ML20151K296
| ML20151K296 | |
| Person / Time | |
|---|---|
| Issue date: | 07/03/1984 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20151H981 | List:
|
| References | |
| FOIA-84-656 NUDOCS 8407110450 | |
| Download: ML20151K296 (44) | |
Text
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7 JUL 3iW IfEMORANDutt FOR:
Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements Office of the Executive Director for Operations FROM:
Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
FINAL POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT Enclosed is a final Policy Statenent on Engineering Expertise on Shift which provides two alternatives for ensuring that adequate engineering and accident assessment expertise is available to the shift supervisor. Licensees and applicants for operating licenses may continue with their approved STA program or may combine the licensed senior operator (50) and Shift Technical Advisor (STA) functions into one dual-role (50/STA) position as an acceptable alternative for meeting the requirements of 10 CFR 50.54(m)(2).
This final Policy Statement was preceded by a draft Policy Statenent on Engineering Expertise on Shift which was reviewed by CRGR as part of the Licensed Operator Staffing Rule on January 6,1983, and January 12, 1983.
After the two January 1983 CRGR meetings, your neno to Mr. Dircks, dated January 19, 1983, indicated approval for the rule (effective as of January 1,1984) based on the assumption that the draf t Policy Statenent would become final. We are now preparing to make that Policy Statenent final. The draf t Policy Statement was published in the Federal Register on July 25, 1983.
Eighteen Thirty-four letters were received during the public coment period.
of the letters included support for the flexibility provided by the Policy Statenent. These supportive corraents were submitted by 12 utilities, Enclosure A (Federal VJ!C, Inc. , AIF and the Anerican Nuclear Insurers.
Register Notice) gives a sumary of the major points made in the public coment, a sumary of the Comission's response to these najnr Enclosure points, and B the anended Policy Guidance Section of the Policy Statement.
(Resolution to Public Coments) contains a detailed analysis of all the public coments and their resolution.
Two technical issues were identified during the public coment period. The '
first issue concerns the equivalency options to a bachelor's degree in engineering. Comentors stated that the equivalency options should be This clarified and expanded. Hence, the staff undertook further analysis. t analysis included a literature search, review of the Office of Personnel flanagement's engineering degree and equivalency options, discussions with thex r Accreditation Board for Engineering and Technology (ABET), the National e "- '
Council of Engineering Examiners (NCEE), engineering academicians, ,
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- Victor Stello, Jr. JUL 3 1984 consultants to industry, and evaluators of experience, training, and course work for college credit. As a result of this analysis, the staff has revised and clarified the degree and alternatives as follows:
" Bachelor's degree in engineering from an accredited institution or an acceptable alternative....an acceptable alternative to an engineering degree has to include (1) a thorough knowledge of the physical and mathematical sciences underlying professional engineering, and (2) a good understanding, both theoretical and practical, of engineering sciences and techniques. The adequacy of such a background can be demonstrated by one of the following five alternatives:
(a) Professional Engineer's license; (b) Successful completion of the Engineer-in-Training (EIT) examination; (c) Bachelor's degree in engineering technology (BET) from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; (d) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, and engineering sciences; (e) Successful completion of the technical portion of a bachelor's degree in engineering from an accredited institution. The technical portion should be comprised of courses in the physical, mathematical and engineering sciences.
The second issue concerns combining the STA and 50 functions into one dual-role position. Four individuals comented that in establishing a dual-role position, the independence of the STA to provide engineering expertise would essentially be eliminated. They state that the STA should provide a separate, perhaps different perspective to problems that arise.
. The staff's position is that combining the STA and S0 functions would not compromise engineering expertise on shift but would enhance it. The Policy Statement continues to require specific STA training of the STA/50 in accicent assessnent. The STA/50 could provide that expertise during an abnormal occurrence.
' In addition, analysis of studies conducted by Pacific Northwest Laboratories for the Division of Human Factors Safety (NUREG/CR-3396 and PNL-4751) and staff experience with the STA position have indicated inconsistent application of the STA requirement. Those programs that appear to have been the most successful include the following features:
- STAS with an operator's license, and "3
- STAS who rotate as part of the operating crew.
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JUL 3 1984
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These features result in crew acceptance of the STA.
The staff believes that the STA/50 position wouldincreasing assure specificthe operator STA's ability training and on-the-job experience, thereby (1) to apply engineering expertise in an emergency through their knowledge improving the of specific systems and viable intervention strategies and (2) crew acceptance of the STA as part of the team.
The final Policy Statement received Division and Office review and the enclosed package incorporates changes and recomendations suggested by If the you review. We request that you set a date for a briefing of the CRGR.
have any questions about the final Policy Statenent, please contact lluch Thompson (X29595), Clare Goodman (X24894), or J. Persensky (X24892).
Ong>W scoed W IL R. Donte Harold R. Denton, Director Office of fluclear Reactor Regulation Enciosure:
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For: The Commissioners From: William J. Dircks Executive Director for Operations
Subject:
FINAL POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT Pur:ose: To obtain Commission approval to publish a final Policy Statement in the Federal Register which would enable facility licensees and applicants for a facility operating license to combine the positions of licensed senior operator (50) and Shift Technical Advisor (STA) as an alternative th method 10 CFR Part of 50.54 meeting(2). (m)e staffing requirements in -
Background:
On July 25, 1983, a draf t Policy Statement on Engineering Expertise On Shift was published in the Federal Register (48 FR 33781) for a 30-day public coment period (Enclosure E). Licensees electing to use the policy guidance, which provides flexibility in meeting the new requirements of 10 CFR 50.54(m)(2), may continue with their approved STA program or may combine the licensed Senior Operator (50) and Shift Technical Advisor (STA) functions into one dual-role (50/STA) position. This guidance pemits the technical capabilities generally provided by the STA to-be provided by the normal operating staff, i.e., by one of the required 50s including the shift supervisor. The j
otfective of this Policy Statement is to retain sufficient engineering and accident assessment expertise on each shift while meeting the requirement for minimum licensed operator staffing.
Discussion: Thirty-four letters were received in response to the Federal Register Notice on the draft Policy Statement.
Approximately three-fourths of the responses came from utilities while one-fourth of the respondents were private citizens identified with the nuclear industry (e.g., STAS i and operators). Eighteen of the letters included support for the flexibility provided by the Policy Statement. These supportive comments were submitted by 12 utilities, KMC, Inc., AIF and the American Nuclear Insurers.
CONTACT: C. Goodman, NRR 49-24894
i The Commissioners s .. .. .
The following major points were raised in'the comments:
- 1. Opposition to combining the functions of the 50 and the STA; .
- 2. Opposition to a bachelor's degree requirement for the 50/STA position;
- 3. Recommendation that equivalency to a bachelor's degree be further defined;
- 4. Concern that a bachelor's degree requirement would result. in a higher turnover rate or limited career paths for shif t employees; and
- 5. Reference to a proposed bachelor's degree requirement for the shift supervisor believed to be currently unoer NRC consideration.
Enclosure A (Federal Reaister Notice) gives a summary of the major points made in the public comment, a summary of the ,
Commission's response to these major points, and the amended Policy Guidance Section of the Policy Statement.
Enclosure B (Resolution of Public Comments) contains a detailed analysis of the public comments and the resolution of the public comments. ,
Following careful review of the comments concerning the type of bachelor's degree required and the equivalency options considered acceptable, the staff undertook further analysis.
This analysis included a literature search, review of the Office of Personnel itanagement's engineering degree and equivalency cptions, discussions with the Accreditation Board for Engineering and Technolooy (ABET), the National Council of Engineering Examiners (NCEE), engineering academicians, consultant: ' - industry, and evaluator of experience, trainino. d'd c urse work for college credit.
As a result of this a 14yt , the staff has revised and clarified the degree ano c 2ivalency alternatives. Note that the term " equivalent" in the final Policy Guidance Section (2a.) has been changed to "an acceptable alternative." The proposed " acceptable alternatives" to a bachelor's degree in engineering from an accredited institution are summarized below:
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The Commissioners , ,, , , ,
- a. Some states have or have had 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 a great deal 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 incividual successfully pass a fundamentals of engineering examination or the principles and practice of engineering examination, or both examinations.
Although 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. In light of these rigorous state -
requirements, the PE and EIT options remain acceptable alternatives in order to include those individuals who do not have a college degree but who have met the requirements for designation as a PE or an EIT.
