ML20199H028
| ML20199H028 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1984 |
| From: | Major R Advisory Committee on Reactor Safeguards |
| To: | Ward D Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML20151H981 | List:
|
| References | |
| FOIA-84-656 ACRS-GENERAL, NUDOCS 8604090286 | |
| Download: ML20199H028 (4) | |
Text
.[
"o, UNITED STATES
,8',
}
NUCLEAR REGULATORY COMMISSION r
DVisORY COMMITTEE ON REACTOR SAFEGUARDS
%.',,,. *#[
=
o, WASHINGTON, D. C. 20555 July 24, 1984 l
MEMORANDUM FOR:
D. A. Ward, Chairman ACRS Subcommittee on Human Factors FRCN:
Richarc Najor, Senior Staff Engineer
SUBJECT:
STATUS REPORT FOR FULL COMMITTEE CONSIDERATION OF THE FINAL POLICY STATEMENT OF ENGINEERING EXPERTISE GN SHIFT, THE DUAL-ROLE (SRO&STA) POSITION
Purpose:
The purpose of this review is to give ACRS advice to the Comission in letter form on whether or not the Committee supports the final policy statement which gives licensees and applicants the option of either continuing with their approveo STA program, or they may combine the Licensed Senior Reactor Operator (SRO) and Shift Technical Aavisor (STA) functions into one dual-role SRO/STA position as an alternative for r.eeting the requirements of 10 CFR 50.54 (m)(2).
This issue was brought before the full Comittee last month.
The Staff made a presentation on Thursday, July IE,1984.
The Committee attempted to write a letter on Saturday July 14, 1984, however a number of questions arose ano this issue was set aside until this month. Hopeful-ly this status report and a brief staff question and answer period will allow the Conmittee to proceed with giving its advice.
Time:
Currently this item is scheduled for one hour on Friday, August 10,1984 f rom 8:30 a.m. to 9:30 a.m.
Place:
This is a full Com.ittee meeting session and will be held in the Comittee's main meeting room, Room 1046, 1717 H St. NW.,
Washington, D.C.
Backgrounc:
The Committee had seen this policy statement (called shift crew galificaticns) prior to a public coment period.
Basically, the statement allows licensees and applicants for an operating license to continue with their approved STA program, or they may combine the Licensed Senior Operator (SRG) and Shift Technical Advisor (STA) functions into one dual-role SR0/STA position as an alternative for meeting the requirements of 10 CFR 50.54 (m)(2).
The Comittee in its December 14, 1982 letter to Chairman Palladino,
Subject:
"ACRS Comments on Rulemaking Concerning Staffing at Nuclear Power Plants and Draft Policy 5tatement on Shift Crew (ualifications," saio:
"We strongly endorse this proposal anc believe it is preferable to the separate Shift Technical Adviscr positior, ncw required."
The Comittee hac also commented on the dual-role SR0/STA in an August 9,1963 letter on a " Proposed Hule Requiring On-Shif t Engineering Exper-tise." (It is unfortunate the titles on the proposed rule and the policy statement, under consideration, are so similar.
They are not the same issue although they are somewhat related.
The proposal rulemaking g40 6 860213 DELLS,4-656 I
ppg
M Human Factors 2
has been dropped; it would have required the Shift Supervisor to have a B.S. degree and an SRO license by 1987. A new proposed rule regarding a Senior Manager on shift is very similar to the proposed rule that was dropped. The dual-role SH0/STA was called an interim measure by the i
Staff.
It is possible that over the next few years requirements for a shift manager may develop.
However, at this point the dual-role SR0/STA is an option the utilities can select instead of the separate STA position). The quote from the August 9, 1983 letter is:
"We note that this proposal is a n.ove away from the concept of a Shift Technicai Aavisor (STA) who is independent of the operations staff. The Corunittee hus previously (letter of December 14,1982) endorsed a proposal for combining functions of the SRO and the STA (i.e., engineering expertise) in one person. We continue to endorse that proposal and thus are in agreement with the central thrust of the proposed rule which is to combine these qualities in the shift supervisor."
