ML20154D849
| ML20154D849 | |
| Person / Time | |
|---|---|
| Issue date: | 06/24/1987 |
| From: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20150F860 | List: |
| References | |
| NUDOCS 8809160152 | |
| Download: ML20154D849 (36) | |
Text
UNITED STATES o,,
NUCLEAR REGULATORY COMMISSION f
g g
a w AsHIN GTON, D.C. 20656
%,,,,,, p June 24, 1987 CFFKE OF THE SECRETARY MEMORANDUM FOR:
Victor Stello, Jr. Executive Director for Operations O.{ M amuel J. Chilk, Secretary FROM:
SUBJECT:
SECY-87-101 - ISSUES AND PROPOSED OPTIONS CONCERNING DEGREE REQUIREMENT FOR SENIOR OPERATORS This is to advise you that the Commission (with all Commise. inners agreeing) has approved the staff's recommendation to.eparate the training and educational issues discussed in the SECY paper.
While agreeing to separate the training and education issues, commissioner Asselstine believes that additional engineering knowledge is needed by all licensed operators and that each utility should be required to develop and implement programs for all licensed operators which would provide knowledge equivalent to a two year Associate Degree program.
The Commission (with Chairman Zech and Commissioners carr and Bernthal approving) has also agreed that the staff should proceed with the contemplated degree rule and concurrent policy statement as proposed in the ANPM (Option
- 1).
This option will result in all newly licensed SRO's having colicge degrees, four years after the effective date of the rule.
All individuals holding Senior Reactor Licenses prior to that date will be "grandfathered" so as to assure that no SRO lores his/her job and that valuable experience is not lost.
Commissioner Asselstine approved a rule which would require all shift supervisors to hold a Baccalaureate degree no later than five years after the effective date of the rule.
Commissioner Roberts disapproved degree requirements for licensed operators and i
provided comments.
All Commissioners provided comments on the SECY paper proposal.
Copies of their comments have previously been provided to you with their vote sheets.
The proposed rule should be prepared and forwarded for Commission review and approval.
cc Chairmen tech Commissioner Roberts Rec'd Off. EDO b ' dk I-E 7 Commissioner Asselstine DMe -
Commissioner Bernthal EN 3 # d~
Cornissioner Carr Umt
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ACRS ENCLOSURE C l
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e ENCLOSURE D
[7590-01) e NUCLEAR REGULATORY COMMISSION 10 CFR Part 55 Degree Requirement for Senior Reactor Operators at Nuclear Power Plants AGENCY:
Nuclear Regulatory Commission.
ACTION:
Proposed rule.
SUMMARY
- The Nuclear Regulatory Commission is proposing to amend its i
regulations to require that each applicant for a senior operator license to operate a nuclear power reactor must have a bachelor's degree in engineering, engineering technology, or the physical sciences from an accredited university or college. This proposed action is necessary to upgrade the operating, engineering, and accident management expertise provided on shift by combining engineering expertise and operating experience in the senior operator position, r
The Cornission believes that the requirement of a bachelor's degree for the 3
senior operator position would further ensure the protection of the health and i
safety of the public.
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1 Enclosure D
DATES: Coment period expires (60 days following publication in the Federal Register). Coments received after this date will be considered if it is practical to do so, but the Comission is able to assure consideration only for coments received on or before this date.
ADDRESSES: Mail coments to: The Secretary of the Comission, U.S., Nuclear Regulatory Comission, Washington, DC 20555, Attention: Docketing and Service Branch.
Deliver coments to: One White Flint North, 11555 Rockville Pike, Rockville, Maryland, between 7:30 a.m. and 4:15 p.n.
Coments may also be delivered to the NRC Public Document Room, Room 1121, 1717 H Street NW, Washington, DC between 7:30 a.m. and 4:15 p.m.
Examine coments received, the environmental assessment and finding of no significant impact, and the regulatory analysis at the NRC Public Document Room, 1717 H Street NW, Washington, DC.
Obtain single copies of the environmental assessment and finding of no significant impact and the regulatory analysis from M. R. Fleishman, Office of Nuclear Regulatory Research, Washington, DC 20555, telephone (301) 492-3794 l
FOR FURTHER INFORMATION CONTACT:
M. R. Fleishman, Office of Nuclear Regulatory
)
Research, U.S. Nuclear Regulatory Comission, Washington, DC 20555, telephone (301) 492-3794 I
i 2
Enclosure D
SUPPLEMENTARY INFORMATION:
P
Background
Since the Three Mile Island Unit 2 (TMI-2) accident on March 28, 1979, in which 6
human error, among other factors, contributed to the consequences of the accident, the issue of academic requirements for reactor operators has been a major concern of the Nuclear Regulatory Comission (NRC).
In July 1979, P
"TMI-2 Lessons Learned Task Force Status Report and Short-Term Recomendations," (NUREG-0578)I made specific recomendations for a Shift Technical Advisor (STA) to provide engineering and accident assessment expertise during other than normal operating conditions. On October 30, 1979, the NRC notified all operating nuclear power licensees of the short-term STA requirements, i.e., that STAS should be on shift by January 1980, and that they should be fully trained by January 1981.
