ML20136G010

Requests Approval to Publish Encl Final Policy Statement on Engineering Expertise on Shift in Fr

ML20136G010
Person / Time
Issue date:	04/26/1985
From:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
Shared Package
ML20136G017	List: IA-85-689, Responds to FOIA Request for SECY-85-150 Final Policy Statement on Engineering Expertise on Shift & Suppls. SECY-85-150 Available in Pdr.No Suppls Exist ML20136G010 ML20137A698
References
FOIA-85-689, TASK-PIA, TASK-SE SECY-85-150, NUDOCS 8505290349
Download: ML20136G010 (93)

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POLICY ISSUE April 26,1985 SECY-85-150 For: The Comissioners From: William J. Dircks Executive Director for Operations

Subject:

FINAL POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT

Purpose:

To obtain Commission approval to publish one of the two enclosed versions of the Final Policy Statement on Engineering Expertise on Shift in the Federal Register. The policy statement offers licensees options for providing engineering expertise on shift and for meeting the upgraded licensed operator staffing requirement of 10 CFR 50.54(m)(2).

Background:

The staff met with the Commissioners on November 5, 198a, to discuss the riraft Final Policy Statement in SECY-84-355. As a result of that meeting, the Commissioners directed the staff to coordinate the Policy Statement on Engineering Expertise on Shift with the Nuclear Utilities Management and Human Resources Committee (NUMARC).

Discossion: In response to the Commissioners' direction, the staff met with NUMARC and jointly developed a revised policy statement, Version A, which offers utilities two options for providing engineering expertise on shift.

Version B is the revised policy statement with the addition of a third option, as described in a memorandum from N. J. Palladino to W. J. Dircks dated February 22, 1985.

The third option (i.e., an in-line supervisory position in addition to the licensed positions required by 10 CFR 50.54(m)(2)) was presented to the NUMARC Executive i Group at a February 27, 1985 meeting. Mr. J. H. Miller,  :

Chairman, NUMARC Steering Committee stated in a March 7, '

1985 letter (Enclosure H) that a majority of this group

Contact:

Clare Goodman, NRR X24894 C

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The Commissioners 1 I

voted not to support the addition of this option to the policy statement because they believe that engineering and  !

accident assessment expertise is ensured by the two options in Version A of the Policy Statement. Further, Version A does not preclude a utility from creating an in-line supervisory position. The letter states that some utilities have created or are actively pursuing the creation of such positions and, therefore, the organizational issue is one best left to individual licensees.

The Commissioners should note that one means of meeting the training or educational requirements of the combined SR0/STA position in both Version A and B accepts college-level ,

training instead of formal college education. That '

alternative allows a new senior reactor operator who has ,

been a licensed reactor operator for four years and who has successfully completed INP0 accredited STA and SRO training programs to fill the SR0/STA position.

The staff is submitting to the Comissioners two versions of the Federal Register notice for their consideration and approval of one of the versions, i.e., Version A, the two option policy statement, or Version B, the three option ,

policy statement.

The Licensed Operator Staffing Rule in 10 CFR 50.54(m)(2) went into effect on January 1, 1984. Hence, the prompt  :

publication of this Final Policy Statement is important to the approval of proposed staffing levels at some nuclear power plants.

Recommendation: That the Comission: ,

1. Approve publication of one of the two versions of the Final Policy Statement as set forth in Enclosure A or i Enclosure D.

2. Note:

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a. That, in accordance with 10 CFR 651.22(c)(16),

neither an environmental impact statement nor an '

environmental assessment need be prepared in connection with this action because it is eligible

.for categorical exclusion.

F l b. That the Subcomittee on Nuclear Regulation of the '

i Senate Committee on Environment and Public Works and b I the Subcomittee on Energy Conservation and Power of 1:

the House Committee on Energy and Comerce and the Subcomittee on Energy and the Environment of the ,

House Comittee on Interior and Insular Affairs will be informed (Enclosures C or F).

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., The Commissioners c. That a public announcement will be issued (Enclosure G).

d. That ADM will send copies of the Policy Statement to all affected licensees and other interested people following Commission approval for publication of the Policy Statement.

Scheduling: Recommend early affirmation.

William J. Dircks Executive Director for Operations

Enclosures:

Version A A. Federal Register Notice of Final Policy Statement B. Resolution of Public Comments C. Letters to Congress Version B D. Federal Register Notice of Final Policy Statement E. Resolution of Public Comments F. Letters to Congress i

G. Public Announcement (applies to eitherversion)

H. Ma'rch 7, 1985 Letter from J. H. Miller (applies to eitherversion) i

Commissioners' comments should be provided directly to the Office of the Secretary by c.o.b. Tuesday, May 14, 1985.

Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Tuesday, May 1, 1985, with an infor-mation copy to the Office of the Secretary. If the paper is of such a nature that it requires additional time for analytical review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.

This paper is tentatively scheduled for affirmation at an Open Meeting during the Week of May 20, 1985. Please refer to the appropriate Weekly Commission Schedule, when published, for a specific date and time.

DISTRIBUTION:

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NUCLEAR REGULATORY COMMISSION FINAL COMMISSION POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT AGENCY: Nuclear Regulatory Commission.

ACTION: Final Commission Policy Statement on Engineering Expertise on Shift.

SUMMARY

This Policy Statement presents the policy of the Nuclear Regulatory Commission (NRC) with respect to ensuring that adequate engineering and accident assessment expertise is possessed by the operating staff at a nuclear power plant. This Pclicy Statement offers licensees two cptions for providing engineering expertise on shift and meeting licensed operator staffing requirements. .

Option 1 provides for elimination of the separate Shift Technical Advisor (STA) position by allowing licensees to combine one of the required Senior Reacter Operator (SRO) positions with the STA position into a dual-role (SR0/STA) position. Under Option 2, a licensee may continue with an NRC-approved STA program (i.e., a separate STA position), with certain modifications, while meeting licensed operator staffing requirements.

EFFECTIVE DATE:*

FOR FURTHER INFORMATION CONTACT: Clare Goodman, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission, Washington, DC 20555 Telephone: 301/492-4894.

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• Insert date of publication in the Federal Register.

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SUPPLEf!ENTARY INFORMATION:

Background Following the accident at Three Mile Island in March 1979, a number of studies were conducted to determine why the accident occurred, what factors might have contributed to its severity, and what the industry and the NRC could do to prevent the recurrence of the same or a similar accident. These studies concluded, among other things, that a number of actions should be taken to improve the ability of shift operating personnel to recognize, diagnose, and effectively deal with plant transients or other abnormal conditions.

To address these recommended improvements, the NRC initiated both short-term l

and long-term efforts. The short-term effort required that as of January 1, 1980, each nuclear power plant have on duty a Shift Technical Advisor (STA) whose function was to provide engineering and accident assessment advice to 1 the Shift 50pervisor in the event of abnormal or accident conditions. The STA was required to have a bachelor's degree in engineering or the equivalent and specific training in plant response to transients and accidents. The STA requirement was identified to licensees via NUREG-0578 (July 1979)I and NUREG-0737 (November 1980) and was later mandated by plant-specific Confirmatory Orders.

Concurrently, the NRC and industry embarked on a longer-term effort aimed at upgrading staffing levels and the training and qualifications of the operating staffs, improving the man-machine interface, and increasing capabilities for responding to emergencies. At the time the STA requirement was imposed, it was intended that use of the dedicated STA would be an interim measure only until these longer-term goals were achieved.

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Referenced materials are available at the NRC Document Room at 1717 H Street, NW, Washington, DC 20555.

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These long-term initiatives collectively result in an improvement in the capabilities and qualificatiens of the shift crew and their ability to diagnose and respond to accidents. These initiatives include shift staffing increases, training and qualification program improvements, hardware mcdifications, emphasis on human factors considerations, procedural upgrades, and development of extensive emergency response organizations to augment on-shift capabilities during abnormal conditions. They either have been or are in the process of being implemented and include the following:

Every licensee of a nuclear power plant has been required to develop and implement extensive emergency response organizations for the express purpose of assisting in the diagnosis and mitigation of accidents. These organizations are required to be fully mobilized within one hour and provide substantial " engineering expertise" assistance to the shift crew to assist in accident diagnosis and mitigation / protective action strategy.

All operating nuclear power plants are currently required to have emergency plans in place and to conduct exercises on a regular basis.

Implementation of Supplement 1 to NUREG-0737 requires all nuclear plant licensees to conduct a Control Room Design Review (CRDR) of their facility and implement improvements identified in the human factors review.

Implementation of CRDR findings will result in an improvement in the operator's ability to understand and respond to abnormal situations. This will minimize confusion during an accident and increase the likelihood of correct operator actions. All licensees have been required to submit plans and schedules for conducting the CRDR.

In cooperation with the nuclear steam supply system vendor owners groups, the industry has developed symptom-based emergency operating procedures.

The generic development work for these procedures has been completed.

These procedures are designed to make it easier fer the operators to recognize, diagnose, and effectively deal with plant transients and other abnormal conditions. They are designed to aid the operator in maintainirg critical safety functions, i.e., control reactivity, remove core heat, ENCLOSURE A

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provide an ultimate heat sink, and contain radioactivity, thereby minimizing.the probability of a serious incident. Thdse new procedures are of significant benefit to the operator in accident diagnosis and overall response capabilities. All licensees have either implemented or are in the process of converting to these new procedures.

• Implementation of Supplement 1 to NUREG-0737 requires installation of a safety parameter display system (SPDS). The SPDS is a system for rapid and concise display of vital plant status indications in the event of transients or accidents. The availability of this information via the SPDS will assist the operator in performing mitigating or stabilizing actions by providing essential information in a clear and timely manner.

Upgrading and installation of additional instrumentation for post-accident monitoring, as delineated in Regulatory Guide 1.97 and Supplement 1 to I NUREG-0737, will assist the operator in monitoring plant status and the course of an accident. The addition of this type of instrumentation, in conjunction with benefits of the SPDS display, will enhance event diagnosis and lessen the degree of reliance on the-operator's analytical ability. All licensees have provided plans and schedules for Regulatory Guide 1.97 upgrades.

Effective January 1, 1984, the minimum shift crew for a single-unit plant was increased to two licensed senior reactor operators and two licensed reactor operators on each shift; similar increases were required for multi-unit plants. This has resulted in two positive effects. First, an additional senior licensed operator has been added to each shift, thereby providing one more perspective to focus attention on accident assessment and overall emergency direction. Second, one of these senior licensed i operators is now required to be in the control room at all times. As a result, there is assurance that additional experienced senior level expertise will be immediately available at the onset of an accident.

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The industry, through the Institute of Nuclear Power Operations (INPO),

. has established a comprehensive, nationwide accreditation program. This program provides for upgrading of the training programs for all licensed operators as well as the training for other key positions that can directly affect plant operations. An independent Accrediting Board reviews the evaluations of each utility's training programs and either grants accreditation or defers accreditation until the programs meet high standards. Licensees are expected to have these training programs ready for accreditation by the end of 1986. These programs will ensure that operating personnel possess qualifications comensurate with the requirements of their jobs. This issue is being addressed by the Commission via a separate Policy Statement.

Extensive additions have been made to utility training staffs.. The number of full-time personnel per plant dedicated to training increased industry-wide by approximately 375% between 1979 and 1984. This exemplifies the increased recognition of the importance of training and requalification to the effectiveness and capabilities of the shift crew.

As specified in NUREG-0737, Item II.B.4, all licensed operators receive training specifically directed at recognizing and mitigating core damage.

Thjs training serves to familiarize the operator with possible causes and symptoms of a damaged core and expected post-accident plant conditions and corrective actions. As a result, the operator is better prepared to recognize and respond to degraded plant conditions. All licensed operators are required to successfully complete this training.

Simulators are now extensively used throughout the industry; 10 were in use in 1979; at the end of 1984, 40 were in use; and a total of 69 simulators are now in operatior,or are planned. Additionally, NRC criteria for operator licensing now require simulator training. The use of simulators provides more comprehensive training for the operator and allows him to experience transients and accidents in a training l l

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environment. The increased use of simulators will improve the capabilities of the shift crew to respond to emergencies.

The industry, through INPO, has develcped and implemented c comprehensive system for gathering and analyzing information on events that occur in the industry and providing feedback to operating personnel. This allows other licensees to revise their facility design or operation, as necessary, based on the lessons learned in the industry. The NRC endorsed INP0's "SEE-IN" program in Generic Letter 82-04 as acceptable for meeting the information-gathering elements of NUREG-0737, Item I.C.S.

Collectively, these initiatives result in a significant enhancement of the capabilities of the shift crew to diagnose and mitigate accidents.

Draft Policy Statement On July 25, 1983, the Commission published in the Federal Register (48 FR 33781) a Draft Policy Statement on Engineering Expertise on Shift to reassert the Commission's belief that adequate engineering and accident assessment expertise must be available to the operating crew at all nuclear power plants.

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The Draft Policy Statement on Engineering Expertise on Shift offered licensees of nuclear power plants and applicants for operating licenses two options for meeting the staffing requirements of 10 CFR 50.54(m)(2) and the requirement in NUREG-0737, Item 1.A.1.1 for a Shift Technical Advisor (STA).

Option 2 gave them the opportunity to combine the licensed Senior Operators' (SRO) and Shift Technical Advisors' (STA) functions. Licensees that did not want to combine the SRO and STA functions could continue with their approved STA program in accordance with the description in NUREG-0737, " Clarification of TMI Action Plan Requirements."

l Interested persons, applicants, and licensees were invited to submit written I coments to the Secretary of the Commission. Following consideration of the ENCLOSURE A 1

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comments, the Ccmission amended the Draft Policy Statement, as discussed in the following sectipns.

Coments on the Draft Policy Statement A total of 34 responses were received and evaluated. The public comments related primarily to the combined SR0/STA position. The following discussion highlights the major points raised in the coments and the resolution of those coments. A detailed analysis of all public coments and their resolution was also prepared. (Copies of those letters and the detailed analysis of all the public coments are available for public inspection and copying for a fee at the NRC Public Document Room at 1717 H Street N.W.,

Washington, DC 20555.)

Of the 34 letters received,18 included support for the flexibility provided by the Policy Statement. The major points made in the public coments were as follows:

1. Support for the Policy Statement; -

2. Opposition to combining the functions of the SRO and the STA;

3. Opposition to a bachelor's degree requirement for the SR0/STA position;

4. Recomendation that equivalency to a bachelor's degree be further dgfined; ,

, 5. Concern that a bachelor's degree requirement for the SR0/STA position would result in a higher turnover rate and potentially blocked career paths for operators; and

6. Reference to a proposed bachelor's degree requirement for the Shift Supervisor, believed to be currently under NRC consideration.

