ML20246F344

Proposed Rule 10CFR50 & 55, Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants. Proposed Rule Withdraw

ML20246F344
Person / Time
Issue date:	08/09/1989
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 PR-890809, NUDOCS 8908300265
Download: ML20246F344 (10)

Text

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s DOCKETNUMBER $ G0 SC (759 m m PROPOSED RULE

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C 53 FR 51Hd wxma m mIm

'89 ALG -9 P3:48 10 CFR Parts 50 and 55 f

RIN: 3150-AC26

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Motion and Experience Requiramrants for Senior Per Operators ard Supervisors at Nuclear Power Plarrts; Withdrawal of Fm M_ Rulemakirq AGDCI: Nuclear Regulatory r%=4=icri.

ACTIm: ' Prrv==d rule: Withdrawal.

S099RY: 'Ibe Nuclear Regulatory th=inian (NRC) is withdrawing a notice of prW_ rulenakirg 1xiblished in the Federal Register an December 29, 1988 (53 FR 52716), in whicf1 rysmarits were solicited on two pzW alternative ew4u=4. to its regulations. 'Ihe alternatives propaaed in the Federal Register notice would have iW additional education and experience requittmaissi.a for eithe!" Senior operators or wasi.rul IDcIn supervisors. In consideration of the ocannants Inceived an the y--

-i rule and the status of irdustry initiatives to enhance the education level of its operating perk u el, the th =i m ian concludes that it should withdraw the pr

• rule published m 2 29, 1988. 'Ibe th=4"ian is publishing a policy statement that presents its views concerning dntion for senior operators and shift supervisors at ruclear power plants.

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FOR IURIMER IhTORl931W 0:NDCI:

M. R. Fleishman, office of Nuclear l

Regulatory P-%, U.S. Nuclear Recplatory Otxanission, Washington, DC 20555, telephone (301) 492-3794.

SUFFIDIENDEC DEURt92IN:

l On May 30, 1986, the NRC published an advance notice of pm-M rulemaking (ANPR) (51 IR 19561) to solicit public cxxaments on a tw=4mian proposal to fs,linia$ is $'

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increase the current level of ergineerirq expertise on shift, arxi to ensure that senior operators have operatirg experience on a cxamercial nuclear reactor operatirs at greater than twentv p=wunt. power. 'No hundred letters were receivM in response to the ANRP; most of than were t 1-: =A to a degree requirement for senior ope:.ators.

Although cxmanents receivaci on the ANPR were generally opposed to a degree requit= imet, the Ox=immion believed that it would be beneficial to obtain*

additional public m.ed. on two alternative amendmaats to its regulaticos.

'1he pr*_ rule - Tducation and Experierce Requia-ess for Senior Reactor opstors and Supervisors at Nuclear PJwer Plants - was published in the Federal Register on December 29,1988 (53 FR 52716) for a 60 day public rymmnt period, whitt2 was later extended to Martti 29, 1989. '!he alternatives st--W in the Federal Register notice would have 4=v-M additional ahtien arx1 experience requirements for eitbar senior operators (Alternative 1) or muul room shift supervisors (Alternative 2).

A total of 250 conunent letters were received cn the st-- W rule. All of the m..tw have been reviewed and evaluated.

(copies of the cxzeent letters are available for public i& tion and copyirg for a fee at the NRC Public rhwt Rocn at 2120 L St71het, !M., lower level, Washirgton,

[C). Of the 259 m4ed.s received, 214 (appronmately 98 percent) were frtxn people who are part of or a=8miated with the regulated industry. Of the remainirg six counments, five came frtxn people associated with l

educational institutions and one came frtun a citizen's group. A total of 237 m.= users (approximately 95 percent), were r5Tewud to both Alternative 1 and Alternative 2 of the w ; M rule. Wttile no utilities favored the rule, about ten m.=(wrs, who either irx11cated that they were or appeared to be operators, were in favor of one or both alternatives. 'the M 'Ibe term " shift supervisor" is beirq used to refer to that perscn holdirg a senior operator license for all fueled units at the site who is assigned responsibility for cuerall plant operation at all times there is fuel in any unit. Hben a sirgle operator does not hold a senior ep=2E^ws-license on all fueled units at the site, a licensee must have at ttw site two or more senior operatcrs, who in combination are licensed as senior cperators on all fueled units.

