ML20154D845
| ML20154D845 | |
| Person / Time | |
|---|---|
| Issue date: | 06/17/1988 |
| From: | Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Jordan E Committee To Review Generic Requirements |
| Shared Package | |
| ML20150F860 | List: |
| References | |
| NUDOCS 8809160148 | |
| Download: ML20154D845 (13) | |
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NUCLEAR REGULATORY COMMISSION l
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PEMORANDUM FOR:
Edward L. Jordan, Chaiman Comittee to Review Generic Requirerents FROM:
Eric 5. Beckjord. Director Office of Nuclear Regulatory Research
SUBJECT:
PROPOSED RULE TO REQUIRE DEGREES FOR SENIOR REACTC9 OPERATORS Your June 9,1988 remorandum to re indicated your desire to have CRGR review the subject preposed rule.
Enclosed are twenty copies of the Comission paper for CRGR consideration.
I request your review at the earliest possible date i
so that we can avoid further slippages in our schedule for this rulemaking which is on the Chairman's agenda, l'
Tom Murley and I have strong reservations about the advisability of requiring a degree for senior operators. However, we feel that the paper is responsive to the Comission's direction to prepare the proposed ruler.aking and that the package should go forward to the Comission essentially as enclosed. We are willing to defer resolution of our concerns pending review of the public coments received on the proposed rule and development of a final staff recomendation to the Ccerission, i
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Eric 5, Beckford Dirt etor Office cf Nuclear Regulatory Research
Enclosures:
As stated Cc:
T. Rehm, OEDO l
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9009160140 000700 l
PDM REVGP NRCCRGR PEETIN9143 PNU i
o For:
The Comnissioners From:
Victor Stello, Jr.
Executive Director for Operations
Subject:
PROPOSED REVISION OF 10 CFR PART 55 TO REQUIRE DEGREES FOR SENIOR Rr. ACTOR OPERATOR $
M ose:
To obtain Ccmission approvs1 to publish a notice of proposed rulemaking trat revises $55.31 of 10 CFR Part 55 to require that each sen w reactor operator (50) hold a bachelor's degree from an accredited college or university.
Category:
This paper covers a major policy matter. Resource estimates are Category 1.
Issue Whether sufficient justification exists to revise 10 CFR 55 to require that 50s have bachelor's degrees from an accredited college or university.
Backaround:
An Advance Notice of Proposed Rulemaking (ANFRM) was published on May 30,1986 (51 FR 19561) that described a proposed rule to require a bachelor's degree in engineering or the physical sciences from an accredited institution for each applicant for a senior operator's license (Enclosure A). The staff prepared a sumary and analysis of the cone,ents in SECY 87-101, dated April 16, 1987, presented several options for consideration by the Comission, and requested Comission guidance on which option should be developed. The options considered were:
1.
Proceed with the co9templated degree rule and concurrent policy statement as proposed in the ANPRM. This option would in the long tem result in two Senior Operators on shift who have bachelor's degrees.
2.
Propose a rule to require an individual on shift with a degree, similar to a Senior Manager as described in SECV 84-106. "Proposed Rulemaking Concerning RequireP+nts for Senior Managers."
Contact:
M. Fleishman, RES 492-3794
IO q
The Comissioners 2
3.
Amend the Policy Statement on Engineering Expertise on Shift-(50 FR 43621) to explicitly encourage licensees to develop programs leading to degrees, to utilize the combined SO/STA option and to phase out use of a separate STA.
The Advisory Comittee on Reactor Safeguards (ACRS) also considered the proposed requirement and discussed it at several meetings in 1986 and 1987. The ACRS strongly supported the concept of having engineering expertise on each shift (Enclosure B). They did not agree that requiring a degree for senior operators was the best approach tho'Jgh they agreed that specific technical knowledge should be required.
They believed that, because of the concern about adverse effects raised by many knowledgeable individuals, the proposed rule should be reconsidered.
On June 24, 1987, in a staff requirements memorandum (Enclosure C), the staff was informed that the Comission had agreed to proceed with the contemplated degree rule and concurrent policy statement as proposed under Option 1 in SECY 87-101. The staff was directed to prepare and forward the proposed rule to the Comission for review and approval.
The staff has prepared a Federal Register notice (Enclosure D), that we believe is responsive both to the Comission's directive and to the opinions expressed during the deliberative process followirg issuance of the ANPRM. The basic cNeept as descrf bed it, the ANPRM, requiring a bachelor's degree for 5% and grandfathering current 50s, has been adhered to, however, some changes have been made as a result of Comissioner, ACRS, and public coments following the ANPP.M. The=e are:
I 1.
The rule is limited to applicants for nuclear power reactor $0 licenses and does not apply to S0s for non-power reactors such as research and test reactors.
l 2.
As requested by the Comission and various comenters, l
the cut-off date is specified as 4 years following the l
effective date of the rule rather than January 1,1991.
l 3.