A general description of the major public coments and responses to these are as follows:

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1. Support for the Policy Statement -

Eighteen cementors favored the option offered in the Draft Policy Statement of combining the SR0 and STA functions into one dual-role position. They endorsed the flexibility provided by the Policy Statement. They supported the view that it is beneficial to combine engineering expertise with operating experience.

2. Opposition to the Dual-Role SR0/STA Position -

Four individual comentors stated that there is a possibility that the person in the dual-role position would function as an additional operator in the event of an abnormal occurrence instead of being available to provide the engineering and accident assessment expertise necessary in these circumstances. In response, the Comission notes it is the intent of the Policy Statement that the person in the dual-role position have specific training in accident assessment and provide that expertise during an abnormal occurrence. The staffing levels required by -

10 CFR 50.54(m)(2), which became effective January 1, 1964, increased the number of operators and Senior Operators on shift after the initial STA position was required. This increase in shift personnel would allow the SR0/STA to provide both accident assessment expertise and to analyze and respond to off-normal events when needed. Experience has shown that an STA, who is also an SRO, is better accepted by the shift crew.

Therefore, the assessment and direction by an SR0/STA in an off-normal event might be better accepted by the crew than assessment and advice by a separate STA.

3. Opposition to a Bachelor's Degree for the SR0/STA Pcsition -

Several commentors felt that the person who filled the SR0/STA position should not be required to have a bachelor's degree. The Comission notes that since NUREG-0737, Item I.A.l.1, specified that the STA shculd have a ENCLOSURE A ,

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bachelor's degree or the equivalent in a scientific or engineering discipline, the degree requirement is no,t new. This continues to be the educational requirement for a dedicated STA. However, the educational requirements for the dual-role (SRO/STA) position have been changed to allow the individual to meet one of several educational alternatives or

have four years of experience as a licensed operator at an operating nuclear power plant and have successfully completed INP0-accredited STA

.i and SRO training programs.

4. Recommendation that Equivalency to a Bachelor's Degree Be Further Defined -

Hany commentors stated that the equivalency options were too restrictive or required clarification. In response, the Commission notes that a bachelor's degree in engineering is no longer a basic requirement but is one of several educational alternatives. The term " equivalent" has been deleted.

Changes related to educational alternatives are summarized below:

Most states require a bachelor's degree of the individual who has the

. designation of PE or EIT. Other states do not presently require a degree or have not in the past; however, they have a provision which l allows registration of these individuals if they meet the stringent requirements of a state board of registration through a combination of experience, examination, long-established practice and eminence.

Although the requirements vary from state to state, they all require

, the applicants to show evidence that their engineering work experience is at a grade and of a type satisfactory to the state board. Many states require that a portion of the applicant's engineering work experience be at a level of direct control and supervision of engineering work. The majority of states also require that the individual successfully pass a fundamentals of engineering examination or the principles and practice of engineering examination, or both. In ENCLOSURE A

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light of these rigorous state requirements, the PE and EIT options remain acceptable alternatives. ,

Other bachelor's degrees determined to be acceptable alternatives are a bachelor's degree in engineering technology from an accredited 2 institution or a bachelor's degree in a physical science from an accredited institution. These degree programs are acceptable provided

that they include course work in the physical, mathematical, and/or engineering sciences. These requirements are intended to ensure that j the individual has substantial knowledge and understanding of the physical and mathematical sciences and the principles of engineering.

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Another acceptatle alternative requires successful completion of the j i technical portion of a bachelor's degree in engineering or engineering  ;

technology from an accredited institution. The technical portion of

an engineering or engineering technology degree program is acceptable

! provided that it is comprised of courses in the physical, mathematical

! and engineering sciences. The Commission will find this alternative i acceptable if it receives a communication from the credit-granting

, university that all the technical courses required in its engineering f or engineering technology degree program have been successfully completed. Since names of courses and amount of credit vary from i university to university, the Commission will not specify the l technical courses required for this alternative. However, individuals who have completed 80 semester hours in the physical, mathematical and  ;

engineering sciences will be considered acceptable and will not i

! require a comunication from the university. The 80 semester hours j requirement is based on the ABET accreditation criteria for the basic l requirements of a bachelor's degree in engineering.

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5. Concern that.a Bachelor's Degree Requirement-Would Result in a Higher Turnover Rate and a Potentially Blocked Career Path for Shift Employees -

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Several cementors expressed concern that degreed individuals would leave for other positions in the plant, contributing to a high turnover rate on shift. Another concern of comentors was that career paths to the senior operating positions would be blocked for those individuals without degrees. In response, the Comission notes that since the bachelor's degree in engineering is no longer a basic requirement for the SRO/STA, but is only one of several educational alternatives, this should not affect career paths for individuals without a degree nor should it contribute to a high turnover rate.

6. Reference to a Proposed Bachelor's Degree Requirement for the Shift Supervisor -

A few comentors on the Federal Register notice took the opportunity to coment on whether a bachelor's degree should be required for specific positions in the operating staff of nuclear power plants, and in particular, for the Shift Supervisors' position.

The Final Policy Statement on Engineering Expertise on Shift does not address the issue of requiring a degree for the Shift Supervisor. Early in 1984, the staff considered a " proposed Rulemaking Concerning Rtquirements for Senior Managers" in SECY-84-106. This proposed rulemaking would have required that an additional degreed, SRO-licensed individual be assigned to each shift of a nuclear power plant who would be responsible for managerial direction of all plant functions including chemistry, health physics, maintenance, operations, security, and technical services. Following several meetings with the staff and industry representatives, the Comission concluded that this proposed rulemaking was not warranted, and it was disapproved. One of the primary bases for the proposed senior manager rule was the need to provide engineering expertise to the shift crew, which is also the primary objective of this Policy Statement.

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Development of Final Policy Statement ,

As a result of the analysis of public coments received, the Comission clarified and expanded the educational alternatives of the dual-role (SR0/STA) position. The revisions to the Draft Policy Statement resulted in SECY-84-355, a draft Final Policy Statement on Engineering Expertise on Shift.

The main difference between the Draft Policy Statement and SECY-84-355 concerns the educational qualifications for the dual-role position. The Draft Policy Statement required, of the person filling the dual-role position, a baccalaureate degree in engineering or related sciences or one of three equivalents to the degree. SECY-84-355 required a bachelor's degree in l engineering from an accredited institution or one of five acceptable alternatives to the engineering degree.

i l The staff met with the Comissioners on November 5,1984, to discuss SECY-84-355. As a result of that meeting, the Comissioners directod the staff to coordinate the Policy Statement on Engineering Expertise on Shift with the Nuclear Utilities Management and Human Resources Committee (NUMARC).

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This Final Policy Statement is the result of the Comissioners' direction,

staff analysis, resolution to public coments, and staff coordination with NUMARC.

i The major change from the Draft Policy Statement to this Final Policy Statement is the qualification requirements for the dual-role position (SR0/STA). The Draft Policy Statement required a baccalaureate degree or equivalent in engineering or related sciences. The Final Policy Statement requires that one of several educational alternatives be met or,that a l licensed operator have four years experience as a licensed operator at an operating nuclear power plant and have successfully completed INPO-accredited STA and SRO training programs. Hence, the Final Policy Statement accepts college-level training instead of formal college education for the dual-role position.

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Finally, although the Final Policy Statement incluces an option which allows l for the continued use of the STA position, as did the Draft Policy Statement, j the former encourages licensees to work towards having the STA assume an i active role in shift activities.

While it is the Comission's preference that licensees move toward the l

i dual-role (SR0/STA) position, continuation of an approved STA program remains i an acceptable option. The Comission acknowledges that some licensees may I

prefer the dedicated STA position for a number of reasons. The Comission i 4

j also recognizes the advantages of integrating the qualifications and training j of the STA into the licensed operating staff. Thus, this Policy Statement is j j structured to allow different means for ensuring that the plant operating ,

staff has adequate engineering and accident assessment expertise. ,

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! Policy Statement  !

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! The Comission continues to stress the importance of providing engineering j and accident assessment expertise on shift. The term " accident assessment" 1s defined as immediate actions needed to be taken while an event is in ll progress. This Policy Statement does not require any changes in the formal l education and training of operators and senior operators not expected to f l fulfill the dual-role SR0/STA position. , j i

4 The intent of this policy guidance may be satisfied by either of the options

described below. The Comission prefers a combined SR0/STA position  ;

i (0ption 1). In addition, in the long term, the Comission would prefer that the STA be combined with the Shift Supervisor position. 1 i Either Option 1 or Option 2 may be used on each shift. A utility may use

[ Option 1 on scme shifts and Option 2 on other shifts, or may use the same f option on every shift. If Option 1 is used for a shift, then the separate 1 STA position may be eliminated for that shift.  ;

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Option 1: Combined SR0/STA Position This option is satisfied by assigning an individual with the following qualifications to each operating shift crew as one of the SR0s (preferably the Shift Supervisor) required by 10 CFR 50.54(m)(2)(1):

a. Licensed as a senior operator on the nuclear power unit (s) to which assigned, and

b. Completion of either of the following training and educational requirements ((1) or (2)):

(1) Meets the STA criteria of NUREG-0737, Item I.A.1.1, and one of the following educational alternatives:

(a) Bachelor's degree in engineering from an accredited institution; (b) Professional Engineer's (PE) license; (c) Successful completion of the Engineer-in-Training (EIT) examination; (d) Bachelor'sdegreeinengineeringtechnology(BET)fromai accredited institution, including course work in the physical, mathematical, and/or engineering sciences; (e) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; or (f) Successful completion of the technical portion of a bachelor's degree in engineering or engineering technology from an accredited institution. The technical portion should be comprised of courses in the physical, mathematical, and engineering sciences.

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(2) Four years of experience as a licensed operator at an operating nuclear power plant and successful completion of INP0-accredited STA and SRO training programs. The programs described in the INP0 Guidelines " Nuclear Power Plant Shift Technical Advisor:

Recommendations for Position Description, Qualifications, Education, and Training," and either "PWR Control Room Operator, Senior Control Room Operator, and Shift Supervisor Qualification" are acceptable to satisfy the requirements for STA and SRO training. It is not the intent of this policy guidance to require that personnel who complete STA or SRO training programs prior to their accreditation by INP0 be required to repeat that training subsequent to INPO accreditation, except for participation in continuing training. The items added to the programs as a result of accreditation would be ir.cluded in the next training cycle.

Optien 2: Continued Use of STA Position This option is satisfied by placing on each shift a dedicated Shift Technical Advisor (STA) who meets the STA criteria of NUREG-0737, Item 1

I.A.1.1. The STA should assume an active role in shift activities. For example, the STA should review plant logs, participate in shift turnover activities, and maintain an awareness of plant configuration and status.

The Commission recognizes that several years may be required to meet this policy guidance. For the interim period, continuation of an STA program that meets the guidance of NUREG-0737, Item I.A.1.1 is acceptable. Licensee proposals different than the two options described above will be considered by the staff on a case-by-case basis.

To eliminate the STA position, a licensee of an operating reactor should ,

apply for a modification to its license and an applicant for an operating license should modify its Final Safety Analysis Report to reflect elimination l of the STA position and a commitment to provide a required SRO on shift with the qualifications described in Option I above.

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NRC will accept a utility's modifications if it finds that the proposal meets the intent of this Policy Statement. On a case-by-case basis, utilities with multi-unit sites with dual-licensed SR0s will ensure that an adequate number of licensed staff are available and that engineering expertise can be provided when needed. It is the intent of this Policy Statement to ensure that adequate engineering and accident assessment expertise is possessed by the plant operating staff.

Dated at Washington, DC, on this day of , 1985.

For the Nuclear Regulatory Commission, Samuel J. Chilk, Secretary of the Commission.

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ENCLOSURE B RESOLUTION OF PUBLIC COMMENTS e

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Resolution of Public Coments on Draft Policy Statement on Engineering Expertise on Shift A. List of Comentors Letter Number Comentor 1 Glenn L. Koester, Kansas Gas & Electric Company 2 PROS Society 3 Paul Swinburne, Oswego, NY 4 Raymond P. Termini, Comonwealth Edison 5 W. L. Stewart, Virginia Electric and Power Company 6 D. L. Farrar, Comonwealth Edison 7 Donald A. Bearden, Arroyo Grande, CA 8 Thomas C. Houghton, KMC, Inc.

9 M. R. Wisenburg, Houston Lighting and Power 10 D. W. Jones, Memphis State University 11 J. Ed Smith, Chairman, ANS-3 12 Leo Mariani, American Nuclear Insurers 13 Marvin W. Onnen, Big Lake, MN 14 Hal B. Tucker, Duke Power Company 15 G. C. Sorenson, Washington Public Power Supply System 16 J. O. Schuyler, Pacific Gas and Electric Company

'17 Donald J. Broehl, Portland General Electric Company 18 B. D. Kenyon, Pennsylvania Power and Light Company 19 John DeVincentis, Public Service of New Hampshire (Yankee Atomic Electric Company) 20 J. R. Thorpe, GPU Nuclear Corporation 21 Jimie Harris, La Jolla, CA 22 J. P. Bayne, New York Power Authority 23 Joseph W. Williams, Jr., Atomic Industrial Forum, Inc.

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24 John R. Marshall, Arkansas Power and Light Company 25 Donald Schnell, Union Electric Company 26 W. G. Counsil, Northeast Utilities 27 Robert E. Uhrig, Florida Power and Light Company 28 M. I. Lewis, Philadelphia, PA 29 R. E. Helfrich, Yankee Atomic Electric Company 30 John E. Parkyn, Stoddard, WI 31 David Musolf, Northern States Power Company 32 R. B. Bradbury, Stone & Webster Engineering Corporation 33 David E. LaBarge, Professional Reactor Operator Society 34 C. W. Fay, Wisconsin Electric Power Company Comments are referred to by two numbers. The first corresponds to the number assigned to each letter above, and the second refers to the comment number within the letter. For example, comment 2-1 refers to the first comment in letter number 2.

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1. Comments 1-7, 1-8, 3-1, 3-3, 4-1, 5-1, 8-2, 8-21, 9-1, 12-1, 14-1, 14-2, 14-7, 15-1, 15-2, 16-1, 18-1, 18-2, 19-1, 20-1, 20-2, 20-3, 22-1, 23-3, 30-1, 30-2, 31-1, and 32-1 favored the option offered in the Draft Policy Statement of combining the licensed Senior Operators' (SRO) and Shift Technical Advisors' (STA) functions into one dual-role position.

They endorsed the flexibility provided by the Policy Statement. They supported the view that it is beneficial to combine engineering expertise with operating experience.

Resolution: The comments have been noted.

11

2. Comments 4-2, 4-3, 4-4, 4-5, and 4-6 request the Commission to specify the detailed responsibilities of the dual-role position.

