ML20154D260
| ML20154D260 | |
| Person / Time | |
|---|---|
| Issue date: | 09/07/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8809150216 | |
| Download: ML20154D260 (54) | |
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UNITED STATES OF AMERICA
- NUCLEAR REGULATORY COMMISSION l
Title:
Briefing on Proposed Rule on Degreed Operctors
- Public Meeting -
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Location: Rockville, Maryland I l
Date: Wednesday, september 7, 1988 l Pages: 1 - 35 l l
Ann Riley & Associates Court Reporters 1625 l Street, N.W., Suite 921 Washington, D.C. 20006 I (202) 293 3950 pk
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DISCLAIMER This' is an unof ficial transcript of 'a meeting of the United States Nuclear Regulatory Commission held on Sept. 7, 1988 in the Commission's office at One White Flint North, Rockville, Maryland. The meeting was open to pubile attendance and observation. This transcript has not been rev'iewed, corrected or edi ted, and. it may !
I contain inaccuracies.
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The transcript is intended solely for general
- informational purposes. As provided by 10 CFR 9.103, it is not part of the formal or informal record of decision of the 1 matters discussed. Expressions of opinion in this transcript do not necessarily reflect final determination or beliefs. ,
1 No pleading or'other paper may be filed with the Commission i
in any proceeding as the result of, or addressed to, any stat'ement or argument contained herein, except as the ,
! Commission may authorize. '
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- 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 BRIEFING ON 5 PROPOSED RULE ON DEGREED OPERATORS 6 ***
7 PUBLIC MEETING 8 ***
. 9 Nuclear Regulatory Commission 10 One White Flint North 11 Rockville, Maryland 12 13 WEDNESDAY, SEPTEMBER 7, 1988 14 15 The Commission met in open session, pursuant to 16 notice, at 10:03 a.m. , the Honorable LANDO W. ZECH, Chairman of 17 the Commission, presiding.
18 COMMISSIONERS PRESENT:
19 LANDO W. ZECll, Chairman of the Commission 20 THOMAS M. ROBERTS, Member of the commission 21 KENNETH ROGERS, Member of the commission 22 23 24 25
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2 s 1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
2 3 S. Chilk V. Stallo 4 Z. Rosztoczy W. Lahs 5 E. Beckjord T. Murley 6 M. Malsch 7
8 AUDIENCE SPEAKERS:
9 10 J. Persenski 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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. 3 1 PROCEEDINGS 2 (10:03 a.m.]
3 CHAIRMAN ZECH: Good morning, ladies and gentlemen.
4 Mr. Carr is on travel and will not be with us this morning.
5 Today we'll here from the NRC staff concerning a proposed rule 6 which would require future senior reactor operators licensed by 7 the NRC to possess a Bachelor's degree. The proposed rule, the I
8 proposed degree rule and an alternative proposed by the NRC 9 staff are described in SECY 88-245, which I understand is 10 available as you enter the meeting room today.
11 In addition, I understand that copies of the handouts 12 to be used during the briefing are also available. This ,
13 meeting is an information briefing. Do any of my fellow 14 Commissioners have any opening comments to make before we 4
15 begin?
16 (No response.]
i 17 l CHAIRMAN ZECH: If not, Mr. Stallo, you may proceed.
18 MR. STELLO: Thank you, Mr. Chairman. In a moment, l I 19 I'll turn to Zoltan Rosztoczy to do the briefing. But before I 20 do, I thought I'd point out that this issue is an issue that's I
21 been before a number of commissions. In fact, the issue arose 22 in July 1979 when none of the present commissioners were even l
23 on the Commission at that time. It has a very, very long i
1 24 history. It has been with us for a very, very long time.
25 It's been my observation and the feedback that I get i i 1
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1 from others as well, but from my visits to the plant, that this 2 continues to be an issue of major concern to operators. I 3 think the bottom line issue is the fact that it's not decided 4 and has not been decided for so long.
5 So I have a simple message. And that's just simply I 6 think we ought to everything we can to get the issue decided as 7 soon as we can. I think the lack of bringing this issue to 8 closure is more of a concern to me than whatever the closure ,
9 might be, so I think I would urge that we find a way to 10 finally bring the issue to some decision making, get a decision 11 made, and got on with it. I think that whatever that decision 12 will be vill cause considerable settling in the industry.
13 With that, let me turn to Dr. Rosztoczy to begin the 14 briefing.
15 MR. ROSZTOCZY: I will be using the briefing handout 16 and I will be referring to the pages of the handout as we go 17 on. The first paga of the handout is the outline of the 18 presentation. I will be outlining the purpose of today's l 19 briefing and I will provide you with background information on l l
20 the proposed rule. I will describe the proposed rule in some l l
21 detail, what will it require. I will mention the policy 22 statement that will be issued concurrent with the rule and give l
23 you nome idea about the inpacts that the rule would have, both '
24 the benefits and the potenti'al drawbacks of the rule.
25 Finally, I would like to present the potential i
4 1
, 5 1 alternative that you might want to consider. Turning now to 2 the second page, the purpose of today's briefing. Today's 3 briefing is basically -- the purpose is basically three-fold.
4 We would like to present to you, describe to you the rule and 5 present the background for the rule. We would like to offer a 6 potential alternate approach that you might consider. And then 7 ve would like to obtain the Commission's decision regarding the t i
8 rule.
9 We have prepared the rule. It is in pretty much 10 finished form. So if you wish to proceed with the rule, it's ,
11 ready to go out for public comment. I am turning now to Page 3 12 of the background. As Mr. Stello mentioned, this rulemaking 13 has a long background. I am starting only from 1986, and more !
14 recent even.
15 COMMISSIONER ROBERTS: That's correct. Because in i 16 1982, ths Commission had an advisory panel that strongly 17 recommended against the degree requirements and pointed out 1
18 some potentially negative aspects. And in 1984, the Commission i 19 disapproved a proposed senior manager rule. So there is a lot l l
20 of background. I don't go back to '79, Vic, but thet peer 21 panel in '82 could not have been more emphatic about their 22 disapproval of this notion. Excuse me. Continue.
l 23 MP. ROSZTOCZYt Following all of thobe even'.s, i t. l l
24 1986 an advanced notice of proposed rulemaking was issued for l 25 public comment. We have received 200 comments on the proposed
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- 6 1 rulemaking and these were overwhelmingly negative in the sense 2 that they opposed a rule for degree requirement, but at the 3 same time, most the comments acknowledged the need for 4 additional training.
