ML20199G870
| ML20199G870 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1983 |
| From: | Fischer D NRC |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20151H981 | List:
|
| References | |
| FOIA-84-656 ACRS-GENERAL, NUDOCS 8604090257 | |
| Download: ML20199G870 (1) | |
Text
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- June 2H, 1983 fiEM04A!iquit FOR: ACRS rienbers FPO't : 0 Fischer, Staff Engineer
SUBJECT:
FINAL RtlLE CONCERNING LICENSED OPERATOR STAFFING AT NUCLEAR POWER UNITS On April 21, 1983, the Connission approved the Final Rule Concerning Licensed Operator Staffing at Huclear Power Units. The related policy statement on " Shift Crew Qualification" is still being considered by the Connission. You may recall that the Comittee reviewed the proposed final rule and a proposed draft policy statenent during its Movember and December 1982 neetings. The Comittee's coments on both are included in the attached letter to the Chairman dated December 14, 1983. The decision was recently nade not to delay further the publi-cation of the Final Staffing Rule in the Federal Register. Publishing of the rule was on hold until the policy statement was approved. The policy statement would have permitted licensees to conbine the functions of the SR0 and the Shift Technical Advisor in one individual, provided that person:
- a. had a baccalaureate degree or equivalent in engineering or related sciences, and
- b. was licensed as a senior operator on the particular nuclear power unit (s), and
- c. had completed the STA training requirements of NUREG-0737.
The Connission is concerned about how the Staff will determine equivalency in neeting the RS degree requirenent (ie., what standards and guidelines will be used by the Staff). At any rate, the rule and policy statement are now decoupled. The rule will be published very shortly (for a single unit site the rule will require 2 SR0s on shift, one in the control roon at all times). Until the policy statenent is approved, the STA will be considered l
a seperate position by the Staff. Combining the STA and one of the SR0's will not be allowed until the policy statement is approved. The Staff in-tends to liberally grant extensions to the January 1,1984 rule implemen-tation date until the policy statement receives Comission approval. The July 1,1983 deadline for subnitting a request for an extension will be changed.
Attachment:
x As stated cc: ACRS Technical Staff
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UNITED STATES o NUCLEAR REGULATORY COMMISSION 5 '
~I ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
'o W ASHINGTON, D. C. 20555 December 14, 1982 Tne Honorable Nunzio J. Palladino Chai rman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Dr. Palladino:
SUBJECT:
ACRS COMMENTS ON RULEMAKING CONCERNING STAFFING AT NUCLEAR POWER PLANTS AND DRAFT POLICY STATEMENT ON SHIFT CREW QUALIFICATIONS During its 271st meeting, November 4-5, 1982, and its 272nd meeting, Decem-ber 8-10, 1982, tne ACRS considered the proposed final rule entitled "Li-censed Operator Staffing at Nuclear Power Units" and a proposed draft policy statement on " Shift Crew Qualifications." These matters had been previously discussed with representatives of the NRC Staff and industry at a Subcommit-tee meeting in Washington, D.C. on October 28, 1982. Tne proposed rule was not reviewed by the ACRS before it was issued for public comment.
We agree with the proposal to amend 10 CFR Part 50.54(m) to require a suf-ficient number of licensed Senior Reactor Operators on each shift to assure adequate supervisory coverage in the control room while permitting the Shift Supe rvi sor, who is also an SRO, flexibility to move about the facility.
We believe it is highly desirable that an individual with the training and experience required of an SRO be present in the reactor control room a very large fraction of the time. However, the requirement for 100 percent coverage is too restrictive. We urge that the NRC Staff consider some flexibility concerning how near an SR0 must be to the control room or wnat small f raction of the time he or she might be absent.
We endorse postponement to January 1,1984 of the originally proposed imple-mentation date for the rule. Selecting, training, and licensing the highly qualified individuals required to operate nuclear power reactors is a com-plex process. While most licensees already meet the intent of the proposed rule, or are scheduled to meet it well in advance of the proposed date, we believe a reasonable time should be permitted to allow the remaining licen-sees to comply.
The proposed policy statement on "Shif t Crew Qualifications" would permit licensees to combine tne functions of the SR0 and the Shift Technical Advisor in one individual, provided that person meets all the requirements of both i positions. We strongly endorse this proposal and believe it is preferable to the separate Shift Technical Advisor position now required. Combination of supervisory autnori ty and perspective with engineering and analytical i
njhb ik -
l
Honorable Nunzio J. Palladino December 14, 1982 l
capability will provi de an effective shift organization for dealing with both normal and emergency situations.
Additional comments bj ACRS Member Dr. H. W. Lewis are presented below.
Sincerely,
\*
P. Shewmon Chairman Additional Comments by ACRS Member Dr. H. W. Lewis While I agree with the sense of the Committee letter, there remain a couple of points that concern me.
Fi rst , in view of the somewhat more relaxed schedule for the implementation proposed in the current version of the rule, I cannot see why it should not go through the Committee to Review Generic Requirements. I had thought that the function of that Committee was to assure high quality for proposals such as this.
Second, I would greatly strengthen the ACRS recommendation that the NRC Staff consider some relaxation of the admittedly arbitrary 100 percent attendance feature of the proposed rule. Any understanding of accident probabilities leads to the conclusion that small absences (in space or time) make correspondingly small contributions to the risk.
Third, I am troubled by the underlying philosophy, which suggests that numbers in the control room are the important issue. While there surely exi st accident sequences which require several people for their management, it is equally true that Three Mile Island revealed more deficiencies in quality tnan quantity. There is little evidence that the Staff has tried to trade of f these values. Of course, the upgrading from RO to SR0 implies a higher level of training, but the proposed rule deals with more SR0s, not better SR0s. However, if the fusing of the roles of SRO and Snif t Technical Advisor is really implemented, that will be a move in the right direction.
This rule, as finally promulgated, will nave a long life -- there is every -
reason to be a little more certain that it has the right form. <
Reference:
- 1. Draft memo to Commissioners from William J. Dircks, Executive Director i for Operations, Suoject: Final Rulemaking Concerning Staffing at 7.. ,' ~
r Nuclear Power Plants and Draf t Policy Statement on Shif t Crew Quali.
fications, transmitted by memo f rom L. Goller dated December 3,19q C
.