Resolution

The Commission has established guidance on the responsibilities of the licensed Senior Operator and the Shift Technical Advisor (NUREG-0737). It is not the objective of this Policy Statement to redefine those responsibilities.

3. Comments 7-1, 7-2, 7-3, 7-4, 7-5, 13-1, 13-7, 21-1, 21-2, 21-3, 21-4, 21-5, 21-6, 21-7, 21-8, 21-9, 28-1, 28-2, and 28-3 oppose combining the functions of the licensed Senior Operator and the Shift Technical.

Advisor and express concern that this individual would perform as an additional operator during an off-normal event, and therefore, would not retain the perspective required to provide the necessary engineering and accident assessment expertise.

Resolution: In response, the Commission notes it is the intent of the Policy Statement that the person in the dual-role position have specific training in accident assessment and provide that expertise l during an abnormal occurrence. The staffing levels required by 10 CFR 50.54(m)(2), which became effective January 1, 1984, increased the numbcr of Operators and Senior Operators on shift after the ENCLOSURE B 4

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STA position was initially required. This staffing increase should allow the individual functioning in the dual-role position to provide accident assessment expertise and to analyze and respond to off-normal events when needed.

Experience and study have shown that an STA, who is also an SRO, is better accepted by the shift crew. Therefore, the assessment and direction by an SRO/STA in an off-normal event would be better accepted by the crew than assessment and advice by an STA.

Additionally, possessing a Senior Operator's license should enhance correct assessment of the total situation.

4. Comments 2-1, 2-2, 2-3, 2-4, 2-7, 2-20, 2-21, 3-5, 8-3, 8-4, 8-5, 8-6, 8-7, 8-8, 8-9, 8-14, 8-15, 8-22, 8-24, 11-4, 12-2, 12-3, 12-4, 13-4, 13-6, 23-6, 24-1, 24-7, 26-10, 26-11, 27-5, 27-6, 29-1, 32-2, 33-1, 33-2, 33-3, 33-4, 33-7, 33-8, 33-9, 33-35, and 33-37 state that there is no technical justification to support a degree requirement or its equivalent (as defined in the Draft Policy Statement) for the individual filling the dual-role SR0/STA position or for any member of the operating crew. Commentors are concerned about safe plant operations while experienced shift members are away from their shift duties so that they may obtain a college degree. Commentors state that before any decisions are made regarding qualifications for this dual-role position, the requirements of the job must be determined.

Resolution: The Comission notes that since NUREG-0737, Item I. A.l.1 specified that the STA should have a bachelor's degree or the equivalent in a scientific or engineering discipline, the degree requirement is not new. This continues to be the educational requirement of an approved STA program. The educational requirements for the dual-role (SR0/STA) position have been changed to allow the individual to meet one of several educational alternatives or have four years of experience as a licensed operator at an operating l

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nuclear power plant and have successfully completed INP0-accredited STA ar;d SR0 training programs.

5. Equivalency: Several commentors (as listed in (a) through (e) below) commented on the concept of equivalency to the bachelor's degree. Since a bachelor's degree in engineering is no longer a basic requirement but rather one of six acceptable alternatives, the use of " equivalency" is not needed.

(a) Coment 33-25 states there are at least 27 categories of engineering, and asks which engineering degrees would be acceptable in meeting the requirements for a degree in engineering or related sciences. Comments 2-18, 10-1, 10-2, 10-3, and 33-24 express concern that the Bachelor of Professional Studies degree in Nuclear Industrial Operations may not be acceptable as an equivalent to an engineering degree.

Resolution: The NRC has provided minimum qualifications for the joint SR0/STA position. If the bachelor's degree in engineering alternative is chosen for meeting the educational requirement, it is the responsibility of the licensees to determine which engineering degrees are acceptable. The four-year Bachelor of Professional Studies in Nuclear Industrial Operations would be acceptable as would a bachelor's degree in engineering technology and a bachelor's degree in a physical science, provided they include course work in the physical, mathematical and/or engineering sciences. In addition other non-college degree educational alternatives are acceptable.

(b) Comments 3-7, 6-10, 6-11, 6-12, 6-13, 6-14, 9-3, 14-3, 14-4, and 27-7 point out that the PE license and successful completion of the EIT examination should not be used as equivalents for the bachelor's degree for the following reasons:

Each state has its own criteria for the PE license and for sitting for the EIT examination.

ENCLOSURE B

Most states require a four year degree for either of the designations.

• To meet the minimum requirements to sit for the exam, each state evaluates the education and experience of the applicants, and these vary from state to state.

Resolution: The PE and EIT alternatives are no longer " equivalents" but are two of several educational alternatives.

Most states require a bachelor's degree of the individual who has the designation of PE or EIT. Other states do not presently require a degree or have not in the past; however, they have a provision which allows registration of individuals who do not have a college degree.

These individuals have met the stringent requirements of a state board of registration through a combination of experience, examination, long-established practice and eminence. Although the requirements vary from state to state, they all require the applicants to show evidence that their engineering work experience is at a grade and of a type satisfactory to the state board. Many states require that a portion of the applicant's engineering work experience be at a level of direct control and supervision of engineering work. The majority of states also require that the individual successfully pass a fundamentals of engineering examination or the principles and practice of engineering examination, or both. In light of these rigorous state requirements, the PE and EIT options remain acceptable alternatives.

(c) Comments 6-16, 24-4, 25-1, and 33-36 state the need for further clarification as to what comprises Item c. of equivalency, " completion of the technical portion of an accredited, four year engineering degree." Comments 6-17, 6-18, 6-19, 8-11, 17-1, 22-4, and 22-5 state that this method of equivalency is excessive, is beneficial to very few ENCLOSURE B

candidates, may not be uniformly applied, and may undermine the attainment of a full four year engineering degree.

Resolution: The Policy Statement has been revised to read

" Successful completion of the technical portion of a bachelor's degree in engineering or engineering technology from an accredited institution." The technical portion of an engineering or engineering technology degree program is acceptable provided that it is comprised of courses in the physical, mathematical, and engineering sciences.

The Commission will find this alternative acceptable if it receives a communication from the credit-granting university that all the technical courses required in its engineering or engineering technology degree program have been successfully completed. These requirements ensure that the individual has substantial knowledge and understanding of the physical, mathematical, and engineering sciences and techniques underlying the basic requirement of an engineering or engfraering technology degree curriculum. However, since names of courses and amount of credit varies from university to university, 1 the Commission will not specify the technical courses required for this alternative.

Individuals who have completed 80 semester hours in the physical,

' ~

mathematical, and engineering sciences will be considered acceptable and will not require a communication from the university. The 80 semester hours is based on the Accreditation Board of Engineering and Technology (ABET) accreditation criteria for the basic requirements of a bachelor's degree in engineering program.

(d) Comments 2-8, 3-2, 3-4, 3-6, 13-2, 13-3, 13-5, 14-5, 18-3, 23-2, 24-2, 27-1, 27-2, 27-3, 27-4, 27-6, 33-10, 33-11, 33-25, 33-27, 33-28, and 33-34 state there is a greater value to on-the-job operating experience over a period of years than an engineering degree when responding to normal and abnormal events.

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Resolution: It is not the intent of this policy guidance to diminish the value of "on-the-job" operating experience. On the contrary, combining the STA and SR0 functions acknowledges the importance of both operating experience and technical knowledge.

(e) Comments 1-1, 1-2, 1-3, 1-4, 1-5, 1-6, 1-9, 1-10, 1-11, 3-8, 6-9, 8-12, 8-13, 9-2, 9-4, 9-5, 9-6, 9-7, 11-1, 11-2, 11-3, 11-4, 11-6, 12-5, 12-6, 12-7, 14-6, 15-3, 15-4, 15-5, 15-6, 15-7, 15-9, 15-10, 15-11, 15-12, 15-13, 16-4, 17-2, 17-3, 22-4, 22-5, 23-11, 23-12, 23-13, 23-14, 24-3, 24-5, 25-2, 26-1, 26-2, 26-3, 26-4, 26-5, 26-6, 26-7, 26-8, 26-9, 26-12, 30-3, and 34-1 state there is a need for greater flexibility in meeting equivalency. Some commentors suggest that rather than requiring a baccalaureate degree in engineering or related sciences of the individual filling the dual-role position, it would be more appropriate to require that person to have completed technical courses directly related to nuclear power plant operations. They suggest acceptance of an INP0 accreditation program, INP0 approved STA guidelines, an NRC approved curriculum, or the technical courses of an engineering technology degree program. In addition, one commentor expresses concern that the Policy Statement would invalidate its long-term plans for combining in one person the SR0/STA positions because that person would not meet the qualifications for equivalence as outlined in the Draft

-Policy Statement. Another commentor requests that a provision should be made for grandfathering persons "... who currently meet STA training requirements, and who are technically degreed SR0s."

Resolution

It is not the intent of this policy guidance to revise the educational requirements for a continuation of an approved STA program. However, the educational requirements for the SR0/S:A have been changed so that a bachelor's degree in engineering is not a basic requirement but one of several alternatives, including INP0 accreditation, acceptable in meeting the educational requirements.

i ENCLOSURE B L

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6. Comments 3-9, 11-5, 15-8, 23-1, 23-8, 33-16, 33-21, 33-22, 33-33, 34-2, and 34-3 state that the degree requirement or equivalent will impact shift staffing by blocking the career paths for some employees to Senior Operator positions, and by encouraging a higher turnover rate among degreed individuals who will leave shift work for other more desirable positions.

Resolution: The Shift Technical Advisors' position has always required a degree or equivalent. Under Option 2, this requirement remains the same. However, under Option 1 (the SR0/STA position),

the bachelor's degree in engineering is not a basic requirement, but one of several alternatives offered as acceptable in meeting the educational requirements. Hence, it should not block career paths nor should it affect the turnover rate.

7. Comments 6-4, 6-7, 6-8, 8-10, 16-2, 22-2, 23-4, and 29-2 state the need for further clarification regarding the use of Options 1 and 2 of the Policy Statement. They ask: May either or both options be used by any plant at any given time?

Resolution: Any one of the options may be used on each shift. For example, a utility can use one option on one shift and another option on another shift or the same option on each shift. The Policy Statement was changed to clarify this point. No further action is necessary by utilities which select Option 2, i.e., an approved STA program.

8. Recommendations for Clarifications and Editorial Changes (a) Comments 6-15, 16-3, 19-3, and 31-2 state that Item (c) in the definition of equivalency should be revised to include "related sciences."

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I Resolution: The term " equivalency" has been deleted and replaced with " educational alternatives."

(b) Comment 19-2 states that Option 2, Item a. of the Policy Guidance Section reads " Baccalaureate degree or equivalent in engineering or related sciences, and...". As currently worded, it could be interpreted that a baccalaureate degree in any area of study or equivalent in engineering or related sciences would be acceptable.

Resolution: That interpretation was not the intent of the guidance.

The Policy Statement has been reworded as follows, " bachelor's degree in engineering from an accredited institution."

(c) Comments 6-5 and 24-6 request that Option 2, Item c. should be rewritten to delete the following words "... plant design and layout, capabilities of instrumentation and controls in the control room..."

because these are the qualifications for a senior reactor operator license (Item b.) which is required along with Items a. and c. and is, therefore, a reiteration of Option 2, Item b.

Resolution: This option of the Policy Statement has been rewritten to delete those words.

(d) Comment 5-2 states that, to be consistent with the wording in the second sentence of the " Background" Section, i.e., "... engineering expertise be available to the shift supervisor...," the wording in the second sentence of the " policy guidance" section should be changed from

...at least one individual with this expertise is on shift" to "...is on duty."

Resolution: If a utility selects the dual-role SR0/STA option, then that individual must be on shift. If a utility selects continuation of an approved STA program, then the STA must assume an active role ENCLOSURE 8 L _ _ _. _ _ . _

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in shift activities. The Connission recognizes that several years may be required to meet this policy guidance.

(e) The first sentence of the Policy Guidance Section reads "The l

! Commission continues to stress the importance of providing engineering j and accident assessment expertise on shift." Connent 6-1 states that

" previous NRC official publications addressed (1) the accident assessmentroleand(2)theoperatingexperienceassessmentrole." The second role was not required to be filled on shift. The statement, therefore, is misleading in that linking of engineering and accident assessment is new and not " continuing."

Resolution: The functions of " engineering and accident assessment" ,

are separate from, and were not intended to address, the " operating experience assessment" function generally conducted by a group such as the Independent Safety Engineering Group (ISEG). The term

" accident assessment" as used in the Policy. Statement is intended to indicate actions taken while an event is in progress, not evaluations made after the event.

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(f) Comment 6-6 states "It is not clear whether an application to eliminate the STA from the Technical Specifications or Safety Analysis

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l ' Report needs to replace wording with new wording which is acceptable to NRC staff or whether a commitment letter containing utility policy will suffice. Current NRC practice, especially for new plants, is to include 4

'connitments' into ' conditions of license' in lieu of Technical Specifications."

4 Resolution: If a utility intends to utilize the dual-role position, then it must apply for a modification to their license (for a

licensee of an operating plant) or it must modify their Safety

! Analysis Report (for an applicant for an operating license).

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(g) The second sentence of the Policy Guidance Section reads

... licensees of operating plants and applicants for operating licenses should establish policies that..." Comment 6-2 states "The word

'should' is especially weak. Evidently, it is not required in order to modify the Technical Specification or FSAR."

Resolution: The word "should" is appropriate for use in policy guidance.

(h) The first sentence of the second paragraph of the Policy Guidance Section reads "The intent of this policy guidance can be accomplished..." Comment 6-3 states "The word 'can' is unusual (rather thanshould,shall,ormay). Evidently there are other means permissible."

Resolution: The Policy Statement has been revised as follows: "The intent of this policy guidance may be satisfied by either of the following options."

(i) Comment 22-3 requests that Option 2.b should be modified to include a reactor operator.

Resolution: The dual-role position must be filled by a licensed Senior Operator because of that position's need for extensive operating experience and training.

9. Comments 2-5, 2-6, 2-9, 2-10, 2-11, 2-12, 2-13, 2-14, 2-15, 2-16, 2-17 I

2-19, 8-1, 8-16, 8-17, 8-18, 8-19, 8-20, 8-23, 8-25, 18-4, 18-5, 23-5, 23-7, 23-9, 23-10, 29-3, 29-4, 29-5, 33-5, 33-6, 33-12, 33-13, 33-14, 33-15, 33-17, 33-18, 33-19, 33-20, 33-23, 33-26, 33-29, 33-30, 33-31, and 33-32 express concern that this draft Policy Statement is a prelude to an NRC proposed rule which would require the Shift Supervisor to hold a bachelor's degree.