5 In SECY 87-101, 1987, we reported the results of the 6 public comments to the Commission and also offered three 7 options at that time. SECY 87-101 recommended that the 8 training issue be separated from the educational requirements 9 and presented the three options for consideration.
10 The Commission accepted the separation of the 11 training and the educational requirements and sent a staff 12 requirement memo to the staff in June of 1987 requesting that 13 the staff prepara a rule according to Option 1 of SECY 87-101.
14 The staff proceeded along these lines. In the meantime, we 15 have also discussed this issue with the ACRS and the ACRS 16 issued their report in August of 1987. .
17 They also acknowledged that there is a need for 18 technical knowledge on shift, but they felt that the proposed 19 rule should be reconsidered due to the advetse affects.
20 Following --
1 21 COMMISSIONER ROBERTS: Well, now let's get it all i
j 22 out. They strongly unanimously were opposed to degree i 23 requirements for operators. Now, that's what they said and i
1 24 that's what ought to be said in this meeting.
1 J 25 MR. ROSZTOCZY: Yes. They indicated that, thst they l
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~ 1 do not recommend to go ahead with the degree requirement rule, 2 but at the same time they cephasized that additional craining 3 and additional knowledge on the shift would be beneficial.
4 COMMISSIONER ROBERTS: Okay. But let's say 5 2verything and not be selective in what we omit or what we 6 volunteer.
7 MR. ROSZTOCZY: Following this, then we prepared the i
6 rule, the actual rule to be issued and we presented the rule to a 9 CRGR. CRGR reviewed it recently, 4.. July of this year, and j 10 they have issued their letter on it also.
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11 COMMISSIONER ROBERTS: And what did that say?
12 MR. ROSZTOCZY: They said that while it is desirable 13 for SO's to have a dagree, they do not see any evidence that l
- i 14 the rule requiring a degree is necessary. More recently, in
{ l i
j 15 this month -- last month, August of 1983, we has the benefit of l 16 a presentation from the industry. An industry group supported l
l 17 by a nunbar of utilities, conducted a survey of the operators I
} 18 on the degree requirement and related questions. And they 1 19 documented the results in a report form which has been 20 submittod to the Commission recently.
21 Tha operator survey was conducted through the PROS 22 organization. This is the Professional Reactor Operators 23 Society. And their members were the ones who were surveyed.
24 The outcome of the survey indicated that they see some morale j 25 problems in terar. of reactor operators who do not have degree
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8 1 advancement, and they see sr2e problems in terms of senior 2 operators turnover because with having a degree and having the 3 opportunity to progress into other positions, they felt that 4 they would try to get out of shift work. Apparently the 5 operators, in general, prefer to get off from shift if the 6 opportunity shows up.
7 They also saw some negative impact on safety. These
, 8 findings from the PROS survey was very similar to the comments i
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9 that we have received from PROS during the comment period of l 10 the advanced notice for rulemaking.
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11 And turning now to Page 4 which describes the SECY 12 87-101 options. There are basically options offered. One of 13 them is the degree requirement which would require that after a l 14 certain data, every senior operator, in order to receive a 15 senior operator license, would have to have a degree. The j 16 result of this would be that eventually there would be two ;
4 17 neniet operators on shift with degrees. l l
18 The second option was a rule on a senior manager with 19 degree. This option instead of requaring that the senior '
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- 20 operators possess a degree, would simply require that on each 1 i 21 site, there would be a senior manager who has both a degree and 22 an SO license on shif t at every time.
23 And the third option which was described in SECY 87-24 101 was the policy statesent option. In that case, there would 25 be no rule issued at all. There would be only a policy 1
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9 1 statement. In the first option, the degree requirement would 2 also have a policy statement with it. And then I will come 3 back to the alternate approach which is kind of an updating of 4 the second option. We are recommending that if that goes 5 forward, that that would have a policy statement going with it 6 also.
7 so all three of these options do include the policy 8 statement and it would be basically the same policy statement.
9 The purpose of the proposed rule is to upgrado 10 operating, engineering, and accident management expertise on 11 shift. It would require that a Bachelor's degree in 12 engineering, engineering technology, or physical sciences must 13 be possessed by anyone who wants to apply for a senior i 14 operator's license.
15 It does not have an equivalency statement. Some of l
4 16 our other regulations say that an engineering degree or !
17 equivalent. This rule would not have that. It would also 18 require two years of nuclear power plant experience which is ,
19 the same as the present requirement, but it would be more i 20 restrictive in one respect, that it would require at least one 21 year out of these two be spent as an operator at greater than 22 20 percent of power. l 23 The current requirerents for someone who already l l
24 possesses a degree do not specifically require operating l 25 experience. So someone with a degree and the two years of '
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1 nuclear power plant experience, for example engineering 2 experience, could qualify. Under the new rule, hands-on 3 experience would be required for at least one year.
4 Current regulations also provide for some exceptions 5 to facilitate special cases, like new plants starting up or 6 plants which have been shut down for a relatively long period 7 of time, and we would carry those over so those exceptions 8 would apply in this case also. In connection with those SO's 9 who already have an so license, there would be a grandfathering i 10 clause which will permit them to retain their so license for i 11 their life, and it would also permit them to obtain a new So l 12 license it needed without possessing a degree.
13 So for example, if somebody has an SO license for a 14 pressurized water reactor today, and if he happens to change j 15 jobs maybe ten years from now and moves to a boiling water 16 reactor and needs an so license for that, he could apply for .
] 17 the So license even though he doesn't possess a degree. A !
I 18 degree would not be required. The rule will go into ef fect I l
19 four years after the effective date of the rule. So anyone who ,
l l 20 possesses a license at the effective date would be l 21 grandfathered.
22 We expect that the actual rulemaking would taka 23 approximately a year, so it would be approximately five years 24 from now, and then it would go into effect. And we certainly i
25 feel that's sufficient time for those operators who intend to 1
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- 1 get an So license, but do not intend to possess a degree, they 2 should be able to do it, to do it in that time period.
3 The rule is written in such a way that it would not 4 apply to resaarch and test reactors. It would apply only to 5 power reactors. And as I mentioned earlier, the equivalency 6 statement has been eliminated so there would be no action on l
7 that. Let me turn now to Page 6 which is a table, and it 8 compares the current requirement to the proposed requirement.