- b. Other bachelor's degrees determined to be acceptable alternatives to an engineering degree 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 shculd include course work in the physical, ,
mathematical, and/or engineering sciences. These requirements are intended to e'nsure that the individual has substantial knowledge and understanding of the physical and mathematical sciences and the principles of engineering.
- c. Another acceptable alternative requires successful completion of the technical portion of a bachelor's degree in engineering from an accredited institution.
The staff believes that the technical portion of an engineering degree program 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 degree program have been successfully
The Commissioners s .o .. .
completed. However, 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. Individuals who have completed 80 semester hours in the physical, mathematical and engineering sciences will be considered acceptable. This is based on the ABET accreditation criteria for the basic requirements of an engineering bachelor's degree program.
Commentors on the draft policy guidance took the opportunity to comment 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 supervisor position. This issue is separate from and, therefore, not addressed by the final Policy Statement on Engineering Expertise on Shift. The public will be given an opportunity to comment on a proposed rule for a degree requirement for operating plant personnel when that proposed rule is published in the Federal Reoister.
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 several nuclear power plants.
Recemnendation: That the Commission:
- 1. Aoprove publication of the final Policy Statement as set forth in Enclosure "A"; and
- 2. In order to satisfy the requirenents of the Regulatory Flexibility Act, 5 U.S.C. 605(b), certify that this Policy Statement, if promulgated, will not have a significant economic impact on a substantial nunber of srall entities. This certification is included in the enclosed Federal Recister Notice.
- 3. Note: ,
- a. That, in accordance with 10 CFR N51.22(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. g
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- The Commissioners , ,, ,, ,
- b. Review by the Office of Management and Budget is not required.
- c. That the Subcommittee on Nuclear Regulation of the Senate Committee on Environment and Public Works and the Subcommittee on Energy Conservation and Power of the House Committee on Energy and Commerce and the Subconnittee on Energy and the Environment of the House Committee on Interic.' and Insular Affairs will be informed (Enclosure C).
- d. That a public announcement will be issued (Enclosure D).
- e. 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.
That the Chief Counsel for Advocacy of the Small t
f.
3 Business Administration will be informed of the -
certification and the reasons for it as required by the Regulatory Flexibility Act.
Scheduling: Recommend notation vote.
William J. Dircks Executive Director for Operations
Enclosures:
A. Federal Register Notice of Final Policy Statement B. Resolution of Public Corcents C. Letters to Congress
- D. Public Announcement E. Draft Policy Statenent i
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ENCLOSURE A FEDERAL REGISTER NOTICE l
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.o FINALCOMMISS10NPOLICYSTATEliENTONENGlNEERiNG EXPERTISE ON SHIFT AGENCY: Nuclear Regulatory Commission.
ACTION:
Final Commission Policy Statement on Engineering Expertise on Sh .
SUMMARY
This final Policy Statement presents NRC's position for ensuring that adequate engineering and accident assessment expertise is provided t the shift supervisor.
Licensees and applicants for operating licenses may continue with their approved Shift Technical Advisors' (STA) program combine the licensed senior operator and Shift Technical Advisor functions inte one dual-role senior operator / Shift Technical Advisor (SO/STA) p as an alternative for meeting the requirements of 10 CFR 50.54(m)(2). The objective of this guidance is to permit the technical capabilities gen provided by the STA to be provided by the normal operating staff, . ., byi e one of the required senior operators.
EFFECTIVE DATE:"
FOR FURTHER INFORMATION CONTACT:
Clare Goodman, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Cormission, Washington, .
DC 20555 Telephone: 301/492-4894.
- The effective cate should be on publication in the Federal Register ENCLOSURE A
- O ,e
- J SUPPLEMENTARY INFORMATION:
Background
Following the Three Mile Island (TMI) accident, a number of studies and investigations conducted by the NRC, the industry, and others recommended changes in the numbers, qualifications, and organization of nuclear power plant personnel. One of these recommendations was that engineering expertise be available to the shift supervisor for the purpose of improving the plant operating staff's capabilities for responding to abnormal conditions and for evaluating operating experience.
The initial response to this recommendation was the interin establishment of the position cf STA as described in an October 30, 1979 letter to all operating nuclear power plants. NUREG-0578 (July 1979)I and NUREG-0585 (October 1979) established that the purpose of the STA is to provide engineering expertise and advice to the shift supervisor in the event of abnormal or accident conditions. Following issuance of NUREG-0578 and NUREG-0585, the NRC issued a series of letters and repcrts to clarify the details of the STA job function and to present an acceptable approach for implementation. Four documents were prepared by the NRC for 411 operating nuclear power plants: two letters from NRC officials (September 13, 1979 and ,
October 30, 1979); NUREG-0660 (May 1980); and NUREG-0737 (November 1980). In I Referenced materials are available at the NRC Public Document Room at 1717 H Street, N.W., Washington, DC 20555.
ENCLOSURE A e e
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addition, the Institute for Nuclear Power Operations (INPO) issued a report (April 1980) providing " interim guidance" to utilities for formulating their STA programs which were referenced in NUREG-0737. The INPO report also provides guidance on education and training recomended for STA candidates.
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. Following publication of the draft statement, public coments were received and analyzed. At this time, the Comission is issuing a final Policy Statement on Engineering Expertise on Shift.* This final Policy
- Statement will provide flexibility in meeting the new requirements of 10 CFR 50.54(m)(2). It is not the intent of this Policy Statement to dilute the engineering and accident assessment expertise on shift, but to incorporate these cualifications in a member of the operating crew.
Draft Policy Staterent -
The draft Policy Statement on Engineering Expertise on Shift offered licensees of nuclear pcwer plants and applicants for operating licenses two alternatives. Alternative 2 gave them the opportunity to combine the
- An NRC regulation concerning a senior manager on shift may be forthcoming.
If a proposed rule is published in the Federal Register, then its effect on the Policy Statement will be discussed.
ENCLOSURE A
a . . .. .
. e licensed senior operators' (50) and Shift Technical Advisors' (STA) functions. Licensees which do not want to combine the 50 and STA functions could choose Alternative 1, continuation of an STA program approved in accordance with the STA position described in NUREG-0737, " Clarification of TMI Action Plan Requirements."
Interested persons, applicants, and licensees were invited to submit written comments to the Secretary of the Commission. Following consideration of the cenrents, the Commission amended the draft Policy Statement, as discussed in the following section.
Comrents on the Draft Policy Statement A t:tal of 34 respenses were received and evaluated. The public comments primarily relatec to Alternative 2 of the Policy Guidance Section, i.e., the combined 50/STA position. The following discussion highlights the major A
points raised in tne comments and the resolution of those comments.
detailec analysis of all public comments and their resolution was also prepared. (Copies of those letters and the detailed analysis of all the public comments are available for public inspection and copying for a fee at the NRC Public Dccurent Room at 1717 H Street N.W.,
Washington, DC 20555.)
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Of the 34 letters r'eceived, 18 included support for the flexibility provided \
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as follows:
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- 1. Support for the Policy Statement;
- 2. Opposition to combining the functions of the 50 and the STA;
- 3. Opposition to a bachelor's degree requirement for the 50/STA position;
- 4. Recommendation that equivalency to a bachelor's degree be further defined;
- 5. Concern that a bachelor's degree requirenent for the 50/STA 3
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 comments and responses to these are as follows:
- 1. Support fer the Policy Statement -
Eighteen commentors, including 12 utilities, KMC, Inc., AIF and ANI, favored the optien offered in the draft Policy Statement of combining the 50 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 f
experience.
- 2. Opposition to the Ccmbination 50/STA Position -
ENCLOSURE A h
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J Four individual commentors 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) increased the number of operators and senior operators on shif t af ter the initial STA position was recuired. The STA/SO functioning in the dual-role position can provide accident assessment expertise and can analyze and respond to off-normal events when needed.
3.
Opposition tc a Bachelor's Degree for the S0/STA position -
Several commentors felt that the person who filled the 50/STA position should nct be required to have a bachelor's degree. The Commission notes that this is new in that NUREG-0737 specified a bachelor's degree or the equivalent for the STA.
The qualifications for each position (STA and 50) have not been changed but are cerely combined in the dual-role position, thereby allowing the utilities to use one person instead of two.
4 t
Recommendation ' hat Equivalency to a Bachelor's Degree Be Further Defined -
ENCLOSURE A
r Many commentors stat d that the equivalency options were c ve too or required clarification.