In November 1980, "Clarification of TMI Action Plan Requirements," (NUREG-0737), provided further details to licensees regarding implementation of the STA position.
l The qualifications of operators were also addressed by the 1979, "Lessons Learned Task Force," (NUREG-0585), the 1980 Rogovin report, "Three Mile Island: A Report to the Comissioners and to the Public," (NUREG/CR-1240),
and the 1982, "Report of the Peer Advisory Panel and the Nuclear Regulatory l
I Copies of all NUREGS referenced may be purchased through the U.S. Government Printing Office by calling (202) 275-2060 or by writing to the U.S. Government Printing Office, f
P.O. Box 37082 Washington, DC 20013-7082. Copies may also be purchased from the National Technical Infomation Service, U.S. Department of Comerce, 5285 Port Royal r
Road, Springfield, VA 22161. A copy is available for inspection and/or copying for
{
a fee in the NRC Public Document Room, 1717 H Street, NW. Washington, DC.
I i
3 Enclosure D
Comission on Operator Qualifications," (SECY 82-162).2 The consensus among these reports was that greater technical and academic knowledge among shift operating personnel would be beneficial to the safety of nuclear power plants.
On October 28, 1985, the NRC published in the Federal Pegister (50 FR 43621) a final policy statement on engineering expertise on shift to allow an alternate means of providing the necessary technical and academic knowledge to the shift crew. Option 1 of the Policy Statement permits an' individual to serve in the combined Senior Operator / Shift Technical Advisor (SO/STA) role if that individual holds either a bachelor's degree in engineering, engineering technology, physical science, or a professional engineer's license. Option 2 pemits continuation of the separate STA who rotates with the shift and holds a bachelor's degree or equivalent and meets the criteria as stated in, "Clarification of TMI Action Plan Requirements," (NUREG-0737). The Comission also encourages the shift supervisor to serve in the dual-role position, and the STA to take an active role in shift activities.
On May 30, 1986, the NRC published an advance notice of proposed rulemaking (ANPRM) (51 FR 19561). The purpose of the ANPRM was to extend the current level of engineering expertise on shif t, as described in the Comission's Policy Statement on Engineering Expertise on Shift (50 FR 43621) and to ensure that senior operators have operating experience on a comercial nuclear reactor operating at greater than twenty percent power, e.g., "hot" operating experience (Generic Letter 84-16)2 The ANPRM was the result of a Comission decision to consider an amendment to its regulations (Parts 50 and 55) and to 2 SECY 82-162, SECY 84-106. SECY 87-101, and Generic Letter 84-16 are available at the NRC Public Document Room at 1717 H Street NW, Washington, DC.
4 Enclosure D
obtain coments on the contemplated action to upgrade the levels of operating, engineering, and accident management expertise on shift.
Besides describing the proposed rule in general, the ANPRM presented a list of twenty questions concerning various aspects and implications of the proposed rule.
Two hundred letters were received in response to the ANPRM.
A sumary 2
and analysis of the coments are included in SECY-87-101 dated April 16, 1987.
The NRC has reviewed, in detail, all the coments made on the ANPRM as well as l
coments received since that time.
In general, except for five comenters, the preponderance of comenters were opposed to a degree requirement for senior operators. The proposed rule in this notice reflects in detail many of the coments and responses to the questions posed. Apart from the detailed coments on the proposed contents of the rule, a number of general, adverse coments were raised. These can be categorized as:
1.
The proposed rule is not necessary.
2.
Experience is more important than a bachelor's degree.
3.
The proposed rule will have a negative impact on safety.
4 The proposed rule will result in a greater operator turn over rate.
5.
The proposed rule will basically block the career path of i
reactor operators.
5 4
The Advisory Comittee on Reactor Safeguards (ACRS) also considered the proposed requirement and discussed it at several meetings in 1986 and 1987 I
4
(
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5 Enclosure D
o The ACRS strongly supported the concept of having engineering expertise on each shift. They did not agree that requiring a degree for senior operators was the best approach though they agreed that specific technical knowledge should be required. Thay believed that, because of the concern about adverse effects raised by many knowledgeable individuals, the proposed rule should be reconsidered.
The Commission has carefully considered the numerous comments received on the ANPRM as well as the recommendations of the ACRS.
During its deliberations subsequent to the ANPRM the Commission considered the following three options regarding improving engineering expertise on shift:
1.
Proceed with the contemplated degree rule and concurrent policy statement as proposed in the ANPRM. This option would in the long term result in two Senior Operators on shift who have bachelor's degrees.
2, Propose a rule to require a degreed individual on shift similar to a Senior Manager, as described in SECY-84-106, "Proposed Rulemaking Concerning Requirements for Senior Managers."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 50/STA option and to phase out use of a separate STA, 6
Encicsure D
In spite of the generally unfavorable reaction to the ANPRM, the Commission believes that it would be beneficial to have a full public airing of views by publication of a notice of proposed rulemaking and decided to proceed with Option 1.
Concurrent Policy Statement The Commission will publish concurrently with the final rule a policy statement which encourages nuclear power plant licensees, working with the I
nuclear industry, to:
l 1.
Implement personnel policies that emphasize the opportunities for L
licensed operators to assume positions of increas'd management responsibility; 2.
Develop programs that would enable currently licensed senior I
operators and reactor operators to obtain college degrees; and i
L 3.
Obtain college credit for appropriate nuclear power plant training i
and work experience througis arrangements with the academic sector.