Following the public coment period, the policy statement was put into final form. Little in the policy statement changed as a result of the public connents received.
Last month this issue had not been brought before the CRGR. By now CRGR cocr..ents may be available and the Statf's response to the coments may be available.
Answers to Some Question on This Topic Raisea by The Committee Last Month It is important to keep in mino the dual-role SR0/STA will be an option available to licensees and applicants.
If a particular utility is satisfied with the performance of their STA program; they are free to continue it.
There was some discussion on whether or not the cual-role SR0/STA would possess the same cualifications as the separate STA.
It is my understancing that the dual-role SR0/STA must meet all the requirerients for each of the separate positions covered. Dis-cussions with the Staff indicates that the alternatives allowed for the b.S. requirement are more restrictive in the case of the dual-rcle SRO/STA than for the separate STA.
The Comuittee was divided on the importance of maintaining an independent STA. This was also a topic comented on during the public comment period. The Staff's position is that combining the STA and SR0 functions would not compromise engineering expertise on shift but would enhance it. The Policy Statement continues to require specific STA training of the SRO/STA in accident assess-ment. The SR0/STA could provide that expertise curing an abnormal occurrence.
(The short one page report on, " Experience With The Position of Shift Technical Advisor," which is included describes some prublems with the separate STA position.)
In the original requirement for the STA found in NUREG-0737,
g Clarification of TMI Action Plan, item I.A.1.1 the following is sdio:
"The need for the STA position may be eliminated when the quali-fications of the shift supervisors and senior operators have been upgraded and the man-machine interface in the control room has been acceptably upgraded. However, until those long-term improvements are attainea, the need for an STA program will continue."
The Air Florida Boeing 737 that crashed into Washington D.C.'s 14th Street bridge did not have an independent flight engineer on board.
A copy of the NTSB Accident Report of this incident was sent to all certbers.
One ut the causal factors for the crash was the captain's failure to abort the takeoff in its early stage when the first officer called his attention to puzzling engine instrument readings. A summary of the Air Florida tragedy is presented in the hTSB Annual Report to Congress for 1982, the applicable portion is attached.
There was confusion created by the similarity between the title of the dual-role SR0/STA policy statement (Engineering Expertise on Shift) and a proposed rule the Comittee commented on last sumer (00-Shift Engineering Expertise). They are separate, but related issues. The Policy Statement which we are now considering allows utilities the option of either continuing their present STA program or replacing the separate STA with a dual-role SR0/STA.
Last summer's rulemaking had as its primary thrust requiring the shift supervisor to hold a B.S. degree and an SRO license by 1987. This particular rulemaking package was dropped.
There is still some Staff effort underway to crate a senior manager on shift.
1he dual-role SR0/STA is certainly a step in that direction.
It was described last month as an interim policy pending the cevelopment over the next few years of criteria for a Senior Manager On Shift. At the present time, the Staff is waiting for input from the industry on the Staff's proposal to require a senior manager with a B.S., and SR0, and 5 years of experience on shift.
It appears that the industry is having a tough time trying to decide the merit of such a position.
There are views on both sides of this issue.
For the present though, the Staff is only focused on allowing utilities an option to combine two positions into the dual-role SRO/STA individual.
i
Enclosures:
- 1. Final Policy Statement on Engineering Expertise on Shift (with cover letter from Denton to Stello.)
- 2. NRk Article, Experience with the Position of Shift Technical Advisor.
l
- 3. ACRS Ltr. to Chairman Palladino,
Subject:
ACRS Comments on Rulemaking Concerning Staffing at huclear Power Plants and Draft Policy Statement i
on Shift Crew Qualifications, Dec. 14, 1984.
- 4. ACRS Ltr. to Chairman Palladino,
Subject:
ACRS Report on a Proposed Rule Requiring On-Shift Engineering Expertise, August 9, 1984.
- 5. NUREG-0737, Clarification of TM1 Action Plan Requirements. Item I.A.1.1 Shift Technical Advisor.
l
ACRS Subst, on Human Factors 4
- 6. National Transportation, Safety Board, Annual R: port to Congr:ss, 1982, PGS 3-6.
.