ML20137S427

Staff Requirements Memo Re 850912 Affirmation/Discussion & Vote in Washington,Dc Concerning SECY-85-286,SECY-85-287 & SECY-85-150

ML20137S427
Person / Time
Issue date:	09/25/1985
From:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
To:	Dircks W, Plaine H NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO), NRC OFFICE OF THE GENERAL COUNSEL (OGC)
References
REF-10CFR9.7 ALAB-809, M850912B, NUDOCS 8509300286
Download: ML20137S427 (20)

Text

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-9q IN RESPONSE, PLEASE e seau REFER TO: M850912B

1. ' UNITED STATES

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g NUCLEAR REGULATORY COMMISSION W ASHIN GTON. D.C. 20555 M

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% *. . . . ,o September 25, 1985 OFFICE OF THE SECRETARY MEMORANDUM FOR: William J. Dircks, Executive Director for Operations Herzel H.E. Plaine, General nsel FROM: Samuel J. Chilk, Secretary

SUBJECT:

STAFF REQUIREMENTS - AFFIqMA ON/ DISCUSSION AND VOTE, 3:30 P.M., THURSDA , SEPTEMBER 12, 1985, COMMISSIONERS' CONFERENCE ROOM, D.C.

OFFICE (OPEN TO PUBLIC ATTENDANCE)

I. SECY-85-286 - " Exceptions" to Commission Order Establishing Information Hearing on Babcock and Wilcox Parks Township Facility The Commission, by a 5-0 vote, approved an order which denies a July 30, 1985 request that the Commission amend its July 24, 1985 Order that had referred a hearing request on B&W's Parks Township Facility to the ASLBP for consideration in an informal hearing, and asked for a formal hearing instead.

(Subsequently, on September 19, 1985 the Secretary signed the orde r. )

II. SECY-85-287 - Review of ALAB-809 The Commission, by a 5-0 vote, approved an order that_ vacates ALAB-809 and the underlying Licensing Board decision as moot.

because the Licensing Board has subsequently completed its consideration of the Graterford emergency planning contentions.

(Subsequently, on September 19, 1985 the Secretary signed the order.) ,

III. SECY-85-150 - Final Policy Statement on Engineering Expertise on Shift The Commission, by a vote of 4-1 (with Commissioner Roberts disagreeing), approved Version A of the Final Policy Statement on Engineering Expertise on Shift subject to the following:

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1. Item b(1) (b) of Option 1 should be amended to read:

"A Professiona,1 Engineer's (PE) license _obtained by successful completion of the PE examination." (Chairman Palladino and Commissioners Bernthal and Asselstine agree.)

2. Item b(1) (c) of Option 1 should be deleted. (Chairmen Palladino and Commissioners Bernthal and Zech agree.)

3. Item b(1) (f) of Option 1 should be deleted. (Chairman Palladino and Commissioners Bernthal and Zech agree.)

4. Item b(2) of Option 1 should be deleted. (Chairman Palladino and Commissioners Asselstine, Bernthal and Zech agree.)

5. The reference to 10 CFR 50.54 (m) (2) (1) 'should be corrected I to 50. 54 (m) (1) (i) .

Commissioner Roberts provided additional comments (attached) to be included in the Federal Register Notice.

The Commission understands that the staff has given conditional approved to several licensee programs to combine the SRO/STA positions based upon the policy statement as submitted to the Commission in.SECY-85-150. If the approved policy statement will cause significant difficulties for these licensees, you should so advise the Commission and indicate any actions'to be taken to alleviate the situation.

A marked up copy of the modified policy statement is attached.