9 The top row indicates that the educational ,
10 requirement obviously would change. Instead of a high .:hool 11 diploma required, it would require a Bachelor's degree. In l
l 12 terms of the experience required for those who do not possess a 13 degree, it would stay the same experience. The only additional l
14 requirement now is that you must have your So prior to the cut 15 off date. Otherwise, you could not progress into the senior ;
i j 16 operator position. ,
j 17 In terms of the experience required with a degree, 18 there have been two main requirements in the past. Two years j 19 of responsible nuclear power plant expurience and six months of 20 this at the specific plant where the license is obtained. We 21 would retain those two requirements and then we would add the j 22 third one, which would require one year as an actual operating 23 experience.
24 Let me turn now to Page 7, which indicates the 26 staffing requirement for a one-unit plant. We selected the ll
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, 1 one-unit plant just for simplicity, but basically the same 2 things will apply for multi-unit plants also. At the present 3 time, in terms of reactor operators, the requirement is that 4 either five or four people be present. If none of the senior 5 operators possesses a degree, then an STA is required. And in 6 that case, five people are on the shift. If one of the senior 4
7 operators possesses a degree, that can double up as So and STA 8 at the same time. And in that case, there are only four people 9 required on the shift. So it's either five or four.
10 Under the new rule, the staffing requirement would 11 basically say the same. If both of the operators are 12 grandfathered operators and therefore do not possess a degree, l 13 then an STA will be required in the future also and that would
! r 14 make an operating crew of five people. However, if one of the l 15 senior operators or if both of. the senior operators possess a j :
16 degree, then only four people would be required on shift. So l
17 it's basically the same and the expectation is that with time 18 going by, the shift would toward one or both SO's having
>i 19 degrees so the shift would be definitely in t1e order of having 20 only four people on the shift. (
21 Let me turn now to Page 8 of the handout, the i 22 concurrent policy statement. In adottion to the rule, at the l 23 same time that the rule is issued in final form, there would be 24 also a policy statement issued. The purpose of the policy 25 statement would be to encourage the utilities to have their 1
13 1 employees achieve degrees. They would be encouraged to set up 2 programs which permit -- which leads to degrees, so utility ,
3 waployees could take advantage of this.
4 Employees or operators would also be encouraged to 5 take advantage of these programs and to obtain degrees. In 6 addition to this, the policy statement would also encourage the 7 utilities to provide opportunities for senior operators who 8 want to progress into other positions in tna utility 9 organization, including utility management, including 10 engineering and so on.
11 So the policy statement would put all this forth, 12 lateral with the issuance of the rule which would simply spell 13 out the actual requirements. Let me turn now to Page 9, which 14 lists the potential advantages of the degree rule. The main 15 advantage that we can see is that it would enhance capability 16 on shift to handle unusual events, abnormal events. Events 17 that they are not trained for exactly, but events where they '
18 have to make certain decisions, react on the spot.
19 Another benefit would be that it would provide ,
20 improved career opportunities for senior operators. It would 21 be easier for them to progress into other entire more 22 responsible positions in the utility organization. The third 23 benefit would be that by this process, there would be an 24 infusion of people with t;perating experience into other fields l l
25 within the utility organization as well as maybe in other I
14 1 organisations also involved in the nuclear industry and even in 2 the regulations. So it would provide more movement of people 3 with operating experience.
4 We also expect that the new rule would represent 6
l 5 improvement in terms of attentiveness to controls and plant 4
- 6 accommodations, and in terms of quality of communications in i
. 7 the control room and between the control room and others. So 8 those are basically the main benefits that we see from the 9 rule.
l 10 The next page, which is Page 10 of the handout, i j 11 discusses the possible negative impacts. We do foresee a ;
I 12 reduction in overall experience on shift. And we do see this I ,
13 for two reasons, one of them that there would be greater
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14 turnover of the senior operators. By having more opportunities 1
! 15 to progress into other positions, senior operator positions, 16 they probably will stay shorter in this position _than they l 17 presently are staying.
i 18 The other reason is the pool of applicants from whom 19 the senior operatorn will be picked. At the present time, many 1
1 20 of them are coming up on the operating side where they have 21 been operating the plants for nany years before they become
- 22 senior operators. Under the new rule, some of them would be
{ 23 coming up along those lines, some of them would be coming 1
1 24 through a different pool. They would be coming more from young ;
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l 25 engineers who have just graduated and obviously they would have
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. 1 less operating experience than the first group of people.
2 The third disadvantage that we see is the 3 individual's morale and inci.vidual's potential for advancement 4 for the reactor operators. So these are reactor operators who 5 do not have degrees. They would be more restricted. They 6 would have to get into a degree program if they want to become [
7 senior operators. They couldn't progress the way it's done 8 today.
- 9 Let me turn now to Page 11, which discusses some of l 10 the cost involved. When the advanced notice of rulemaking was l 11 issued, one of the questions that we asked was what would be 1 1? the associated costs. We have received different types of ,
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- 1J estimates. Different people approaching it differently. Some 1
2 14 were calculating the total number of dellars which would be
] 15 spent. For example, if the sent all of the operators to '
16 college for four years before they continue as senior operators l
. 17 in the plant, an.' came up with a relatively la Je number.
i 18 I do ncn have all of those numbers here. Wha", we l
1 4 19 have here is a listing of the estimates of how much doed it j 20 cost to have an accredited program on site for the operators no 21 they car, enter into a degree program. The estimates for this
, 22 type oi a program varied from $250,000 to $480,000 per year.
- 23 These ware sent in about a year ago, so they could be slightly j 24 out-of-date, but they're probably very close to what it 25 actually costs.
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. 16 1 We have also received a little bit more information 2 on one of the programs, which is the Grand Gulf program,.which 3 actually costs $250,000. They have approximately 60 people in 4 the program. It is an accredited program administered by the
, 5 American Technical Institute and it is set up in such a manner
- 6 that it accommodates the needs and timing schedules of people ;
7 working in the plant, independent of what shift they are 8 working on.
9 For example, they offer some of the classes more than 10 once and if you are unable to take it at one time period, then 11 you can go and take it at another time period. i 12 r,OMMISSIONER ROGERS: What degree does that program l
i 13 lead to or is there more than one degree that's possible?
14 MR. ROSZTOCZY: I do not know the answer to that. My !
15 guess would be it's probably more than one. Bachelor's in
! 16 nuclear technology is the answer.
