ML20195F144

Proposed Rules 10CFR50 & 55, Degree Requirement for Senior Operators at Nuclear Power Plants. Rules Would Require, After 910101,that Applicants for Senior Reactor Operator Licenses Hold Baccalaureate Degree in Engineering/Sciences

ML20195F144
Person / Time
Issue date:	05/27/1986
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:
References
FRN-51FR19561, RULE-PR-50, RULE-PR-55 PR-860527, NUDOCS 8606090391
Download: ML20195F144 (21)

Text

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NUCLEAR REGULATORY COMMISSION 10 CFR Parts 50 and 55 ,

Degree Requirement for Senior Operators s at Nuclear Power Plants ' O YE 93EL.. _ . ./

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AGENCY: Nuclear Regulatory Commission, oV -

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ACTION: Advance notice of proposed rulemaking.

SUMMARY

The Commission is considering an amendment to its regulations to require, after January 1,1991, that applicants for licenses as a Senior Operator of a nuclear power plant hold a baccalaureate degree in engineering or the physical sciences from an accredited institution. Other baccalaureate degrees from an accredited institution may be accepted on a case-by-case basis.

This contemplated rulemaking action is due to a Commission decis'on to enhance the levels of engineering and accident management expertise on shift. The current requirement, for candidates with a baccalaureate degree, of two years of responsible nuclear power plant operating experience, would be amended to require at least one of the two years of operating experience be with a similar commercial nuclear reactor operating at greater than twenty percent power.

DATES: Comment period expires July 29, 1986 ,

B606090391 060527 PDR PR 50 51FR19561 PDR

• The public coment period expires sixty days after publication 0 l l

in the Federal Register.

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9 Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or eefore this date.

ADDRESSES: Send written comments or suggestions on the proposed rulemaking to the Secretary of the Commission, U. S. Nuclear Regulatory Commission, Washington, DC 20555, Attention: Docketing and Service Branch. Copies of the comments received may be ,

examined at the NRC Public Document Room at 1717 H Street NW.,

Washiitgton,DC. .

FOR FURTHER INFORMATION CONTACT: F. H. Rowsome, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission, Washington, DC 20555, Telephone: (301)492-4813.

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SUPPLEMENTARY INFORMATION:

BACKGROUND The issue of academic requirements for reactor operators has long been a concern of the Nuclear Regulatory Commission (NRC).

In July 1979, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations," (NUREG-0578)I made specific recommendatins 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.

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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, P.O. Box 37082, Washington, DC 20013-7082. Copies may also be purchased from the National Technical Information Service, U.S. Department of Commerce, 5285 Port Royal 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.

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O 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 Commissioners and to the Public," (NUREG/CR-1240), and the 1982, " Report of the Peer Advisory Panel and the Nuclear Regulatory Commission on Operator Qualifications," (SECY 82-162).2 The consensus among these 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 Register (50 FR 43621) a final policy statement on engineering expertise on shift. Option 1 of the Policy Statement allows an individual to serve in the combined Senior Operator / Shift Technical Advisor (SO/STA) role holding either a baccalaureate degree in engineering, engineering technology, physical science, or a professional engineer's license. Option 2 permits continuation of the separate STA who rotates with the shift and holds a baccalaureate degree or equivalent and meets the criteria as stated in, " Clarification of TMI Action Plan Requirements,"

(NUREG-0737). The Comission also encouraged the shift supervisor to serve in the dual-role position, and the STA to take an active role in shift activities.

2 SECY-82-162 and Generic Letter 84-16 are available at the NRC Public Document Room at 1717 H Street, NW., Washington, DC.

e The current advanced notice of proposed rulemaking is intended to extend the current level of engineering expertise on shift, as described in the Commission's Policy Statement on Engineering Expertise on Shift (50 FR 43621) and to ensure senior operators have operating experience on a commercial nuclear reactor operating at greater than twenty percent power, e.g.,

" hot" operating experience (Generic Letter 84-16). This Advance Notice of Proposed Rulemaking is the result of a Commission decision to consider an amendment to its regulations (Parts 50 and

55) and to obtain coments on the contemplated action to upgrade -

the levels of operating, engineering, and accident management expertise on shift.