Discussion The purpose of this proposed rule is to upgrade the operating, engineering, and accident management expertise provided on shift by combining both engineering 7
Enclosure D
expertise and operating experience in the senior operator function. The NRC believes that having personnel on shift with enhanced qualifications is necessary to further ensure the protection of the health and safety of the public.
The NRC is concerned that operator qualific3tions to deal with accidents beyond design basis conditions warrant improvement. Operator training programs and related emergency operating procedures generally do not consider accident conditions beyond inadequate core cooling.
There is a general consensus that 1
well qualified operators can substantially mitigate the effects of severe accidents. The Industry Degraded Core Rulemaking Program (IDCOR) industry group, for example, has developed arguments that operators could substantially reduce the risk posed by these conditions. The NRC is considering the need for I
more extensive severe accident training and emergency operating procedures as well as engineering qualifications for senior operators.
The policy statement on engineering expertise on shift published in the Federal Register on October 28, 1985 (50 h 43621) provided an interim method of achieving more engineering capability on shift.
Essentially the NRC is noving from interim requi ements which provide engineeriag capability for accident conditions (the STA), to requiring engineering capability, and nuclear power plant operating experience, in the same individual (the 50).
1 J
This proposed rule would require each applicant for a Senior Operator (50) l license to operate a nuclear power reactor, after [4 years following the effectivedateoftherule),tohaveabachelor'sdegreeinengineering, 8
Enclosure D 1
engineering technology, or the physical sciences from an accredited university or college. Applicants with other bachelor's degrees from an accredited institution, or with bachelor's degrees from a foreign college or ' university, will be considered on a case-by-case basis.
Degree equivalency will no longer be accepted. A bachelor's degree in another sub,iect area would be considered if the utility (licensee) certifies that the applicant has demonstrated engineering expertise, leadership qualities, and high potential for the 50 position. An accredited university or college is defined as an educational institution in the United States which has been approved by a regional accrediting body.
The proposed rule would apply only to applicants for a 50 to operate a nuclear power reactor.
People who held 50 licenses on [4 years following the effective date of the rule) would be exempt from the degree requirement. Furthermore, l
l the proposed rule would not apply to 50 applicants for non-power nuclear l
reactors such as research and test reactors. Licensed reactor operators (R0s) would not be required to have a degree. Thus, those persons wno are senior operators on [4 years following the effective date of the rule), would be "grandfathered" by the proposed rule.
It is recognized that "grandfathering" current 50s could result in 50s without degrees for an extended period of time.
Since the Commissions' intent is to maintain at least the same degree of engineering expertise on shift as currently exists, the STA policy described under options 1 end 2 in the October 28, 1985 policy statement (50 FR 43621) would continue in effect. Thus, if two "grandfathered" S0s are used on shift, the facility licensee would be required to have a separate individual on 9
Enclosure D
o shift who has the STA education and experience described in NUREG-0737.
If one of the 50s has a degree and one is "grandfathered," Option 1 of the i
policy statement would be satisfied. When all 50s have degrees, the policy statement would no longer be needed.
The concurrent policy statement will encourage previously licensed 50s to obtain degrees.
In the past the NRC has accepted "equivalents" to the bachelor's degree for a separate STA.
The equivalents were based upon specialized utility training or other work experiences.
For the proposed rule, however, equivalency would not be acceptable to the NRC in lieu of a degree.
Because the Comission is not in a position to evaluate the academic equivalency of utility training, it encourages utilities to seek out academic institutions who will evaluate the i
training programs and grant course credit for such equivalency based upon work experience or specialized training.
Thus the concurrent policy statement will encourage efforts to have the training accepted by the colleges for partial credit toward fulfilling the requirements of an accredited degree.
j The degree requirement would not apply to licensed reactor operators (R0s).
However, the concurrent policy statement will encourage R0s to obtain degrees so that they can progress to the 50 position and to other utility positions.
The Comission believes a degree requirement for 50s on shift, alon9 with the concurrent policy statement will not only enhance public health and safety, but will also provide a route for promoting 50s.
1 The cutoff date of four years following the effective date of thc rule for
)
application for a 50 license by individuals who do not have degreet is chosen i
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10 Enclosure D i
1
for three reasons.
First, it will allow operators now in training sufficient time and notice to complete a degree before application.
Second, it should net cause undue hardship on operators who are now in the process of preparing and i
i training for the senior operator license, and third, licensees have been encouraged by the Policy Statement on Engineering Expertise on Shift (Option 1)
I to move toward a dual-role 50/STA position.
Furthermore, those operators who are licensed as 50s on the cutoff date would be "grandfathered."
l 1
l
]
The proposed rule would also require one year of "hot" and at least 2 years 1
total operating experience for each applicant for a S0 license. A R0 license is required in order to get "hot" control room operating experience; thus, the l
I proposed rule expands the current NRC policy, described in Regulatory Guide 1.8, Revision 2. dated April 1987, "Qualification and Training of Personnel for Nuclear Power Plants " to ensure that degreed 50s have sufficient operating experience. Regulatory Guide 1.8, in position C.I.e., allows an applicant for j
i j
a 50 license with a degree to have only 2 years of responsible power plant j
l; i
experience, none of which needs to be as a reactor operator. Thus, Regulatory j
Guide 1.8 will be revised if the proposed rule is adopted. The proposed rule I
l would require the 50 with a degree to serve as a R0 at greater than 70% power i
i j
for at least 1 year. This does not mean that the reactor must be at power 100%
l of the time during the year, however, th; 1 year time period should not include l
periods of significant down time for maintenance or refueling (i.e., periods j
that exceed 6 weeks duration). Special provisions are proposed in order to
[
accomodate those applicants from facilities that are unable to operate above I
\\
twenty percent power due either to (a) the facilities not having completed their infilal startup program and being licensed to run at power, or j
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11 Enclosure D
(b) the facilities being in an extended shutdown mode.