17 COMMISSIONER ROBERTS: Who is the accrediting 18 organization? You say the program ic accredited by whom?
19 MR. ROSZTOCZY: The way that colleges are being 20 accredited in the country, there are regional accrediting 21 bodies, four or five of these for the United States and each j 22 cover a certain region. They ar1 the ones who are accrediting 23 all the universities and colleges. The same organization is 24 accediting this progret.. So it's up to the same. If a 25 university wanted to apply for accreditation, it goes to the 1
17 1 same regional organization.
2 COMMISSIONER ROGERS: Excuse me. That's regional, 3 not ABET?
4 MR. ROSZTOCZY: I believe it's called Regional !
5 Accrediting --
6 MR. PERSENSKI: I'm J. Persenski from the Office of 7 Research. I believe that's accredited by the Southeastern 8 Association of colleges and Universities. That particular
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9 program.
10 COMMISSIONER ROGERS: Is it accredited by the 11 Accreditation Board for Engineering and Technology?
12 MR. PERSENSKI: I do net believe that program is.
13 CHAIRMAN ZECH: Thank you. Let's proceed, please, j 24 MR. ROSZTOCZY: I would like to turn now to Page 12 4
15 of the handout, which is the potential alternative. After
] 16 hearing .some of the negative comments on the proposed rule, we 17 were trying to look at other possibilities, basically with the 18 purpose of trying to retnin the advantages that everybody has 19 acknowledged in connection with the rule. And at the same 20 time, trying to minimize the negative aspect. 1 21 Trying to put this together, we arrived back to the 22 second altetnative in the original proposal which is the senior 23
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manager approach. But we would like to supplement this with a 24 policv statement if thic option is selected. This would 1
25 require an engineering degree as well as a senior operator 4
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18 1 license for the senior manager. The senior manager would have 2 to be on-shift. There would be one senior manager per shift.
3 So there are a number of plants on the site where there would 4 be only senior manager. And he would be responsible for 5 integrative management. There are a number of issues which i
6 would have to be worked out. If you wish us to proceed along l 4
7 these lines, we have not verked those out yet, but we could do 8 it.
9 Let me turn now to the last page, Page 13 --
- 10 COMMISSIONER ROGERS
- Excuse me. I just want to make 11 sure I heard that correctly. That approach is that the senior 12 manager could be responsible for more than one plant on-site, i i
13 more than one reactor on-site?
14 MR. ROSZTOCZY: That's correct.
15 COMMISSIONER ROGF.RS: A site manager, then.
j 18 site, we would be still working on the details, whether ha 19 would have to be an additional person or whether he could --
20 worked out in such a way that he would, at the same time, be I 21 also the backup senior operator. That would be something that 22 we would have to work on more before any recommendation.
I 23 Let me turn then to Page 13, recommendations. We l
! 24 would like to recommend that the Commission consider the 1
1 25 alternate approach which would establish a senior manager i
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19 1 position. Second recommendation is that if the Commission so 2 desires, then the staff would develop a rule and policy 3 statement for the alternate approach. And finally, the third 4 recommendation is that the Commission decide how to proceed 5 with the proposed rule, whether to proceed with the proposed 6 rule.
7 If you decide to proceed with it as is, then we will 8 be ready to issue it for public comment. If you have any 9 comments or recommendations that we ought to consider before we 10 issue it for public comment, we'd like to hear those. That 11 completes my presentation.
I 12 MR. STELLOt We're through.
13 CHAIRMAN ZECH: All right. Any comments from my 14 fellow Commissioners? Mr. Roberts?
15 COMMISSIONER ROBERTut Well, I would like to quote 16 from the ilummary the attitude survey of nuclear power plan,t I ,
i 17 operation personnel, Powell Associates, August 1988. This 18 attitude survey on operations personnel will be a bold faced ,
- 19 opposition of the degree requirement for the SRO license.
- 20 Those operators surveyed expressed a conviction that the degree 1
4 21 requirement would have a negative impact on safety and I 1
22 efficiency of nuclear power production, citing increased i 23 attrition rates, lower morale among non-degreed operators, and I 24 substantial problems with the recruitment of degreed engineers 25 in the operation.
1
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-, 1 I'm not going to read this whole thing. I got two 2 more sentences. Perhaps most significant was not this finding 3 itself, but rather how widely spread the opposition to the 4 degree requirement was among all, underlined, ranks of 5 operations personnel, including those already possessing 6 technical degrees and those protected by the anticipated 7 grandfathering provisions of the proposed rule.
8 For example, among licensed operators with a 9 technical degree, now this is awkwardly said, three responded 10 that safety would decrease under the proposed rule for everyone 11 who felt it would increase. And even in your presentations, 12 you say, in proposing this rule, you make the positive 13 statement we're going to have a decrease in experience on 14 shift. I an obviously very much opposed to this notion. Thank 15 you.
16 CHAIRMAN ZECH: Mr. Rogers? ,
17 COMMISSIONER ROGERS: Well, I've given this matter a 18 lot of thought and it seems to me to come down to ultimately 19 the question of what is the relationship to safety, that that's 20 our business. We've been told by Congress that's our only l 21 business and it certainly is our principal concern and starting )
22 point for everything. And when I look at all the documentation 23 that has been submitted to me and talk to people in the field, 24 I have not been convinced that the degree requirement for 25 operators is required for safety.
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. 21 1 As commissioner Roberts has pointed out, there have 2 been statements that it could be negative, but I certainly have
! 3 seen it as required for safety. And I'm disinclined to 4 establish a rule on a basis that is not clearly founded in ,
5 safety. There are a number of good spinoffs and long torn 6 effects that are positive, could be positive, but I don't see 7 it as bearing a direct relationship to operation safety at this 8 particular time in terms of a degree requirement for operators.
, 9 However, I do feel that there is a relationship I
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10 between the presence on shift of an individual with the kind of 11 educationalal background that would allow that person to 12 analyze very difficult and unusual situations that go beyond
! 13 any of the training procedures that are in place. I understand
- 14 that the STA position which was created to deal with that har.
l 15 really not worked out entirely satisfactorily, and so that it j
l 16 is important to look at other possibilities. '
1 i
17 And in coming to my position on this, I have to say
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18 that I can't support a degree requirement for SRo's across the
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- 19 board, although I do see its advantages and I do see why we l j i
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20 should encourage it. But I cannot go so far as to see that it .
j 21 should be established by rule. I do see, however, this gap 22 between the kind of analytical and systems thinking based on
] 23 fundamental principlas that it's highly desireable to be i j
24 present on shift in the event of an unusual situation.