Specific contents concerning the equivalency options were as follows:
the Engineer-In-Training (EIT) examination s considered as equivalent to a bachelor's degree in engineer since that degree is required for either of those options in mos states.
individuals who did not have a bachelor's deg place.
Four Year Engineering Program" was con comentors.
Other commentors requested clarification about the courses whicn comprised the technical portions of the degree.
A as bachelor's degree an acceptable in engineering technology should be offer alternative.
Follcwing careful review of these coments, the Commission unde further analysis.
This included a literature search, review of the Office of Personnel Management's engineering degree and e options, ar.d discussions with the Accreditation Board for En Technology (ASET), the National Council of Engineering E engineering academicians, consultants to industry, and evaluators o experience, training, and course work for college credit.
As a result of this analysis, the Comnission has revised and clarified ree andthe deg equivalency alternatives.
The term " equivalent" in the final Policy Guidance Section (2a.) has been changed to "an acceptable al since it is the Conmission's intent to present only " acceptable alternatives" to the engineering degree.
ENCLOSURE A
s .. . . .
Other changes related to acceptable alternatives are summarized below:
Some states have or have had a provision which allows registration of 1 individuals who do not have a college degree. These individuals have to 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 a great deal 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 examinations.
Although mest states require a bachelor's degree of the individual who has the cesignation of PE or EIT, other states do not presently recuire a degree or have not in the past. In light of these rigorous state requirements, the PE and EIT options remain acceptable l alternatives in order to include those individuals who'do not have a l college degree but have met the requirements for designation as a PE or an EIT. .
Other bachelor's degrees determined to be acceptable alternatives to l
I an engineering degree are a bachelor's degree in engineering ENCLOSUP.E A l
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technology from an accredited institution or a bachelor's degree in a physical science from an accredited institution. These degree programs would have to 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 from an accredited institution. The technical portion of an engineering degree program 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 degree program have been successfully completed. However, 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. Individuals who have completed 80 semester hours in the physical, mathematical and engineering sciences will be considered acceptable. The 80 semester hours requirement is based on the ABET accreditation criteria for the basic requirements of a bachelor's degree in engineering.
ENCLOSURE A a
J e o e 'e *
- 5. Concern that a Bachelor's Degree Requirement Would Result in a Higher Turnover Rate and a Potentially Blocked Career Path for Shift Employees -
Several commentors expressed concern that degreed individuals would leave for other positions in the plant, contributing to a high turnover rate on shift. The Connission agrees that individuals may move to other positions within the utility. However, this ability to nove about can be viewed as desirable, since it should increase the number of employees with valuable operating experience in other positions at the utility.
Another concern was that career paths to the senior operating positions would be blocked for those individuals without degrees. The Commission does not view this as a major obstacle. The only positions which may not be available for these individuals would be the STA or the 50/STA positions. The career path to senior operating positions, including shift supervisor, remain available. Furthermore, at the same time that utilities implenent this new S0/STA position, they must also meet the requirements of 10 CFR 50.54(m)(2) which adds an additional senior operator position to the shif t crew.
- 6. Reference to a Pecpesed Sachelor's Degree Requirenent for the Shift Supervisor -
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A few commentors or, the Federal Register notice took the opportunity to
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comment on whether a bachelor's degree should be required for specific ,... /~
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particular, for the shift supervisors' position. The Commission believes that this issue is separate from and, therefore, not addressed by the final Policy Statement on Engineering Expertise on Shift. The public will be given an opportunity to comment on a proposed rule for a degree requirement for operating plant personnel when that proposed rule is published in the Federal Register.
Final Policy Guidance The Commission continues to stress the importance of providing engineering and accident assessment expertise on shift. The term " accident assessment"*
is intended te indicate immediate actions needed to be taken while an event is in progress. Therefore, licensees of operating nuclear power plants and applicants for operating licenses should establish policies that will ensure that at least one individual with this expertise is Eea-sh4543 available within ten minutes to the shif t staff whenever a nuclear power unit is in an operational mode other than cold shutdown or refueling as defined by the ,
unit's Technical Specifications. At this time, the're are no changes proposed for fornal educatien of operators and senior operators not fulfilling the engineering and accident assessment function.
- For ease of review, new material is underlined and deleted material is lined through and bracketed. The underlining, etc. will be deleted before this is
, published.
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ENCLOSURE A 1 a
s The intent of this policy guidance Etaa3 my be accomplished by either of the following two alternatives:
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- 1. EGentimwatien-ef3 An approved STA program, or
- 2. Combined 50/STA position. Assignment of an individual with the following qualifications to the operating shift crew as one of the senior operators (including the shift supervisor) required by 10 CFR 50.54(m)(2)(1):
, a. Bachelor's Degree in Engineering from an accredited institution or an acceptable alternative, and EEasealaureate-degree-er equivatest-in-emg4meer4mg-er-weiated-se4emeesi-and]
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- b. Licensed as a senior operator on the nuclear power unit (s) to which assignec, and
- c. Specific trair.ing in the response to and analysis of plant transients andaccidentsEpiaat-des 4gm-and-layewti-capab(14 ties-ei ,
! 4mstrese=tatte5-aad-seataets-4P-the-eentrel-ree=3andtraininginthe I
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relationship of accident conditiens to offsite consequences and protective action strategies.
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For individuals fulfilling the engineering and accident assessnent 1
function,asdelineatedinAlternative2,Parta.above,[etw4valemey3an acceptable alternative to an engineering degree has to include ENCLOSURE A i
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Ebe-defined-as3(1) a thorough knowledge of the physical and mathematical sciences underlying professional engineering and (2) a good understanding, both theoretical and practical, of engineering sciences and technioues. The adecuacy of such a background can be demonstrated by one of the following five alternatives:
(a) Professional Engineer's license; (b) Successful completion of the Engineer-in-Training (EIT) examination; (c) Bachelor's degree in engineering technology (BET) from an accredited institution, including course work in the physical, mathematical and engineering sciences.
(d) Bachelor's degree in a physical science from an accredited institution, including course work in the physical, mathematical, and/or engineering sciences. .
(e) Successful ccepletion of the technical portion of a bachelor's degree in engineering from an accredited institution. The technical portion should be comprised of courses in the physical, mathematical,andengineeringsciences.[am-aeeredited,-fewr-year engineering-degreeprogram3 EfiCLOSURE A
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A Either Alternative 1, or Alternative 2, can be used on each shift.
utility may use Alternative 1 on one shift and Alternative 2 on another shift, or the same alternative on every shift.
! If [the-seeemd-aiternat4ve] Alternative 2 is selected for a shift, then the separate STA position may be eliminated for that shift. Eweweve*3 It is not the intent of this policy guidance to dilute the engineering and accidentassessmentexpertiseonshift,butEemly3toprovideutilities the flexibility to incorporate these qualifications in a certer of the
- operating crew.
In order to eliminate the STA position, licensees of operating reactors should aetly for modification to their Technical Specifications and
', acplicants for an operating license should apoly for modification to their Final Sa'ety Analysis Recort and E'e4eensees-may-apply-for med4(4eatae m-te-their-Teekm4eal-Spee4f4 eat 4 ems-er-Safety-Amalys45-Reports te-ei4=4aate-the-STA-pes 4t4em s -4f-they3 commit to providing a required Senior Operator on shift with the qualifications described in Alternative 2 above.
1 EAeeeptance-e4-seeniNRCwillacceptautility'smodifications[will-be l subjeet-te-46-(4md4mg3ifitfindsthattheproposalmeetstheintentof this Policy Statement. NRC will review on a case-by-case basis _ [spee4al attent4em-w414-be-g4ven-te! multi-unitsites[with-eemmem-sentrol-rooms andswithdual-licensedsenioroperatorstoensurethatanadequate(w4th l
regard-te-the-teta43numberoflicensedstaffareavailableandthat l
ENCLOSURE A
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engineering expertise can be provided when needed. In addition, total shift manning at a utility will need to be sufficient to Errev4de stafs4mg3 meet the intent of the staffing levels to handle emergency preparedness as discussed in Supplement 1 to NUREG-0737 (December 1982) and in " Requirements for Emergency Response Capability" (Generic Letter 82-33). 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 capability to the shift crew during an abnormal occurrence.