CONCURRENT POLICY STATEMENT The Commission also intends to prepare a concurrent policy statement which will encourage nuclear power plant licensees, i.e., owner-operators, to:

1. Implement personnel policies that emphasize the opportunities for licensed operators to assume positions of increased management responsibility;

2. Develop programs that would enabie currently licensed

e senior operators and reactor operators to obtain college degrees; and

3. Obtain college credit for appropriate nuclear power plant training and work experience through tarangements wi',h the academic sector.

DISCUSSION The purpose of the contemplated rulemaking is to upgrade the -

operating, engineering, and accident management expertise provided on sSift by. combining both engineering expertise and operating I experience in the senior operator function. This is being done to further ensure the protection of the health and safety of the public by having personnel on shift with enhanced qealifications.

The NRC is concerned that operator qualifications 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 general consensus that 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 proposed by these i

conditions. The NRC is considering the need for 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 (October 28, 1985; 50 FR 43621) provided an interim way of achieving more engineering capability on shift. Essentially the NRC is moving from interim requirements which provide engineering capability for accident conditions (the STA), to requiring engineering capability, and nuclear power plant operating -

experience in the same individual (the S0).

The contemplated rulemaking action would require that all applicants for a Senior Operator (50) license after January 1,

1991, must have a baccalaureate degree in engineering, engineering technology or the physical sciences from an accredited university or college. Other baccalaureate degrees from an accredited institution may be accepted on a case-by-case basis. Degree equivalency will no longer be accepted. A baccalaureate degree in another subject area would be acceptable if the utility (licensee) certifies that the applicant has demonstrated high potential for the 50 position.

The contemplated rule would apply only to the 50. Licensed l

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S0s or otherwise fully qualified applicants prior to January 1, 1991, would be exempt from the degree requirement. Licensed reactor operatorc (R0s) would not be required to have a degree.

Current tenior operators and senior operator applications accepted by the NRC prior to January 1, 1991, would be

" grandfathered" with regard to the contemplated rule. It is recognized that "grandfathering" current S0s could result in undh> greed S0s for an extended period of time.

The proposed concurrent policy statement will encourage previously licensed S0s to obtain degrees. It is the intent of the present advance notice of proposed rulemaking to specify that senior operator license applications received after January 1, 1991, would not be accepted by the Commission unless the license application holds a baccalaureate degree from an accredited college or university.

In the past the NRC has accepted " equivalents" to the raccalaureate degree. The equivalents were based upon specialized utility training or other work experience. For the contemplated rule, equivalency would not be acceptable to the NRC in lieu of a degree. Because the Commission is not in a position to evaluate the academic equivalency of utility training, it encourages academic institutions to allow course credit for such equivalency

based upon work experience or specialized training. Thus the proposed concurrent policy statement would encourage efforts to have the training accepted by the colleges for partial credit toward fulfilling the requirement of an accredited degree.

The degree requirement would not apply to licensed reactor operators (R0s). However, the proposed concurrent policy statement would encourage degrees for R0s. The Commission believes a degree requirement on shift, along with the concurrent proposed policy statement will not only enhance public health and -

safety, but will also provide a route for promotion by S0s.

The cut off date of January 1,1991, for application for an 50 license by individuals who are not degreed is chosen for three reasons. First, it will allcw operators now in training

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sufficient time and notice to complete a degree before application. Second, it should not cause undue hardship on operators who are now in the process of preparing and training for the senior operator license. Third, licensees are encouraged by the Policy Statement on Engineering Expertise on Shift (Option 1) to move toward a dual-role S0/STA position. Furthermore, operators who are licensed as S0s prior to January 1, 1991, would be " grandfathered." The proposed rule would only allow one re-examination for 50 applicants who apply for a license just l

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I prior to January 1, 1991. This would prevent essentially unqualified individuals (without degrees) from applying just to

" beat" the deadline.