$ I 25 Therefore, I an inclined towards something like the alternative I
1 .
22
- 1 that is suggested here.
2 However, I have to say that I'm concerned about just 3 the nature of those degrees that would qualify. The program 4 which was cited here as an example at Grand Gulf, if it is not 5 ABET accredited, and ABET stands for Accreditation Board for [
6 Engineering and Technology, which is a national organization ,
g 7 which accredits all engineering and engineering technology l
j 8 programs in the United states, in addition to accreditation of !
, 9 institutions by regional accrediting organizations, and there's, i i
10 quit a "1bstantial difference between those two types of )
i I
11 accreditation.
12 And ABET accreditation has very specific requirements !
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13 with respect to the kinds of resources that must be provided in 14 the training programs and educational programs that are not l' 1,
15 necessarily those of a regional accrediting commission. So 16 that I think that one should look not only at the question of a 1
j 17 degree, but what kind of a degree, what's involved in that, so !
18 that the objective, the safety objective is set.
19 And therefore, I am not entirely comfortable with the 1
20 range of degrees that were cited in the proposed rule because I
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21 think it's too broad. And I would tend to want to see specific ;
1
. 22 requirement of an engineering degree from an ABET accredited '
23 program and not expanded beyond that if we were to talk about a 1
24 degree requirement for anyone in any way, or in some sense the 25 equivalent which would be, in my view, a professional 5
23 1 engineer's license, might serve that purpose.
2 However, I am not in favor of the degree requirement 3 for SRO's across the board, although I think we should 4 encourage in every way, through a policy statement, the 5 programs which could lead to SRO's being acquired by those 6 individuals that really want ultimately to move forward in 7 management. So where I come down is that I like the 8 alternative approach that staff has presented.
9 However, I do have a problem with what was in the 10 SECY in that it seems to require the creation of a new 11 management line within the organization and it would seem to me 12 that that doesn't seem to be necessary as long as the 13 individual, the management individual who has charge of thosa 14 persont. on chift has the degree, I don't see that it's 15 necessary for us to impose a newly defined line of management 16 within each organization. ,
17 So I'd like to comment on that further if we happen 18 to go that way. I do think that the SECY 84-106, which I have 19 not only -- could just get my hands on recently, and haven't 20 studied in great detail, seems to provide a mechanism that 21 would satisfy me and I know that's re-treading old ground, but 22 we're re-treading so very old ground on the degree requirement.
23 And my position as of now is that I feel that I would like to 24 see a degreed individual on shift, on every shift, in a 25 position of responsibility, but not necessarily require that
. 24 1 individual to be an SRO.
2 CHAIRMAN ZECH: Thank you very much. I guess first 3 of all I'd like to ask how many at this table do not have a 4 degree? -
5 (No response.)
6 CHAIRMAN ZECH: I wonder how many
) I guess we all do.
7 in the audience do not have a degree.
8 (No response.)
9 CHAIRMAN ZECH: I don't see any hands up. I guess 10 perhaps that would mean that if we had senior reactor operators 1
11 with 15-20 years of experience, they probably would not be here 12 today to land their experience to what we're about.
13 Let me just say this. I think in the P.egulatory i i
14 Commission, our primary responsibilities are to bring the l 1 L 15 benefits of nuclear energy to the public with the reasonable !
16 assurance that the public health and safety will ce protected.
l l t
1 17 That's fundamental. Our primary responsibility is safety and I i
!' 18 ve know that.
s i
19 The second point I'd like to make is that if there is t
20 to be a future of nuclear energy in our country or throughout !
l 21 the world, in my judgment, the primary responsibility we have r I
22 as far as power plants are concerned, is to keep those plants f j 23 operating safely, 4
f 24 The third point I'd like to make is that in my view, 25 education provides an incentive to enhance operator 1
I L i
25 I
, 1 understanding of engineering and technical aspects of the powsr 2 plant. I believe that education encourages curiosity. It 3 encourages the use of our imagination. It encourages an 4 understanding. It adds the confidence of our thought-making !
5 process. It broadens our interests. These are intangible !
6 benefits, I will submit. But I do believe that educ. tion does 7 permit us and encourages us and allows us to make better use of 8 our human abilities.
9 It is my view that the migration of qualified and 10 experienced reactor operators upward into plant management will 11 raise the level of professionalism of the utility and will 12 contribute to improved plant safety. I've heard the polls, 13 I've heard the surveys, I've heard the other arguments, and I'm 14 giving you my personal view. I believe that professionalism j 15 will be increased and that improved plant safety will result ,
r 16 from raising the education level as.well as the training of our i i
17 control room personnel. That's my personal view. '
18 Therefore, from the operator's standpoint, it seems
{
19 to me we are limiting their career opportunities. We are l 20 precluding them from participating at this table or in this 21 audience. It's an unwritten policy, I believe we can conclude, 22 that only degreed personnel, in general, are allowed in the 23 management of the utilities. I agree that there are some --
24 acknowledge that there are scie exceptions, but not too many. j l
25 Not all operators would want the added 1 1
l
r 26
! 1 responsibilities of management, but I don't believe we should I ,
2 preclude those from attaining those increased responsibilities i'
) 3 if they so desire. From the utility management viewpoint, if I !
4 were a utility manager, I would want to bring about an infusion l
5 of operating experience into my utility management. I would f 6 think that would add strength to my organization.
7 I would personally believe that, although difficult (
8 to measure and intangible, that safety would be improved by i I
9 adding to professionalism and education in my utility, if I f I
10 were a utility manager. I would attempt to eliminate the gulf j i
11 between the control room and the board room, which I believe l
t 12 exists now. I would attempt to remove that gulf, or at least l 13 partially remove that gult by upgrading professionalism, by l I
14 increasing plant safety. I think they would both come about by i
15 encouragement of educational process of my very fine and very [
16 competent control room operators.
17 I would attempt then to have a greater integration f i
18 between the control room and management. I2 I were a utility j 19 executive, I would be confident that I would be adding strength 20 to my organization. I would also be adding safety in my j 21 personal view. Well, those are my thoughts. I an encouraged 22 by my plant visits to note that many utilities have already in 23 place some very fine programs whereby they are indeed allowing r i
24 the opportunity for their control room personnel to achieve l 25 degrees. l l
27 i
. 1 I ask this at most every utility I visit and I must 2 say that in_my most recent visits during this past year, I have r
3 been encouraged, in general, by recognizing that the utilities 4 have indeed placed some of the excellent programs in place 5 whereby their operators can voluntarily, and many times paid 6 for completely by the utility, achieve a degree.