The supplementary information that accompanies the pol' icy statement should be modified-to be consistent with the agreed upon policy statement. The revised Federal Register Notice should be returned for signature and publication in the Federal Register. A copy of the policy statement should be sent to all affected licensees. You should also advise NUMARC of the Commission's decision on the policy statement. l (EDO) (SECY Suspense: 10/18/85)

Attachments:

As stated cc: Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech Commission Staff Offices PDR - Advance DCS - 016 Phillips

COMMISSIONER ROBERTS ADDITIONAL COMMENTS ON SECY-85-15 I am in agreement with the majority's intent that operators should be well trained and qualified to perform their duties. However, this policy, by requiring that an individual have both an SR0 license and a f BS degree in engineering or related science or have passed the P.E.

examination prior to assuming the combined STA/SRO duties, places inordinate confidence in " academic" credentials. Strikingly absent from the policy are the specific skills or abilities needed to perform those duties. Thus, .the Commission has postponed the question of what those skills should be and how they should or could be achieved and. demon-strated. Thisleavesmenochoicebuttovoteagainstthemodifications proposed to the Policy Statement on Engineering Expertise on Shift. By eliminating alternatives to a Bachelor's Degree for individuals who would otherwise occupy the dual role, the Commission would be. ignoring the ccmpelling arguments made in public coments and the staff's pro-posal for flexibility. We would be imposing our solution without addressing the benefits that will be eliminated by not allowing flexi-bility. This leaves the utilities with little incentive to change 'from the current position, which is allowed by option 2. Since a majority of the Commission has already determined that improvement from the current-program would be desirable, the Commission should provide sorre mechanism to move toward improvement. The proposed statement, as modified, does not provide.that mechanism, and we provide no jusitfication for over-riding the staff's evaluation of the benefits that the flexibility would .l bring.

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HUCLEAR REGULATORY CCi*111SSION FINAL COVlCSSION POLICY STATEMENT ON ENGINEER!f.G EXPERTISE CN SHIFT AGENCY: _ Nuclear Regulatory Comission.

ACTION: Final Comissien Policy Statement on Engineering Expertise on Shift.

SUMMARY

This Policy Statement presents the policy of the Nuclear Regulatory Ccamission (NRC) with respect to ensuring that adequate engineering and accident assessment expertise is pcssessed by the operating staff at a nuclear power plant. This Policy Statement offers licensees two cptions for providing engineering expertise on shift and meeting licensed cperator staffing requirements.

Option 1 provides for elimination of the separate Shift Technical Adviser (STA) positien by alicwing licensees to combine one of the required Senior Reacter Operatcr (SRO) positions with the STA position into a dual-role (SR0/STA) position. Under Option 2, a licensee may continue with an NRC-approved STA prcgram (i.e., a separate STA position), with certain modifications, while meeting licensed cperator staffing recuirements.

EFFECTIVE DATE:*

FOR FURTHER INFORMATION CONTACT: Clare Goodman, Office of Nuclear Reacter Regulation, U. S. Nuclear Regulatory Commission, Washington, DC 20555, Telephone: 301/492-4894.

• Insert date of publicatien in the Federal Register.

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SUPPLEMENTARY INFORMA' TION:

Backcround Following the accident at Three Mile Island in March 1979, a number of studies were conducted to determine why the accident occurred, what factors might have contributed to its severity, and what the industry and the NRC cculd do to prevent the recurrence of the same or a similar accident. These studies concluded, among other things, that a number of actions should be taken to improve the ability of shift operating perscnnel to recognize, diagnose, and effectively deal with plant transients or other abnormal conditions.

To address these reccmmended improvements, the NRC initiated both short-term and long-term efforts. The short-term effort required that as of January 1, 1980, each nuclear power plant have on duty a Shift Technical Advisor (STA) whose function was to provide engineering and accident assessment advice to the Shift Supervisor in the event of abnormal or accident conditiens. The STA was required to have a bachelor's degree in engineering or the equivalent and specific training in plant response to transients and accidents. The STA recuirement was identified to licensees via NUREG-0578 (July 1979)I and NUREG-0737 (November 1980) and was later mandated by plant-sp'ecific Confirmatory Orders.

Concurrently, the NRC and industry embartied on a longer-term effort aimed at upgrading staffing levels and the training and qualifications of the operating staffs, improving the man-machine interface, and increating capabilities for responding to emergencies. At the time the STA requirement was imposed, it was intended tha+. use of the dedicated'STA would be an interim measure only until these longer-term goals were achieved.