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Resolution: This Policy Statement does not address the issue of requiring a degree for the Shift Supervisor. A proposal for a degreed Senior Manager was presented in SECY-84-106 which was later disapproved by the Commissioners.

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Index of Public Coments Comment Resolved by Comment Resolved by 1-1 5(e) 2-17 9 1-2 5(e) 2-18 5(a) 1-3 5(e) 2-19 9 1-4 5(e) 2-20 4 1-5 5(e) 2-21 4 1-6 5(e) 3-1 1 1-7 1 3-2 5(d) 1-8 1 3-3 1 1-9 5(e) 3-4 5(d) 1-10 5(e) 3-5 6 1-11 5(e) 3-6 5(d) 2-1 4 3-7 5(b) 2-2 4 3-8 5(e)

• 2-3 4 3-9 6 2-4 4 4-1 1 2-5 9 4-2 2 2-6 9 4-3 2 2-7 4 4-4 2 2-8 5(d) 4-5 2 2-9 9 4-6 2 2-10 9 5-1 1 2-11 9 5-2 8(d) 2-12 9 6-1 8(e) 2-13 9 6-2 8(g) 2-14 9 6-3 8(h) 2-15 9 6-4 7 2-16 9 6-5 8(c)

ENCLOSURE B l

Comment Resolved by Comment Resolved by 6-6 8(f) 8-10 7 6-7 7 8-11 5(c) 6-8 7 8-12 5(c) 6-9 5(e) 8-13 5(e) 6-10 5(b) 8-14 4 6-11 5(b) 8-15 4 6-12 5(b) 8-16 9 6-13 5(b) 8-17 9 6-14 5(b) 8-18 9 6-15 8(a) 8-19 9 6-16 5(c) 8-20 9 6-17 5(c) 8-21 1 6-18 5(c) 8-22 4 6-19 5(c) 8-23 9 7-1 3 8-24 4 7-2 3 8-25 9 7-3 3 9-1 1 7-4 3 9-2 5(e) 7-5 3 9-3 5(b) 8-1 9 9-4 5(e) 8-2' 1 9-5 Sle) 8-3 4 9-6 5(e) 8-4 4 9-7 5(e) 8-5 4 10-1 5(a) 8-6 4 10-2 5(a) 8-7 4 10-2 5(a) 8-8 4 11-1 5(e) 8-9 4 11-2 5(e)

ENCLOSURE 8 e O

Comment Resolved by Comment Resolved by 11-3 5(e) 15.4 5(e) 11-4 5(e) 15-5 5(e) 11-5 6 15-6 5(e) 11-6 5(e) 15-7 5(e) 12-1 1 15-8 6 12-2 4 15-9 5(e) 12-3 4 15-10 5(e) 12-4 4 15-11 5(e) 12-5 5(e) 15-12 5(e) 12-6 5(e) 15-13 5(e) 12-7 5(e) 16-1 1 13-1 3 16-2 7 13-2 5(d) 16-3 8(a) 13-3 5(d) 16-4 5(e) 13-4 4 17-1 5(c) 13-5 5(d) 16-4 5(e) 13-6 4 17-3 5(e) 13-7 3 18-1 1 14-1 1 18-2 1 14-2 1 18-3 5(d) 14-7 5(b) 18-4 9*

14-4 5(b) 18-5 9 14-5 5(d) 19-1 1 14-6 5(e) 19-2 8(b) 14-7 1 19-3 8(a) 15-1 1 20-1 1 15-2 1 20-2 1 15-3 5(e) 20-3 1 ENCLOSURE B

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S Comment Resolved by Comment Resolved by i'

21-1 3 24-1 4 21-2 3 24-2 5(d) 21-3 3 24-3 5(e) 21-4 3 24-4 5(c) 21-5 3 24-5 5(e) 21-6 3 24-6 8(c) 21-7 3 24-7 4 21-8 3 25-1 5(c) 21-9 3 25-2 5(e) 22-1 1 26-1 5(e) 22-2 7 26-2 5(e) 22-3 5(i) 26-3 5(e) 22-4 5(c) 26-4 5(e) l 22-5 5(c) 26-5 5(e)

I 23-1 6 26-6 5(e) j 23-2 ' 5(d) 26-7 5(e) 23-3 1 26-8 5(e) 23-4 7 26-9 5(e) 23-5 9 26-10 4 1

23-6 4 26-11 4

23-7 9 26-12 5('e) 23-8 6 27-1 5(d)

! 23-9 9 27-2 5(d) l 23-10 9 27-3 5(d) 23-11 5(e) 27-4 5(d)

23-12 5(e) 27-5 4 l 23-13 5(e) 27-6 5(d) 23-14 5(e) 27-7 5(b) j 27-8 4 ENCLOSURE B

Comment Resolved by Comment Resolved by 28-1 3 33-14 9 28-2 3 33-15 9 28-3 3 33-16 6 29-1 4 33-17 9 29-2 7 33-18 9 29-3 9 33-19 9 29-4 9 33-20 9 29-5 9 33-21 6 30-1 1 33-22 6 30-2 1 33-23 9 30-3 5(e) 33-24 5(a) 31-1 1 33-25 5(a) 31-2 8(a) 33-26 9 32-1 1 33-27 5(d) 32-2 4 33-28 5(d) 33-1 4 33-29 9 33-2 4 33-30 9 33-3 4 33-31 9 33-4 4 33-32 9 33-5 9 33-33 6 33-6 9 33-34 5(d) 33-7 4 33-35 4 33-8 4 33-36 5(c) 33-9 4 33-37 4 33-10 5(d) 34-1 5(e) 33-11 5(d) 34-2 6 33-12 9 34-3 6 33-13 9 ENCLOSURE B

i e ENCLOSURE C PROPOSED LETTERS TO CONGRESS e

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8 \o UNITED STATES NUCLEAR REGULATORY COMMISSION l

h WASHINGTON, D. C. 20655 1

%,...../

CHAIRMAN r

The Honorable Alan Simpson, Chairman 1 Subcommittee on Nuclear Regulation Comittee on Environment and Public Works United States Senate Washington, D. C.- 20510

Dear Mr. Chairman:

f

! The Nuclear Regulatory Comission has sent the enclosed Final Policy Statement on Engineering Expertise on Shift to the Office of the Federal l Register for publication. The Final Policy Statement provides licensees with '.

l two options to ensure that adequate engineering and accident assessment

{

expertise is available to the operating crew.

! Option 1 provides flexibility to licensees for meeting the requirements of 10 CFR 50.54(m)(2) and the requirement for a Shift Technical Advisor (STA) by

, allowing licensees to combine one of the required licensed Senior Reactor Operator (SRO) positions with the STA position into one dual-role (SR0/STA) position. The individual who fills this dual-role position should meet the STA criteria of NUREG-0737, Clarification of TMI Action Plan Requirements.

Item I.A.1.1, and meet one of several educational alternatives, or have four years experience as a licensed operator at an operating nuclear power plant 3

and have successfully completed INPO-accredited STA and SRO training i programs. This individual should also be licensed as a Senior Reactor j Operator on the nuclear power unit (s) to which assigned.

Option 2 allows licensees, and applicants for o with an approved Shift Technical Advisor (STA) program, perating licenses, as described in to continue NUREG-9737. However, the Comission encourages licensees to work towards having this STA assume an active role in shift activities. ,

Sincerely, i

l 1

l Nunzio J. Palladino

Enclosure:

As stated Identical letters sent to

cc: Senator Gary Hart The Honorable Morris K. Udall cc: Rep. Lujan Subcomittee on Energy and the Environment Comittee on Interior and Insular. Affairs The Honorable Edward J. Markey cc: Rep.

. Subcomittee on Energy Conser- Moorhead I vation and Power

! Comittee on Energy and Comerce l

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% 0 Y

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n VERSION B O

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ENCLOSURE D FEDERAL REGISTER NOTICE e e

[7590-01]

NUCLEAR REGULATORY COMMISSION I FINAL COMt11SS10N POLICY STATEMENT ON EhGINEERING EXPERTISE ON SHIFT l

AGENCY: Nuclear Regulatory Comission.

ACTION: Final Comission Policy Statement on Engineering Expertise on Shift.

SUMMARY

This Policy Statement presents the policy of the Nuclear Regulatory j Comission (NRC) with respect to ensuring that adequate engineering and accident assessment expertise is possessed by the operating staff at a nuclear power plant. This Policy Statement offers licensees three options for providing engineering expertise on shift and meeting licensed operator  ;

staffing requirements.

Option 1 provides for elimination of the separate Shift Technical Advisor (STA) position by allowing licensees to combine ene of the required Senior j Reactor Operator (SRO) positions with the STA position into a dual-role (SR0/STA) position. Under Option 2, a licensee may continue with an f

! NRC-approved STA program (i.e., a separate STA position), with certain modifications, while meeting licensed operator staffing requirements. Under Option 3, a licensee may place on shift an in-line supervisory position with the qualifications of both the STA and SRO and would allow for the elimination of the separate STA position. This in-line supervisory position would be in addition to the licensed operator staffing requirements.

4 EFFECTIVE DATE:*

FOR FURTHER If4 FORMATION CONTACT: Clare Goodman, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Cemission Washington, DC 20555 Telephone: 301/492-4894.

• Insert date of publication in the Federal Register.

ENCLOSURE D

[7590-01)

SUPPLEMENTARY INFORMATION:

Backarcund Following the accident at Three Mile Island in March 1979, a number of studies were conducted to determine why the accident occurred, what factors might have contributed to its severity, and what the industry and the NRC could do to prevent the recurrence of the same or a similar accident. These studies concluded, among other things, that a number of actions should be taken to improve the ability of shift operating personnel to reccgnize, diagnose, and effectively deal with plant transients or other abncrmal conditions.

To address these reconnended improvements, the NRC initiated both short-term and long-term efforts. The short-term effort required that as of January 1, 1980, each nuclear power plant have on duty a Shift Technical Advisor (STA) whose function was to provide engineering and accident assessment advice to the Shift Supervisor in the event of abnormal or acciddnt conditions. The STA was required to have a bachelor's degree in engineering or the equivalent and specific training in plant response to transients and accidents. The STA requirement was identified to licensees via NUREG-0578 (July 1979)I and NUREG-0737 (November 1980) and was later mandated by plant-specific Confirmatory Orders. -

Concurrently, the NRC and industry embarked on a longer-term effort aimed at upgrading staffing levels and the training and qualifications of the operating staffs, improving the man-machine interface, and increasing capabilities for responding to emergencies. At the time the STA requirement was imposed, it was intended that use of the dedicated STA would be an interim measure only until these longer-term goals were achieved, l

Referenced materials are available at the NRC Document Room at 1717 H Street, NW, Washington, DC 20555.

ENCLOSURE D

[7590-01)

These long-term initiatives collectively result in an improvement in the capabilities and qualifications of the shift crew and their ability to diagnose and respond to accidents. These initiatives include shift staffing increases, training and qualification program improvements, hardware modifications, emphasis on human factors considerations, procedural upgrades, and development of extensive emergency response organizations to augment on-shift capabilities during abnormal conditions. They either have been or are in the process of being implemented and include the following:

• Every licensee of a nuclear power plant has been required to develcp and implement extensive emergency response organizations for the express purpose of assisting in the diagnosis and mitigation of accidents. These organizations are required to be fully mobilized within one hour and provida substantial " engineering expertise" assistance to the shift crew to assist in accident diagnosis and mitigation / protective action strategy.

All operating nuclear power plants are currently required to have emergency plans in place and to conduct exercises on a regular basis.

• Irplementation of Supplement 1 to hbREG-0737 requires all nuclear plant licensees to conduct a control Room Design Review (CRDR) of their facility and implement improvements identified in the human factors review.

Imglementation of CRDR findings will result in an improvement in the ,

operator's ability to understand and respond to abnormal situations. This will minimize confusion during an accident and increase the likelihood of correct operator actions. All licensees have been required to submit plans and schedules for conducting the CRDR.

In cooperation with the nuclear steam supply system vendor owners groups, the industry has developed symptom-based emergency operating procedures.

The generic development work for these procedures has been completed.

These procedures are designed to make it easier for the operators to recognize, diagnose, and effectively deal with plant transients and other abnormal conditions. They are designed to aid the operator in maintaining critical safety functions, i.e., control reactivity, remove core heat.

ENCLOSURE D

[7590-01) provide an ultimate heat sink, and contain radioactivity, thereby minimizing the probability of a serious incident. These new procedures are of significant benefit to the operator in accident diagnosis and overall response capabilities. All licensees have either implemented or are in the process of c:nverting to these new procedures.

Implementation of Supplement 1 to NUREG-0737 requires installation of a safety parameter display system (SPDS). The SPDS is a system for rapid and concise display of vital plant status indications in the event of transients or accidents. The availability of this information via the SPDS will assist the operator in performing mitigating or stabilizing actions by providing essential information in a cicar and timely manner.

Upgrading and installation of additional instrumentation for post-accident monitoring, as delineated in Regulatory Guide 1.97 and Supplement 1 to NUREG-0737, will assist the operator in monitoring plant status and the course of an accident. The addition of this type of instrumentation, in conjunction with benefits of the SPDS display, will enhance event diagnosis and lessen the degree of reliance on the operator's analytical ability. All licensees have provided plans and schedules for Regulatory Guide 1.97 upgrades.

• Effective January 1, 1984, the minimum shift crew for a single-unit plant was increased to two licensed senior reactor operators and two licensed reactor operators on each shift; similar increases were required for multi-unit plants. This has resulted in two positive effects. First, an additional senior licensed operator has been added to each shift, thereby providing one more perspective to focus attention on accident assessment and overall emergency direction. Second, one of these senior licensed operators is now required to be in the control room at all times. As a result, there is assurance that additional experienced senior level expertise will be immediately available at the onset of an accident.

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l The industry, through the Institute of Nuclear Power Operations (INP0),

has established a comprehensive, nationwide accreditation program. This program provides for upgrading of the training programs for all licensed operators as well as the training for other key positions that can directly affect plant operations. An independent Accrediting Board reviews the evaluations of each utility's training programs and either grants accreditation or defers accreditation until the programs meet high standards. Licensees are expected to have these training programs ready for accreditation by the end of 1986. These programs will ensure that operating personnel possess qualifications commensurate with the requirements of their jobs. This issue is being addressed by the Comission via a separate Policy Statement.

Extensive additions have been made to utility training staffs. The number of full-time personnel per plant dedicated to training increased industry-wide by approximately 375% between 1979 and 1984. This exemplifies the increased recognition of the importance of training and requalification to the effectiveness and capabilities of the shift crew.

As specified in NUREG-0737, Item II.B.4, all licensed operators receive training specifically directed at recognizing and mitigating core damage.