In the case of the facilities not yet licensed to run at power, alternative approaches to meet the twenty percent power requirement may be approved by the Comission.
In the case of facilities in extended shutdown, the Comission may process the application and administer the written and operating tests but would defer issuance of the senior operating license until the twenty percent power requirt; ment is fulfilled.
This proposed requirenant for a 50 applicant with a degree also implies that an applicant for a RO with a degree must a '
. law 1 year of related nuclear power plant expericnce. This is a change '.
're guidance in Regulatory Guide 1.8 which indicates that a R0 applicant must have e minimum of 3 years of power plant experience of which at least 1 yeae shall be nuclear power experience.
If the proposed rule is adopted it would supersesie the guidance in etegulatory Guide 1.8 and necessitate its revision in accord with the rule. Also, position C.1.d of Regulatory Guide 1.8, on educatioral criteria, would have to be revised to reflect this rule. The above requirement is proposed because it is essential that the 50 know and understand plant operations as well as the theoretica), enginearing, and accident management aspects of the position.
The concurrent policy statement is intended to encourage licensees (utilities) o and the nuclear industry tn provide incentives and manaJement opportunities for 50s as well as to improve the engineering capabilities of the on shif t crew. 1he 50 with a degree and shift operating experience can become a valuable personnel resource for the utility, one who combines *,hift operational management experience with the potential for greater management responsibility.
The policy statement, among other things, will encourage licensees to provide that career path.
12 Enclosure D
)
The Commission believes that requiring a degree will contribute to the goal of having S0s who have operational experience, technical and academic knowledge, and educational credentials that should imprcVe their performance as operators and possibly open career paths from which they may have been excluded in the past. The 50s should be able to respond better to off normal incidents. While there will be increased training to cover accident conditions, training alone is not sufficient.
It is impossible to cover every eventuality during training. The operators must have sufficient understanding of baric engineering principles, and detailed knowledge of nuclear design and operation to appropriately respond to situations that have not been previously covered in training sessions-In addition, S0s with degrees will have gteater l
opportunity for professional growth since they will have the qualifications needed to advance to managerial positions. With the chance for personal growth should come greater job satisfaction. The validity of these beliefs has been reenforced by the experiences of licensed operators participating in an ongoing utility sponsored program similar to what is being proposed herein. The Comission also believes that there will be a net improvement in plant safety if sizable numbers of 50s migrate upward into plant manag9 ment.
In sumary, while the benefits of the proposed rule cannot be directly quantified, the Comission believes that the degree program should result in greater plant safety. This benefit will be achieved over time by improved I
quality of the operatirnal personnel and by plant management that has a better understanding of the unique operational problems associated with nuclear power reactor operations, i
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13 Enclosure D I
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Environmental Impact--Categorical Exclusion The NRC has determined that this, proposed regulation is the type of action described in categorical exclusion 10 CFR 51.22(c)(1). Therefore neither an environm ntal impact statement nor an environmental assessment has been prepared for this proposed regulation.
Paperwork Reduction Act Statement This proposed rule contains no information collection requirements and i
therefore is not subject to the requirements of the Paperwork Reduction Act of 1980 (44 U.S.C 3501 et seq.).
Regulatory Analysis The Comission has prepared a draft regulatory analysis for this proposed
]
regulation. The analysis examines the costs and benefits of the alternatives considered by the Comission. The draft regulatory analysis is available for inspection and copying for a fee at the NRC Public Document Room,1717 H Street NW, Washington, DC. Single copies of the analysis may be obtained from M. R. Fleishman, Office of Nuclear Regulatory Research, Washington, DC 20555, i
l telephone (301)492-3794.
The Comission requests public coment on the draft analysis.
Coments on the I
l draft analysis may be submitted to the NRC as indicated under the ADDRESSES i
l heading.
1 14 Enclosure D l
Regulatory Flexibility Certification As required by the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b), the Commission certifies that this rule, if adopted, will not have a significant economic impact upon a substantial number of small entities. This proposed rule affects only the licensing and operation of nuclear power plants.
It also affects individuals licensed as operators at these plants. The companies that own these plants and the individual plant employees licensed to operate them do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act or the Small Business Size Standards j
set out in regulations issued by the Small Business Administration in 13 CFR Part 121. Since these companies are dominant in thMr earvi.ce areas, this proposed rule does not fall within the purview of the Act.
1 However, because there may be now or in the future small entities which will provide licensed operators to nuclear power plants on a contractual basis, the NRC is specifically seeking coment as to how the regulation will affect them and how the regulation may be tiered or otherwise modified to impore less l
stringent requirements on them while still adequately protecting the public I
health and safety. Those small entities which offer coments on how the regulation could be modified to take inte account the differing needs of small entities should specifically discuss the following items:
(a) The size of their business and how the proposed regulation would result j
in a significant economic burden upon them as compared to larger organizations in the same business comunity.
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I 15 Enclosure D l
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(b) How the proposed regulation could be modified to take into account their differing needs or capabilities.