! IReferenced materials are available at the NRC Occument Recm at 1717 H Street, NW, Washington, DC 20555.

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These long-tarm initi~atives cellectively result in an improvement in the capabilities and qualifications of the shift crew and their ability to diagnose and respond to accidents. These initiatives include shift staffing increases, training and qualification progran improvements, hardware mcdifications, emphasis on human factors considerations, procedural upgrades, and development of extensive emergency response organizations to augment en-shift capabilities during abnormal conditions. They either have been or

.are in the process of being implemented and include the following:

Every licensee of a nuclear pcwer plant has been required to develop and implement extensive emergency response organizations for the express purpose of assisting in the diagnosis and mitigation of accidents. These crganizaticns are required to be fully mobilized within ene hour and provide substantial " engineering expertise" assistance to the shift crew to assist in accident diagnosis and mitigation / protective action strategy.

All cperating nuclear power plants are currently required to have emergency plans in place and to conduct exercises on a regular basis.

Implementaticn of Supplement I to NUREG-0737 recuires all nuclear plant licensees to conduct a Control Room Design Review (CRCR) of.their facility and implement improvements identified in the human factors review.

Implementation of CRDR findings will result in an improvement in the operator's ability to understand and respond to abnormal situations. This will minimize confusion during an accident and increase the likelibcod_of correct operator acticns. All licensees have been required to submit plans and schedules for conducting the CRDR.

In cocperation with the nuclear steam supply system vendor cwners grcups, the industry has developed sy.ptem-based emergency operating procedures.

The generic development work for these procedures has been completed.

These procedures are desigred to make it easier for the operators to recognize, diagnose, and effectively deal with plant transients and cther abnormal conditions. They are designec to aid the cperator in roaintaining critical safety functions, i.e., control reactivity, remove core heat, ENCLOSURE A

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provide an ultimate heat sink, and contain radioactivity, thereby minimizing the probability of a serious incident. These new procedures are of significant benefit to the operator in accident diagnosis and overall response capabilities. All licensees have either implemented or are in the process of converting to these new procedures.

• Implementation of Supplement 1 to NUREG-0737 requires installation of a safety parameter display system (SPDS). The SPDS is a system for rapid and concise display of vital plant status indications in the event of transients or accidents. The availability of this information via the SPDS will assist the operator in performing mitigating or stabilizing actions by providing essential information in a clear and timely manner.

Upgrading and installation of additional instrumentation for post-accident monitoring, as delineated in Regulatory Guide 1.97 and Supplement I to NUREG-0737, will assist the operator in monitoring plant status and the course of an accident. The addition of this type of instrumentation, in conjunction with benefits of the SPDS display, will' enhance event diagnosis anc lessen the degree of reliance on the cperator's analytical ability. All licensees have provided plans and schedules for Regulatcry Guide 1.97 upgrades.

Effective January 1, 1984, the minimum shift crew for a single-unit plant was increased to two licensed senior reactor operators and two licensed reactor operators on each shift; similar increases were required for multi-unit plants. This has resulted in two positive effects. First, an additional senior licensed operator has been added to each shift, thereby providing one more perspective to focus attention on accident assessment and overall emergency direction. Second, one of these senior licensed operatcrs is now required to be in the control room at all times. As a result, there is assurance that additional experienced senior level expertise will be immediately available at the onset of an accident.

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• The industry, thro' ugh the Institute of Nuclear Power Operations (INFO),

has established a comprehensive, nationwide accreditation program. This program provides for upgrading of the training programs for all licensed operators as well as the training for other key positions that can directly affect plant operations. An independent Accrediting Board reviews the evaluations of each utility's training programs and either grants accreditation or defers accreditation until the prograns meet high standards. Licensees are expected to have these training programs ready for accreditation by the end of 1986. These programs will ensure that operating personnel possess qualifications commensurate with the requirements of their jobs. This issue is being addressed by the Commission via a separate Policy Statement

• Extensive additions have been made to utility training staffs. The number of full-time personnel per plant dedicated to training increased industry-wide by approximately 375% between 1979 and 1984. This exemplifies the increased recognition of the importance of training and recualification to the effectiveness a'nd capabilities of the shift crew.