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educational grtups generally offered conments agartiing implementation of the p3 alternatives and were divided on whether or not the rule s

should be made effective. 'Ibe citizen's group preferred Alternative 2 to I

Alternative 1 and also believed that an NRC administered examinaticri should be used to naasure the qualifications of the shift supervisors and ensuzu j

uniform standartis in the industry.

Because of the coments received on the prrmaad rule, the supor.s bairq nade by utilities to voluntarily obtain engineerisq expertise cri shift, and DGO initiatives both to increase professionalism of the cperatirg staff and to review the adegaacy of trainirg and education regai4w =rs for shift supervisors, the hiemian has concluded that it should withdraw the prrr==4 rule published hr 29, 1988.

We have incitded below a summary of cxrnents that provides a general description of the type ard trne of ocmnents reatived. 'Ihis sunnary theribes the nost prevalent otranents as well as sane coments that praeant unusaal insights. '!he coments and responses to them are as follows:

1.

0:2 MENT: Drery organization that has studied the issue has :onclu$ed that there is no valid reason for a dispce regain =-E - these irclude the NRC Advisory Ccratittee on Reactor Safetyaartis (AGS), the NRC Cormnittee to Review Generic Requiimarris, the Reactor Operator Osalifications Peer Review Panel, the American Ibclear Society, the Institute of luclear Power Operations (INPO), the Ibclear Wi ard Pa=mtes Cturcil, Inc., the Professional Reactor Operator Society and the National Pacaartd1 council of the National Acxt=ny of Sciences.

'Ibere is no evideros to indicate that an operator with a degree would perform better than one without a degree darizg either normal or abnorncl situations.

RIEPCNSE: While the hie = ion has conclu3ed that it is une="y to mandate specific degree regaiiwens for senior operators or shift supervisors, we continue to believe the presence of individuals with a degree in the control rocxn is beneficial to safe operations. 'Ibe gaestian is not whether an operator with a degree performs better than

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one withcut a degree. Instead, the question is whether, under j

unanticipated circu:: stances, a grtup of operators, as a team, wtuld perform better if sczne of them had technical and acaderic ):nowledge prwided 1:y a col.lege degree. We are not aware of any relwant technical data that could answar this gaestion. However, most organizations acknowleckped a need for " engineering ):nowle&pe" on shift. The Camnission believes that the safety of comercial power reactorr, is enhanced by having on ancts shift a team of HRC-licensed e

professionals that combine technical and acwheic ):nowledge with plant-specific trainirg tnd trabstantial hands-on aparating experianos.

2.

02NDE: '!here have been many inprcumunts in design, organizatist, sucidares, and cperatcr trairling since the 'ILree Mile Island ('DE) l accident so tire the rule is not r===%9 RESPONSE: '!here have been many inptwenants in design, organization, and sucolares since the 'IMI accident but these do not alleviate the need for high quality technical )cnowledge on the operating shift.

However, we have withdrawn the rulemaking in favor of a policy stateme.t.

3.

03HDCS:

(A) 7be ability to deal with unanticipated situations regaires site specific systens krnwleckye aogaired thrugh harris-at, site specific, experience and trainirq.

(B) operators are alreaty gettire training in basic ergineeriry principles, detailed ruclear design, arri detailed ):rowledge of ruclear plarst operations, as well as diagnostics and mrmartications, and are generally well preparmi to deal with ur+M situations.

RESpDNSE: We agree that quah are getting reqaired basic training 1

arri that site specific systa:n. ):nowledge and hands-on operatire experience are r - e y to deal with unanticipated situations.

However, a good operator must have the ability to assixtilate and integrate ):nowledge of multiple systes to assess the causes of events i

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3-nce covered in training sessions and direct the =wielate reponse.

.We believe education in a technical discipline can eW an operator

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wledge in scientific and engineering fundamentals and'can battar prepare an operator to handle situations nct covered by training.

4.

CQtENT: ' If the nwniemian believes that note knowledge is'needed,'

su& as might be attained frtan a bachelor's degree program, the knowledge should be identified, the material should be irwy==ted into operator training prograns, and th.t NRC should test operators for that knowledge.

RESPONSE: 'Ihe NRC staff is considering this ocument with r%T. to operator training programs However, although sczne specific areas for improved training may be identified, adulation, as dimW above, l

should also be emphasized.