The contemplated rule also requires one year of " hot" operating experience for a degreed 50 after January 1,1991. This is simply a continuation of current NRC established policy to provide engineering and accident expertise on shift. It is essential that the S0 know and understand plant operations as well as the theoretical, academic, and accident management aspects of -

the position.

The concurrent policy statement is planned as a way of encouraging licensees (utilities) and the nuclear industry to provide incentives and management opportunities for S0s as well as improving the engineering capabilities of the on-shift crew. The S0 with a degree and shift operating experience can become a valuable personnel resource for the utility, one who combines shift operational management experience with the potential for greater management respensibility. The policy statement will encourage licensees to provide that career path.

A regulatory analysis and a backfit assessment will be developed after the comments are received and evaluated, prior to notice of the proposed rulemaking and concurrent policy statement.

INVITATION TO COMMENT Comments regarding the proposed rule ere encouraged.

Comments on the contemplated rule are solicited in regard to:

1. Is January 1,1991, a feasible deadline for requiring senior operators to be degreed and licensed, and if not, what should the deadline be?

2. What the implementation and operation costs of the contemplated rule to utilities would be?

3. Assuming regular shift rotation, could the typical S0 obtain an engineering or technical degree prior to J

January 1, 1991?

4. What type of engineering degree would be appropriate, e.g., nuclear, electrical, mechanical, industrial, etc?

5. What has been the industry's experience in securing college-equivalent credit for nuclear power plant training and/or work experience?

6. Should there be similar experience requirements for one-of-a-kind advanced reactors?

7. What are the combined impacts of requiring two years of responsible nuclear power plant experience, the degree

requirements, and one year " hot" operating requirement  !

l for the position of S07

8. Should the contemplated degree requirement for senior operators be supplemented with or replaced by intensive focused training requirements in severe accidents for nuclear power plant operators?

9. What are tte appropriate criteria for assessine utility's certification that an individual witi .

baccalaureate degree in other than engineering or the physical sciences has " demonstrated high potential" for the 50 position?

10. What are the implications of this contemplated rulemaking on decisions concerning future reactor designs?

11. Should the NRC require specialized training in severe reactor accidents beyond inadequate core cooling and/or require extension of emergency operating procedures into j r

the realm of more severe accidents instead of or in addition to baccalaureate degrees? What are the implications of the work by IDCOR for the qualifications, training, and emergency operating procedures for licensed reactor operators and senici operators? I l

12. What is an appropriate cut-off date for allowing only one re-examination for those 50 applicants without a degree who apply for a license just prior to January 1, 1991?

13. The proposed rule would require an S0 applicant to have a baccalaureate degree in engineering or the physical sciences from an accredited university or college. What should be the appropriate definition (e.g., Department of Education, ABET, etc.) for "an accredited university or college?"

14. What immediate impact will the contemplated rule have on operator morale?

15. [ Chairman Palladino believes] that the attached Table

[1] correctly identifies the present control room staffing as well as that envisioned by the ANPRM by 1991 and after 1991. Should other alternative control room staffing requirements be considered?

16. TMI improvements in control room capabilities and staffing have been undertaken by the industry, i.e.,

STA's have been added, detailed control room design reviews have been undertaken, safety parameter display systems have been installed, emergency operating procedures have been improved, and the combined 50/STA

position has been approved by policy. To what extent have these improvements been effective?

17. Requiring S0's in the control room to have a technical college degree will have an impact on R0's and A0's, especially with regard to a career path for these personnel. To what extent will the SO requirement drive out capable operators, and result in high personnel 4

turnover and instability in the workforce?

18. Presently one degreed engineer is required to be within 10 minutes of the control room or a member of the control room staff, the STA or the combined SR0/STA, respectively. While requiring a second control room operator to have a technical degree may enhance operator organizational status, professionalism and esprit de corps, will a second degreed engineer significantly improve operator performance beyond the STA or combined i

SR0/STA improvements? Will these improvements become apparent in the short term or the long term?