As specified in h0 REG-0737, Item II.B.4, all licensed operators receive training specifically cirected at reccgnizing and mitigating core damage.

This training serves to familiarize the operator with pcssible causes and symptoms of a damaged core and expected post-accident plant' conditions and corrective actions. As a result, the cperator is better prepared to recognize and respond to degraded plant conditions. All licensed operators are requireo to successfully complete this training.

• Simulators are now extensively used throughout the industry; 10 were in use in 1979; at the end of 1984, 40 were in use; and a total of 69.

simulators are now in operation or are planned. Additionally, NRC criteria for operator licensing now r W iire simulator training. The use of simulators provides core comprehensive training for the operator and allows him to experience transients ano accidents in a training ENCLOSURE A

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environment. The increased use of simulators will improve the capabilities of the shift crew to respond to emergencies.

The industry, through INPO, has developed and implemented a comprehensive system for gathering and analyzing information on events that occur in the industry and providing feedback to operating personnel. This allows other licensees to revise their facility design or operation, as necessary, based on the lessons learned in the industry. The NRC endorsed INP0's "SEE-IN" program in Generic Letter 82-04 as acceptable for meeting the information-gathering elements of NUREG-0737, Item I.C.5.

Collectively, these initiatives result in a significant enhancement of the capabilities of'the shift crew to diagnose and mitigate accidents.

Draft Policy Statement .

On July 25, 1983, the Commission published in the Federal Register (48 FR 33781) a Draft Policy Statement on Engineering Expertise on Shift to reassert the Commission's belief that adecuate engineering and accident assessment expertise must be available to the operating crew at all nuclear pcwer plants.

The Draft Policy Statement on Engineering Expertise on Shift offered licensees of nuclear power plants and applicants for cperating licenses-two options for meeting the staffing requirements of 10 CFR 50.54(m)(2) and the requirement in NUREG-0737, Item 1.A.1.1 for a Shift Technical Advisor (STA).

Option 2 gave them the opportunity to combine the licensed Senior Operators' (SRO) and Shift Technical Advisors' (STA) functions. Licensees that did not want to combine the SR0 and STA functions could continue with their approved STA program in accordance with the description in NUREG-0737, " Clarification of TMI Action Plan Pequirements."

Interested persons, applicants, and licensees were invited to submit written comments to the Secretary of the Commission. Following consideration of the ENCLOSURE A

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comments, the Ccmmission amended the Draft Policy Statement, as ciscussed in the fellowing sections.

Comments en the Draft Policy Statement A total of 34 responses were received and evaluated. The public comments related primarily to the combined SR0/STA position. The following discussicn highlights the major points raised in the comments and the resolution of those ccmments. .A detailed analysis of all public comments and their resolution was also prepared. (Copies of those letters and the detailed analysis of all the public comments are available for public inspection and copying for a fee at the NRC Public Document Room at 1717 H Street N.W.,

Washing.cn, DC 20555.)

Of the 24 letters received, 18 included support for the flexibility provided by the Policy Statement. The major points made in the public ccaments were as folicws:

1. Suppcrt for the Policy Statement;

2. Oppesition to ccmbining the functions of the SRO and the STA;

3. Oppcsition to a bachelor's degree requirement for the SR0/STA position; 4 Recommendation that equivalency to a bachelor's degree be further defined;

5. Ccncern that a bachelor's degree requirement for the SR0/STA position would result ir. a higher turncver rate and potentially blocked career paths for operatcrs; and

6. Reference to a proposed bachelor's degree requirement for the Shift Supervisor, believed to be currently under NRC consideration.

