ML20245B634
| ML20245B634 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/1989 |
| From: | Remick F Advisory Committee on Reactor Safeguards |
| To: | Zech L NRC COMMISSION (OCM) |
| References | |
| ACRS-R-1364, NUDOCS 8906230263 | |
| Download: ML20245B634 (3) | |
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UNITED STATES I
NUCLEAR REGULATORY COMMISSION o
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ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 O
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June 15,1989 The Honorable Lando W. Zech, Jr.
Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Chairman Zech:
SUBJECT:
PROPOSED COMMISSION POLICY STATEMENT ON EDUCATION FOR SENIOR OPERATORS AND SHIFT SUPERVISORS AT NUCLEAR POWER PLANTS During the 350th meeting of the Advisory Committee on Reactor Safeguards, June 8-10, 1989, we discussed the proposed Commission Policy Statement on Education for Senior Operators and Shift Supervisors at Nuclear Power Plants.
l Our Subcommittee on Human Factors met with the NRC staff on June 7,1989 to discuss the proposed policy statement.
We previously commented on this general matter in a report to you dated August 12, 1987 entitled, "ACRS Comments on the Advance Notice of Proposed Rulemaking:
Degree Requirements for Senior Operators."
We endorse the proposal to issue a policy statement that presents the Com-mission's views concerning education for senior operators and shift super-visors, in contrast to promulgating a rule that would mandate that either all senior operators or all shift supervisors possess a baccalaureate degree.
This matter, under discussion for nearly a decade, has created considerable concern among licensee personnel, and thus should be resolved.
As indicated in our previous report, we strongly support the concept of having engineering expertise on each shift.
Further, we endorse the goals of enhancing profes-sionalism in plant operations, and we believe that this will provide a cadre of individuals with plant operating experience who would be available for promotion to higher management positions.
However, we do not think that requiring all senior operators to have degrees is the best approach to achieving these goals.
We believe the policy statement should indicate more clearly that it is not the Commission's intent that all senior operators and shift supervisors have a degree but that it intends to encourage licensee management to employ individuals with a mix of education, training, and experience in plant op-erations.
Further, some of these individuals should hold degrees or be seeking degrees.
We do not believe that it is feasible for all licensees to hire college graduates into entry level positions on the operating staff, if entry level means auxiliary or nonlicensed operators.
Therefore, we suggest that the first sentence of the fifth paragraph of the proposed policy statement provided to us read as follows:
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Th'e Honorable Lando W. Zech, Jr. Junc 15,1989
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Additionally, the Comission encourages nuclear plant licensees to hire college graduates for positions on the operating staff at levels consistent with the employment practices of the licensee.
In response to Commissioner Roberts' request, we have specifically addressed the question of encouraging degrees from accredited. institutions as stated in the proposed policy statement.
Design, construction, operation, and regula-q tion of complex, highly techr.ical facilities, such as nuclear power plants, require competent individuals with quality education and training. Hiring an employee with a degree from an accredited program or institution is not a guarantee of such competence and education.
However, accreditation has been developed through the years by academic institutions and professional organi-u zations to provide some assurance that certain standards of quality are j
maintained among educational institutions.
Therefore, we endorse the Com-mission's encouragement to licensees to attract ' individuals with science or
. engineering degrees from accredited institutions to operating staff pcsitions in their plants, and in particular to encourage the recruitment of graduates with engineering or engineering technology degrees from accredited programs.
Although we believe the policy statement could be written more concisely, we recomend that the Comission -issue the proposed policy statement as an expression of its general views on education for senior operators and shift supervisors.
Additional coments by ACRS members William Kerr, Harold W. Lewis, Chester P.
Siess, and David A. Ward are presented below.
Sincerel Forrest J. Remick l
Chairman Additional Coments by ACRS Member William Kerr l
This proposed policy statement appears to have evolved from an earlier i
proposed rule. The evolution is not mature.
It retains material irrelevant to a policy statement, is unfocused, incoherent, and, occasionally, incon-sistent.
If a policy statement is to be issued, it should be shortened and its focus should be sharpened.
1 Further, I am concerned that this policy statement appears to be encroaching L
on prerogatives and responsibilities of utility management.
While some of l
the suggestions may be appropriate to some utilities, there may well be alternatives that are as good or better. These should be identified and im-plemented by responsible management.
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- 3 Th'e' Honorable Lando W. Zech,-Jr. June 15,- 1989 I
Additional Coments by ACRS' Member Harold W. Lewis I believe that this is a classic example of.a case in which the best action by the Ct, mission would be no action at all.
The primary rationale for the policy statement is that something' needs to be said, now that the decision has been made not to issue ~ a rule.
The Comission could say that INP0 has-L written a fine: statement on professionalism, and it is pleased.
As the Committee has said earlier, there is no known connection between a degree and professionalism, and surely the intent is to get the best avail-
.able-people,into the nuclear business.
Arbitrary limitations on the supply of candidates are bound to be' counterproductive.
l' The same is true of managers' need for operating experience.
It is obvious that management is best among those who understand what they are managing.
It is far from clear that this understanding is best acquired.by serving as an operator.
The. pool of qualified people in all these categories is limited.
I see no need to put 'ill-conceived restrictions on the acquisition process.
Every-person chosen for (or promoted to) any job in the nuclear business should be the best person available for the jab at that time, and incentives should i
then be provided 'for further self-improvement.
That.is what is meant by 1
encouraging professionalism.
Additional Coments by ACRS Member Chester P. Siess The staff's attempt to translate a proposed rule into a policy statement and to accommodate the varying views of the. Commissioners has led to an unfocused.
statement that is unlikely to send a clear message to the public, the Con-gress, or.the industry.
I do not believe flat a policy statement is needed to tell the industry that nuclear power plants should be operated and managed j
by competent and dedicated people.
Nor do I agree that a college degree is j
either necessary or sufficient to provide people with those attributes.
-l Additional Conments by ACRS Member David A. Ward 1
I believe the proposed policy statement should not be issued. While some of
'the goals of the policy are laudable, they have not been clearly thought out.
Most important, it is not evident that the policy statement is necessary or will be instrumental in achieving the goals.
It might very well be counter-productive.
This is a matter best left to INPO which is moving effectively in this area.
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