This training serves to familiarize the operator with possible causes and symptoms of a damaged core and expected post-accident plant conditions and corrective actions. As a result, the operator is better prepared to recognize and respond to degraded plant conditions. All licensed operators are required to successfully complete this training.

Simulators are now extensively used throughout the industry; 10 were in use in 1979; at the end of 1984, 40 were in use; and a total of 69 simulators are now in operation or are planned. Additionally, NRC criteria for operator licensing now require simulator training. The use of simulators provides more comprehensive training for the operato: and allows him to experience transients and accidents in a trainino ENCLOSURE D .

[7590-01] l environment. The increased use of simulators will improve the capabilities of the shift crew to respond to emergencies.

The industry, through INP0, has developed and implemented a comprehensive system for gathering and analyzing information on events that occur in the industry and providing feedback to operating personnel. This allows other licensees to revise their facility design or operation, as necessary, based on the lessons learned in the industry. The NRC endorsed INP0's "SEE-IN" program in Generic Letter 82-04 as acceptable for meeting the infonnation-gathering elements of NUREG-0737, Item I.C.S.

Collectively, these initiatives result in a significant enhancement of the capabilities of the shift crew to diagnose and mitigate accidents.

Draft Policy Statement On July 25, 1983, the Comission published in the Federal Register (48 FR 33781) a Draft Policy Statement on Engineering Expertise on Shift to reassert the Comission's belief that adequate engineering and accident assessment expertise must be available to the operating crew at all nuclear power plants.

The Draft Policy Statement on Engineering Expertise on Shift offered ,

licensees of nuclear power plants and applicants for operating licenses two options for meeting the staffing requirements of 10 CFR 50.54(m)(2) and the requirement in NUREG-0737, Item 1.A.1.1 for a Shift Technical Advisor (STA).

Option 2 gave them the opportunity to combine the licensed Senior Operators' (SRO) and Shift Technical Advisors' (STA) functions. Licensees that did not want to combine the SR0 and STA functions could continue with their approved STA program in accordance with the description in NUREG-0737, " Clarification of TMI Action Plan Requirements."

Interested persons, applicants, and licensees were invited to submit written coments to the Secretary of the Comission. Following consideration of the ENCLOSURE D

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coments, the Comission amended the Draft Policy Statement, as discussed in the following sections.

Comments on the Draft Policy Statement A total of 34 responses were received and evaluated. The public co m ets related primarily to the combined SRO/STA position. The follow ag aieassion highlights the major points raised in the coments and the resolution of those coments. A detailed analysis of all public coments and their resolution was also prepared. (Copies of those letters and the detailed analysis of all the public coments are available for public inspection and copying for a fee at the NRC Public Document Room at 1717 H Street fl.W.,

Washington, DC 20555.)

Of the 34 letters received, 18 included support for the flexibility provided by the Policy Statement. The major points made in the public comments were as follows:

1. Support for the Policy Statement;

2. Opposition to combining the functions of the SRO and the STA;

3. Opposition to a bachelor's degree requirement for the SR0/STA position;

4. Recomendation that equivalency to a bachelor's degree be further defined;

5. Concern that a bachelor's degree requirement for the SRO/STA position would result in a higher turnover rate and potentially blocked career paths for operators; and

6. Reference to a proposed bachelor's degree requirement for the Shift Supervisor, believed to be currently under NRC consideration.

A general description of the major public coments and responses to these are as follows:

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1. Support for the Policy Statement -

Eighteen commentors favored the option offered in the Draft Policy Statement of combining the SR0 and STA functions into one dual-role position. They endorsed the flexibility provided by the Policy Statement. They supported the view that it is beneficial to combine engineering expertise with operating experience.

2. Opposition to the Dual-Role SR0/STA Position -

Four individual comentors stated that there is a possibility that the person in the dual-role position would function as an additional operator in the event of an abnormal occurrence instead of being available to provide the engineering and accident assessment expertise necessary in these circumstances. In response, the Commission notes it is the intent of the Policy Statement that the person in the dual-role position have specific training in accident assessment and provide that expertise during an abnormal occurrence. The staffing levels required by 10 CFR 50.54(m)(2), which became effective January 1, 1964, increased the number of operators and Senior Operators on shift after the initial STA position was required. This increase in shift personnel would allow the SR0/STA to provide both accident assessment expertise and to analyze and respond to off-normal events when needed. Experience has shown that an STA, who is also an SRO, is better accepted by the shift crew.

Therefore, the assessment and direction by an SR0/STA in an off-normal l event might be better accepted by the crew than assessment and advice by l

a separate STA.

l

3. Opposition to a Bachelor's Degree for the SR0/STA Position -

Several commentors felt that the person who filled the SR0/STA position should not be required to have a bachelor's degree. The Commission notes that since NUREG-0737, Item I.A.1.1, specified that the STA should have a l

l l

l ENCLOSURE D

[7590-01]

bachelor's degree or the equivalent in a scientific or engineering discipline, the degree requirement is not new. This continues to be the educational requirement for a dedicated STA. However, the educational requirements for the dual-role (SR0/STA) position have been changed to allow the individual to meet one of several educational alternatives or have four years of experience as a licensed operator at an operating nuclear power plant and have successfully completed INP0-accredited STA and SR0 training programs.

4. Recomendation that Equivalency to a Bachelor's Degree Be Further Defined -

Many commentors stated that the equivalency options were too restrictive or required clarification. In response, the Commission notes that a bachelor's degree in engineering is no longer a basic requirement but is one of several educational alternatives. The term " equivalent" has been deleted.

Changes related to educational alternatives are summarized below:

Most states require a bachelor's degree of the individual who has the designation of PE or EIT. Other states do not presently require a

~

degree or have not in the past; however, they have a provision'which allows registration of these individuals if they meet the stringent requirements of a state board of registration through a combination of experience, examination, long-established practice and eminence.

Although the requirements vary from state to state, they all require the applicants to show evidence that their engineering work experience is at a grade and of a type satisfactory to the state board. Many states require that a portion of the applicant's engineering work experience be at a level of direct control and supervision of engineering work. The majority of statas also require that the individual successfully pass a fundamentals of engineering examination or the principles and practice of engineering examination, or both.

1 ENCLOSURE D i

[7590-01]

In light of these rigorous state requirements, the PE and EIT options <

remain acceptable alternatives.

Other bachelor's degrees determined to be acceptable alternatives

. are a bachelor's degree in engineering technology from an accredited institution or a bachelor's degree in a physical science from an accredited institution. These degree programs are acceptable provided 4 that they include course work in the physical, mathematical, and/or engineering sciences. These requirements are intended to ensure that the individual has substantial knowledge and understanding of the physical and mathematical sciences and the principles of engineering.

Another acceptable alternative requires successful completion of the technical portion of a bachelor's degree in engineering or engineering technology from an accredited institution. The technical portion of an engineering or engineering technology degree program is acceptable I

provided that it is comprised of courses in the physical, mathematical and engineering sciences. The Commissior, will find this alternative acceptable if it receives a communication from the credit-granting university that all the technical courses required in its engineering or engineering technology degree program have been successfully 4

completed. Since names of courses and amount of credit vary from '

~

' university to university, the Commission will not specify the technical courses required for this alternative. However, individuals who have completed 80 semester hours in the physical, mathematical and engineering sciences will be considered acceptable and will not require a communication from the university. The 80 semester hours requirement is based on the ABET accreditation criteria for the basic requirements of a bachelor's degree in engineering.

5. Concern that a Bachelor's Degree Requirement Would Result in a Higher Turnover Rate and a Potentially Blocked Career Path for Shift Employees -

4 I ENCLOSURE'D

.-. _. -- ,---,..re_., - . . .-m ,,,_ ... , . , , , _ . . ,

. . ~ . . , , _ . , , _ _ . , _ , , - . - , , _ _ _ , . . _ - ,

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[7590-01]

Several commentors expressed concern that degreed individuals would leave for other positions in the plant, contributing to a high turnover rate on shift. Another concern cf commentors was that career paths to the senior operating positions would be blocked for those individuals without degrees. In response, the Commission notes that since the bachelor's degree in engineering is no longer a basic requirement for the SR0/STA, but is or.ly one of several educational alternatives, this should not

- affect career paths for individuals without a degree nor should it contribute to a high turnover rate.

6. Reference to a Proposed Bachelor's Degree Requirement for the Shift Supervisor -

A few commentors on the Federal Register notice took the opportunity to commeat on whether a bachelor's degree should be required for specific positions in the operating staff of nuclear power plants, and in particular, for the Shift Supervisors' position.

The Final Policy Statement on Engineering Expertise on Shift does not address the issue of requiring a degree for the Shift Supervisor. Early in 1984, the staff considered a " proposed Rulemaking Concerning Requirements for Senior Managers" in SECY-84-106. This preposed .

rulemaking would have required that an additional degreed, SRO-licensed individual be assigned to each shift of a nuclear power plant who would be responsible for managerial direction of all plant functions including chemistry, health physics, maintenance, operations, security, and technical services. Following several meetings with the staff and industry representatives, the Commission concluded that this proposed rulemaking was not warranted, and it was disapproved. One of the primary bases for the proposed senior manager rule was the neea to provide engineering expertise to the shift crew, which is also the primary objective of this Policy Statement.

ENCLOSURE D

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Development of Final Policy Statement As a result of the analysis of public comments received, the Comission clarified and expanded the educational alternatives of the dual-role (SR0/STA) position. The . revisions to the Draft Policy Statement resulted in SECY-84-355, a draft Final Policy Statement on Engineering Expertise on Shift.

The main difference between the Draft Policy Statement and SECY-84-355 concerns the educational qualifications for the dual-role position. The Draft Policy Statement required, of the person filling the dual-role position, a baccalaureate degree in engineering or related sciences or one of three equivalents to the degree. SECY-84-355 required a bachelor's degree in engineering from an accredited institution or one of five acceptable alternatives to the engineering degree.

The staff met with the Comissioners on November 5,1984, to discuss SECY-84-355. As a result of that meeting, the Comissioners directed the i staff to coordinate the Policy Statement on Engineering Expertise on Shift with the Nuclear Utilities Management and Human Resources Committee (NUMARC).

This Final Policy Statement is the result of the Comissioners' direction, staff analysis, resolution to public coments, and staff coordination with NUMARC. .

One major change from the Draft Policy Statement to this Final Policy Statement is the qualification requirements for the dual-role position (SR0/STA). The Draft Policy Statement required a baccalaureate degree or equivalent in engineering or related sciences. The Final Policy Statement requires that one of several educational alternatives be met or that a

~

licensed operator have four years experience as a licensed operator at an operating nuclear power plant and have successfully completed INP0-accredited STA and SRO training programs. Hence, the Final Policy Statement accepts college-level training instead of formal college education for the dual-role position.

ENCLOSURE D

. .__ ~_ -

[7590-01]

A second major difference in the Final Policy Statement is the addition of a third option: an "in-line supervisory operations position." Under Option 3, each shift would have a position, in addition to the licensed positions required by 10 CFR 50.54(m)(2), that has supervisory authority over the 4

licensed operators. The individual filling this position would hold a senior operator's license for at least one unit on site, meet the STA criteria of NUREG-0737, Item I.A.1.1, and fulfill one of severa' educational alternatives.

Finally, although the Final Policy Statement includes an option which allows for the continued use of the STA position, as did the Draft Policy Statement, the former encourages licensees to work towards having the STA assume an active role in shift activities.

While it is the Commission's preference that licensees move toward the dual-role (SR0/STA) position, continuation of an approved STA program remains an acceptable option. The Commission acknowledges that some licensees may prefer the dedicated STA position for a number of reasons. The Commission also recognizes the advantages of integrating the qualifications and training of the STA into the licensed operating staff. Thus, this Policy Statement is I

structured to allow different means for ensuring that the plant operating staff has adequate engineering and accident assessment expertise.

i Policy Statement l.

The Commission continues to stress the importance of providing engineering

and accident assessment expertise on_ shift. The term " accident assessment" l is defined as immediate actions needed to be taken while an event is in progress. This Policy Statement does not require any changes in the formal education and training of operators and senior operators not expected to fulfill the dual-role SR0/STA position or the in-line supervisory position.

The intent of this policy guidance may be satisfied by any of the options described below. The Commission prefers a combined SRO/STA position ENCLOSURE D l

l i

[7590-01]

1 l

(Option 1). In addition, in the long term, the Ccmmission would prefer that 'l the STA be combined with the Shift Supervisor position.

Either Option 1, Option 2 or Option 3 may be used on each shift. For example, a utility may use Option 1 on some shifts.and Option 2 on other shifts, or may use the same option on every shift. If Option 1 or Option 3 is used for a shift, then the separate STA position may be eliminated for that shift.

Option 1: Combined SRO/STA Position This option is satisfied by assigning an individual with the following qualifications to each operating shift crew as one of the SR0s (preferably the Shift Supervisor) required by 10 CFR 50.54(m)(2)(1);

a. Licensed as a senior operator on the nuclear power unit (s) to which assigned, and

b. Completion of either of the following training and educational requirements ((1) or (2)):

(1) Meets the STA criteria of NUREG-0737, Item I.A.1.1, and one of the following educational alternatives: -

i (a) Bachelor's degree in engineering from an accredited institution; (b) Professional Engineer's (PE) license; (c) Successful completion of the Engineer-in-Training (EIT) examination; (d) Bachelor's degree in engineering technology (BET) from an accredited institution, including course work in the l

physical, mathematical, and/or engineering scie'nces; (e) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; or ENCLOSURE D

[7590-01]

(f) Successful ccmpletion of the technical portion of a i bachelor's degree in engineering or engineering technology I

from an accredited institution. The technical portion should be comprised of courses in the physical, mathematical, and engineering sciences.

t or (2) Four years of experience as a licensed operator at an operating nuclear power plant and successful completion of INP0-accredited STA and SRO training programs. The programs described in the

. INPO Guidelines " Nuclear Power Plant Shift Technical Advisor:

Recommendations for Position Description, Qualifications, Education, and Training," and either "FWR Control Room Operator, Senior Control Room Operator, and Shift Supervisor Qualification" are acceptable to satisfy the requirements for STA and SR0 training. It is not the intent of this policy guidance to require that personnel who complete STA or SRO training programs prior to their accreditation by INPO be required to repeat that

, training subsequent to INP0 accreditation, except for participation in continuing training. The items added to the

~

programs as a result of accreditation would be included in the ~

I next training cycle.

Option 2: Continued Use of STA Position This option is satisfied by placing on each shift a dedicated Shift Technical Advisor (STA) who meets the STA criteria of NUREG-0737, Item l

I.A.1.1. The STA should assume an active role in shift activities. For example, the STA should review plant logs, participate in shift turnover i activities, and maintain an awareness of plant configuration and status.