7 So I think it's happening in many utilities. I an ,
8 only discouraged by the fact that not all utilities have as ,
1 9 aggressive a program as many do. I think a rule would be j 10 he.; ful. A rule and a degree doesn't necessarily make an !
11 operator a better operator. I fully recognize that. But f do j 12 think for the long haul, we should be increasing i
13 professionalism, increasing safety, and as intangible as it i 14 might be, I think that that's why the subject has been debated j 15 for so many years.
. 16 I, too, want to bring it to closure. I hope we can l
17 do that soon, at least for the time being. I can't help but i i
is feel though that unless we put in place some program that !
19 appears to be attempting to improve professionalism and improve 20 safety, that some other commission in the future will be {
l 21 vrestling again with this same issue, j 22 I have great respect for my colleagues and the l
23 different viewpoints. I simply feel that putting some kind of i 24 a program in place that would allow the operators themselves to 1
25 have more opportunities to advance, have their strength I
l 28 1 capabilities to management, is the right thing to do. And L i
2 almost even moreso from the utilities standpoint, I feel ,
3 they're not taking advantage of the talent we have.
4 I've been impressed by the operators that we have in l 5 our plants. In general, I think they're excellent and I just - I 6 - I simply don't feel that we're taking advantage of the talent [
l r 7 that we have. Well, those are my thoughts and I would ask for :
a any comments from colleagues.
l 9 COMMISSIONER ROGERS: Wall, just that I think that i 10 this is an issue that reasonable people coming to very 1
11 thoughtfully and carefully can come to somewhat different II conclusions on. It's not a very simple matter or it would have l 13 been settled a long time ago. I certainly am not one who will j 14 speak against education. It's been the better part of my life f f
15 for the last 30 years. L f
16 However, I think that we have to be clear on our j 17 objectives and very clear on how we go about them using the f
l 18 tools that are available to us as regulators. And I guess what 19 I really have trouble with is how we're using a rule to create 20 a situation that we think is a good situation, but we really '
1 1
21 can't defend entirely on its direct relationship to immediate 22 safety concerns.
23 And I feel that NRC rules should be inviolable. They f
24 shouldn't be subject to any discretion in a sense. And that to 1
25 create a rule which can't be directly connected with the safety l l l l
1
29
! 1 requirement, I feel weakness all NRC rules, and therefore, we ;
2 should try to avoid them.
3 so I think that the opportunities for education are !
- 4 very, as the Chairman has stated, I agree really with 5 everything the Chairman has said in terms of the desirable ,
6 features of education programs and education opportunities.
1 7 But I stop short of agreeing that a rule is the proper tool to i 8 use to help to encourage that kind of a situation.
( 9 It would require a certain procedure and I feel tnat '
10 our requirements should be those that stand on a very, very
! 11 rock solid base, and that they should not be discretionary in i i j 12 any way and, therefore, should not apply to situations in which l
- 6 1
13 there is -- really there should be some room for discretion. ;
14 I believe that it's entirely appropriate for some i ,
15 individuals to see the peak of their careers in the control I i :
16 room. Degreed -- not degreed, but as reactor operators or l 17 senior reactor operators, as the peak of their aspirationc.
18 Because they have that kind of an interest and dedication and a 1 I 19 professional approach to that kind of activity. That does not {
1 )
j 20 lead them to wish to go higher in the management chain of !
a e
d 21 command, 1
i 22 Management tends very often to become less technical, 23 less technically involved, and that individuals whose heart and j 24 soul is in the techno.ogy of that particular plant, I could i
j 25 envision feeling very, very contented and professionally l
. - . - . . - - - , - . , _ , , _ . .._.a p., , . _ , . n,_w ,._e._,,n..n--_,_,y .- _ - _ . - , . , _ , , , - - , , , . , , . -- _.
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30
_ 1 satisfied in an SRO position, without aspiring, in a sense, to 2 nove up the management chain.
3 And therefore, I would see the control room 4 ultimately populated by people who wish to move ultimately into 5 management, and those who do not. And that both kinds of 6 individuals are important and can do a superb job in the 7 control room.
8 Therefore, I would want to provide opportunities for 9 those who ultimately want to move into management through the 10 acquisition of a degree as a very, very desirable and important 11 objective. But not necessarily one which we require to be the 12 case.
13 I also would like to see that experience in the 14 control room that comes from many years on the job. I think 15 retraining and refreshment is very important, so I think the 16 training programs are essential. But moving out of the control 17 room into management is not necessarily, in ny view, what we 18 should expect for every person who has a professional attitude 19 in the control room. I don't necessarily equate aspirations 20 towards higher management with or against professionalism. I 21 think they're separate issues and that I can see a professional 22 class in the control room that ultimately might all have 23 degrees, but that might be just the way it eventually works 24 out. But I don't see the necessity of imposing that 25 requirenant to achieve professionalism.
l 31 l
l r- 1 I would like to see us, in fact, think of other ways 2 to encourage professionalism in the control room and among the l
l
- 3 operators rather than through a simple device of requiring a 1
j 4 degree. I think there's much more that we could do to l
5 encourage that and I would be concerned that if, for example, 6 we passed a degree requirement rule, that we would then back 7 away from other possible ways of encouraging and developing 8 continued sense of professionalism in the control room.
l l- 9 So I think we've got hold of a difficult complex
( 10 problem. I've said I think somewhat my thoughts on it and I 11 respect the chairman's opinisna and statements because I think 12 they make a great deal of sense, but I would have to stop short 13 of a rule requiring a degree for all SRO's. I still would like !
14 to pursue this alternative that is offered and explore that to 15 a further degree. I have some questions about that.
16 But I'd like to just raise one question with you as 17 to why in your proposal for a rule, why you did not include ,
i 18 research and test reactors in this because it would seem to me f
19 that those are situations that even more require the i
20 sophistication of the highest level of education in their 21 operation. And is there a reason why you felt that it was l
22 inappropriate to extend your thinking of any kind of a 23 requirement in that direction, because it's automatically taken 24 care of by the situations in which they exist or whatever? I'm 25 just curious as to your thinking on that matter.