The rule now clearly states that the one year of "hot" f
operating axperience must be as a licensed operator.
This was only implied in the ANPRM.
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Since the 4 year period is specified and we are going l
thru both the proposed and final rulemaking process, it was felt that it would not be necessary to include the i
one reexamination feature for applicants without degrees i
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The Commissioners 3
who apply just before the cut-off date. The feeling is that there exists sufficient time for all applicants to apply for and receive their 50 licenses. Thus, only persons who have an 50 license on the cut-off date would be exempt from the degree requirement.
Finally, it should be noted, as indicated in the Federal Register notice (Enclosure D) and the Regulatory Analysis (Enclosure E), that regulatory guidance provided in Regulatory Guide 1.8 and NUREG-1021 would require revision if the proposed rule went into effect.
Current guidance in position C.I.e of Regulatory Guide 1.8, Revision 2, April 1987 "Qualification and Training of Personnel for Nuclear Power Plants," allows an applicant for a 50 license with a degree to have only 2 years of responsible power plant experience, none of which needs to be as a reactor operator.
This would have to be revised if the proposed rule went into effect since the proposed rule would require a 50 with a degree to serve as a It0 at grecter than 20% power for at least 1 year.
Furthermore, the current guidance indicates that a R0 applicant must have a minimum of 3 years of power plant experience of which at least 1 year shall be nuclear power experience. This would also have to be revised since it is incon!: ster. with the proposed rule which implies that an applican for a R0 with a degree must only have 1 year of related nuclear power plant experience. Position C.I.d of this Regulatory Guide, on educational criteria, would also need to be revised to reflect the rule.
Also, because of the "grandfathering" provision and until all S0s are degreed, the current policy, as described in the Policy Statement on Engineering Expertise on Shift (50 FR 43621), would have to remain in effect to ensure that at least one person on each shift has a degree.
Resource Estimates:
It is anticipated that there will be relatively minor impact on NRC staff resources as a result of implementing the i
proposed rule. There may be some increase in the number of applications to process and tests to administer, due to the attempts of current R0s to become 50s prior to the cut-off date, but this should not cause a significant impact on the NRC staff. No new resource requirements are expected.
The Office of General Counsel has reviewed this proposed l
rulemaking and has no legal objection.
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The Comissioners 4
Recomendatioas: That the Comission:
1.
Approve the publication of a proposed amendment, as set forth in Enclosure D, which would require each applicant for a senior operator license to operate a nuclear power reactor to have a bachelor's degree in engineering, engineering technology, or the physical sciences from a accredited university or college. Those persons holding a S0 license at the cut-off date, which is four years after the effective date of the rule, would be exempt from the bachelor's degree requirement.
2.
Note that:
a.
The notice of proposed rulemaking in Enclosure D will be published in the Federal Register, allowing 60 days for public coment.
b.
Pursuant to 151.22(c)(1) of 10 CFR Part 51 of the Comission's reguhtions, neither an environmental impact statement nor an environmental assessment has been prepared.
c.
Pursuant to the Regulatory Flexibility Act of 1980, the proposed rule contains a statement that the Comission certifies that the rule will not, if promulgated, have a significant economic impact upon a substantial number of small entities and a copy of this certification will be forwarded to the Chief Counsel for Advocacy, SBA by the division of Rules and Records, ARH; d.
The subcomittee on Nuclear Regulation of the Senate Comittee on Environment and Public Works, the Subcomittee on Energy and the Environment of the House Comittee on Interior and Insular Affairs, the Subcomittee on Energy Conservation and Power of the House Comittee on Energy and Comerce, and the Subcomittee on Environment, Energy and Natural Resources of the House Comittee on Government Operations will be informed, e.
A hulatory Analysis is attached as Enclosure E; f.
Copies of the Notice of Proposed Rulemaking will be distributed by the Office of Administration and Resources Management, Division of Publication Services to each affected utility licensee, and other interested parties.
_ - _ _ _, _,_., _ - _... _ _, _. _ _. -, _ _. _ _ -... _ _ _ _. -, ~ - _, _ -..
The Commissioners 5
I g.
The ACRS has been regularly consulted concerning this proposed rule change and has separately provided formal comments.
Scheduling:
No specific circumstance is known to the staff which would require Commission action by any particular date in the near te rm.
Victor Stello, Jr.
Executive Director for Operations
Enclosures:
A - Advance Notice of Proposed Rulemaking, 05/30/86 B - Letter from W. Kerr to L.W. Zech, Jr. dated 08/12/87 C - Memo from S. Chilk to V. Stello, Jr.
dated 06/24/87 D - Notice of Proposed Rulemaking E - Regulatory Analysis I
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ENCLOSURE A f
Faderal Register / Vcl. 51. N;,104 / P.iday, rMay 30, 1966 / Proposed Rul:s 19561 conduct all or a portion of the other,.