ENCLOSURE D

- - - + - - e w .m , -we - - - ~ - - - - , -------.,4 ,--,y e-,,-r, , ----r -----,e --m

[7590-01]

Option 3: In-Line Supervisory Operations Position This option is satisfied by placing on each shift an in-line supervisory position to be filled by an individual with the qualifications of a. and

b. below. This individual would be in addition to the licensed positions required by 10 CFR 50.54(m)(2).

Qualifications:

a. Holds a senior operator's license for at least one unit on site, and

b. Meets the STA criteria of NUREG-0737, Item I.A.1.1 and one of the following educational alternatives:

(1) Bachelor's degree in engineering from an accredited institution; (2) Professional Engineer's (P.E.) license; (3) Successful completion of the Engineer-in-Training (EIT) examination; (4) Bachelor's degree in engineering technology (BET) from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; (5) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; or -

(6) Successful completion of technical portion of a bachelor's degree in engineering or engineering technology from an accredited institution. The technical portion should be comprised of courses in the physical, mathematical, and engineering sciences.

This individual may have any additional credentials or responsibilities as may be defined by the licensee.

The Comission recognizes that several years may be required to meet this policy guidance. For the interim period, continuation of an STA program that meets the guidance of NUREG-0737, Item I.A.1.1 is acceptable. Licensee ENCLOSURE D

[7590-01]

proposals different than the three options described above will be considered by the staff on a case-by-case basis.

To eliminate the STA position, a licensee of an operating reactor should apply for a modification to its license and an applicant for an operating license should modify its Final Safety Analysis Report to reflect elimination of the STA position and a commitment to provide a required SR0 on shift with the qualifications described in Options 1 or 3 above.

NRC will accept a utility's modifications if it finds that the proposal meets the intent of this Policy Statement. On a case-by-case basis, utilities with multi-unit sites with dual-licensed SR0s will ensure that an adequate number of licensed staff are available and that engineering expertise can be provided when needed. It is the intent of this Policy Statement to ensure that adequate engineering and accident assessment expertise is possessed by the plant operating staff.

Dated at Washington, DC,*cn this day of , 1985.

For the Nuclear Regulatory Commission, Samuel J. Chilk, Secretary of the Commission.

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ENCLOSURE D

1 ENCLOSURE E RESOLUTION OF PUBLIC COMMENTS e *

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1 1

Resolution of Public Comments on Draft Policy Statement on Engineering Expertise on Shift A. List of Commentors Letter Number Commentor 1 Glenn L. Koester, Kansas Gas & Electric Company 2 PROS Society 3 Paul Swinburne, Oswego, NY 4 Raymond P. Termini, Commonwealth Edison 5 W. L. Stewart, Virginia Electric and Power Company 6 D. L. Farrar, Commonwealth Edison 7 Donald A. Bearden, Arroyo Grande, CA 8 Thomas C. Houghton, KMC, Inc.

9 M. R. Wisenburg, Houston Lighting and Power 10 D. W. Jones, Memphis State University 11 J. Ed Smith, Chairman, ANS-3 12 Leo Mariani, American Nuclear Insurers 13 Marvin W. Onnen, Big Lake, MN 14 Hal B. Tucker, Duke Power Company 15 G. C. Sorenson, Washington Public Power Supply System 16 J. O. Schuyler, Pacific Gas and Electric Company 17 Donald J. Broehl, Portland General Electric Company 18 B. D. Kenyon, Pennsylvania Power and Light Company 19 John DeVincentis, Public Service of New Hampshire (Yankee Atomic Electric Company) 20 J. R. Thorpe, GPU Nuclear Corporation 21 Jimmie Harris, La Jolla, CA 22 J. P. Bayne, New York Power Authority 23 Joseph W. Williams, Jr., Atomic Industrial Forum, Inc.

ENCLOSURE E 1

. 24 John R. Marshall, Arkansas Power and Light Company 25 Donald Schnell, Union Electric Company 26 W. G. Counsil, Northeast Utilities 27 Robert E. Uhrig, Florida Power and Light Company 28 M. I. Lewis, Philadelphia, PA 29 R. E. Helfrich, Yankee Atomic Electric Company 30 John E. Parkyn, Stoddard, WI 31 David Musolf, Northern States Power Company 32 R. B. Bradbury, Stone & Webster Engineering Corporation 33 David E. LaBarge, Professional Reactor Operator Society 34 C. W. Fay, Wisconsin Electric Power Company Comments are referred to by two numbers. The first corresponds to the letter number and the second refers to the comment number within the letter. For i example, comment 2-1 refers to the first comment in letter number 2.

4 4

ENCLOSURE E

1. Comments 1-7, 1-8, 3-1, 3-3, 4-1, 5-1, 8-2, 8-21, 9-1, 12-1, 14-1, 14-2,

! 14-7, 15-1, 15-2, 16-1, 18-1, 18-2, 19-1, 20-1, 20-2, 20-3, 22-1, 23-3, 30-1, 30-2, 31-1, and 32-1 favored the option offered in the Draft Policy Statement of combining the licensed Senior Operators' (SRO) and Shift Technical Advisors' (STA) functions into one dual-role position.

They endorsed the flexibility provided by the Policy Statement. They supported the view that it is beneficial to combine engineering expertise with operating experience.

Resolution: The coments have been noted.

l 1

2. Coments 4-2, 4-3, 4-4, 4-5, and 4-6 request the Comission to specify the detailed responsibilities of the dual-role position.

. Resolution: The Comission has established guidance on the responsibilities of.the licensed Senior Operator and the Shift Technical Advisor (NUREG-0737). It is not the objective of this Policy Statement to redefine those responsibilities.

3. Coments 7-1, 7-2, 7-3, 7-4, 7-5, 13-1, 13-7, 21-1, 21-2, 21-3, 21-4, 21-5, 21-6, 21-7, 21-8, 21-9, 28-1, 28-2, and 28-3 oppose combining the functions of the licensed Senior Operator and the Shift Technical ,

Advisor and express concern that this individual would perform as an additional operator during an off-normal event, and therefore, would not retain the perspective reytired to provide the necessary engineering and accident assessment expertise.

l Resolution: In response, the Comission notes it is the intent of the Policy Statement that the person in the dual-role position have specific training in accident assessment and provide that expertise during an abnormal occurrence. The staffing levels required by 10 CFR 50.54(m)(2), which became effective January 1, 1984, increased the number of Operators and Senior Operators on shift after the ENCLOSURE E

STA position was initially required. This staffing increase should allow the individual functioning in the dual-role position to provide accident assessment expertise and to analyze and respond to off-normal events when needed.

Experience and study have shown that an STA who is also an SR0 is better accepted by the shift crew. Therefore, the assessment and direction by an SR0/STA in an off-normal event would be better I accepted by the crew than assessment and advice by an STA.

Additionally, possessing a Senior Operator's license should enhance correct assessment of the total situation.

4. Comments 2-1, 2-2, 2-3, 2-4, 2-7, 2-20, 2-21, 3-5, 8-3, 8-4, 8-5, 8-6, 9 8-7, 8-8, 8-9, 8-14, 8-15, 8-22, 8-24, 11-4, 12-2, 12-3, 12-4, 13-4, 4

13-6, 23-6, 24-1, 24-7, 26-10, 26-11, 27-5, 27-8, 29-1, 32-2, 33-1, 33-2, 33-3, 33-4, 33-7, 33-8, 33-9, 33-35, and 33-37 state that there is no technical justification to support a degree requirement or its

) equivalent (as defined in the Draft Policy Statement) for the individual

, filling the dual-role SR0/STA position or for any member of the operating crew. Comentors are concerned about safe plant operations while experienced shift members are away from their shift duties so that they may obtain a college degree. Comentors state that before any i -decisions are made regarding qualifications for this dual-role posit';n, j the requirements of the job must be determined.

1 Resolution: The Commission notes that since NUREG-0737, Item I.A.1.1 specified that the STA should have a bachelor's degree or the equivalent in a scientific or engineering discipline, the degree i requirement is not new. This continues to be the educational requirement of an approved STA program. The educational requirements

for the dual-role (SR0/STA) position have been changed to allow the j individual to meet one of several educational alternatives or have four years experience as a licensed operator at an operating nuclear 1

3 ENCLOSURE E

power plant and have successfully completed INP0-accredited STA and SR0 training programs.

5. Equivalency: Several comentors (as listed (a) through (e) below) comented on the concept of equivalency to the bachelor's degree. Since a bachelor's degree in engineering is no longer a basic requirement but rather one of six acceptable alternatives the use of " equivalency" is not needed.

(a) Coment 33 *d states there are at least 27 categories of engineering, and asks which engineering degrees would be acceptable in meeting the requirements for a degree in engineering or related sciences. Coments 2-18, 10-1, 10-2, 10-3, and 33-24 express concern that the Bachelor of Professional Studies degree in Nuclear Industrial Operation,s may not be acceptable as an equivalent to an engineering degree.

Resolution: The NRC has provided minimum qualifications for the joint SR0/STA position. If the bachelor's degree in engineering alternative is chosen for meeting the educational requirement, it is the responsibility of the licensees to determine which engineering degrees are acceptable. The four-year Bachelor of Professional Studies in Nuclear Industrial Operations would be acceptable as would a bachelor's degree in engineering technology and a bachelor's degree in a physical science, provided they include course work in the physical, mathematical and/or engineering sciences. In addition other non-college degree educational alternatives are acceptable.

(b) Coments 3-7, 6-10, 6-11, 6-12, 6-13, 6-14, 9-3, 14-3, 14-4, and 27-7 point out that the PE license and successful completion of the EIT examination should not be used as equivalents for the bachelor's degree for the following reasons:

Each state has its own criteria for the PE license and for sitting for the EIT examination.

ENCLOSURE E

. 1 Most states require a four year degree for either of the designations.

To meet the minimum requirements to sit for the exam, each state evaluates the education and experience of the applicants, and ,

these vary from state to state.

Resolution

The PE and EIT alternatives are no longer " equivalents" but are two of several educational alternatives.

l Most states require a bachelor's degree of the individual who has the designation of PE or EIT. Other states do not presently require a degree or have not in the past; however, they have a provision which allows registration of individuals who do not have a college degree.

4 These individuals'have met the stringent requirements of a state l board of registration through a combination of experience, i examination, long-established practice and eminence. Although the l

requirements vary from state to state, they all require the

) applicants to show evidence that their engineering work experience is at a grade and of a type satisfactory to the state board. Many states require that a portion of the applicant's engineering work experience be at a level of direct control and supervision of engineering work. The majority of states also require that the individual successfully pass a fundamentals of engineering examination or the principles and practice of engineering examination, or both. In light of these rigorous state requirements, the PE and EIT options remain acceptable alternatives.

(c) Comments 6-16, 24-4, 25-1, and 33-36 state the need for further clarification as to what comprises Item c. of equivalency, " completion of the technical portion of an accredited, four year engineering degree." Coments 6-17, 6-18, 6-19, 8-11, 17-1, 22-4, and 22-5 state that this method of equivalency is excessive, is beneficial to very few ENCLOSURE E

candidates, may not be uniformly applied, and may undermine the attainment of a full four year engineering degree.

Resolution: The Policy Statement has been revised to read

" Successful completion of the technical portion of a bachelor's degree in engineering or engineering technology from an accredited institution." The technical portion of an engineering or engineering technology degree program is acceptable provided that it is comprised of courses in the physical, mathematical, and engineering sciences.

The Commission will find this alternative acceptable if it receives a communication from the credit-granting university that all the technical courses required in its engineering or engineering l

technology degree program-have been successfully completed. These requirements ensure that the individual has substantial knowledge and

' understanding of the physical, mathematical, and engineering sciences and techniques underlying the basic requirement of an engineering or engineering technology degree curriculum. However, since names of courses and amount of credit varies from university to university, the Commission will not specify the technical courses required for this alternative.

Individuals who have completed 80 semester hours in the physical, i mathematical, and engineering sciences will be considered acceptable and will not require a communication from the university. The 80 semester hours is based on the Accreditation Board of Engineering and

[

Technology (ABET) accreditation criteria for the basic requirements of a bachelor's degree in engineering program.

l

{ (d) Comments 2-8, 3-2, 3-4, 3-6, 13-2, 13-3, 13-5, 14-5, 18-3, 23-2, 24-2, 27-1, 27-2, 27-3, 27-4, 27-6, 33-10, 33-11, 33-25, 33-27, 33-28, and 33-34 state there is a greater value to on-the-job operating experience over a period of years than an engineering degree when responding to normal and abnonnal events.

ENCLOSURE E

Resolution: It is not the intent of this policy guidance to diminish the value of "on-the-job" operating experience. On the contrary, combining the STA and SR0 functions acknowledges the importance of both operating experience and technical knowledge.

(e) Coments 1-1, 1-2, 1-3, 1-4, 1-5, 1-6, 1-9, 1-10, 1-11, 3-8, 6-9, 8-12, 8-13, 9-2, 9-4, 9-5, 9-6, 9-7, 11-1, 11-2, 11-3, 11-4, 11-6, 12-5, 12-6, 12-7, 14-6, 15-3, 15-4, 15-5, 15-6, 15-7, 15-9, 15-10, 15-11, 15-12, 15-13, 16-4, 17-2, 17-3, 22-4, 22-5, 23-11, 23-12, 23-13, 23-14, 24-3, 24-5, 25-2, 26-1, 26-2, 26-3, 26-4, 26-5, 26-6, 26-7, 26-8, 26-9, 26-12, 30-3, and 34-1 state there is a need for greater flexibility in meeting equivalency. Some commentors suggest that rather than requiring a baccalaureate degree in engineering or related sciences of the individual filling the dual-role position, it would be more appropriate to require that person to have completed technical courses directly ,

related to nuclear power plant operations. They suggest acceptance of an INP0 accreditation program, INP0 approved STA guidelines, an NRC approved curriculum, or the technical courses of an engineering technology degree program. In addition, one commentor expresses concern that the Policy Statement would invalidate its long-term plans for combining in one person the SR0/STA positiors because that person would not meet the qualifications for equivalence as outlined in the Draft Policy Statement. Another commentor requests that a provision should be made for grandfathering persons "... who currently meet STA training requirements, and who are technically degreed SR0s."

Resolution: It is not the intent of this policy guidance to revise the educational requirements for a continuation of an approved STA program. However, the educational requirements for the SR0/STA have been changed so that a bachelor's degree in engineering is not a basic requirement but one of several alternatives, including INP0 accreditation, acceptable in meeting the educational requirements.