Increase in staffing levels, as required by 10 CFR 50.54(m)(2)(1), allows l
the 50/STA to function in the engineering and accident assessment role while the ether operators and senior operator (s) perform their recuired functions.
Dated at Washingten, DC, on this day of , 1984 For the Nuclear Regulatory Commission, l
- i Samuel J. Chilk, Secretary of the Comnission, i
i ENCLOSURE A 1
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ENCLOSURE B RESOLUTI0fi 0F PUBLIC COMitENTS 4
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tf 'e a
Resolgtfon 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
Dor.ald A. Bearden, Arroyo Grande, CA 8 Thcmas C. Houghton, KMC, Inc.
9 M. R. Wisenburg, Houston Lighting and Power .
10 D. W. Jones, Memphis State University 11 J. Ed Snith, Chairman, ANS-3 12 Lee 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, Facific Gas and Electric Company '
17 Donald J. Breehl, Portland General Electric Company 18 B. D. Kenyon, Pennsylvania Power and Light Company-19 Jchn DeVincentis, Public Service of New Hampshire (Yankee Atomic Electric Company) 20 J. R. Thorpe, GPU Nuclear Corporation 21 Jimmie Harris, La Jcila, CA 22 J. P. Baysa, New Ycrk Power Authority 23 Joseph W. Williams, Jr., Atomic Industrial Forum, Inc.
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ENCLOSURE B i
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24 John R. Marshall, Arkansas Power and Light Company 25 Donald Schnell, Union Electric Company 26 W. G. Counsfl, Northeast Utilities 27 Robert E. Uhrig, Florida Power and Light Company 28 M. I. Lewis, Philadelphia, PA
, 29 R. E. Helfrich, Yankee Atonic 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 l
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 example, comment 2-1 refers to the first comment in letter number 2.
1 4
ENCLCSURE B
- 1. Coninents 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' (50) 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.
- 2. Comments 4-2, 4-3, 4-4, 4-5, and 4-6 request the Ccmmission 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. Co=ents 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 26-3 oppose combining the '
functions of the licensed senior operator and the Shift Technical Advisor and express concern that this individual would perform as an I additional operator during an off-nomal event, and therefore, would not retain the perspective required to provide the necessary engineering and accident assessment expertise.
Resolution: Staffing levels required by 10 CFR 50.54(m)(2) increased the number of cperators and senior operators on shift, thereby freeing the person functioning in the dual role position to provide accident assessment expertise and to analyze and respond to off-nomal events, when needed.
i
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l ENCLOSURE B l
4 Coments 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, 27-8, 29-1, 32-2
, 33-1, 33-2, 33-3, 33-4, 33-7, 33-8, 33-9, 33-35, and 33-37 state t no technical justification to support a degree requirement or its equivalent (as defined in the draft Policy Statement) for the ind filling the dual role 50/STA position or for any member crew. of the rating Commentors are concerned about safe plant operations while experienced shift members are away from their shift duties may obtain a college degree.
Commentors state that before any decisions are nade regarding qualifications for this dual-role position, the requirererts of the job must be determined.
Resolution: ::
is nct the purpose of this Policy Statement to change the existing arrangerents for either the licensed senior roperator the Shift Technical Advisor position.
NUREG-0737 specified a degree or equivalent for the Shift Technical Advisors' position. However, this pclicy statement more clearly defines the type of degree ns and to the degree that are acceptable to meet the necessities dual-role position. e of th
- 5. Ecuivalerev:
alternative." The term " equivalent" has been changed to an " accept It is the Cornission's intent to present " acceptable alternatives" to the engineering deg-ee.
(a)
Corrent 33-25 states there are at least 27 categories of engineering, and asks which engineering degrees would be a neeting the recuirements for a degree in engineering or related sciences. Cements 2-18, 10-1, 10-2, 10-3, and 33-24 express concern that the Bacheier of Professional Studies degree in Nuclear ustrial Ind Operations degree. may nct be accettable as an equivalentg to an engi ENCLOSURE B
Resolution: The NRC has provided minimum qualifications for the joint 50/STA position. 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.
(b) Comments 3-7, 6-10, 6-11, 6-12, 6-13, 6-14, 9-3, 14-3, 14-4, and j 27-7 point out that the PE license and successful completion of the EIT exanination should not be used as equivalents for the bachelor's degree
' for the following reasons:
l Each state has its own criteria for the PE license and for .
sitting for the EIT examination.
I
- 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 frce state to state. *.
Resolution: Some states have or have had a provision which allows registration of indivicuals 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 a great deal 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 ENCLOSURE B 4
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l 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 botn examinations.
Although 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. In light of these rigorous state requirements, the PE and EIT options remain acceptable alternatives in order to include those individuals who do not have a' college degree but have met the requirements for designation as a PE or an EIT.
(c) Co ments 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 I 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 j
candidates, may not be uniformly applied, and may undernine the attainment of a full four year engineering degree.
Resolution: ThePolicyStatementhasbeenrevisedtoread[ Item (e)]
" Successful completion of the technical portion of a bachelor's degree in engineering from an acc7 edited institution. The technical portion of an engineering degree program is comprised of courses in the physical, mathematical, and/or engineering sciences. The Commission will find this alternative acceptable if it receives a communication from the credit-granting university that all the techmcal courses '
required in its engineering degree program have been successfully completed. These requirements ensure that the indivicual has substantial knowledge and understanding of the physical, mathematical, g and engineering sciences and techniques underlying the basic requirpreat ,
r of an engineering degree curriculum. However, since names of coup and amount of credit varies from university to university, the C
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Comission 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. 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.
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 50 functions acknowledges the importance of both operating experience and technical knowledge. However, operating experience alone cannot replace the STA qualifications which currently require a degree or the equivalent.
(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 coerentors 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 persen to have completed technical courses directly
' related to nuclear power plant operations. They suggest acceptance of s* .
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an INPO 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 50/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 50s."
Resolution: It is not the intent of this policy guidance to revise the STA requirements. The dual-role position should be filled by an individual who meets the requirements of the STA and the 50 positions, thereby allowing utilities to meet the policy guidance ,
with one person instead of two. However, the equivalency options in Item 2a. of the Policy Guidance Section have been revised and further defined as a result of public coment (see attached Federal Register fictice Items (a) through (e)). Licensees may have the opportunity to propose other alternatives after the Comission publishes a proposed rule for operator licensing and for training and qualifications of civilian nuclear power plant personnel.
- 6. Comments 3-9,11-5,15-8,23-1,23-8,33-16,35-21,33-22,33-33,34-2, and 34-3 state that the degree requirenent 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 indiviouals who will leave shift work for other more desirable positions.
Resolution: The Shift Technical Advisors' position has always necessitated a degree or equivalent. The degree needed for the s
EriCLOSURE B
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dual-role position is the same as that for the STA position. However, the definition of equivalent has been clarified (see 2a. (a)-(e)) in the Federal Register Notice.
The only positions which may not be available to the individual who does not have a degree or equivalent are the STA or the dual role 50/STA. Other senior operating positions including shift supervisor remain available. Furthermore, at the same time that utilities implement this new S0/STA position, they must also meet the requirements of 10 CFR 50.54(m)(2) which adds an additional operator position to the shift.
There should be no undue concern about a higher turnover rate because degreed individuals with operating experience may move to other positions within the utility. This ability to move about can be seen as desirable since it should increase the number of employees with valuable operating experience in other positions at the utility.
C
- 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 Alternatives No. I and No. 2 of the Policy Statement. They ask: May either or both alternatives be used by any plant at any given time? May the Policy Statement be disregarded if presently approved STA programs are acceptable, including those that provide STA coverage which does not rotate with the shift? .
Resolution:
Either Alternative No. I or Alternative No. 2 may be used on each shift. For example a utility can use Alternative 1 on one shift and Alternative 2 on another shift or the same alternative on each shift.
The Policy Statement was changed to clarify this point. No further action is necessary by utilities which select Alternative No.1, an approved STA program, including those providing STA coverage not rotating with the shift.
ENCLOSURE B
- 8. Reconrnendations for Clarifications and Editorial Changes (a) Conrnents 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."
Resolution: The definition of equivalency has been revised and clarified (see Items (a)-(e) in the Federal Register Notice).
(b) Alternative 2, Item a. of the Policy Guidance Section reads
" Baccalaureate degree or equivalent in engineering or related sciences, and..."