A general description of the major public comments and responses to these are as follcws:

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1. Support for the Policy Statement -

Eighteen ccmmentors favored the option offered in the Draft Policy Statement of combining the SRO and STA functions into one dual-role position. They endorsed the flexibility provided by the Policy Statement. They supported the. view that it is beneficial to combine engineering expertise with operating experience.

2. ' Opposition to the Dual-Role SR0/STA Position -

Four individual commenters stated that there is a possibility that the persen in the dual-role position would function as an additional operator in the event of an abnormal occurrence instead of being available te provide the engineering anc accident assessment expertise necessary in these circumstances. In respcnse, the Cocmjssicn notes it is the intent of the Policy Statement that the person in the dual-rcle position have specific training in accident assessment and provide that expertise during an abnormal eccurrence. The staffing levels 'equired r by 10 CFR 50.54(m)(2), which became effective January 1, 1984, increased the number of cperators and Senior Operators on shift after the initial STA position was required. This increase in shift personnel wculd allow the SR0/STA to provide both accident assessment expertise and to analyze and respond to off-normal events when needed. Experience has shown'that an STA, who is also an SRO, is better accepted by the shift crew.

Therefore, the assessment and direction by an SR0/STA in an off-normal event might be better accepted by the crew than. assessment and advice by I

a separate STA.

3. Oppcsition to a Bachelor's Degree for the SRO/STA Fcsition -

Several commentors felt that the person who filled the SR0/STA positien shculd not be required to have a bachelor's degree. The Commission notes that since NUREG-0737, item I.A.l.1, specified that the STA shculd have a 1

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bachelor's degree or the equivalent in a scientific or engineering discipline, the degree requirement is not new. This continues to be the educational requirement for a dedicated STA. Hcwever, the educational requirements for the dual-role (SR0/STA) position have been changed to allow the individual to meet ene of several cducational alternatives or have four years of experience as a licensed operator at an operating nuclear power plant and have successfully ccmpleteo INFO-accredited STA and SRO training programs.

4 Recomendation that Equivalency to a Bachelcr's Degree Be Further Defined -

flany commentors stated that the equivalency options were too restrictive or required clarification. In response, .the Comission notes that a bachelor's degree in engineering is no longer a basic requirement but is one of several educational alternatives. The term " equivalent" has been deleted.

Changes relatea to educaticnal alternatives are summarized below:

' Most states recuire a bachelor's degree of the incividual who has the designation of PE or EIT. Other states do not presently require a degree or have not in the past; however, they have a provision which allows registration of these individuals if they meet the stringent requirements of a state board of registration through a combination of experience, examination, long-established practice and eminence.

Although the requirements vary from state to state, they all require the applicants to show evidence that their. engineering work experience is at a grade and of a type satisfactory tc the state board. Many states recuire that a portion of the applicant's engineering work experience be at a level of direct centrcl and supervision of engineering work. The majority of states also recuire that the individual successfully pass a fundamentals of engineering examination er the principles and practice of engineering exam.ination, or both. In ENCLCSURE A

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light of these rigorous state requirements, the PE ar.d EIT options remain acceptable alternatives.

• Other bachelor's degrees determined to be acceptable alternatives are a bachelor's degree in engineering technology from an accredited institution or a bachelor's degree in a physical science from an accredited institution. These degree programs are acceptable provided that they include course work in the physical, mathematical, and/or engineering sciences. These requirements are intended to ensure that the individual has substantial knowledge and understanding of the physical and mathematical sciences and the principles of engineering.

• Another acceptable alternative requires successful completien of the technical portion of a bachelor,'s degree in engineering or engineering technology frcm an accredited institution. The technical portion of an engineering or engineering technology degree program is acceptable provided that it is ccmprised of courses in the physical, mathematical and engineering sciences. The Ccccission will fine this alternative acceptable if it receives a ccmmunication trcm the credit-grar. ting university that all the technical courses requirec in its engineering or engineering technology degree progran have been successfully ccmpleted. Since names of courses anc amcunt of credit vary from university to university, the Commission will not specify the technical courses required for this alternative. Hewever, individuals who have cenpleted 80 semester hours in the physical, mathematical and engineering sciences will be considered acceptable and will not require a communication from the university. The 8C semester hours requirement is based on the ABET accreditation criteria for the basic requirements of a bachelor's degree in_ engineering.