Room at 171711 Street NW.,
baccalaureate degree in engineenng.
duties that need to be perfortned at a Washington, DC.
engineering technology, physical science, or a professional enluneer's
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federal animal quarantine atation.
pon Pusmeen sospomasATsou costTAcT:
This document requesta comments F. H. Rowsome. Office of Nuclear license. Option 2 permita continuation of concerning whether the Department Reactor Regulation U.S. Nuclear the separate STA who rotates with the should take action to contract with Regulatory Commission. Washington, shift and holds a baccalaureate degree private firms to conduct auch activities.
DC 20555, Telephone:(301) 482 4813.
or equivalent and meets the criteria as atatedin.*1C&arificetion of TMi Action Done at Washinston DC,this 27th day of suPPt.Esetlef ART sesPomes ATlo8C Plan Requirements."(NUREG-0737).
y y 38,4 8 gmund The Commission also encourages the IX Atwell.
De issue of academic requirements shift supervisor to serve in the dual role Deputy A dialnistMor, Feserinary Serwoes.
for reactor operators has long been a position, and the STA to take an active (FR Doc. 86-12110 Filed 5-as-et a45 eel concern of the Nuclear Regulatory role in ahlft activities.
Commission (NRCf. In July 1979,**TM1-2
%e current advenced notice of lessons learned Task Force Status proposed rulemaking la intended 1o Report and Short Term extend the current level of engineering NUCt. EAR REQUI.ATORY Recommendations,"tNUREG-e578)I expertise on shift, as described in the COMMISSION made specific recommendauona for a Commiesion's Policy Staternent on Shift Technical Adrisor (STA)to Engineering Expertiee on Shift (50 F11 10 CFR Parts 50 and 55 provide engmeering and accident 43621) and to eneure senier operators assessment expertise during other than have opers ting experience on a Degree Requiremeedfor Sen6of normal operatint conditions. On commerciel nneleat reactur operating at Operators at Nuc4est Power Plants October 30,1979,94 NRC notified all greater than twenty percent power, e 3.,
rating nuclear power beensees of the "bot" operating experience (Generic Aosney: Nuclear Regulatory ofort. term STA requAinents,i.e., that letter 64-16).This AdvanceWotice of e
Conalui'"'
STAS should be on shift by January Proposed Rulemaking is the result of a ACTiosc Advance notice of proposed 1980, and that they should be fully Commissito decision to consider an rulemaking-trained by January 1981. In November amendment to its regu]ations (Parts 50 1980, "Clarifica and 55) !nd to obtain comments on the Requirements,, tion of TMI Action Plan contemf oted action to upgrade the suesasAmT he Commfuton is (NUREG-0737).
considering an amendment to its provided further details to licensees Jevels c.M.erating. engineering and q m aftu J N Y l' regarding implementation of the STA accident nianagement expertise on shift.
gu a n ns a
Senior Operator of a nuclear power E he7ualifications of operators were Coucurrent Polky statement
(.
plant hold a baccalaureate degree in also addressed by the 1979.
- lessons
%e Commission also intends to engineering or the physical scienms teamed Task Force."(NUREG-0585),
prepare a cxmeurrent polley statement from an accredited institution. Other the 1980 Rogovin report. "Three Mile which will encourage nuclear power baccalaureate degrees from an Island: A Report to the Commissioners plant licensees, i.e., owner. operators, to:
accredited institution may be accepted and to the Public,"(NUREG/CR-1240),
- 1. Implement personnel policies that on a case-by case basis.This and the 1982,* Report of the Peer emphasise the opportunities for licensed contemplated rulemaking action la due Advisory Panel and the Nuclear operators to assume pesitions of to a Commission decialon to enhance Regulatory Commisslon on Op.retor increa sed management responsibility;
, thelevels of engineering and accident Qualtfica tiona," (SECY 42-181).* Th'
- t. Develop ams that would management expertise on shift. no consensus among these was that greater enable curren censed senior current requirement, for candidates with technical and academic knowledge o(erstors and reactor operators to a baccalaureate degree, of two years of among shift opersting personnel would
, tain college degrees; and 7
responsible nuclear power plant be beneficial to the safety of nuclear J. Obtain coue8e credit far operating experience, would be power plants.
appropriate nuclear power plant training I
amended to require at lesat one of the On October 28,1965, the NRC and work experience through
,l two years of operating experience be published in the Faders! Register (50 FR arrangements W Be aca emk sector.
with a similar commercial nuclear 43621) a final policy statement on reactor operating at greater than twenty engineering expertise on shift. Option 1 Discusalon i
l percent power-of the Policy Statement allows an ne urpose of the contemplated
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DATt: Comment period expires hly 29, individual to serve in the combined rulema ng la to upgrade the operating.