(b) Coment 19-2 states "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 or an acceptable alternative."
(c) Comments 6-5, 24-6 recuest that Alternative 2, Item c. should be rewritten to delete the following words "...pla'nt 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 Alternative 2, Item b.
Resolution: Alternative 2, Item c. of the Policy Statenent has been rewritten to delete those words.
ENCLOSURE B
(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 S0/STA position (Alternative 2), then that individual must be on shift. If a utility selects continuation of an approved STA program (Alternative 1), then the STA must be available to the shift supervisor.
(e) The first sentence of the Policy Guidance Section reads "The Commission 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."
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. This policy statement does not add "new" duties to the already existing STA functions.
(f) Ccament 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 acceptable to ENCLOSURE B
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NRC staff or whether a commitment letter containing utility policy will suffice. Current NRC practice, especially for new plants, is to include
'connitments' into ' conditions of license' in lieu of Technical Specifications."
Resolution: If a utility intends to utilize the dual-role position, the Technical Specifications (for a licensee of an operating plant) or Safety Analysis Report (for an applicant for an operating license) must be modified.
(g) The seccnd 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 reacs "The intent of this policy guidance can be accomplished..." Conrent 6-3 states "The word 'can' is unusual (rather than should, shall, or may). Evidently there are other means permissible."
Resolution: The policy statenent has been revised to use the words "may" and "two" to make clear that only the two alternatives are <
acceptable.
l (i) Comment 22-3 requests that Alternative 2.b should be modified to (
include a reactor operator. 7 ,.. f- -
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Resolution: The dual ' role position must be filled by a licensed senior operator because of that person's increased 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, 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.
Resolution: This draft Felicy Statement does not address the issue of requiring a degree for the Shift Supervisor. Therefore, these comments .
are not appropriate to the Policy Statement. The staff is presently developing a rulemaking package on a degree requirement for a senior manager on shift, and expects to publish a proposed rule sometime in 1984 At that time, the public will have the opportunity to comment on the proposed regulations, and those comments will be taken into consideration as the final rule is being developed.
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Index of Public Coments Resolved by Coment Resolved by Coment 1-1 5(e) 2-17 9 1-2 5(e) 2-18 5(a) 2-19 9 1-3 5(e) 2-20 4 1-4 5(e) 2-21 4 1-5 5(e) 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) ,
3-5 6 1-10 5(e) '
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 ..
Resolved by Coment Resolved by Coment 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) 8-14 4 6-10 5(b) 8-15 4 6-11 5(b) 8-16 9 6-12 5(b) 8-17 9 6-13 5(b) 6-14 5(b) 8-18 9 8-19 9 6-15 8(a) 6-16 5(c) 8-20 9 6-17 5(c) 8-21 1 8-22 4 6-18 5(c) 8-23 9 6-19 5(c) 8-24 4 7-1 3 3 8-25 9 7-2 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) j 8-2 1 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 11-1 5(e) 8-9 4 11-2 5(e)
EliCLOSURE B
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, o Coment Resolved by Comnent Resolved by 11-3 5(e) 15.4 11-4 5(e) 5(e) 15-5 11-5 5(e) 6 15-6 11-6 5(e) 5(e) 15-7 12-1 5(e) 1 15-8 6 12-2 4 15-9 12-3 5(e) 4 15-10 12-4 5(e) 4 15-11 12-5 5(e) 5(e) 15-12 12-6 5(e) 5(e) 15-13 12-7 5(e) 5(e) 16-1 1 13-1 3 16-2 7 13-2 5(d) 16-3 13-3 8(a) 5(d) 16-4 13-4 5(e) 4 17-1 13-5 5(c) 5(d) 16-4 13-6 4 5(e) 17-3 13-7 5(e) 3 18-1 1 14-1 1 18-2 1 14-2 1 18-3 14-3 5(d) 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 14-7 _
8(b) 1 19-3 15-1 8(a) 1 20-1 1 15-2 1 20-2 1 15-3 -
5(e) 20-3 1 ENCLOSURE B
Resolved by Coment Resolved by Comment 3 24-1 4 21-1 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) 3 24-7 4 21-7 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) 22-5 5(c) 26-5 5(e) 23-1 6 26-6 5(e) 4 23-2 5(d) 26-7 5(e) 23-3 1 26-8 5(e) 23-4 7 26-9 5(e) 26-10 4 23-5 9 4 26-11 4 23-6 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) 27-5 4 23-12 5(e) 23-13 5(e) 27-6 5(d) 23-14 5(e) 27-7 5(b) 27-8 4 EfiCLOSURE B
r Resolved by Coment Resolved by Comment 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) 4 33-35 4 33-7 33-8 4 33-36 5(c) 33-9 4 33-37 4
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33-10 5(d) 34-1 5(e) 33-11 5(d) 34-2 6 -
33-12 9 34-3 6 ,.
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EXPERIENCE WITH THE POSITION OF SHIFT TECHNICAL ADVISOR Division of Human Facters Safety Contact is Robert Benedict, Licensee Qualification Branch .
The. position of Shift Technical Advisor was mandated after the TMI accident to provide engineering expertise on shift at nuclear power plants in order to
- advise the operations crew in the event of an emergency and review plantAt the re operating experience during normal circumstances.of the Pacific Northw officials from nine sites about the effectiveness of Shift Technical Advisors and published the results as NUREG/CR-3396 in March 1984.
The effectiveness ofReported Shift Technical Advisorsthat off-normal situations was found needed to be limited:unde assistance off-normal conditiens. In some plants, inexperience beyond the operat ug shift crew were few in number.
of the Shift Technical Advisors resulted in a lack of their The ability tothat expect'ation contribute one initially, but their capability improved over time.
individual would possess all the skills needed to resolve off-normal situations was seen as unrealistic. -The effectiveness of Shift Technical Advisors under normal conditions was primarily in terms of providing an additional safety review role, extra manpower, and an engineering perspective, which were seen as beneficial but not crucial to plant safety.
Personnel problems encountered with Shift Technical Advisors were a lack of a labor supply of individuals with both a degree in engineering and experience in nuclear operations, under-utilization of staff during the implementation period of these new positions, and competition with shift crew personnel for supervisory positions.
The table below gives the views of persons in various job positions as to the conditions under which operations shift crews need engineering expertise.
When Needed Almost Off-Normal Nc m l and Job Position Never Only Of'-S rma l Plant Manager 3 2 Training Manager 1 2 0 1 1 Personnel Manager 4 2 C Operations Superintendent Shift Supervisor 3 2 i 1 4 :
STA I & C Engineer 2 1 Total 14 14 g,
Most Shift Technical Advisors recommended an engineering positic- on-shift
- (onsite), while plant managers and shift supervisors are dividec, with approximately half recocnending such a position and half recommeding that engineering expertise be on-call (offsite). Of those supporting an on-shift m ition, the Shift Technical Advisors and shift supervisors all recommended
_ *, ~~
nior reactor operator license be a qualifications requirement. With l
a the NRC requirement for a bachelor's degree, only one of the four tagers specified that this be a required qualification.
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"9,, NUCLEAR REGULATORY COMMISSION f .
E I ADVISORY COMMITTEE ON REACTOR SAFEGUARDS CASHINGTON, D. C. 20085
\o...,/ December 14, 1982 The Honorable Nunzio J. Palladino Chairman U.S. Nuclear Regulatory Comission Washington, D.C. 20555
Dear Dr. Palladino:
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SUBJECT:
ACRS COMMENTS ON RULEMAXING CONCERNING STAFFING AT MUCLEAR POWER PLANTS AND DRAFT POLICY STATEMENT ON SHIFT CREW QUALIFICATIONS During its 271st meeting, November 4-5, 1982, and its 272nd meeting, Decem-ber 8-10, 1982, the ACRS considered the proposed final rule entitled "Li-censed Operator Staffing at Nuclear Power Units" and a proposed draft pclicy These matters had been previously statement on " Shift Crew Qualifications."
discussed with representatives of the NRC Staff and industry at a Subcommit-tee meeting in Washington, D.C. on October 28, 1982. The proposed rule was not reviewed by the ACRS before it was issued for public comment.
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We agree with the proposal to amend 10 CFR Part 50.54(m) to require a suf-ficient number of licensed Senior Reactor Operators on each shift to assure adequate supervisory coverage in the control room while permitting the Shift Supervi sor, who is also an SRO, flexibility to move about the facility.