I i
i 1
I l
32 ,
l I
1 MR. ROSZToCzY: I think basically the consideration j 2 was that, fn terms of public safety, they are less contributors l
3 to the risk than the power reactors and maybe the requirement i
l 4 wasn't needed. We can foresee in the university for research ;
l 5 reactor, senior operators who have been there operating a l [
6 certain plant for a long time without a degree, and we didn't l 7 see the need for it.
8 COMMISSIONER ROGERS: I don't want to cloud the issue 9 by bringing that in. I think we have a problem in front of us 10 and I think we're talking about nuclear power plants and should 11 focus our attention on those. But I still have a concern about i 12 how we handle the research and test reactor situations. '
13 CHAIRMAN ZECH: Thank you very much. Well, an I i
14 stated, my position really is in favor of a rule because I 15 really do believe that professionalism and safety would be ,
16 enhanced and I believe that a rule would increase safety and ,
17 increase professionalism. And although my colleagues have j 18 differences, that's my position. But I would, first of all, !
l l i
19 let me thank the staff for a very thoughtful presentation on a t i 20 very controversial and difficult subject and one that has been 21 discussed for a nusber of years. j l ,
l 22 I think you have done what we askei you to do. You I
23 have additionally given us an option that I think is certainly '
24 worth our consideration. I would ask my colleagues to 25 thoughtfully consider the paper before us. I do recognize the
f 33 i
-- 1 importance of bringing to closure this issue. I would ask my 2 colleagues to, in their comments on the paper, perhaps to put 3 down any thoughts they may have that perhaps could attempt to 4 get some kind of a consensus on'this, whether we go from one 5 extreme to the other. I recognise that perhaps a compromise of f
)
6 some kind is necessary if we're going to make any progress at l t
7 all or really come to some kind of closure on this issue.
8 so I'd ask my colleagues to give their best thought ,
9 to it and perhaps in their comment could give their vieta that 10 might allow some kind of a consensus that would at least, try to ,
11 bring this issue to closure without just doing nothing. In f
i 12 other words, how best can we implement it, it we should av all. j 13 I think the staff has given us what I consider are four f i
14 options.
15 One is the rule that they proposed with the SRO j 16 requiring a degree in time, and .along with that a policy !
17 statement that would encourage education. The second would be f 18 a rule regarding the senior vanager. That is their alternative l
19 approach, also with the policy statement. The third would be a i 20 policy statement itself rather than a rule that would encourage !
i 21 education. And the fourth I suppose, although not proposed, l 22 but I suppose it's there, would be to do nothing. In other ;
i 23 words, the status quo.
24 l
So I'd ask my colleagues if they would give their :
l 25 thought to what is the best way to come to closure on this l
l
34 l 1 issue. What should we do to keep a focus on contributing to 2 safety. And what is the best way to resolve this issue. And I 3 hope we can come to closure on this in a reasonable length of I
- 4 time, hopefully perhaps within the next week or so. So that's 5 what I would hope we can do. And again, I'd ask my colleagues 6 to give it their best thought and attention so that we para ys 5 7 might accomplish this with the best result we possibly can for J
8 this vary difficult issue.
> 9 Are there any other comments from my fellow i
j 10 Commissioners?
11 COMMISSIONER ROGERS: Well, just that I would ask 12 staff to think about this question of professionalism among i
j 13 operators. Ways that we might approach that in addition to the 14 proposed way of the degree requirement. I thf.nk that there are 15 a number of things thrit might be done there and I would ask l
! 16 staff to give some real thought to that question to look at the 17 operator group, to try to see if there aren't otbar ways that 1
18 we could encourage continued developmaat of a sense of i
j 19 professionalism among the operators to achieve the kind of i
20 sense that they are deserving of recognition as professionals, -
21 and what we might possibly do in that reaard. I q 22 Cl! AIRMAN ZECH: I'd like to suggest though that that l
] 23 may be a separate subject. I really would like to come to !
l l 24 closure on this.
25 COKMISSIONER Rte >'.4 No, absolutely. Not as a i
35
, 1 condition for dealing with this, but just to take that on as a 2 separate matter.
3 CHAIRMAN ZECH: All right. Any other comments?
4 Thank you very much. We stand adjourned.
5 (Whereupon, at 11:05 a.m., the hearing was 6 adjourned.)
7 a
9 i 10 11 12 1 13 14 15 16 17 18 l 19 1
! 20 21
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25
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CERTIFICATE OF TRANSCRIBER This is to certify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled:
TITLE OF MEETING: Briefing on Proposed Rule on Degreed Operators Public Meeting PLACE OF MEETING: Washington, D.C.
DATE OF MEETING: Wednesday, September 7, 1988 1
were transcribed by me. I further certify that said transcription is accurate and complete, to the best
. c' my ability, and that the transcript is a true and :
1 i
accurate record of the foregoing events.
t s_- -
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Ann Riley & Associates, Ltd.
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DEGREE REQUIREMENT FOR SENIOR REACTOR OPERATORS r
- PRESENTATION FOR THE COMMISSION P
i SEPTEMBER 7, 1988 l
ZOLTAN R, RoszTocZY, 49-23760 .
! WILLIAM R LAHS, 49-23774 -
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OUTLINE OF PRESENTAT M PURPCSE BACKGROUND
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PROPOSED RULEMAKING POLICY STATEF.ENT IMPACTS AND COSTS POTENTIAL ALTERNATIVE ',
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PURPOSE i
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t i i i PRESENT THE BACKGROUND 1 JD BASIS FOR THE PROPOSED ;
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OFFER A POTENTIAL ALTERNATE APPROACH d
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- OBTAIN A COMMISSION DECISION REGARDING PUBLICATION OF j PROPOSED RULE !
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BACKGROUND MAY 30 1986 ADVANCED NOTICE OF PROPOSED RULEMAKING APRIL 16, 1987 SECY-87-101: ISSUES AND PROPOSED OPTIONS CONCERNING DEGREE REQUIREMENT FOR SENIOR OPERATOR 1
J JUNE 24, 1987 STAFF REQUIREMENTS MEMO 2
AUGUST 12, 1987 ACRS COMMENTS JULY 14, 1988 CRGR MEETING 1,
AUGUST 4, l'988 OPERATOR SURVEY BY INDUSTRY 1
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. t SECY-87 101 OPT 103S.