Senior Operator / Shift Technical engineering, and accident management 1986.
Advisor (SO/STA) role holding either a expertise provided on shift by Comments received after this date will be considered if it is practical to do combining both engineering expertise so, but assurance of consideration gC Q Q T g"d" g' ",8 and operating experience in the senior cannot be given except as to comments omw by cauma 902) us-sono w by witma is the Operator function. nis is being done to received on or before this date, u s covemc ent Prmtn Ofru P.O Ibn snar.
further ensure the protection of the i
wnm w.Dc anse Wu mer sia be health and safety of the public by having a
A00meests: Send written cornments or suggestions on the propored rulemaking
@"us
$ N c h $""4 personnel on shift with enhanced pont nos& accaa iea vA : m A wpr 6e quallDcations, to the Secretary of the Comalssion U.S.
r Nuclear Regulatory Commisake.
evedew tw ineranca aw/w =ryme tw e tw se The NRC le concerned that operator ee nc huc Dwumat toom.tnr H Stnet qualifications to deal with accidents
<I Washington,DC20$L Attention:
Docketing and Servics Branch. Coples on N* $ ' M,7 j w tann m eere beyond design basis conditions warrant k',
the comments received may be evenee et the oc hbue comment neos et in, improvement. Operalor training examined at the NRC Public Document H 5tnet h. J.aea cas Oc programs and related emergency ENCLOSURE A
u 19562 Feder:1 Regist:r / Vol. 51. No.104 / Friday.' May 30, 1986 / Proposed Rules eperatinc procedures, generally do not baccalaureate degree from an licensees (utilities) and the nuclear consider accident conditfor.s beyond accredited college or university.
Industry to provide incentives and inadequate core cooling There is in the past the NRC has accepted management opportunities for sos as general consensus that well qualified "equivalents" to the baccalaureate well as improdng the engineering cperators can substantially mitigate the degree. The equivalents were based capabilities of the on. shift crew.The SO cffects of severe accidents.The Industry upon specialized utility training or other with a degree and shift operating Degraded Core Rulemaking Program work experience. For the contemplated experience can become a valuable (IDCOR) industry group for example, rule, equivalency would not be personnel resource for the utility, one has developed arguments that operators acceptable to the NRC in lieu of a who combines shift operational could substantially reduce the risk degree. Because the Commission is no:
management experience with the proposed by these conditions.The NRC in a position to evaluate the academic potential for greater management.
is considering the need for more equivalency of utility training. it responsibility.ne policy statement will extensive severe accident training and encourages academic institutions to encourage lice.nsees to provide that emerFency operating procedures as well allow course credit for such equivalency career path.
cs engineering quahfications for senior based upon work experience or A regulatory analysle and a backfit cperators.
specialized training. Thus the proposed assessment will be developed after the The policy statement on engineering concurrent policy statement would comments are received and evaluated, cxpertise on shif t (October 28,1985; 50 encourage efforts to have the trainina prior to notice of the proposed FR 43621) provided an interim way of accepted by the colleges for partial rulemaking and concurrent policy ach'eving more engineering capability credit toward fulfilling the requirement statement.
on shift. Easentially the NRC is moving
. of an accredited degree.
invitation to ComnEnt from interim requirements which The degree requirement would not provide engineering capability for apply to licensed reactor operators Comments t'egarding the proposed eccident conditions (the STA), to (ROs). However, the proposed rule are encouraged. Comments on the requiring engineering capability, and concurrent policy statement would coatemplated rule are solicited in regard nuclear power plant operatine encourage degrees for ROs. The to:
experience in the same individual (the Commission believes a degree 1.!: January 1.1991, a feasible S0).
requirement on shift along with the deadline for requiring senior operators The contemplated rulemaking action concurrent proposed policy statement to be degreed and licensed, and if not.
would require that all applicants for a will not only enhance public health and what should the deadline be?
Senior Operator (SO) license after safety, but will also provide a route for
- 2. What the implementation and lanuary 1.1991, must have a promotion by Sos.
operation costs of the contemplated rule baccalaureate degree in engineering.
The cut off date of January 1.1991. for to utilities would be?
)
engineering technology or the physical application for an SO license by
- 3. Assuming regular shift rotation.
sciences from an accredited university individuals who are not degreed is could the typical SO obtain an or rollege. Other baccalaureate degrees chosen for three reasons. First. It will engineering or technical degree prior to from an accredited institution may be.
allow operators now in training cceepted on a case by case basis.
sufficient time and notice to complete a january 1.19917
- 4. W hat tge of engineering degree Degree equivalenc degree before application. Second,it eccepted. A baccafawill no longer be a pro a g nuee ureate degree in should not cause undue hardship on
]o g
g another subject area would be
' operators who are now in the process of
- 5. W, hat has been the industry,a acceptable if the utility (licensee) preparing and training for the senior certifies that the applicant has operator license. nitd. lleensees are experience in securing college-demonstrated high potential for the SO encouraged by the Policy Statement on equivalent credit for nuclear power position.