We believe it is highly desirable that an individual with the training and experience required of an SRO be present in the reactor control room a very large fraction of the time. However, the requirement for 100 percent coverage is too restrictive. We urge that the NRC Staff consider some flexibility concerning how near an SR0 must be to the control room or what small f raction of the time he or she might be absent.
We endorse postponement to January 1,1984 of the originally proposed imple-mentation date for the rule. Selecting, training, and licensing the highly qualified individuals required to operate nuclear power reactors is a com-plex process. While most licenseesit well already meet the intent of the proposed in advance of the proposed date, we rule, or are scheduled to meet believe a reasonable time should be permitted to allow the remaining lican-sees to comply.
The proposed policy statement on "Shif t Crew Qualifications" would permit licensees to combine the functions of the SR0 and the Shift Technical Advisor in one individual, provided that person meets all the requirements of both s
positions. W detrongl1 endorse thbroposal and_ believe it isCombination preferabli
-j to the_upar_an_ Shift Technic ~aTTdvisor position now required.
of supervisory autnority and perspective with engineering and analytical I
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Honorable Nunzio J. Palladino . . December 14, 1982
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l capability will provide an effective shift organization for dealing with !
both normal and emergency situations.
Additional comments by ACRS Member Dr. H. W. Lewis are presented below.
Sincerely, t P. Shewmon Chairman Additional Coments by ACRS Member Dr. H. W. Lewis While of pointsI agree with theme.
that concern sense of the Comittee letter, there remain a couple First, in view of the somewhat more . relaxed schedule for the implementation preposed in the current version of the rule, I cannot see why it should not go through the Comittee to Review Generic Requirements. I had thought that the such as this.function of that Comittee was to assure high quality for proposals Second, I would greatly strengthen the ACRS recomendation that the NRC Staff consider some relaxation of the admittedly arbitrary 100' percent attendance feature of the proposed rule. Any understanding of accident probabilities leads to the conclusion that small absences (in space or time) make correspondingly small contributions to the risk.
Third, numbers I am troubled by the underlying philosophy, which suggests that in the control room are the important issue. While there surely exist accident it is equally sequences which require several people for their management, quality than quantity.true that Three Mile Island revealed more deficiencies in to trade off these values.There is little evidence that the Staff has tried Of course, the upgrading from RO to SRO implies a higher better level of training, but the proposed rule deals with more SR0s, not SR0s. However, if the fusing of the roles of SRO and SiiTTt Technical Advisor is really inplemented, that will be a move in the right direction.
t This rule, as finally promulgated, will have a long life -- there is every reason to be a little more certain that it has the rignt form.
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Reference. 1 1.
Draft memo to Comissioners from William J. Dircks, Executive Director for Operations,
Subject:
Final Rulemaking Concerning Staffing at i Nuclear Power Plants and Draft Policy Statement on Shift Crew Quali-fications, transmitted by memo from K. Goller dated December 3,1982
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NUCLEAR REGULATORY COMMISSION
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%, . . . . p August 9,1983 Honorable Nunzio J. Palladino Chai rma n U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Dr. Palladino:
SUBJECT : ACRS REPORT ON A PROPOSED RULE REQUIRING ON-SHIFT ENGINEERING EXPERTISE During its 280th meeting, August 4-6, 1983, the ACRS reviewed a new rule, proposed by the NRC Staff to be issued for public comment. This rule would require licensees of nuclear power plants to provide personnel with engi-neering expertise on each shift. The matter was also discussed with the NRC Staf f during a meeting of our Subcommittee on Human Factors on June 30, 1983.
The proposed rule would require that, by 1987, at least one person on each shift at an operating nuclear power plant have a bachelor's degre'e or equiva-lent
- and also hold a Senior Reactor Operators (SRO) license. Further, the
( rule would require that, beginning in 1987, each licensee have a plan and schedule to assure that all shift supervisors will have bachelor's degrees.
The NRC Staff believes these requirements will provide enhanced on-shift diagnostic and response capability, cross-fertilization of the operations and engineering groups within each utility, and increased professionalism of the operating staf f. The proposed rule is part of a package of new regulations, related to qualifications and training of nuclear power plant personnel, being developed in response to Section 306 of the Nuclear Waste Policy Act of 1982.
We note that this proposal is a move away from the concept of a Shif t Tech-nical Advisor (STA) who is independent of the operations staff. The Com-mittee has previously (letter of December 14,1982) endorsed a proposal for combining functions of the SR0 and the STA (i.e., engineering expertise) in one person. We continue to endorse that proposal and thus are in agreement with the central thrust of the proposed rule which is to combine these qualities in the shif t supervisor.
We note that the proposal for implementation would permit flexibility in applying the requirement for a degree during Phase 1 of the implementation; it is not explicit in the Phase 2 implementation as described to us. We urge k
- A more complete definition is given in the proposed rule.
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August 9,1983 Honorable Nunzio J. Palladino that this flexibility be interpreted in a manner to permit currently well-qualified shift supervisors who do not have bachelor's degrees to continue to hold this responsibility. If the shift supervisor does not have the bache-lor's degree, then it should be required that another SR0 on-shift have this technical qualification.
We disagree, however, with defining the necessary engineering expertise as "a While baccalaureate degree or equivalent in engineering or a related field."
this, or a similar definition, may be an appropriate minimum requirement or selection criterion, it is not a sufficient description of the qualities desirable in the shift leadership. Existing requirements for an STA provide for engineering a more comprehensive definition of the qualities required expertise. We recommend that the NRC develop a more complete set of require-These requirements ments for shift supervisors at nuclear power plants.
should be embodied in a license for shift supervisors separate from and at a higher level than the present license for SR0s.
While the proposed rule is not necessarily incompatible with the above recommendation, we believe it does not address all of the essential issues Tne particular with regard to providing engineering expertise on-shift.
issue addressed of this rule has been singled out by the Staff forWe develop-believe ment in advance of the remainder of the Section 306 package.
that more time is needed to consider our recommendations and suggest that it
'( might be better to consider the rule along with the rest of the package.
Additional comments by ACRS Meubers M. W. Carbon, J. C. Ebersole, C. Michel-son, and C. P. Siess are presented below.
Sincerely, r
n J. J. Ray Chairma n Additional Comments by ACRS Members M. W. Carbon, J. C. Ebersole, C. Michel-son, and C. P. 51ess We do not agree with the proposed requirement that, some time afterWe 1987, the believe shi f t supervisor must have a bachelor's degree or equivalent.
that a technically competent and knowledgeable person should be in the control room or available on short notice, and that this person should have a bachelor's . degree, an appropriate amount of experience, and should hold an SR0 license. We see nc reason, however, why this person must be the shift supervisor, and we have some doubts as to whether he should De.
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).A.1.1 SHIFT TECHNICAL ADVISOR 1
Position Each licensee shall provide an on-shift technical advisor to the shift super-visor. The shift technical advisor (STA) may serve more than one unit at a multiunit site if qualified to perform the advisor function for the various units.
The STA shall have a bachelor's degree or equivalent in a scientific or engineering discipline and have received specific training in the response and analysis of the plant for transients and accidents. The STA shall also receive training in plant design and layout, including the capabilities of instrumenta-tion and controls in the control room. The licensee shall assign normal duties to the STAS that pertain to the engineering aspects of assuring safe operations of the plant, including the review and evaluation of operating experience.
Changes to Previous Requirements and Guidance There are no changes to the previous requirements resulting from NUREG-0660 and the October 30, 1979 letter from H. R. Denton to all operating nuclear power plants.
Clarification The letter of October 30, 1979 clarified the short-term STA requirements. That letter indicated that the STAS must have completed all training by January 1,1981.
This paper confirms these requirements and requests additional information.
The need for the STA position __may be eliminatad when the qualifications of the shif t supervisors and senior operators have hopn upgraded and the man-machine ~
fnterf ace in the control room has been acceptably __uparaded. However, unTTT---
those long-term improvements are attained, the need for an STA program w1Tt--
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centinue.
The staf f has not yet established the detailed elements of the academic and training requirements of the STA beyond the guidance given in its October 30, 1979 letter. Nor has the staff made a decision on the level of upgrading required for licensed operating personnel and the man-machine interface in the cor. trol room that would be acceptable for eliminating the need of an STA.