(c) The benefits that would accrue, or the detriments that would be avoided, if the proposed regulation was modified as suggested by the comenter.
(d) How the proposed regulation, as modified, would nore closely equalize the impact of NRC regulations or create more equal access to the benefits of Federal programs as opposed to providing special advantages to any individuals or groups.
(e) How the proposed regulation, as modified, would still adequately protect the public health and safety.
The coments should be sent to the Secretary of the Comission U.S. Nuclear Regulatory Comission. Washington, DC 20555 Attn:
Docketing and Service Branch.
Backfit Analysis As required by 10 CFR 50.109, the Comission has completed a backfit analysis for the proposed rule. The Comission has determined, based on this analysis, that backfitting to comply with the requirements of this proposed rule will provide a substantial increase in protection to public health and safety or the comon defense and security at a cost which is iustified by the substantial increase. The backfit analysis on which this determination is based reads ss follows:
16 Enclosure D
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1.
Statement of the specific objectives that the proposed backfit is designed to achieve.
The objective of the proposed rule is to upgrade the operating, engineering, and accident management expertise provided on shift by combining both engineering expertise and operating experience in the senior operator function.
2.
General description of the activity that would be required by the licensee or applicant in order to complete the backfit.
This proposed rule would require each applicant for a Senior Operator (50) license to operate a nuclear power reactor, after (4 years following the effective date of the rule), to have a bachelor's degree in engineering, engineering technology, or the physical sciences from an accredited university or college. Applicants with other bachelor's degrees from an accredited institution will be considered on a case-by-case basis. Degree equivalency will no longer be accepted. A bachelor's degree in another subject area would be acceptable if the utility (licensee) certifies that the applicant has demonstrated engineering expertise, leadership qualities, and high potential for the 50 position. An accredited university or college is defined as an educational institution in the United States which has been approved by a regional accrediting body.
The proposed rule would apply only to applicants for a 50 to operate a nuclear power reactor, People who held 50 licenses on [4 years following the effective date of the rule] would be exempt from the degree 17
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requirement.
Furthermore, the proposed rule would not apply to S0 applicants for non-power nuclear reactors such as research and test reactors.
Licensed reactor operators (R0s) would not be required to have a degree. Thus, those persons who are senior operators on [4 years following the effective date of the rule) would be "grandfather 1d" by the i
proposed rule. The proposed rule would also require one year of "hot" (i.e. as an R0 at greater than 20% power) and at least 2 years total operating experience for each applicant for a S0 license. Special provisions would be proposed to accommodate those applicants from facilities that are unable to operate above 20% power.
The proposed requirements would only apply to power reactor licensees indirectly. There would be no modification of or addition to the organization, i.e. administrative and functional structure, required to operate a nuclear power reactor as a result of this proposed rule because:
i j
i 1.
the person to whom the 50s report would not change; i
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11.
the number of S0s per shift would not change;
)
111. the total number of operators per shift would not change; 1
iv.
the training requirements, written examinations and operating tests for a 50 would not change; and v.
the tasks performed by a 50 would not change.
l However, the power reactor licenses would have to get new S0s from a group of individuals who already have appropriate degrees or else provide the I
educational opportunity for their own employees to obtain a degree.
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3.
Potential change in the risk to the public from the accidental off-site release of radioactive material.
It is not feasible to quantitatively evaluate the change in risk to the public as a result of the proposed rule. That is, the effect of the 50 on the probability and consequences of an accident, and the change in the probability and consequences of an accident as a result of requiring the 50 to have a bachelor's degree is unknown.
The Comission believes that requiring a degree will contribute to the goal of having 50s who have operational experience, techn Hal and academic knowledge, and educational credentials that should improve their perfortnance as operators and possibly open career paths from which they may have been excluded in the past. The 50s should be able to respond better to off normal incidents.
While there will be increased training to cover accident conditions, training alone is not sufficient.
It is impossible to cover every eventuality during training. The operators must have sufficient understanding of basic engineering principles, and detailed knowledge of nuclear design and operation to appropriately respond to situations that have not been previously covered in training sessions.
In addition, 50s with degrees will have greater opportunity for professional growth since they will have the qLalifications needed to advance to managerial positions. The Comission believes that there will be a net improvement in plant safety if sizable numbers of 50s migrate upward into plant management.
19
4.
Potential impact on radiological exposure of facility employees.
There is not expected to be any significant change in the radiological exposure of facility employees due to the proposed rule except for the unquantifiable reduction in the probability and consequences of an accident "J.o the subsequent reduction in exposure.
5.
Installation and continuing costs associated with the backfit.
including the cost of facility downtime or the cost of construction delay.
One of the questions posed in the May 30, 1986 ANPRM concerned what the implementation and operation costs of the proposed rule to the utilities would be. The cost estimates received ranged from negligible to prohibitive.
Various scenarios for achieving the desired staffing level of 50s with degrees were assumed. These varied from hiring individuals with degrees and passing them thru the norum1 utility training programs to taking R0s and sending them to college while either paying them at overtime rates or hiring replacement R0s. A utility could also implement an onsite college degree program for its operators, for example, a program currently being run for an operating plant costs $250,000 per year to train 60 people. The range of costs of such an onsite program are estimated to vary from $250,000 to $480,000 per year.
It is clear that there are numerous methods that can be used to implement the proposed rule with an extreme range of costs depending on the method adopted.