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CG9ENT:- the fundamentals exam, curthy being oansidered for both Boiling Water Reactors (IMRs) ard Pressu]ized Water Reactors (IWs),

oculd be used as an initial step in react:or operator licensing. 'Ihis exam, which could be oriented to nuclear cperations and engineering fuWmantals, would be more suitable than would an engineer-in-training (EIT) exam, profeastcnal engineer (PE) lioenee, q

or a bachelor's degree.

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BESE giEt 'Iha effectiveness of the fw L 441s exam in improving the

.l level of operator training is still being asaammed. 'Iha develyznent i

of this exam is underway and we will contirman to monitor its l,

effectiveness.

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6.

339ENT: Nuclear. Utilities Management and Review conmittee (N. NARC)

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commented that the results of a survey they perforned irriicated that i

72 p= v A. of the utilities toy.u.L that they are alzmady 3 awn.4.ing 4

1 operators without degrees into m%

4. positions abcue the shi.ft supervisor position.

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.~ 4 RESPct E : 'Ihis is very encouraging, ard is one of the reasons we have decided not to pivcesi with the rule. However, while utilities my be prmating same operators without degrees into manam >L positions abc've the shift supervisor position, e.g., maintenance manager, it is not yet clear that these opairwi. are getting into all phases of upper managenent. 'Jhe h4== ion believes that piwtaas which em"w= experienced nuclear professionals to obtain college ?-,3-and personnel with d=:gos to obtain a senior cpartwi-license and hands-on operating experience create an izptLmt source of managenant talent for the industry. 'Ihese individuals are more likely to be selected for manamL positions and, tw ause of their understanding of the unique operational problems associated with nuclear pcner plant operation, are in a better position to erfance nuclear safety by fostering a =L&m3 safety culture within their organization.

7.

0291ENT: It would be desirable to retain the i@ndent a===marit

, apability of the Shift 'Dechnical Advisor (SIA). 'Ibe SIA plurides a valuable ocritribution to the operating staff and is effective har=mm the STA is not rus sible for pivw. lural matters during a transient.

r PET <tE: We agreer hewever, we believe tnat there is also a benefit ~

to be derived frm having operations expertise ard engineering knowledge in the same individual. In its policy state m nt on education for senior operators and shift supervisors publistxx1 elsewhere in this issue, the n = iceian reaffirms its position regarding the presence of an SIA on shift and reemphasizes its desire that all licensees move toward a dual role senior operator / shift technical advisor (SO/SIA) position.

8.

COMNTS:

(A) It would be very difficult for a worker on a rotating shift to atterd college on a part-time basis, atrthermore, pi w tau-accredited by the Accreditation Bcard for Engineering and 'Dectnology 1

(ABET) are generally not very accessible to operating plant personnel.

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(B) Ongoing on-site suyaus leading to a bachelor's degree in Nuclear Science, that have been initiated by utilities in re:f: paine to perceived h4=aien desires, will be jeopardized since they are not ABET accredited.

l (C) 'Ihe detailed requit==ius related to the ABET accredited degree are too prescriptive. A bachelor's degree in any scientific discipline fran a reglanally accredited ptw am, plus a senior operator license with its a - iated site specific training in accident diagnostics and engineering fundamentals, is equivalent to a

- bachelor's degree in engitaring.

RESK46E: We agree that it is very difficult to work full-time on shift as an operator and cbtain a college degree. Several utilities have been offering swtam laarling to a degree that am----Mtes shift work, but while many people have entered the s wtaus, few have actually cm pleted the swtam and obtained degrees.. 'Ibe ^==4caion believes that these ptwsom should be encouraged hsw ause the wtL.inity should be made available for highly motivated indivirkule I

to overcome institutional barriers and obtain a degree; furthermore, 1

the demands of shift work are not the same at every utility. We continue to believe that it is important that the degrees obtained be fran accredited institutions to provide confidence mmning the quality of the uhmtion and the value of the degree.

9.

CDEENT: 'Ibe bachelor's degree requitment should include the applied sciences along with engineering, engineering technology, and the physical sciences.

EEPONSE: Education in the important focus here. While many degrees may be acceptable, certain degrees are preferred as providirq better preparation for operators. 'Ihe policy statenent irriicates that degrees in physical science, engineering, or engineering technolcgy are preferable.

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COMENTS:

(A) Negotiated labor agreenents with unions do not have a rxpit==:ust for a senior operator to have a bachelor's degree.

'Ihe unions indicate that they would go to court to fight the requi4===4L for a bachelor's degree since no need for the requit-s L has been

&===Ltated.