Uatil these requirements for eliminating the STA position have been established, t*.e staf f continues to require that, in addition to the staffing requirements watified in its July 31, 1980 letter (as revised by item I.A.1.3 of this enclosure), an STA be available for duty on each operating shift when a plant '
's being operated in Modes 1-4 for a PWR and Modes 1-3 for a BWR. At other t m,.s. an 51 A is not required to be on duty. ,
W a the October 30, 1979 letter was issued, several efforts have been made c t' establish, for the longer term, the minimum level of experience, education, ,
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and training for STAS. These efforts include work on the revision to ANS-3.1, work by the Institute.of Nuclear Power Operations (INPO), and internal staff eiforts.
INPO recently made available a document entitled " Nuclear Power Plant Shift Technical Advisor--Recommendations for Position Description, Qualifications.
Education and Training." A copy of Revision 0 of this document, dated April 30, 1980, is attached as Appendix C. Sections 5 and 6 of the INPO document describe the education, training, and experience requirements for STAS. The NRC staff finds that the descriptions as set forth in Sections 5 and 6 of Revision 0 to the INPO document are an acceptable approach for the selection and training of personnel to staff the STA positions. (Note: This should not be interpreted to mean that this is an NRC requirement at this time. The intent is to refer to the INPO document as acceptable for interim guidance for a utility in planning its STA program over the long term (i.e., beyond the January 1, 1981 requirertent to have STAS in place in accordance with the qualification require-ments specified in the staff's October 30, 1979 letter).)
No later than January 1,1981, all licensees of operating reactors shall provide this office with a description of their STA training program and their plans for requalification training. This description shall indicate the level of training attained by STAS by January 1, 1981 and demonstrate conformance with the qualification and training requirements in the October 30, 1979 letter.
Applicants for operating licenses shall provide the same information in their application, or amendments thereto, on a schedule consistent with the NRC licensing review schedule.
No later than January 1,1981, all licensees of operating reactors shall provide this of fice with a description of their long-term STA program, including qualification, selection criteria, training plans, and plans, if any, for the eventual phasecut of the STA program. (Note: The description shall include a comparison of the licensee / applicant program with the above-mentioned INP0 document. This request solicits industry views to assist NRC in establishing long-term improvements in the STA program. Applicants for operating licenses shall provide the same information in their application, or amendments thereto, on a schedule consistent with the NRC licensing review schedule.)
Applicability This requirement applies to all licensees of operating reactors and applicants for operating licenses.
Implementation (1) Training that meets the lessons-learned requirements shcIl be co.:,,1 A..J by January 1,1981 or by the time the fuel-loading license is issmd, vMch-ever is later.
r ". (2) A description of the current training program and demonstration of ca..fu..
ance with the October 30, 1979 letter shall be submitted I.A.1.1-2
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(a) no later and than January 1,1981 for litcn< te, of opt . aling reactors; (b) on a schedule consistent with re,ic,e schefele for applicants for operating licenses.
(3) A description of the long-term STA p. ogcc.n Wicli Lc t ' mitted (a) noandlater than January 1, 1981 fvr 'icct. aes of cperating reactors; (b) on a schedule consistent with rcsic.i >.b.dule for applicants for operating licenses.
Type of Review Operating reactors will undergo postimplementation review.
Applicants for operating licenses will be re.icwed as part of the licensing review .
Documentation Required Documentation will be required as noted above.
Technical Specification Changes Required Changes to technical specifications will be required.
References NUREG-0578, Recommendation 2.2.1.b NUREG-0660 INPD Document, see Appendix C tetter from October 30, H. R. Denton, NRC, to All Operating Nuclear Power Plants , dated 1979.
!*tter 1980. from D. G. Eisenhut, NRC, to All Licensees and Applicants , dated July 31, I.A.I.1-3 3-5 AW
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1982
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Calendar Year 1982 was the Nationa! The new Act also strengthened the in addition to the original five Safety Transportation Safety Boarc s 15th an- Board's position in pressing for action Board members named by President neversary by tne Department of Transportation Johnson.11 Members were appointed Created by the Department of on Board Safety Recommendations. by Presidents Nixon, Ford, Carter, and Transoortation Act of 1966. the Sa'ety The Secretary of Transportation was Reagan between 1969 and 1982. Nam-Board officiahy came into being cy ex. recuired to respond. in writing. within ed last year were Jim Burnett, who was ecutive order. on April 1.1967 Actual- 90 days of each recommendation to designated as Chairman, and Donald ly. it was May 2 wnen the first five- the Department, anc to give detai'ed D Engen They joined sitting Members member Board. appointed by the Presi- reasons whenever the Department re- Patricia A. Goldman, who was dent with the advice and consent of the lected a recommendation. The Safety designated as Vice Chairman, G. H.
Senate. was sworn into office Board in turn. instituted a formal pro- Patrick Bursley. and Francis H.
The Boarc was to be inceoencent in cecure for monitoring resconses to Mc Adams, who in 1982 completed its operations. out for housekeeo:ng recommencations. and for evaluating nis third five year term and was the on-purposes it was mace a ca 1 of the new them ly remaining Member of the 1967 Safe-Department of Transportation Nealy in 1982. the 1974 legislation was ty Board 8 years later. the Transpo !ation Safety arnenced to g:ve the Safety Board Act of 1974 estachshed the Boarc as ' prior;ty over an othe investigations an entirely independent agency anc in- by otne Federal agencies" in sur-creased the Board's statutory mancate face transoortation cases Provision for investtgat:on of certain surface was rnace for participation of other transportation accidents agencies in Board investigations. and the Bca'c s rignts to examine physical evicence were extended speci6cally to
~~any venic:e. roning stock. track. or oceve comconent" involved in an ac-cicent 3
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i The Sa.ety Boarc en 1967 inhentec the nave taken every man. woman and grabbed nis gear. lef t his vehicle to his ;
entire Bur eau of Safety of the Civu cnoc in the country on a thgnt of more carpool and walked to the scene.
The ice-choked Potomac and conn-Aeronautics Board-a orofessional tha" 2 000 moes nuing bitter cold-it was below zero on staff with a history of more than 50 the fourth cay-made for a difficult on- 1 years of pioneenng work in cW awa- Winter Flying scene investigation. It was a week l tion acticent invest gaton its "go.
before Ine recorcers were recovered team" organizabon and its emonasts it was nearly two weeks before the last on specianzec stucy of au face's of an incteen days into the New Year this accicent nac ceen 'ecogn'zec 'cr its 'e'ramac e recora came to a shatter- of tne wreckage was hauled out of the escenence anc emu a'ec inroog oat mg enc An Ar Ronca Boeing 737. tak- river for investigators to study and mg o*f from Washington Nat'onal Air- document the world '
in the Boa'c s 15 years anre sate- port in the nat;on s capitat crashec on- Ten days after the Air Flonda Crasn ty has impro.ec s'eal'y in 1967 the to a onage in a snowstorm anc o.unged in the Wasnington snowstorm. a Wood 4
airkne fatal accicent ra'e was 0 006 in into the Potomac River Seventy Airways DC-10 skidded off the end of every mnhon aircra't mi:es f:ce By cassengers. ' car crewmemoe's and icy Runway 15R at Boston's Logan international Airport ana into Boston 1980. it was coan to o 001. a recact on +ca' cersons on the bndge were kiMed of 83 percent And on January 1.1982. Four Dasse"ge's and one tagnt atten- HarDor As it pfunged off the end U S airknes nac comotetec 26 movs cent escacea the plane anc were of the runway the fuselage snapped without a Catast'c0nte Crasn of a pu'e- rescued from the icy nver just benind the Cockpit. and the Tre bnage was virtuahy within sight nose of the wide-Dody jethner sagged jet transport Tne cenoc sca-nec 19K and 1981. never cetore nac there Deen o' the Boarc s read:!uarters building into the water even one catencar year w inout sucn Tre snowstorm had promptec early There were 208 persons on board i an acciaent Thec*eoousrecocnac re ease of Boarc and otne' go.ernment tne DC 10. and in the immediate a'ter.