It would be a utility's choice as to which method to adopt, taking into account the various cost and personnel considerations.
20 Enclosure D
O 1
6.
The potential safety impact of changes in plant or operational complexity, including the effe:t on other proposed and existing regulatory requirements.
There would be no changes in the plant or operational complexity and hence, no potential safety impact related to them. However, there would be an effect on the guidance provided in Regulatory Guide 1.8.
Current guidance in Regulatory Guide 1.8, Revision 2, April 1987, "Qualification and Training of Personnel for Nuclear Power Plants," allows a degreed applicant for a 50 license to have only 2 years of responsible power plant experience, none of which needs to be as a re': tor operator. This would have to be revised if the proposed rule went into effect since the proposed rule would require a SO with a degree to serve as a R0 at greater than 20% power for at least 1 year.
Furthemore, the guidance indicates q
j that a R0 applicant must have a minimum of 3 years of power plant experience of which at least 1 year 3 hall be nuclear power experience, i
This woulti have to be revised since it is inconsistent with the proposed
'i rule which implies that an applicant for a RO with a degree must only have 1 year of related nuclear power plant experience.
Finally, position C.I.d l
of the Regulatory Guide would have to be revised to indicate that a bachelor's degree is the minimum educational requirenent for a 50 candidate rather than a high school diploma, 7.
The estimated resource burden in the NRC associated with the proposed j
backfit and the availability of such resources.
It is anticipated that there will be relatively minor impact on NRC staff
)
resources as a result of implementing the proposed rule. There may be some increase in the number of applications to process and tests to 21 Enclosure D I
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.
8.
The potential impact of differences in facility type, design or age on 1
the relevancy and practicality of the proposed backfit.
The proposed rule only applies to 50 applicants for operation of a nuclear power reactor.
It does not apply to 50 applicants for non-power nuclear reactors such as research and test reactors. The facility type, design or age should have no relevancy to the impact or practicality of the proposed backfit. Of more significance would be the degree to which each utility licensee has already implemented an educational program. Those facilities which have implemented such a program will clearly be less affected by the proposed backfit than would those facilities that have not.
9.
Phether the proposed backfit is interim or final and, if interim, the iustification for imposino the proposed backfit on an interim basis.
m The proposed rule, when made effective, would be done so in final form and not on an interim basis.
List of Subjects in 10 CFR Part 55 Manpower training programs, nuclear power plants and reactors, penalty, reporting and recordkeeping requirements.
22 Enclosure D
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For the reasons set out in the preamble and under the authority of the Atomic l
Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as
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amended, and 5 U.S.C 553, the NRC is proposing to adopt the following i
amendments to 10 CFR Part 55.
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I PART 55 - OPERATORS' LICENSES I
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- 1. The authority citation for Part 55 continues to read as follows:
AUTHORITY: Sees.107,161,182, 68 Stat. 939, 948, 953, as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2137, 2201, 2232, 2282); secs.
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201, as amended 202, 88 Stat. 1242, as amended, 1244 (42 U.S.C. 5841, 1
5842).
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Sections 55.41, 55.43, 55.45, and 55.59 also issued under sec. 306, Pub.
1 L.97-425, 96 Stat. 2262 (42 U.S.C. 10226).
Section 55.61 also issued under
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secs. 186, 187, 68 Stat. 955 (42 U.S.C. 223C, 2237),
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For the purposes of sec. 223, 68 Stat. 358, as amended (42 U.S.C. 2273);
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_ 55.3, 55.21, 55.49, and 55.53 are issued under sec. 1611, 68 Stat. 949,
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l as amended (42 U.S.C. 2201(1)); and 55.9, 55.23, 55.25, and 55.53(f) are i
issued under sec. 161o, 68 Stat. 9f0, as amended (42 U.S.C. 2201(o)).
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- 2. In 555.4, a new definition is added in alphabetical order to read as follows:
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23 Enclosure D f
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4 155.4 Definitions.
l "Accredited university or college" means an educational institution in the United States which has been approved by a regional accrediting body.
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- 3. In 655.31, a new paragraph (e) is added to read as follows:
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l 155.31 How to apply.
(e)Each applicant for a senior operator license to operate a nuclear power reactor, after [4 years following the effective date of the rule?, must have i
a bachelor's degree in engineering, engineering technology, or the physical 6
sciences from an accredited university or college. Applicants with other l
bachelor's degrees from an accredited institution will be considered on a case-by-case basis if the reactor plant licensee certifies that the applicant
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j has demonstrated engineering expertise, leadership qualities, and high potential for the senior operator position.
In addition, except as noted in
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l paragraphs (e)(1) and (e)(2) of this section, after [4 years following the t
effective date of the rule), each applicant for a senior operator license must have at least two years of operating experience at a nuclear power plant, of which one years' experience must be as a licensed control room operator for a nuclear power reactor operating at greater than twenty percent power. At least six months of the nuclear power plant experience must be at the plant for which l
the applicant seeks the license. An authorized representative of the facility
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licensee will verify that the requirements of this paragraph have been met as j
a part of certifying the applicant's qualifications pursuant to paragraph 1
24 Enclosure D 1
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(a)(4) of this section. Any person holding a senior operator license on
[4 years following the effective date of the rule' is exempt from the requirement to have 6 bachelor's degree.