(B) It will be difficult for people with degrees to get the required reactor operator experience in sme union plants sinoa the reactor operator position is filled by unico people and people with d, a are generally not in the union but are considered part of management.

RESPJNSE: We do not believe labor agreements or practices should lead to actions which would inhibit the career devah--. 4L of union or norMInion Irei== or be a disinoentive to continued safe operation of facilities.

11. (DHINrS:

(A) 'Ibe rule will reduce the career potential for operators without degrees who n:w view the senior operator and shift supervisor positions as a desirable, long term, career objective. 'Ihe rule imposition vi 1 result in the hiring of people with d,-is who generally view shift-work as an interim step in their carner. 'Ihis I

will create a higher turnover rate and a resulting reducticn in the overall experience level.

(B) Training, edtx:P. tion, and experience are not enough for a good operator; it is x=rrtial that operators remain highly motivated.

'Ihis has been accomplished by incentives for ope.rators to progress through the various steps in the operating organization. 'Ibe r u -"1 rule will disrupt this arrwe,L.

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RESP 3EE:

'Ihe M"icn has decided not to adopt a rule requiring a dv s.

We believe that it is desirable for licensees to have in the control recrn individuals with a nix of education, training ard experience in plant operations. 'Iberefore, utilities should continue to develop reactor operators ard senior operators who have a l

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l significant amount of hands-on operational experience. It is desirable to have senior operators on shift who have p W wssed thrux3h the various steps in the operatira organization.

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12.

CI2 E M P: Alternative 2 cuerlocks the fact that the shift supervisor has many non-technical duties to perform during the early pericxi J

following an accident that precitries the shift supervisor frczn getting involved in the technical aspects of the plant resp ~1se.

RESFCtGE: We agree that this is important arri should not be cuerlooked.

If the shift supervisor is the only person on shift with engineering expertise, then the licensee should take this into acx: cunt in the assimit of shift supervisor responsibilities. We expecc that this issue will also be addressed by Institute for !belear Pcwer Operations (INFO) in the effort it has urriezway to review the adequacy of training and education requim. aid for the shift supervisor position. 'Ibe nmi" ion intends to follcu this effort closely and i

will participate as apewpaiate to ensure successful closure of this issue.

13. CI2HENT: 'Ibe pup M requimmt to serve as a reactor operaf.or for one year wenld upset the cxxcen practice of having ranagement p&muel take the senior operator licensing exam. 'Ihis practice is worttrJtile since it brings operatirg expertise into ranagement arri engineering ranagers get to learn about a plant's details.

RESPotsE: We the nmi" ion has hiaM rot to adapt the pr-M rule it will not irpact the practice of allowirq maragw=>L personnel to h senior operators if these parsons meet all NRC requiments for licensirg.

'Ihe NRC Advisory Ctznittee on Reactor Safegaards (ACRS) also considered the proposed require:aent fer degrees and dienmM it at several meetires in 1986 arxi 1987. 'Ihe ACRS again diemeM the issue in 1989 in relation to C_

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the immmnce of a policy statement as W to a rule.

'1he Ams strtrigly supported the wwL of having engineering expertise on each shift.

However, the ACRS did not agree that requiring a degree for senior operators was the best approacti, though it agreed that specific tactinical knowledge should be required. 'Iha ACRS believed that, because of the ocsicern about adverse effects raised by many knowledgeable indivichm1m, a

- p --M rule requiri29 Ap=:= for senior operators should be reocxisidered.

'Ihe ACRS supported the issuance of a policy statement regarding education for senior operstars and shift supervisors.

Many utilities have provided wdanities for members of their %= ting staff to further their education. INPO has developed, in W ation with many nuclear utilities, " Principles for Enhancing Professionalism of' Nuclear Personnel," dated March 1, 1989, which INFO encourage utilities to inplement. 'Ihese principles reflect nuch of the minian's phi 1%

and are =A=4 by the n=i= ion in the policy statanant. In additien, INIO has an effort urderway to review the W=7 of the training and a+vaticri requit=-nu, for shift supervisors whicta the NRC is followirq with interest.

In view of all of these considerations, the n=imion has concluded that it should not s -wi with adoption of the rule.

Iberefore, the r r -i rule is withdrawn.

Dated at Rockville, Maryland this day of 't6ui 1989.

Pbr the Nuclear Regulatory C%: minion.

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m h==1 J. Chilk,(

Secretary of thn N4= ion.

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