S DEGREE REQUIREMENT FOR SOS, c0NCURRENT POL 1cY STATEMENT RULE ON SENIOR MANAGER WITH DEGREE (SECY-84-106) i f
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1 AMEND POLICY STATEMENT ON ENGINEERING EXPERTISE ON SHIFT l
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PROPOSED RULEMAKING j i
BACHELOR'S DEGREE IN ENGINEERING, F.NGINEERING TECHNOLOGY, OR PHYSICAL SCIENCES REQUIRED FOR SOS, TWO YEARS OF NUCLEAR PLANT EXPERIENCE IS REQUIRED FOR SOS:
AT LEAST 6 MONTHS AT THE PLANT FOR WHICH LICENSE IS
! SOUGHT, d
AT LEAST 1 YEAR AS A LICENSED RO AT GREATER THAN ;
a 20 PERCENT POWER. l l
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EXCEPTIONS ALLOWED FOR APPLICANTS FROM PLANTS THAT I CANNOT ACHIEVE 20 PERCENT POWER, e
EXISTING SOS (ON CUT-OFF DATE) WOULD BE GRANDFATHERED, FOR ,
LIFE. l 1
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i TO GO INTO EFFECT 4 YEARS AFTER THE EFFECTIVE DATE OF RULE. [
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COMPARIS0N OF S,0, REQUIREMENTS
- CURRENT : PROPOSED :
EDUCATION : H S. DIPLOMA OR EQUIVALENT : BACHELOR'S DEGREE :
- :
- 4 YEARS RESPONSIBLE POWER '
- : PLANT CXPERIENCE INCLUDING : :
.: : 2 YEARS NUCLEAR PLANT : :
- F.XPERIENCE : EXPERIENCE : k* SAME AS CURRENT :
) .
- REQUIRED :
- 6 MONTHS AT THE SPECIFIC PLANT : REQUIREMENTS :
f: WITHOUT : FOR WHICH LICENSE IS SOUGHT : :
- DEGREE :
- R0 LICENSE FOR 1 YEAR :. :
- : :
- MUST HAVE S0 :
- : : LICENSE ON :
1
- : CUT-OFF DATE :
- :
- 2 YEARS RESPONSIBLE NUCLEAR :
- 2 YEARS RESPONSIBLE * :
- : POWER PLANT EXPERIENCE : NUCLEAR POWER PLANT i EXPERIENCE : : EXPERIENCE INCLUDING :
- REQUIR'dD : : 1 YEAR AS R0 AT GREATER:
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- WITH : : THAN 20% POWER :
I : DEGREE : : :
1 l : :
- 6 MONTHS AT THE SPECIFIC :
- SAME AS CURRENT :
] : : PLANT FOR WHICH LICENSE IS : REQUIREMENT :
.: : SOUGHT (NOT COUNTING : :
- : TRAINING TIME) : :
6
MINIMUM REQUIREMENTS ON-SITE STAFFING ONE UNIT CURRENT : FQUR YEARS AFTER FINAL RULE.
EITHER 2 S0s, 1 STA : EITHER 2 S0s(G), 1 STA AND 2 R0s, : AND 2 R0s, I
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OR 1 S0/STA (D), 1 S0, : OR 1 S0 (D), 1 SO (G)
AND 2 R0s : AND 2 R0s,
- AND 2 R0s e
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CONCURRENT POLICY STATEMENT WITH FINAL RULE -
ENCOURAGE LICENSED SOS TO GET DEGREES.
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- ENCOURAGE UTILITIES TO PROVIDE PROGRAMS LEADING TO DEGREES FOR OPERATORS.
ENCOURAGE UTILITIES TO OBTAIN COLLEGE CREDIT FOR TRAINING AND WORK EXPERIENCE OF OPERATORS THROUGH ARRANGEMENT WITH ACADEMIC SECTOR.
ENCOURAGE UTILITIES TO ENHANCE OPPORTUNITIES FOR OPERATORS TO ASSUME MANAGEMENT POSITIONS.
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- O e POTENTIAL ADVANTAGES OF DEGREE RULE ENHANCES CAPABILITY TO RESPOND TO ABNORMAL EVENTS IMPROVES CAREER POTENTIAL FOR SOS INFUSES WHOLE PLANT ORGANIZATION WITH AN OPERATIONAL PERSPECTIVE, e
9
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POSSIBLE NEGATIVE IMPACTS h
1 REDUCTION IN OVERALL EXPERIENCE LEVEL ON SHIFT
'I GREATER TURNOVER OF S0s REDUCED POOL OF POTENTIAL APPLICANTS
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REDUCED MORALE OF R0S WITHOUT DEGREES 1
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- _ - - - _ _ _ - _ _ - _ - _ - - _ _ _ _ - - _ _ - - _ - - - _ _ - - _ _ _ - - _ _ _ _ _ _ . - _ _ - _ - _ - - _ _ _ _ - - - _ - _ - - _ _ - - -i
COST COST ESTIMATES FOR ON-SITE TRAINING PROGRAM FOR ENGINEERING !
DEGREE VARIED FROM $250K TO $480K PER YEAR t
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- CURRENT PROGRAM AT GRAND GULF:
ACTUAL COST OF $250K YEAR 1
SIXTY PEOPLE IN PROGRAM.
AMERICAN TECHNICAL INSTITUTE RUNS PROGRAM i
. l PROGRAM IS ACCREDITED ;
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RETAIN ADVANTAGES, MINIMIZE NEGATIVE ASPECTS !
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l SENIOR MANAGER APPROACH OF SECY 84-106 ENGINEERING DEGREE AND S0 LICENSE REQUIRED i
SUPERVISOR TO WHOM OPERATING CREW RESPONSIBLE RESP 0ISIBLE FOR INTEGRATED MANAGEMENT OF SHIFT !
OPERATIONS
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I RECOMMENDATIONS -
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I COMMISSION CONSIDER THE ALTERNATE APPROACH WHICH WOULD [
ESTABLISH A SENIOR MANAGER POSITION.
l L IF DESIRED, STAFF WILL DEVELOP RULE AND POLICY STATEMENT FOR ,
l ALTERNATE APPROACH.
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1 IF COMMISSION DECIDES TO PROCEED WITH PROPOSED RULE, WHICH ,
WOULD REQUIRE A BACHELOR'S DEGREE FOR S0S, APPROVE i
- PUBLICATION OF PROPOSED AMENDMENT FOR PUBLIC COMMENT.
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