ENCLOSURE E l

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6. Comments 3-9, 11-5, 15-8, 23-1, 23-8, 33-16, 33-21, 33-22, 33-33, 34-2, and 34-3 state that the degree requirement or equivalent will impact shift staffing by blocking the career paths for some employees to Senior Operator positions, and by encouraging a higher turnover rate among degreed individuals who will leave shift work for other more desirable positions.

Resolution: The Shift Technical Advisors' position has always required a degree or equivalent. Under Option 2, this requirement remains the same. However, under Option 1 (the SR0/STA position),

the bachelor's degree in engineering is not a bacic requirement, but one of several alternatives offered as acceptable in meeting the educational requirements. Hence, it should not block career paths nor should it affect the turnover rate.

~

7. Comments 6-4, 6-7, 6-8, 8-10, 16-2, 22-2, 23-4, and 29-2 state the need

'for further clarificat :n regarding the use of Options 1 and 2 of the Policy Statement. They ask: May either or both options be used by any plant at any given time?

Resolution: Any one of the options may be used on each shift. For example, a utility can use one option on one shift and another option on another shift or the same option on each shift. The Policy Statement was changed to clarify this point. No further action is necessary by utilities which select Option 2, i.e., an approved STA program.

8. Recommendations for Clarifications and Editorial Changes (a) Cements 6-15, 16-3, 19-3, and 31-2 state that Item (c) in the definition of equivalency should be revised to include "related l sciences."

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ENCLOSURE E

Resolution: The term " equivalency" has been deleted and replaced with " educational alternatives."

(b) Coment 19-2 states that Option 2, Item a. of the Policy Guidance Section reads " Baccalaureate degree or equivalent in engineering or related sciences, and...". As currently worded, it could be interpreted that a baccalaureate degree in any area of study or equivalent in engineering or related sciences would be acceptable.

Resolution: That interpretation was not the intent of the guidance.

The Policy Statement has been reworded as follows, " bachelor's degree in engineering from an accredited institution."

(c) Comments 6-5, and 24-6 request that Option 2, Item c. should be rewritten to delete the following words "... plant design and layout, capabilities of instrumentation and controls in the control room..."

because these are the qualifications for a senior reactor operator license (Item b.) which is required along with Items a. and c. and is, therefore, a reiteration of Option 2, Item b.

Resolution: This option of the Policy Statement has been rewritten to delete those words.

(d) Coment 5-2 states that, to be consistent with the wording in the second sentence of the " Background" Section, i.e., "... engineering expertise be available to the shift supervisor...," the wording in the second sentence of the " policy guidance" section should be changed from

...at least one individual with this expertise is on shift" to "...is on duty."

Resolution: If a utility selects the dual-role SR0/STA option, then l that individual must be on shift. If a utility selects continuation of an approved STA program, then the STA must assume an active role ENCLOSURE E

in shift activities. The Commission recognizes that several years may be required to meet this policy guidance.

(e) The first sentence of the Policy Guidance Section reads "The Comission continues to stress the importance of providing engineering and accident assessment expertise on shift." Comment 6-1 states that

" previous NRC official publications addressed (1) the accident assessment role and (2) the operating experience assessment role." The second role was not required to be filled on shift. The statement, therefore, is misleading in that linking of engineering and accident assessment is new and not " continuing."

i Resolution: The functions of " engineering and accident assessment" are separate from, and were not intended to address, the " operating experience assessment" function generally conducted by a group such as the Independent Safety Engineering Group (ISEG). The term

" accident assessment"'as used in the Policy Statement is intended to indicate actions taken while an event is in progress, not evaluations made after the event.

(f) Coment 6-6 states "It is not clear whether an application to eliminate the STA from the Technical Specifications or Safety Analysis

' Report needs to replace wording with new wording which is accepta'ble to NRC staff or whether a commitment letter containing utility policy will suffice. Current NRC practice, especially for new plants, is to include

' commitments' into ' conditions of license' in lieu of Technical Specifications."

Resolution: If a utility intends to utilize the dual-role position, then it must apply for a modification to their license (for a licensee of an operating plant) or it must modify their Safety Analysis Report (for an applicant for an operating license).

ENCLOSURE E

(g) The second sentence of the Policy Guidance Section reads

... licensees of operating plants and applicants for operating licenses should establish policies that..." Comment 6-2 states "The word

'should' is especially weak. Evidently, it is not required in order to modify the Technical Specification or FSAR."

Resolution: The word "should" is appropriate for use in policy guidance.

! (h) The first sentence of the second paragraph of the Policy Guidance Section reads "The intent of this policy guidance can be accompl i shed. . ." Coment 6-3 states "The word 'can' is unusual (rather thanshould,shall,ormay). Evidently there are other means l

permissible."

j Resolution: The Policy Statement has been revised as follows: "The intent of this policy guidance may be satisfied by any of the j following options."

(i) Coment 22-3 requests that Option 2.b should be modified to include a reactor operator, i

l - Resolution: The dual-role position must be filled by a licensed Senior Operator because of that position's need for extensive operating experience and training.

, 9. Coments 2-5, 2-6, 2-9, 2-10, 2-11, 2-12, 2-13, 2-14, 2-15, 2-16, 2-17, 2-19, 8-1, 8-16, 8-17, 8-18, 8-19, 8-20, 8-23, 8-25, 18-4, 18-5, 23-5, 23-7, 23-9, 23-10, 29-3, 29-4, 29-5, 33-5, 33-6, 33-12, 33-13, 33-14, 33-15, 33-17, 33-18, 33-19, 33-20, 33-23, 33-26, 33-29, 33-30, 33-31, and 33-32 express concern that this draft Policy Statement is a prelude I

to an NRC proposed rule which would require the Shift Supervisor to hold a bachelor's degree.

ENCLOSURE E

Resolution: This Policy Statement does not address the issue of requiring a degree for the Shift Supervisor. A proposal for a i degreed Senior Manager was presented in SECY-84-106 which was later disapproved by the Connissioners. However, Option 3 of the Policy Statement allows utilities to provide a senior in-line manager to fulfill the STA function. This position would be senicr to the Shift Supervisor, thus it should not be interpreted to be a degree requirement for the Shift Supervisor. -

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ENCLOSURE E

Index of Public Comments Comment Resolved by Comment Resolved by 1-1 5(e) 2-17 9 1-2 5(e) 2-18 5(a) 1-3 5(e) 2-19 9 1-4 5(e) 2-20 4 1-5 5(e) 2-21 4 1-6 5(e) 3-1 1 1-7 1 3-2 5(d) 1-8 1 3-3 1 1-9 5(e) 3-4 5(d) 1-10 5(e) 3-5 6 1-11 5(e) 3-6 5(d)

, 2-1 4 3-7 5(b)

2-2 4 3-8 5(e) 2-3 - 4 3-9 6 2-4 4 4-1 1 l 2-5 9 4-2 2 2-6 9 4-3 2 2-7 4 4-4 2

, 2 5(d) 4-5 2-2-9 9 4-6 2 l

2-10 9 5-1 1 2-11 9 5-2 8(d) 2-12 9 6-1 8(e) 2-13 9 6-2 8(g) 2-14 9 6-3 8(h) 2-15 -9 6-4 7 2-16 9 6-5 8(c) f ENCLOSURE E I ~_, _ . . . . - . _ , - . . . . _ , , , - _ _ . _ . . _ _ _ . _ . _ .._ _ _ _. .

Comment Resolved by Comment Resolved by 6-6 8(f) 8-10 7 6-7 7 8-11 5(c)

, 6-8 7 8-12 5(c) 6-9 5(e) 8-13 5(e) 6-10 5(b) 8-14 4 6-11 5(b) 8 4 6-12 5(b) 8-16 9 6-13 5(b) 8-17 9 6-14 5(b) 8-18 9 6-15 8(a) 8-19 9 6-16 5(c) 8-20 9 6-17 5(c) 8-21 1 6-18 5(c) 8-22 4 6-19 5(c) 8-23 9 7-1 3 8-24 4 o 7-2 3 8-25 9 7-3 3 9-1 1 7-4 3 9-2 5(e) 7-5 3 9-3 5(b) 8-1 9 9-4 5(e) 8-2 I 9-5 5(e) 8-3 4 9-6 5(e) 8-4 4 9-7 5(e) 8-5 4 10-1 5(a) 8-6 4 10-2 5(a) 8-7 4 10-2 5(a) 8-8 4 2{-1 5(e) 8-9 4 !s-7 5(e)

ENCLOSURE E

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Comment Resolved by Comment Resolved by 11-3 5(e) 15.4 5(e) 11-4 5(e) 15-5 5(e) 11-5 6 15-6 5(e) 11-6 5(e) 15-7 5(e) 12-1 1 15-8 6 12-2 4 15-9 5(e) 12-3 4 15-10 5(e) 12-4 4 15-11 5(e) 12-5 5(e) 15-12 5(e) 12-6 5(e) 15-13 5(e) 12-7 5(e) 16-1 1 13-1 3 16-2 7 13-2 5(d) 16-3 8(a) 13-3 5(d) 16-4 5(e) 13-4 4 17-1 5(c) 13-5 5(d) - 16-4 5(e) 13-6 4 17-3 5(e) 13-7 3 18-1 1 14-1 1 18-2 1 14-2 1 18-3 5(d) 14-7 5(b) 18-4 9-14-4 5(b) 18-5 9 14-5 5(d) 19-1 1 14-6 5(e) 19-2 8(b) 14-7 1 19-3 8(a) 15-1 1 20-1 1 15-2 1 20-2 1 15-3 5(e) 20-3 1 ENCLOSURE E l

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Comment Resolved by Comment Resolved by 21-1 3 24-1 4 21-2 3 24-2 5(d) 21-3 3 24-3 5(e) 21-4 3 24-4 5(c) 21-5 3 24-5 5(e) 21-6 3 24-6 8(c) 21-7 3 24-7 4 21-8 3 25-1 5(c) 21-9 3 25-2 5(e) 22-1 1 26-1 5(e) 22-2 7 26-2 5(e) 22-3 5(i) 26-3 5(e) 22-4 5(c) 26-4 5(e) l 22-5 5(c) 26-5 5(e) 23-1 S 26-6 5(e) 23-2 -

5(d) 26-7 5(e) 23-3 1 26-8 5(e) 23-4 7 26-9 5(e) 23-5 9 26-10 4 23-6, 4 26-11 4 ,

23-7 9 26-12 5(e) 23-8 6 27-1 5(d) 23-9 9 27-2 5(d) 23-10 9 27-3 5(d) 23-11 5(e) 27-4 5(d) 23-12 5(e) 27-5 4 23-13 5(e) 27-6 5(d) 23-14 5(e) 27-7 5(b) 27-8 4 ENCLOSURE E

Resolved by Comment Resolved by ,

Comment 3 33-14 9 28-1 I 3 33-15 9 28-2 3 33-16 6 ,

28-3 4 33-17 9 29-1 33-18 9 .

29-2 7 33-19 9 29-3 9 33-20 9 29-4 9 9 33-21 6 29-5 33-22 6 30-1 1 33-23 9 30-2 1 30-3 5(e) 33-24 5(a) 31-1 1 33-25 5(a) 33-26 9 31-2 8(a) 32-1 1 33-27 5(d) 32-2 4 33-28 5(d) 4 33 9 33-1 4 33-30 9 33-2 s

4 33-31 9 33-3 4 33-32 9 4

33-4 33-33 6 33-5 9 33-6 9 33-34 5(d) 4 33-35 4 33-7 33-8 4 33-36 5(c) 4 33-37 4 33-9 33-10 5(d) 34-1 5(e) 33-11 5(d) 34-2 6 33-12 9 34-3 6 33-13 9 l

l ENCLOSURE E

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O ENCLOSURE F PROPOSED LETTERS TO CONGRESS e e l l

1. o g UNITED STATES 1 8 o NUCLEAR REGULATORY COMMISSION  !

t j WASHINGTON, D. C. 20555 l

k*....,/

CHAIRMAN The Honorable Alan Simpson, Chairman Subcomittee on Nuclear Regulation Comittee on Environment and Public Works United States Sonate Washington, D. C. 20510

Dear Mr. Chairnan:

The Nuclear Regulatory Comission has sent the enclosed Final Policy St6tement on Engineering Evpertise on Shift to the Office of the Federal Register for publication. The Final Policy Statement provides licensees with three options to ensure that adequate engineering and accident assessment expertise is available to the operating crew.

Option 1 provides flexibility to licensees for meeting the requirements of 10 CFR 50.54(m)(2) and the requirement for a Shift Technical Advisor (STA) by allowing licensees to combine one of the requin2d licensed Senior Reactor Operator (SRO) positions with the STA position into one dual-role (SR0/STA) position. The individual who fills this dual-role position should meet the STA criteria of NUREG-0737, Clarification of TMI Action Plan Requirements, Item I.A.1.1, and meet one of several educational alternatives, or have four years experience as a licensed operator at an operating nuclear power plant and have successfully completed INP0-accredited STA and SRO training programs. This individual should also be licensed as a Senior Reactor Operator on the nuclear power unit (s) to which assigned.

Option 2 allows licensees, and applicants for operating licenses, to continue with an approved Shift Technical Advisor (STA) program, as described in NUREG-0737. However, the Comission encourages licensees to work towards having-this STA assume an active role in shift activities. -

Option 3 is an in-line supervisory operations position which is in addition to the licensed operator positions required by 10 CFR 50.54(m)(2). The individual filling this position would hold a senior reactor operator's license for at least one unit on site, meet the STA criteria of NUREG-0737, Item I.A.1.1, and fulfill one of several educational alternatives.

Sincerely, Nunzio J. Palladino

Enclosure:

l As stated Identical Letters to: (See P. 2) cc: Senator Gary Hart

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Identical Letters to:

The Honorable Morris K. Udall cc: Rep. Lujan Subcomittee on Energy and the Environment Comittee on Interior and Insular Affaris The Honorable Edward J. Markey cc: Rep. Moorhead Subcomittee on Energy Conservation and Power Comittee on Energy and Comerce T

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ENCLOSURE G DRAFT PUBLIC ANNOUNCEMENT TO BE PREPARED AFTER COMMISSION ACTION e =

0

4 ENCLOSURE H MARCH 7, 1985 LETTER FROM J. H. MILLER o

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-. , . _ . , _ - . - - ,-,--. . ,-.- --.-.-- ~ . . ~ - - - - - ,

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Atlanta. G e M 39 ' O l r O Ikis 33149 Charlotte. N C 2S242 Sl CLEAR l'TILITY NtANAUL\1LNT AND Hl:NIAN RL%Ol'RCLs CO\1N11TTLL March 7, 1985 Mr. William J. Dircks Executive Director for Operations U.S. Nuclear Regulatory Commission )

Washington, DC 30555

Dear Mr. Dircks:

In SECY-84-355, the NRC Staff presented a proposed final " Policy Statement on Engineering Expertise on Shift." This proposed policy statement and the related " Proposed Rulemaking Concerning Requirements for Senior Managers" (SECY-84-106) were discussed in Commission meetings on October 12 and November 5, 1984. As you are aware, subsequent to the November 5 meeting, the Commission disapproved the senior management rulemaking (SECY-84-106) and directed the Staff to coordinate development of a revised " Policy Statement on Engineering Expertise on Shift" with the industry (INPO and NUMARC) that would be submitted to the Comission for review and approval.