Engineering Expertise on Shift (Option plant training and/or work experience?
ne contemplated rule would apply
- 1) to move toward a dual. role SO/STA
- 6. Should there be similar experience only to the SO, Ucensed sos or position. Furthermore, operators who requirements for one of a. kind advanced reactors?
ctherwise fully qualified applicants prior are licensed as sos prior to January 1.
I to january 1.1991, would be exsmpt 1991, would be "grandfathered." He
- 7. What are the combined impacts of l
from the degree requirement. Ucensed proposed rule would only allow one re.
requiring two years of responsible reactor operators (ROs) would not be examination for SO applicants who nuclear power plant experience, the l
requ! red to have a degree.
apply for a license just prior to January degree requirements, and one year ' hot _
I Current senior operators and senior 1.1991. nis would prevent essentially operating requirement for the position of operator applications accepted by the unqualified individuals (without SOf NRC prior to January 1.1991, would be degiees) from applying just to "beat" the
- 8. Should.the contemplated degree "grandfathered" with regard to the
- deadline, requirement for senior operators be i
contemplated rule. it is recognized that The contemplated rule also requires supplemen9d with or replaced by "grandfa'hering" current sos could one year of "hot" operating experience intensive focused training requirements l
result in undegreed sos for an extended for a degreed SO af ter janaary 1.1991.
In severe accidents for nuclear power period of time.
His is simply a continuation of current plant operatorst
%e proposed concurrent policy NRC established policy to provide
- 9. What are the appropriate criteria statement will encourage previously engineering and accident expertise on for assessing a utility's certification that licensed sos to cbtaln degrees. it is the shift, it is essential that the SO know an individual with a baccalaureate intent of the present advance notice of and understand plant operstjons as well degree in other than engineering or the proposed rulemaking to specify that se the theoretical, academic. and phy:Icel sciences has
- demonstrated accident management aspects of the high potential" for the 50 positionf senior operator license applicat!ons received af ter january 1,1W1. would not position.
- 10. What are the implications of this
)
be accepted by the Commission unless The concurrent policy staternent is contemplated rulemaking on decisions the license application holds a planned as a way of encouraging concerning future reactor designst i
E'4 CLOSURE A L
Federal Register / Vcl. 51, Ns 1M / Friday, May 30. 1986 / Propos:d Rules 19563
- 11. Should the NRC require
- 15. [ Chairman p.iladino believes} that
- 18. Presently one degreed engineer is
(
specialized training in severe reactor the attached Table [1] cor ectly required to be within to minutes of the accidents beyond inadequate core identifies the present control room staff control room or a member of the control cooling and/or require extension of as well as that envisioned by the room staff, the STA or the combined emergency operating procedures into the ANpRM by 1991 and after 1991. Should SRO/STA, respectively. While requiring realm of more severe accidents instesd other alternative control room staffin8 a second control room operator to has e of or in addition to baccalaureate requirements be consideredt a technical degree may enhance degrees? What are the implications of
- 16. TM1 improvements in control room operator organizational status, the work by '"COR for the capabilities and staffing have been professional!sm and espnt de corps, will
,qualificatio.n. raining, and emergency undertaken by the indus, f.e STA's operating 9:wedures for licensed have been added, detalle control a second degreed engineer significantly reactor o erators and senior operators?
design reviews have been undertaken, improve operator performance beyond
- 12. Wh t is an appropriate cut off date safety parameter display systems bas e the STA or combined SRO/STA for sUowing only one re examination for. been installed, emergency operating irnprovements? Will these improvements those SO applicants without a degree procedures have been improved, and the become apparent in the short term or the
' who apply for a license just prior to combined SO/STA position has been long term?
january 1,19917 approved by polley,To what extent
- 19. What is the industry view about 13.The proposed rule would require have these improvernents been availability of new college graduates an SO applicant to have a baccalaureate effectivet who can be trained in nuclear power degree in engineering or the physical
- 17. Requiring SO's in the control room plant operation or about the feas;bility sciences from an accredited university to have a technical college degree will of having present plant operators pursue or college. What should be the have an impact on RO's and AO's, and obtain a technical college degreet appropriate definition (e g., Department especially with regstd to a career path
- 20. Should there be a numericallimit of Education ABET, etc.) for "an for these personnel.To what extent will on the total number of grandisthered" accredited university or college?"
the SO requirement drive out capable go. at any particular plant?