(1) For each applicant from a facility that has not completed preoperational testing and an initial startup test program as described in its Final Safety Analysis Report, as amended and approved by the Comission, and has not yet been licensed to operate at power, the Comission may approve alternatives that provide experience equivalent to operatien at twenty percent power.
(2) For each applicant from a facility that has (1) completed preoperational testing as described in its Final Safety Analysis Report, as amended and approved by the Comission, and (ii) is in an extended shutdown which precludes operation at greater than twenty percent power, the Comission may process the application and may administer the written examination and operating test required by 555.43 and 155.45 of this part, but may not issue the license until the required evidence of operation at greater than twenty percent power is supplied.
Dated at Rockville, MD this day of
, 1988.
For the Nuclear Regulatory Comission.
Samuel J. Chilk.
Secretary of the Comission.
25 Enclosure D
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ENCLOSURE E
o Regulatory Analysis for Degree Requirement for Senior Reactor Operators 1.
Statement for the Problem
1.1 Background
Since the Three Mile Island Unit (TMI-2) accident on March 28, 1979, in which human error, among other factors, contributed to the consequences of the accident, the issue of academic requirements for reactor operators has been a major concern of the Nuclear Regulatory Comission (NRC).
In July 1979, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recomendations," (NUREG-0578) made specific recomendations for a Shif t Technical Advisor (STA) to provide engineering and accident assessment expertise during other than nonnal operating conditions. On October 30, 1979, the NRC notified all operating nuclear power licensees of the short-tem STA requirements, i.e., that STAS should be on shif t by January 1980, and that they should be fully trained by January 1981.
In November 1980, "Clarification of TMI Action Plan Requirements,"
(NURE3-N 37), provided further details to licensees regarding implementation of the STA position.
1 Enclosure E h
L The qualifications of operators were also addressed by the 1979 "Lessons Learned Task Force " (NUREG-0585), the 1980 Rogovin report, "Three Mile Island: A Report to the Comissioners and to the Public "
NUREG/CR-1240), and the 1982, "Report of the Peer Advisory Panel and the Nuclear Regulatory Comission on Operator Qualifications," (SECY 82-162).
1 The consensus among these reports was that greater technical and academic knowledge among shift operating personnel would be beneficial to the i
safety of nuclear power plants.
On October 28, 1985, the NRC published in the Federal Register (50 FR 43621) a final policy statement on engineering expertise on l
shift. Option 1 of the Policy Statement permits an individual to serve i
in the combined Senior Operator / Shift Technical Advisor (50/SYA) role if l
that individual holds either a bachelor's degree in engineering, l
engineering technology, physical science, or a professional engineer's j
license. Option 2 permits continuation of the separate STA who rotates I
with the shif t and holds a bachelor's degree or equivalent and meets the j
criteria as stated in. "Clarification of TMI Action Plan Requirements "
l (NUREG-0737). The Comission also encouraged the shift supervisor to J
serve in the dual-role position, and the STA to take an active role in t
I shift activities, I
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l On May 30, 1986, the NRC published an advance notice of proposed rulemaking(ANPRM)(51FR19561). The purpose of the ANPRM was to extend i
the current level of engineering expertise on shift, as described in the l
l Comission's Policy Statement on Engineering Expertise on Shift l
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2 Enclosure E l
F (50 FR 43621) and to ensure that senior operators have operating i
experience on a comercial nuclear reactor operating at greater than twenty percent power, e.g., "hot" operating experience (Generic Letter 84-16). The ANPRM was the result of a Comission decision to consider an amendment to its regulations (Parts 50 and 55) and to obtain coments on the contemplated tction to upgrade the levels of operating, engineering, and accident management expertise on shift.
The Comission has carefully considered the numerous comments received on the ANPRM as well as the recomendations of the Advisory Comittee on t
Reactor Safeguards. The Comission believes that it would be beneficial to have a full public airing of views by publication of a notice of i
proposed rulemaking.
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l 1.2 Discussion of Proposed Rulemaking c
This proposed rule would require each applicant for a Senior Operator J
(50) license to operate a nuclear power reactor, after f.4 years following l
l the effective date of the rule], to have a bachelor's degree in l
engineering, engineering technology, or the physical sciences from an P
accredited university or college. Applicants with other bachelor's 1
degrees from an accredited institution will be considered on a l
i case-by case basis. Degree equivalency will no longer be accepted. A r
bachelor's degree in another subject area would be acceptable if the i
utility (licensee) certifies that the applicant has demonstrated i
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3 Enclosure E l
engineering expertise, leadership qualities, and high potential for the 50 position. An accredited university or college is defined as an educational institution in the United States which has been approved by a regional accrediting body.
The proposed rule would apply only to applicants for a 50 to operate a nuclear power reactor.
People who held 50 licenses on f4 years following theeffectivedateoftherule)wouldbeexemptfromthedegree requirement. Furthemore, the proposed rule would not apply to 50 applicants for non-power nuclear reactors such as research and test reactors. Licensed reactor operators (R0s) would not be required to have a degree. Thus, those persons who are senior operators on [4 years followingtheeffectivedateoftherule)wouldbe"grandfathered"by the proposed rule. The proposed rule would also requi, one year of "hot" and at least 2 years total operating experience for each appiteant for a 50 license. Table 1 presents a comparison of the current education and experience requirements for a 50 with those that would be in effect if the proposed rule was enacted.
