifying examinations for reactor operators are conducted by NRC staff or contractors. Until 1983, NRC did not conduct requalification examinations; the utilities conducted these under an NRC-approved requalification training program. Since June 1983, the NRC has increased its role in the assessment of requalification programs for reactor operators.
In response to SECY-79-330E,
" Qualifications of (Power) Reactor Operators," the Commission directed the staff to administer examinations as part of the requalification program for all licensees and applicants.
This requirement was incorporated into TMI Task Action (NUREG-0660) Item I.A.3.1 and clarified in NUREG-0737 and SECY-82-232. To implement this directive, the NRC staff has been conducting requalification examinations as detailed in SECY-83-252. Currently, the Operator Licensing staffs in the Regional Offices are scheduled to audit the requalification examinations of approximately 20 percent of the operators at approximately 50 percent of the facilities each year.
Under proposed revisions to 10 CFR Part 55, included in the response to Section 306 of the Waste Disposal Policy Act of 1982, the NRC could conduct the annual operator requalification exmainations.
Alternatively, the proposed revisions would allow NRC to accept certification by the utility in lieu of an NRC examination.
Thus, the regulatory basis would be established for NRC to conduct 100 percent of the requalification examinations required of licensed reactor operators and also allow participation by utility personnel.
Comparison of the FAA Certification Program with the NRC Requalification Program A comparison of the FAA system for the recertification proficiency checks of airline transport pilots with the NRC system for the requalification of reactor operators points to several major differences.
First, as opposed to the NRC, the FAA regulates an industry with more standardized designs of its equipment. Secondly, for each opening for a pilot there are several hundred trained applicants; therefore, competition for jobs puts pressure on incumbents to desire honors such as selection as a check-pilot.
In the nuclear industry, on the other hand, there is a shortage of trained and experienced operators.
A third consideration is that the designation of FAA authority extends not only to the recertification of pilots, but encompasses the quality assurance program, engineering programs, medical programs, manufacturing, and maintenance activities.
For example, the Administrator delegates authority for Lockheed engineers to review Lockheed parts. Therefore, the aviation industry is familiar with designated representatives and
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, has developed procedures over time for their acceptance and conduct.
On the other hand, the concept of check operators is new to the nuclear industry and there are, as yet, no guidelines for its use and implementation. A fourth difference is that the large number of pilots to be tested makes it less likely that a given check-pilot will check someone with whom he has a close relationship. This may not be the case in the nuclear industry given the much smaller number of operators.
Fifthly, though NRC has the authority to conduct the trial program described below with the gratuitous help of some of its licensees, unlike the FAA's authority on check-pilots, NRC does not have specific authority to delegate check-operator authority.
Licensees can, of course, inspect their own operators or NRC can inspect their operators.
However, NRC's authority to designate operators at one utility's facility to administer, for instance, requalification examinations to operators at other utilities' facilities is unclear. Specific legislation would be preferable for NRC to conduct a mandatory, nationwide program.
Experience from the trial program would be useful to provide the framework for requesting such authority, if it is needed.
Finally, unlike the airline industry, the nuclear industry has a shortage of experienced senior operators. At this time, critical need for this experience at both new plants coming on line and to maintain safe operation of existing plants limits the successful implementation of any program which proposes to use experienced reactor operators.
However, it should be noted that some utilities have an infonnal system in which senior operators are used as auditors in plants other than their own.
The impact of this " sharing" of utility resources is unknown at this time.
Resource Considerations If NRC were to adopt the FAA approach, 100 percent of the licensed
. operators could be checked. The Commission in its budget discussions and in consideration of SECY-79-330 and other papers has promoted the goal that NRC reassess 100 percent of reactor operators annually.
If this were to be accomplished, an estimated 4,000 requalification examinations would have to be conducted each year.
For NRC itself to conduct these examinations would require a large increase in its staff.
However, to conduct these requalification examinations using a check-operator program, NRC would only require an increase in staff of approximately ten PSY per year. Additional one time resources of staff and dollars would be needed to develop and conduct initial training for check-opera tors.
Under Section 3.3, Licensing Examinations, Long-Term Efforts, of the Human Factors Program Plan (NUREG-0985), the FAA check-pilot approach is scheduled for further evaluation by the staff as part of the long-term efforts to explore new strategies of licensing.
This effort is scheduled to begin in FY 1985.