- 14. What immediate impact will the operators, and result in hig personnel contemplated rule have on operator turnover and instability in e amo coes ww moralet workforce?
d O
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ENCLOSURL A
t 19564 Federal Regist:r / Vcl. St. N;.104 / Friday. M:y 30.1986 / Proposed Rules TABLE 1 SECY-86-70 ONE UNIT (l}
ONE CONTROL R00M I
11 111 IV V
PRE-TMI NUREG-0737 SECY 84-355 ANPRM NOW TO 1991 1991 AND AFTER 1 50 2 S0's 2 S0's'
2 S0's 2 S0's(4) 2 R0's 2 R0's 2 R0's 2 R0's 2 R0's 1 STA(E)(5) 1 STA(E)(5) 1 STA(E)(5) 1 STA(E)(5)
--0R--
--0R--
- - O R'- -
1 S0/STA(D)(3) 1 S0/STA(D)(3) 1 S0(D)(3)
~
1 S0 l' SO 1 S0(4) 2 R0's 2 R0's 2 RO's,
--0R---
2 S0's(D)(3) 2 R0's TIME 1979 1979 1985 NOW 1991 l
l (1) 10 CFR 50.54(M)(2).
(2)
As NON-DEGREED GRANDFATHERED S0's RETIRE, OR OTHERW!sE LEAVE THE ItlDUsTRY, CONTROL ROOM STAFFING WILL EVOLVE TO 2 SO's(D) AND 2 RO's.
D = BACCALAUREATE DEGREE IN ENGINEERING OR RELATED SCIENCE (No EQUIVALENCY).
(4)
GRANDFATHERED.
(5)
E = B.S. OR EQUlVALENCY.
4 e
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ENCLOSURE A L
Federal Register / Vol. 51, No.104 / Friday, May 30, 1986 / Proposed Rules 195G5 Additianal Comments of Conanisaloner reactor operator (SRO) licenses and serving knowledge and understan&ng of reactor
.i.
Roberts in the position of shift supervisor.
theory needed by license 3 senior reactor "Although I believe that additional operators nis method would include the The additions! comments of engineenna knowledge is needed by licensed following steps:
Commissioner Thomas M. Robuts on eenior reactor operators, I am not utisfied "1.Eatablish a working group with NRC.
this ANPRM follow:
either with the approach recommended by academic and industry participants. with the
an M wi M81U n a pted by sesponsibility to define the engineenrig "Althoughl continue to believe that well.
trained and quahfied obperators are important p opoj knowledge and understandmg of reactor m ng Cs in assuring safe and re able operation of proposed that after January 1.1991, all theory needed for reactor operators to deal nuclear plants. I am concerned that this apphearts for a senior reactor operator effectively with design basis events and rulemaking wiu negatively affect the level cf beense hold a baccalaunata degree in severe accidents.
experience and expertise of senJor operators engineering or a related science from an "2. Establish a tralning curriculum for ea ch (the potential for negative impbcations was accred ted institution. In addition. the staff nuclear utihty operator training program that raised in the 1982 rep.. of the Commission's proposed a requirement that after January 1, will provide all senior reactor operators with
. Peer Advisory Panel on Operator 1991, at least one SRO per shift at a nucieor the knowledge and understanding defined by Quahfications).1 will be specifically powerplant (the SRO serving as the shift step t.nis cuMeulum would estabbsh
, interested in public comments on;(1) De manager) meet the degree requirement. For milestones in indj ridual subset areas to be extent that a formal degree requirement for purposes of this advance nobce, the ahd by ww SRO can&daus and senior oprators is related to job CommJssion accepted the staff's first rformance. (2) whether requiring a recommendation but not the second.ne previously beensed SRO e and would lead to ccalaunste degree for seruor operators practical effect of the Commission's position
-satisfactory completion of the curriculun not will enhance pubhc health and safety, and (3) is to exempt forever from the degree
- later than January 1.1991.nese curriculums what negative safety impbcations may result requirement any person holding an SRO would be redswed and accredited by NRC or from this proposal."
bcense on lanuary 1,1991.
by an appropriate industry of third party "While the staff and the Commission organisabon.
Additional Views of Commissioner pouls would bring about some
- 3. Develop and administer new NRC Asselstine provement in the engineering knowledae of sedw mctor operator licensing p,," /,'i,",'MC)' [N* I examinations and NRC and licensee SRO The additional views of Commisstoner Jame K. Asselstine on this ANPRM also "4u*12C*ti'"'** min
- tion 8th*8*iUl
l follow:
disadvantebes. First. It is not cleat that achievement by operators at each of the requiring a etalaureate degree in "I have approved this advance notice of engineenns proddes the best means for milestones defined under Step 2. leadtag to a g
assuring that senior reactor operstors have comprehensive examination not later than gg g mf ent on the knowledge needed to carry out their 1991 for au new and previously licensed b ni 3 e an in astry the various options for v ding the level of responsibihties. Some courses required for an senior reactor operators. A passing grade on angineering degree may well be irrelevant to this examina don would be requind to obtain operating. engineering an ccident
(-
d" managernent ex rtise on shift at operating
{$n't or retain an SRO license after January 1.
n e
nuclear powerp ants I agree entfrely with the 3881' en@
knowledp and mctor hory conclusion ex' pressed in this advance nouce needed to understand and cope with beyond List of Subjects that operator quahfications to deal with design basis accident situations will not be 9
accidents beyond the design basis for the covered by the counes needed to obtain a 10 CFR Port 50 plants warrant improvement Qualded baccalaunate engineering deg ee. Second, uf rement fo* SRO's is Antitm st. Classified informa tion, Fire operators can play a potentiaHy significant role in mitigating the consequences of severe imposing a degree teloss of some protection. Incorporation by reference, likely to result in tho accidents. liowever. in order to carry out this experienced and sk1Ued reactor operators.