2.0 Objectives The objective of the proposed rule is to upgrade the operating, engineering, and accident management expertise provided on shift by combining both engineering expertise and operating experience in the senior operator function. The NRC believes that having personnel on shift with enhanced qualifications is necessary to further ensure the protection of the health and safety of the public.
4 Enclosure E
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TABLE 1. COMPARISON OF SO REQUIR7MENTS Current Proposed Education H.S. Diploma or Equivalent Bachelor's Degree 4
Experience 4 years responsible power plant Must have 50 license w/o degree experience including 2 years on cut-off date nuclear plant experience.
i 6 months at specific plant for license
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R0 ifcense for 1 year i
2 years responsible nuclear power 2 years responsible
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w/ degree plant experience nuclear power plant experience including 1 year as RO*
t 6 months at specific plant for 6 months at license (not counting training specific plant for l
time) license (not counting training time) l t
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- Note: These requirements imply that a person with a degree may become a RO with only 1 year of responsible nuclear power plant experience plus the necessary training time, t
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Enclosure E
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Q 3.
Alternatives Three alternative approaches were considered by the Comission during its deliberations on the proposed rule following publication of the ANPRM.
The Comission decided to proceed with the contemplated degree rule and concurrent policy statement as proposed in the ANPRM. This would in the long term result in two Senior Operators on shift who have bachelor's degrees.
4.
Consequences 4.1 Benefits It is not feasible to quantitatively evaluate the consequences of the proposed rule. That is, the effect of the 50 on the probability and consequences of an accident, and the change in the probability and consequences of an accident as a result of requiring the 50 to have a bachelor's degree is unknown. The Comission believes that requirinD a degree will contribute to the goal of having 50s who have operational experience, technical and academic knowledge, and educational credentials that should improve their performance as operators and possibly open career paths from which they may have been excluded in the past. The 50s should be able to respond better to off normal incidents. While there will be increased training to cover accident conditions, training alone is not sufficient.
It is impossible to cover every eventuality during training. The operators must have sufficient understanding of basic 6
Enclosure E
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engineering principles, and detailed knowledge of nuclear design and operation to appropriately respond to situations that have not been
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f previously covered in training sessions.
In addition. 50s with degrees i
will have greater opportunity for professional growth since they will have the qualifications needed to advance to managerial positions. With the 1
chance for personal growth should come greater job satisfaction. The j
validity of these beliefs has been re-enforced by the experiences of l
licensed operators participating in an ongoing utility sponsored program j
similar to what is being proposed herein. The Connission also believes
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that there will be a net improvement in plant safety if sizable numbers of r
50s migrate upward into plant management. Requiring 50s with degrees may s
I result in fewer people in the control room, since a separate STA would not f
be needed, with a concomitant cost saving.
1 4.2 Costs j
One of the questions posed in the ANPRM concerned what the implementation l
and operation costs of the proposed rule to the utilities would be. The cost estimates received ranged from negligible to prohibitive. Various I
scenarios for achieving the desired staffing level of 50s with degrees i
were assumed. These varied from hiring individuals with degrees and l
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passing them thru the norinal utility training programs to taking R0s and sending them to college while either paying them at overtime rates or hiring replacerent R0s. A utility could also implement an onsite college 2
i degree program for its operators, for example, a program currently being run for an operating plant costs $250.00 per year to train 60 people. The l
range of costs of such an onsite program are estimated to vary from
$250.000 to $480.000 per year.
7 Enclosure E
.]
It is clear that there are numerous methods that can be used to implement the proposed rule with an extreme range of costs depending on the method adopted.
It would be a utility's choice as to which method to adopt, taking into account the various cost and personnel considerations. For purposes of this regulatcry analysis, a representative cost to a utility is estimated to be about $500,000 per year.
5.
Decision Rationale While the benefits of the proposed rule cannot be directly quantified, the Commission believes that the degree program should result in greater plant safety. This benefit will be achieved over time by improved quality of the operational personnel and by plant n.anagement that has a better understanding of the unique operational problems associated with nuclear power reactor operations.
6.
Implementation 6.1 Schedule No implementation problems are now anticipated in view of the fact that the date for which the program would start has been changed to 4 years after the effective date of the final published rule (i.e., usually 30 days after publication in the Federal Register). This should be ample time for all affected parties to either decide upon and implement their upgrade program or obtain an appropriate degree.
8 Enclosure E
6-Relationship to other Existing or Proposed Requirements Current guidance in Regulatory Guide 1.8, Revision 2. April 1987, i
"Qualification and Training of Personnel for Nuclear Power Plants,"
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allows an applicant for a 50 license with a degree to have only 2 years of i
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responsible power plant experience, none of which needs to be as a reactor
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operator. This would have to be revised if the proposed rule went into f
1 effect since the proposed rule would require a 50 with a degree to serve l
as a RO at greater than 20% power for a least 1 year.
Futhennore, the i
guidance indicates that a R0 applicant rast have a minimum of 3 years of t
l power plant experience of which at least 1 year shall be nuclear power experience. This would have to be revised since it is inconsistent with l
the proposed rule which implies that an applicant for a RO with a degree j
must only htye 1 year of related nuclear power plant experience.
Finally.
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position C.I.d of the Regulatory Guice would have to be revised to t
indicate that a bachelor's degree is the minimum educational requirement j
for a 50 candidate rather than a high school diploma.
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Enclosure E 7
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