been 15 months. trom becte-te' 197
- emp!cyees. so the scheduled matn of tne accicent it appeared rnat to Decemoe' 1972 investgato'ordenarge anc most of his ali nad survived it tnen oeveloped inat The airknes f:ew more inan na:t a investigators were strugghng tnrou99 two passengers. both apparently bilhon passengers on over 10 manon traffic jams on tneir way home seated in the forward end of tne thghts in the 26.montn penoc-mo'e Another " llc std! at heaccuarters was passenger Compartment where the than half a tnihon passenger moes The ass:gned An operations specialist fuselage oroke, were missing. They are aenal transportation involvec woutc nearc accicent reports on his rad;o. presume to nave Deen fost in the Oay The Board now was investigabng a
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, O .Mene if 4 'h we action One was reconsidered by the l Board FAA responded in November to 1 4 fne 11 recommendations mace in the l accicent reort in August. the response was uncer consideration by the Board i at year s ena On Decemcer 15. 1982. the Safety
- Boarc reportec that the World Airways crash it made 10 safety recommenca- officer caued his attention to puzzhng DC 10 sha ott the ice-and-snow-covered runway at Boston because the tions to the Federa: Awabon Ac- e engme mstrument readings Con- pdot was not given sufficient informa-ministration-an daectec at Ame r tr,cutmg to the accident. tne Boarc tion to snow that it was too shppery for weather procrems ccsec ty te re'c we e ni t~e prc'ongec grounc the DC 10 s stocomg capacihty The Wasnington deahng with tne accident nara c in ofacc Ocn to ce a ,- telneen ce cmg a-c takeoff Board ne'c Inat coin Feder u c ea ance a-c ine resuibng to g er tions and industry pracbces do not cestroymg accum taSo^s o's ca anc cosure of tne ancraf t to snow ac-
~ provice acecuate guidance to airport ice on tions a:rcraf sougnt t wingstct tre solubons e eccm o cc eenca-s cumutabcn (2) tne "known inherent ma agement regard.ng the measur u
of icing of engme n e' c ctes t'a'. c'o- o.tcr a *cra" o c aracterisbcs of the B 737 ment of runway shapermess. they do min even smac amoun ts ci not provide thgntcrews with adequate vice wtal cockpit informa* c ca e g ne snow o <ce on its ung ;eatng edges power tne effects of reaa seca or arc < 3. , means to evaluate. or correlate runway ine om>tec encerience of the conc tions with airo'ane stopping per-s'ush on the takeoff ce"c ma ce cf iet t' gntc'e^ .n jet transport wmter oce a.
aircraft and snow accusa' c or tons formance. and they do not provide run-taxong ancraf t onen tra'fc co c tons way length recunements for each impose ce:ays in ta ec't c.ea a ces in .ts reco<t the Safety Board mace aap'ane consistent with reduced brak-a se es of 11 furtner sa'ety recom- ing pe formance on shopery runways '
The An Florida accice-! issues Ae e mencatens to F AA in accaon to Theim- Boaid also found tnat the airport explored einausbse'y m a ' cay c c < crove; metnocs for ceicmg aanners had tar'ed to "imorove the Concitio hearingBoarc Marcn in Arnngton Memte, V. France g n.aHin ea'!y on tre g ound then goa's incluced of the ice covered runway "
mm.m.rng traff c ce:ays on the grounc Boston controters had requested McAcams who hac 'escc cec to ' e scene of tne accicent in Ja uary m srca u n'e' coerabens. and an anwo'- impro.ed odot trammg in only one traking cond: tion report from presided at the hearing a pdot in 'he 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before the crash thiness directive recuirirg the even though 14 aircraft had landed Of 01 August Board acooted its report on the crase 10. 1982. the Sa'ety necessa y airpiane mocifications the 14 pdots only 5 volunteered su ,
The Board sato the causal factors were anc or r changes n operationa! oro- recorts Two of tne three airplanes lan-cecu es for the B 737 to combat its cing within 11 minutes of World the thgnterew's failure to use engre citen-vo tendency with snow or ice on reported " poor" braking act c anti ice during the long taxi-cut anc tre its wing tead.ng eages -
fakeoff. the pilot s decis on "to take c't controllers did not pass flyera 'eports ,e Eva ualmg FAA's responses to tne on to either the arroort m * '.*~
with snowhee on tne anfod surfacesJ and the caotain's fadu e to abort the 10 recommendations made in January, to tne Woric captain, the
- takeoff in its early stage when the first the Board held that nine showed "ac- With its accide~ '
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adopted 18 safety recommendations trollers made five references on their recommended an inspection of all drawn from the World investigation and respective frequencies to " wind voice recorders of the same model to from a special study of the proDiems shear" of to readings from the be sure they were producing useable posed by snow, sce, slush or standing aaport's low-level wind shear alert tapes And the Safety Board's concern water on runways. The study included system. Throughout this 6-minute with the general adequacy of five-3 days of pubhc heanngs in Washing- penod. Pan Amencan's Fhght 759. a parameter foil recorders dates from ton, chaired by Vice Chaaman Fatocia Boeing 727. was tuned to one or tne 1974, when it recommended FAA ac-A Goldman, at which government and other treauency during a long taniout. tion that would bring about their industry experts reviewed all f acets of it began its takeoff roll on Runway 10 replacement faster than would normal retirement of the aircraf t in which they runway safety Among the goals of the at 4 08 Board's 18 recommendations are Ct pper 759 struck the top of a tree are instaffed. Under existing reguia-2.370 feet beyond the takeoff end of tion, any aircraf t with a type certificate
- Specific. required cntena for clos- the runway and crashed into a residen- issued before September 30, 1969, ing airports and for inspecting and taal area of suburban Kenner. Loui- may be equipped with the old fod improving shapery runways follow- s;ana All 145 persons aboard the recorder no matter how many "stret-ing pdot reports of brakmg inat is airliner and eight persons on the ches" and technological uodatings tne poor or nd. ground were killed in the second worst airkner undergoes. Only later types aahne casn m the md Sates se as weem anners mw mst o Amendment of air traffic contro! cro- e immeaate cuestions facmg in- have the NgdaF dewCes Mal eh cedures to reaune tnat controuers emaus were N m swar aa unicaW mcw data, m mcm (1) make frequent reauests for pilot e nes we maM M N m M is m m @ $ m M braking reports wnen the weather is g e ere ey a m e? N w W far mme cgehensM hkely to worsen braking cond tions M N Neew rew uak % days auer me h Weans and (2) relay poor and nil braking comot tapes awWy answered the crash, the Safety Board made six safe-reports promptly to au pilots and to first avestion But answers to the ty recommendations to FAA. The first aaport management untd manage- secW aN M were neeer WW two caHed fm W a samp%g of voice ment reports that conditions are ac- nor easy. recorders of the discont*ued model ceptable~ Fhght data and cockpit voice that remain in service, and any e FAA work with NASA to expand re. recorders survived the impact and necessary maintenance changes to staren on runway inction measure. post crash fire very well. but their assure their proper operation; and (2) ments so that tney can ce correlated recorded information was very poor. their replacement with improved with aircraft stopping performance, The cockpit recorder was a discon- recorders in no more than 2 years The possibly by use of existing aircraft tinued model Its tape had a signal four other recommendations, in effect, antsskid and mettsal navigation level no higher than background noise. Called for modern technology digital systems. tape speed fluctuation was twice' nor- data recorders in the new generation cm nad W @ d anne A, ad eMaHy m aH
- An FAA led government industry # #*** " #
task force to deve'op a takeoff traneous tones generated by the Noting that at least two U.S. aahnes monitonng system for aircraft recorder itself. already plan conversion of their entire cockpits. The thght data recorder was the fleets from the foil recorders to the metal fod, five " parameter" model digital recorders, the Board recom-designed with the technology of the mended to FAA a four fold solution to Summer Flying early 1950s. It literally scratches on the problem of 30 year old technology the fod a plane's heaoing, airspeed. recorders in virtually brand new Friday, July 9, 1982. It was. all altitude, vertical acceleration and airkners:
observers agreed, a " typical New micrognone keying-important in-
' Orleans summer day"-warm and dicators, but only indirect clues, at
- After a specified date, require that
' humid with' rain showers, some of them best, to the attitude of the aircraft, the pre 1969 airkners be fitted witn a heavy. Afternoon cloud build-ups pro- power its engines were developing and digital recorder that retains data on NS;d thpnderstorms throughout the any wind shear effects on its perfor- 11 measurements of flight,inc6 ding mance and thghtpath. aircraft attitude, engine thrust and
'u' ' Vo~t Airport.
4:08 p m. CDT, it was not a new problem. Fifteen vertical and directional accetera-1nd local con- years earher the Safety Board had tion.
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