. Intergovernmental rela tions. Nucleet role. operstors must have sufficient After 1991, experienced reactor operators power plants and reactors, Penalty, d'
fi h Radiation protection, Reactor siting o un retan p t voru dero e ta g e
e e
f accident con &tions.
Mthout a degree will not be able to advance criteria, Reporting and recordkeeping "Although considerable progrtss has been to the posidos of shift manager or supervisor. requirernenta, made in recent years in improving operator Third. b focusing on degree requirements for training programs and plant emergency SRO's, t ese proposals will require litetsliy operaung procedures, these trotning programs years befors engineering knowledge on shift Manpower training programs. Nuclear and procedures generaUy do not consider is substantiaHy upgraded. In the case of the Power P ants and reactors, Penalty-t accident con & bone beyond inadequate core staff propossl some SRO's wil have coohng Moreover, despite the improvements upgraded engineering experuse (applicants Reporting and recordkeeping in reactor operator training recent for SRO bcenses after january 1,1991, and
- requirements.
e experience Mth N1tC administered nector pt,.jpgg ggo e serving as shift managers)
Autho% Nott operator requahfications examinations while others need not upgrade their indicates that some operators are having engineering knowledse a t au (pre 1991 SRO's
.Ite authority for this advanced notice d fficulty in retaining the level of knowledge not seruns es the shift mensfarg). In the case er Cf roposed tuIemaklng I3' P
of engmeering and reactor theory needed to of the Commission preposal.
e numbers of deal effecuvely with design basis events.
bcensed SRO's could be exempt from any Authority: Sec.161, Pub. t.83-703. 63 Sta t.
These in& cations of weakness in operetot upgrading of their engineering knowledge 943, e amended (42 U.S C. 2:01)-
knowledge of ergineering and reactot theory, because the degree requirement would only Dated at Wa shington. DC, this 27th day of the absence of emergency procedures to deal apply to new SRO eppheants after lenuary 1, with beyond design basis events, and the 1991. To avoid the requirement, e uubty could May 198&
reliance on operator actions as one reearts of simply obtain SRO heenus for allits nector For the Nuclear Regulatory CommisslorL mitigating the effects of ses ere accidents all operators prior 101991.
Sannuell. Callk.
int to the need for more extensive "In view of the disadvantages of the NRC bowledge of engineering and reactor theory staff and Commission proposals,I would Secery c@ Comminion.
on the part of plant operators, and appreciate cor ments on en alternative
[Ht Doc. 86-12153 Filed 6-2S-86,8 41 am]
particularly those operators holding senior enethod for upgrs&ng the engineering s w ee coottsooet.as s
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NUCLEAR REGULATORY COMMISSION c
,I ADVISORY COMMITTEE ON REACTOR FAFEGUARDS
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W ASHINGTON, D. C. 20555 o
4 August 12, 1987 The Honorable Lando W. Zech, Jr.
Chaiman U. S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Chaiman Zech:
SUBJECT:
ACRS COMMENTS ON THE ADVANCE NOTICE OF PROPOSED RULEMAKING:
DEGREE REQUIREMENTS FOR SENIOR OPERATORS During the 328th meeting of the ACRS August 6-8, 1987, and our 327th meeting, July 9-11, 1987, we discussed SECY-87-101, "Issues and Proposed Options Concerning Degree Requirements for Senior Operators," which was prepared in response to public coments on the proposed rule. Meetings of our Subcomittee on Human Factors were also held on July 15, 1986 and 1
June 24, 1987 to discuss this issue with the NRC Staff.
During these meetings, we had the benefit of presentations by the NRC Staff as well as, representatives of the Westinghouse Electric, KMC, and Delian corpora-tions, We also had the benefit of the documents referenced.
l On May 31, 1986 the NRC published an Advance Notice of Proposed Rule-making (ANPRM) to require all applicants for a Senior Peactor Operator (SRO) license to possess a baccalaureate degree in engineering or physical science after January 1,1991.
Two hundred letters of public coment were received in response to the ANPRM of which approximately 98% indicated opposition to the NRC's proposal.