19. What is the industry view about availability of new college graduates who can be trained in nuclear power plant operation or about the feasibility of having present plant operators pursue and obtain a technical college degree?

20. Should there be a numerical limit on the total number of

" grandfathered" S0's at any particular plant?

TABE l SECY-86-70 ONE UNIT III ONE CONTROL ROOM I II III IV V PRE-TMI 11UREG-0737 SECY 84-355 ANPRM NOW TO 1991 1991 Af1D AFTER I SO 2 S0's 2 S0's 2 S0's 2 S0's(4) 2 RO's 2 R0's 2 R0's 2 R0's 2 R0's

- 1 STA(E)(5) 1 STA(E)(5) 1 STA(E)(5) 1 STA(E)(5)

--0R-- --0R--

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- --0R- .

1 S0/STA(D)(3) 1 S0/STA(D)(3) 1 S0(D)(3) 1 SO 1 S0 1 S0(4) 2 R0's 2 R0's 2 R0's '

--OR--

2 S0's(D)(3) 2 R0's TIME 1979 1979 1985 NOW 1991

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III 10 CFR 50.54(M)(2).

As N0ff-DEGREED GRANDFATHERED S0's RETIRE, OR OTHERWisE LEAVE THE INDUSTRY, CONTROL ROOM STAFFING WILL EVOLVE TO 2 S0's(D) AtD 2 RO's.

(3) D = BACCALAUREATE DEGREE IN ENGINEERING OR RELATED SCIENCE (NO EQUIVALENCY),

(4) GRANDFATHERED.

(5) E = B.S. OR EQUIVALENCY.

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ADDITIONAL COMMENTS OF COMMISSIONER ROBERTS The additional comments of Commissioner Thomas M. Roberts on this ANPRM follow:

"Although I continue to believe that well-trained and qualified operators are important in assuring safe and reliable operation of nuclear plants, I am concerned that this rulemaking will negatively affect the level of experience and expertise of senior operators (the potential for negative implications was raised in the 1982 report of the Commission's Peer Advisory Panel on Operator Qualifications). I will be specifically interested in public comments on: 1) the extent that a formal degree requirement for senior operators is related to job performance, 2) whether requiring a baccalaureate degree for senior operators will enhance public health and safety, and 3) what negative safety implications may result from tiis proposal."

ADDITIONAL VIEWS OF CONMISSIONER ASSELSTINE The additional views of James K. Asselstine on this ANPRM also follow:

"I have approved this advance notice of proposed rulemaking for the purpose of obtaining public and industry comment on the various options for unarading the levels of operating, engineering and accident management expertise on shift at operating nuclear powerplants. I agree entirely with the conclusion expressed in this advance notice that oprator qualifications to deal with accidents beyond the design basis for the plants warrant improvement. Qualified operators can play a potentially significant role in mitigating the consequences of severe accidents. However, in order to carry out this role, operators must have sufficient knowledge of engineering and reactor theory to understand plant behavior under severe accident conditions.

"Although considerable progress has been made in recent years in improving operator training programs and plant emergency ,

operating procedures, these training programs and procedures generally do not consider accident conditions beyond inadequate core cooling. Moreover, despite the improvements in reactor operator training, recent experience with NRC-administered reactor operator requalification examinations indicates that some operators are having difficulty in retaining the level of knowledge of engineering and reactor theory needed to deal effectively with design basis events. These indications of weakness in operator knowledge of engineering and reactor theory, the absence of emergency procedures to deal with beyond design basis events, and the reliance on operator actions as one means of mitigating the effects of severe accidents all point to the need for more extensive knowledge of engineering and reactor theory on the part of plant operators, and particularly those operators holding senior reactor operator (SRO) licenses and serving in the position of shift supervisor.