The attached proposed " Policy Statement on Engineering Expertise on Shift" was developed through discussions with Vic Stello and Hugh Thompson.

The positions expressed in this proposed policy statement were endorsed by an overwhelming majority of the NUMARC Executive Group at its February 27, 1985 meeting.

As Vic Stello requested, we reviewed the possible addition of a third option to the proposed policy statement that would allow, in effect, a senior manager on shift.* This option was presented to the NUMARC Executive Group at ,

the meeting on February 27, 1985, and a majority voted not to support the addition of this option to the proposed policy statement. As you recall, a primary objective of the senior manager rulemaking and the engineering exper-tise on shift policy statement is to ensure that adequate engineering and accident assessment expertise is available to the shift crew. We do not believe that the third option adds to this statement. In fact, the policy statement as written does not preclude the third option. Indeed, some utili-ties have created or are actively pursuing the creation of such positions. We believe that the organizational issue is one best left to individual licensees as long as the availability of engineering expertise is assured.

NUMARC is prepared to work with you in seeking final approval of the attached policy statement. We would appreciate the opportunity to review and discuss any further revisions to the attached material prior to formal Commission action.

Very truly yours, I

L.

. H. Mil er, Jr l Chairman i Steering Committee 1

JHM:las Attachment EDO 000424

' *0 RAFT

• 1/18/85 l NUCLEAR REGULATORY COMMISSION COMISSION POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT i

AGENCY: Nuclear Regulatory Commi'ssion

, ACTION: Final Commission Policy Statement on Engineering Expertise on Shift i at Nuclear Power Plants SumARY: This Policy Statement presents the policy of the Nuclear Regulatory Commission (NRC) with respect to ensuring that adequate engineering 4 and accident assessment expertise is possessed by the plant j operating staff. This Policy Statement offers licensees two i

options for providing engineering expertise on shift and meeting the upgraded licensed operator staffing requirements of 10 CFR 50.54(m)(2).

.- Option 1 provides for elimination of the separate STA position by allowing licensees to combine one of the required Senior Reactor Operator (SRO) positions with the STA position into a dual-role 1

(SR0/STA) position. Under Option 2, a licensee may continue with 4

an NRC-approved STA program (i.e., a separate STA position), with certain modifications, while meeting the licensed operator staffing

requirements of 10 CFR 50.54(m)(2).

t i EFFECTIVE DATE: This Policy Statement is effective on the date of publication j in the Federal Register.

! FOR FURTHER INFORMATIDN CONTACT:

Clare Goodman, Office of Nuclear Reactor Ragulation U.S. Nuclear Regulatory Commission

, Washington, DC 20555 Telephone: (301) 492-4894 l

[ SUFPLEMENTARY INFORMATION: "

l Background I Following the accident at Three Mile Island in March 1979, a number of studies

! were conducted to determine why the accident occurred, what factors might have i contributed to its severity, and what the industry and the NRC could do to

prevent the recurrence of the same or a similar accident. These studies I concluded, among other things, that a number of actions should be taken to l improve the ability of shift operating personnel to recognize, diagnose, and

}

i effectively deal with plant transients or other abnormal conditions.

To address these recommended improvements, the NRC initiated both short-term I and long-term efforts. The short-term effort required that as of January 1, l 1980, each nuclear power plant have on duty a Shift Technical Advisor (STA)

whose function was to provide engineering and accident assessment advice to l the Shift Supervisor in the event of abnormal or accident conditions. The STA l was required to have a Bachelor's Degree in Engineering or equivalent and specific training in plant response to transients and accidents. The STA

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• 1/18/85 l

i

' requirement was identified to licensees via NUREG-0578 (July 1979) and NUREG-0737 (November 1980) and was later mandated by plant-specific Confirmatory i Orders.

l Concurrently, the NRC and industry embarked on a longer-term effort aimed at  !

l upgrading staffing levels and the training and qualifications of the operating l l staffs, improving the man-machine interface, and increasing capabilities for '

1 responding to emergencies. At the time the STA requirement was promulgated, it was intended that use of the dedicated STA would be an interim measure only j until these longer-term goals were achieved.

4 These long-term initiatives collectively result in a sufficient improvement in I the capabilities and qualifications of the shift crew and their ability to diagnose and respond to accidents. These initiatives include shift staffing

' increases, training and qualification program improvements, hardware modifications, emphasis on human factors considerations, procedural upgrades, and development of extensive emergency response organizations to augment on-shift. capabilities during abnormal conditions. They either have been or are i

in the process of being implemented and include the following:

f 1

o Every nuclear station has been required to develop and implement extensive emergency response organizations for the express purpose of assisting in 4 the diagnosis and mitigation of accidents. These organizations are

! required to be fully mobilized within one hour and provide substantial j " engineering expertise" assistance to the shift crew to assist in accident J

diagnosis and mitigation / protective action strategy. All operating nuclear power plants are currently required to have emergency plans in j place and to conduct exercises on a regular basis.

l o Implementation of Supplement I to NUREG-0737 requires all nuclear plant licensees to conduct a Control Room Design Review (CRDR) of their facility and implement improvements identified in the human factors review.

Implementation of CRDR findings will result in an improvement in the

operator's ability to understand and respond to abnormal situations. This will minimize confusion during an accident and increase the likelihood of correct operator actions. All licensees have been required to submit-j plans and schedules for conducting the CROR.

i o In cooperation with the nuclear steam supply system vendor owners groups, j the industry has developed symptom-based emergency operating procedures.

The generic development work for these procedures has been completed.

These procedures are designed to make it easier for the operators tn

, recognize, diagnose, and effecitvely deal with plant transients and other j abnormal conditions. They are designed to aid the operator in maintaining critical safety functions, i.e., control reactivity, remove core heat, i provide an ultimate heat sink, and contain radioactivity,.thereby

! minimizing the probability of a serious incident. These new procedures j are of significant benefit to the operator in accident diagnosis and

overall response capabilities. All licensees have either implemented or

! are in the process of converting to these new procedures.

l o Implementation of Supplement 1 to NUREG-0737 requires installation of a safety parameter display system (SPDS). The SPDS is a system for rapid l' and concise display of vital plant status indications in the event of l

5 CORAFT*

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, 1/18/85 i

transients or accidents. The availability of this information via the SPDS will assist the operator in performing mitigating or stabilizing actions by providing essential information in a clear and timely manner.

! o Upgrading and installation of additional instrumentation for post-accident monitoring as delineated in Regulatory Guide 1.97 and Supplement I to NUREG-0737 will assist the operator in monitoring plant status and the course of an accident. The addition of this type of instrumentation, in conjuction with benefits of the SPDS display, will enhance event diagnosis i

and lessen the degree of reliance on the operator's analytical ability.

All licensees have provided plans and schedules for Regulatory Guide 1.97 upgrades.

o Effective January 1, 1984, the minimum shift crew for a single-unit plant

was increased to two licensed senior reactor operators and two licensed

{ reactor operators on each shift, and similar increases were required for J- multi-unit plants. This has resulted in two positive effects. First, an i additional senior licensed individual has been added to each shift which provides one more perspective to focus attention on accident assessment

, and overall emergency direction. Secondly, one of these senior licensed individuals is now required to be in the control room at all times. As a result, there is assurance that additional experienced senior level expertise will be imediately available at the onset of an accident.

i i o The indte ry, through the Institute of Nuclear Power Operations (INPO),

has established a comprehensive, nationwide accreditation program. This program provides for upgrading of the training programs for all licensed l operators as well as the training for other key positions that can

directly affect plant operations. An independent Accrediting Board reviews the evaluations of each utility's training programs and either i

grants accreditation or defers accreditation until the programs meet high

! standards. Licensees are expected to have these training programs ready l for accreditation by the end of 1986. These programs will ensure that

operating personnel possess qualifications comensurate with the l requirements of their jobs. This issue is being addressed by the Commission via a separate Policy Statement. ~

o Extensive additions have been made to utility training staffs. The number of full-time personnel per plant dedicated to training increased

industrywide by approximately 3755 between 1979 and 1984. This j exemplifies the increased recognition of the importance of training and l requalification to the effectiveness and capabilities of the shift crew.

o As specified in NUREG-0737 Item II.B.4, all licensed operators receive training specifically directed at recognizing and mitigating core j

~

damage. This training serves to familiarize the operator with possible causes and symptoms of a damaged core and expected post-accident plant conditions and corrective act'ans. As a result, the operator is better

,- prepared to recognize and respond to degraded plant conditions. All licensed operators are required to successfully complete this training.

o Simulators are now extensively used throughout the industry; 10 were in use in 1979; at the end of.1984, 40 were in use; and a total of 69 simulators are now in operation or are planned. Additionally, NRC

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• 1/18/85 criteria for operator licensing now require simulator training. The use of simulators provides more comprehensive training for the operator and allows him to experience transients and accidents in a training ,

environment. The increased use of simulators will improve the l capabilities of the shift crew to respond to emergencies. )

o The industry, through INPO, has develcped and implemented a comprehensive system for gathering and analyzing information on events that occur in the industry and providing feedback to operating personnel. This a.llows other licensees to revise their facility design or operation, as necessary, based on the lessons learned in the industry. The NRC endorsed INP0's SEE-IN program in Generic Letter 82-04 as acceptable for meeting the ,

information-gathering elements of NUREG-0737 Item I.C.5.

Collectively, these initiatives result in a significant enhancement of the capabilities of the 3hift crew to diagnose and mitigate accidents.

While it is Commission preference that licensees move toward the dual-role (SRO/STA) position, continuation of an approved STA program remains an acceptable option. The Commission acknowledges that some licensees may prefer

the dedicated STA position for a number of reasons. The Commission also i recognizes the advantages of integrating the qualifications and training of

the STA into the licensed operating staff. Thus, this Policy Statement is j structured to allow different means for ensuring that the plant operating staff has adequate engineering and accident assessment expertise.

Early in 1984, the Staff considered a " Proposed Rulemaking Concerning Requirements for Senior Managers" in SECY-84-106. This proposed rulemaking would have required that an additional degreed SRO-licensed individual be assigned to each shift of a nuclear power plant who would be responsible for managerial direction of all plant functions including chemistry, health physics, maintenance, operations, security, and technical services. Following several meetings with the Staff and industry representatives, the Commission

concluded that this proposed rulemaking was not warranted, and it was. .

l' disapproved. One of the primary bases for the proposed senior manager rule was the,need to provide engineering expertise to the shift crew, which is also the primary objective of this Policy Statement.

Policy Statement The Connission continues to stress the importance of providing engineering and accident assessment expertise on shift. The term " accident assessment" is intended to indicate immediate actions needed to be taken while an event is in progress. This Policy Statement does not require any changes in the formal education and training of operators and senior operators not expected to perform the dual-role SRO/STA function.

The intent of this policy guidance may be satisfied by either of the two options described below. The Commission prefers a combined SRO/STA position (Option 1). In addition, in the long term, the Commission would prefer that the STA be combined with the shift supervisor position.

. *0 RAFT 0 1/18/85 Option 1: Combined SR0/STA Position  ;

By assigning an individual with the following qualifications to each operating shift crew as one of the SR0s (preferably the Shift Supervisor) required by 10 CFR 50.54(m)(2)(1):

a. Licensed as a senior operator on the nuclear power unit (s) to which assigned, and

b. Completion of either of the following training and educational requirements ((1) or (2)):

(1) Meets the STA criteria of NUREG-0737 Item 1.A.l.1 and one of the following educational requirements: ,

(a) Bachelor's degree in engineering from an accredited institution; (b) Professional engineer's license; (c) Successful completion of the Engineer-in-Training (EIT)

.- examination; (d) Bachelor's degree in engineering technology (BET) from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; (e) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; or (f) Successful completion of technical portion of a bachelor's degree in engineering or engineering technology from an accredited institution. The technical portion should be comprised'of courses in the physical, mathematical, and engineering sciences.

(2) Four years of experience as a licensed operator at an operating nuclear power plant and successful completion of INPO-accredited STA and SRO training programs. The programs described in the INPO Guidelines " Nuclear Power Plant Shift Technical Advisor:

' Recomendations for Position Description, Qualifications, Education, and Training," and either "PWR Control Room Operator, Senior Control Room Operator, and Shift Supervisor Qualification,"

or "8WR Control Room Operator, Senior Control Room Operator, and Shift Supervisor Qualification" are ecceptable to satisfy the requirements for STA and SRO training. It is not the intent of this policy to require that personnel who complete STA or SR0 training programs prior to their accreditation by INPO be required to repeat that training subsequent to INPO accreditation, except i for participation in continuing training. The items added to the

{ programs as a result of accreditation would be included in the

next training cycle.

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' *0RAFTD

,- 1/18/85 Option 2: Continued Use of STA Position By placing on each shift a dedicated Shift Technical Advisor (STA) who i meets the STA criteria of NUREG-0737 Item I.A.1.1. The STA should assume '

an active role in shift activities. For example, he should review plant logs, participate in shift turnover activities, and maintain an awareness of plant configuration and status.

Either Option 1 or Option 2 may be used on each shift. A utility may use Option 1 on some shifts and Option 2 on other shifts, or may use the same option on every shift. If Option 1 is used for a shift, then the separate STA j position may be eliminated for that shift. i The Commission recognizes that several years may be required to meet the policy guidance given here. For the interim period, continuation of an STA program that meets the guidance of NUREG-0737 Item I.A.1.1 is acceptable.

Licensee proposals different than the two options described above will be considered by the Staff on a case-by-case basis.

To eliminate the STA position, a licensee of an operating reactor should apply for a modification to its license and an applicant for an operating license should modify its Final Safety Analysis Report to reflect elimination of the STA position and a commitment to provide a required SRO on shift with the qualifications described in Option 1 above.

NRC will accept a utility's modifications if it finds that the proposal meets the intent of this Policy Statement. On a case-by-case basis, utilities with multi-unit sites with dual-licensed SR0s will ensure that an adequate number

, of licensed staff are available and that engineering expertise can be provided when needed. It is the intent of this Policy Statement to ensure that adequate engineering and accident assessment expertise is possessed by the plant operating staff.

Dated at Washington, D.C., on this day of , 1985.

For the Nuclear Regulatory Commission i

l i Samuel J. Chilk Secretary of the Commission

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