The nuclear utility industry and the NRC have endorsed a systems ap-l proach to perfomance based training. At the heart of perfomance based training is a detailed Job and Task Analysis (JTA) which analyzes the l
l many tasks that must be performed to carry out the various jobs of personnel filling positions in nuclear per.ser plants, including the t
position of SRO.
The tasks are further anal to determine the various knowledges, skills, and abilities (KSAs)yzed that one must possess to perform the tasks.
The analysis continues further to detemine whether the KSAs should be obtained.through formal education or through specific training in the classroom, in the laboratory, at a simulator, or by self-study.
l A number of JTAs have been perfomed by licensees as part of the conver-sion to performance based training; analysis of these JTAs has not shown I
that a college degree is necessary for Senior Reactor Operators to l
ENCLOSURE B
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t The Honorable Lando W. Zech, Jr.
2 August 12, 1987 perforin the tasks of their jobs to ensure safety of plant operations.
A Peer Advisory Panel appointed by the Comission came to the same conclu-sion in 1982 and recomended against a degree requirement for SR0s.
We have not been infomed of any technical rationale for requiring a degree for SR0s at nuclear power plants; we conclude, therefore, that a degree requirement for all SR0s is primarily a policy issue.
We strongly support the concept of having engineering expertise on each shift.
The Comission's requirement of a Shift Technical Advisor (STA) was a step in that direction.
Further, the Comission's provision of the option to combine the STA function with one of the SRO positions was a step to encourage greater integration of the resulting engineering expertise into shift operations.
The Comittee endorsed both of these actions.
The NRC Staff indicates that the percentage of SR0s with a baccalaureate degree in engineering or physical science has increased from 17% in 1980,to 28% in 1987.
We are infomed that the primary reasons for considering requiring all SR0s in the future to have degrees is to enhance professionalism in reactor operations and to make it more likely that the higher management positions in nuclear utilities will be filled by individuals with plant operations experience.
We endorse these purported goals but question whether they will be realized through the proposed indirect approach of requiring degrees of all SR0s.
We believe there is a more direct approach to achieving these goals than through the proposed rulemaking.
We.recomend that the Comission formulate more specifically its con-cerns and the goals it desires to achieve.
The Comission then should meet with appropriate licensee representatives (e.g., NUMARC) to convey the need for increased attention to the areas of concern. The NRC Staff and the licensees should then work to develop solutions; programs, and schedules for implementation of any changes from current practice deemed necessary.
We realize that proposed rulemaking is one method to gener-ate sufficient attention to encourage licensee initiative; however, we believe a more direct and less adversarial approach is preferable when the proposed action is not driven by clearly identified public safety I
concerns.
In sumary, although the purported goals of the proposed rulemaking are laudable, we think that the depth of the concern about adverse effects i
of the proposed rule should be reconsidered; many of the coments were received from individuals who are knowledgeable about personnel consid-erations in the work place.
We recomend a more direct approach to identifying and addressing the Comission's concerns.
l
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The Honorable Lando W. Zech, Jr.
3 August 12, 1987 Additional coments by ACRS member Glenn A. Reed are presented below.
Sincerely, William Kerr Chaiman Additional Coments by ACRS Member Glenn A. Reed As a I applaud the ACRS letter and wish to add further support to it.
person who earned a university engineering degree and one who held an NRC SRO license, I am opposed to the degree requirement for SR0s, as in my opinion it is not needed from a job task analysis viewpoint, is not in the interest of licensed personnel morale, is not needed in the interest of best safety of operations, and would lessen the experience I have found that a college degree in qualifications of SRO personnel.
probably ensure that an SRO engineering or applicable science will candidate will have an acceptable enough intelligence quotient to be However, there is no assurance from the able to take on-site training.
college degree achievement that the SRO candidate will have the even more important qualifications of mechanical comprehension, logical reasoning, and appropriate personality.
My' thirty plus years of hiring and working with licensed operators has convinced me that acceptable perfomance in a battery of aptitude tests (IQ, mechanical comprehension, logical reasoning, and personality f
traits), coupled with appropriate experience and training, will provide the best SR0 performers and people in overall shift charge. My experi-ence also has convinced me that the Shift Technical Advisor concept that t
l was endorsed some years ago by the NRC can provide the best engineering support, and the best future promotional cross-fertilization into f
utility top management, and into the vendor design field.
References:
l
- 1. SECY-87-101, April 16, 1987 Issues and Proposed Options Concerning I
Degree Requirements for Senior Operators.
- 2. Federal Register, Vol. 51, No.104, Page 19561 Friday, May 30, 1987, Advance Notice of Proposed Rulemaking,10 CFR Parts 50 and 55, Degree Requirements for Senior Operators at Nuclear Power Plants.
- 3. Coments pertaining to the Advance Notice of Proposed Rulemaking -
Degree Requirements for Senior Operators, KMC, Inc., September 29, 1986.
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