"Although I believe that additional engineering knowledge is needed by licensed senior reactor operators, I am not satisfied either with the approach recomended by the NRC staff or with the position adopted by the Comission in this advance notice of proposed rulemaking. The NRC staff proposed that after January 1, 1991, all applicants for a senior reactor operator license hold a baccalaureate degree in engineering or a related science from an accredited institution. In addition, the staff proposed a requirement that after January 1,1991, at least one SR0 per shift at a nuclear powerplant (the SR0 serving as the shift manager) -

meet the degree requirement. For purposes of this advance notice, the Comission accepted the staff's first recomendation but not the second. The practical effect of the Comission's position is to exempt forever from the degree requirement any person holding an SR0 license on January 1, 1991.

"While the staff and the Comission proposals would bring about some improvement in the engineering knowledge of some licensed reactor operators, both of the proposals suffer from a number of disadvantages. First, it is not clear that requiring a baccalaureate degree in engineering provides the best means for assuring that senior reactor operators have the knowledge needed to carry out their responsibilities. Some courses required for an engineering degree may well be irrelevant to an understanding of reactor behavior during accident conditions. At the same time, some engineering knowledge and reactor theory needed to understand and cope with beyond design basis accident situations will not be  !

l 1 covered by the courses needed to obtain a baccalaureate I

4 engineering degree. Second, imposing a degree requirement for SR0's is likely to result in the loss of some experienced and skilled reactor operators. After 1991, experienced reactor operators (R0's) will not be permitted to become SR0's without obtaining a degree, and SR0's without a degree will not be able to advance to the position of shift manager or supervisor. Third, by focusiig on degree requirements for SR0's, these proposals will require literally yr . s before engineering knowledge on shift is substantially upgraded. In the case of the staff proposal, some SR0's will have upgraded engineering expertise (applicants for SR0 licenses after January 1,1991, and pre-1991 SR0's serving as shift managers) while r". ; need not upgrade their engineering knowledge at all (pre . 11 SR0's not serving as the shift manager). In the case of the Comm.ssion proposal, large numbers of licensed SR0's could be exempt from any upgrading of their engineering knowledge because the degree requirement would only apply to new SR0 applicants after January 1, 1991. To avoid the requirement, a utility could simply obtain SR0 licenses for all its reactor operators prior to 1991.

"In view of the disadvantages of the NRC staff and Comission proposals, I would appreciate comments on an alternative method for upgrading the engineering knowledge and understanding of reactor theory needed by licensed senior reactor operators. This method would include the following steps:

"1. Establish a working group, with NRC, academic and industry participants, with the responsibility to define the engineering knowledge and understanding of reactor theory needed for reactor operators to deal effectively with design basis events and severe accidents.

"2. Establish a training curriculum for each nuclear utility operator training program that will provide all senior reactor operators with the knowledge and understanding defined by step 1. This curriculum would establish milestones in individual subject areas to be achieved by new SR0 candidates and previously licensed SR0's and would lead to satisfactory completion of the curriculum n.ot later than January 1,1991. These curriculums would be reviewed and accredited by NRC or by an appropriate industry or third party organization.

"3. Develop and administer new NRC senior reactor operator licensing examinations and NRC and licensee SR0 requalification examinations that will test achievement by operators at each of the milestones defined under Step 2, leading to a comprehensive examination not later than 1991 for all new and previously-licensed l senior reactor operators. A passing grade on this I

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t examination would be required to obtain or retain an SR0 license after January 1,1991."

i LIST OF SUBJECTS IN 10 CFR PARTS 50 AND 55 Part 50: Antitrust, Classified information, Fire protection, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting and recordkeeping requirements.

Part 55: Manpower tra*ning programs, Nuclear power plants ,

and reactors, Penalty, Reporting and recordkeeping requirements.

AUTHORITY CITATION The authority for this advanced notice of proposed rulemaking is: Sec. 161, Pub. L.83-703, 68 Stat. 948, as amended (42 U.S.C. 2201).

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Dated at Washington, DC, this day of , 1986.

For the Nuclear Regulatory Commission.

m. s Ch i [C iSamuel J. Chilkj

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Secretary of th( Comission.

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