5. Concern that a Bachelor's Degree Requirement Woulc Result in a Higher Turncver Rate and a Potentially Blocked Career Path for Shift Employees -

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Several ccmmentors expressed concern that degreed indivicuals would leave for other positions in the plant, contributing to a high turnover rate on

! shift. Another concern of cementors was that career paths to the senior operating positions would be blocked for those individuals without degrees. In respense, the Ccmission notes that since the bachelor's degree in enginee. ring is no longer a basic requirement for the SRO/STA, but is cnly one of several educational alternatives, this should not affect career paths fcr individuals without a degree nor shculd it contribute to a high turnover rate.

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6. Reference to a Proposed Bachelor's Degree Requirement for the Shift Supervisor -

A few commentors on the Federal Register notice took the opportunity to comment on whether a bachelor's degree shculd be required for specific positicns in the cperating staff of nuclear pcwer plants, and in particular, for the Shift Supervisors' position.

The Final Policy Statement on Engineering Expertise en Shift does not address the issue of requiring a degree for the Shift Superviscr. Early in 1984, the staff considered a " proposed Rulemaking Concerning Requirements for Senior Managers" in SECY-84-lC6. This prepcsed rulemaking would have required that an additional degreed, SRO-licensed individual be assigned to each shift of a nuclear power plant who wculd be responsible for managerial direction of all plant functions including chemistry, health physics, maintenance, operations, security, and.

technical services. Following several meetings with the staff and industry representatives, the Comission concluded that this preposed rulemaking was not warranted, and it was disapproved. One of the primary bases for the proposed senior manager rule was the need to provide engineering expertise to the shift crew, which is also the primary cbjective cf this Policy Statement.

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Develocment of Final -Policy Statement As a result of the analysis of public comments received, the Commission clarified and expanded the educational alternatives of the dual-role (SR0/STA) position. The revisions to the Draft Policy Statement resulted in SECY-84-355, a draft Final Policy Statement on Engineering Expertise on

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Shift.

The main difference between the Draft Policy Statement and SECY-84-355 concerns the educational cualifications for the. dual-role position. The Draft Policy Statement required, of the person filling the dual-role l

position, a baccalaureate degree in engineering or related sciences or one of l three equivalents'to the degree. SECY-84-355 required a bachelor's degree in engineering from an accredited institution or one of five acceptable alternatives to the engineering degree.

The staff met with the Commissioners on November 5,1984, to discuss SECY-84-355. As a result of that meeting, the Commissioners directed the staff to cocrdinate the Policy Statement en Engineering Expertise on Shift with the Nuclear Utilities Management and Human Resources Committee (NUMARC).

This Final Policy Statement is the result of the Commissioners' direction, staff analysis, resolution to public comments, and staff coordination with NUMARC.

The major. change from the Draft Policy Statement to this Final Policy Statement is the cualification requirements for the dual-role position (SRO/STA). The Draft Policy Statement required a baccalaureate degree or equivalent in engineering or related sciences. The Final Policy Statement requires that one of several educational alternatives be met or that a licensed operator have four years experience as a licensed operator at an i

operating nuclear power plant and have successfully completed INPO-accredited

, STA and SRO training programs. Hence, the Final Policy Statement accepts college-level training instead of formal college education for the dual-role position.

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Finally, although the final Policy Statement incluces an cptien which al.lcws for the continued use of the STA position, as did the Draft Policy Statement, the fermer encourages licensees to work towards having the STA assume an active role in shift activities.

While it is the Commission's preference that licensees move toward the dual-role (SR0/STA) positien, continuation of an approved STA program remains an acceptable option. The Comission acknowledges that some licensees may prefer the dedicated STA position for a number of reasons. The Commissien also recognizes the advantages of integrating the qualifications and training cf the STA inte the licensed operating staff. Thus, this Policy Statement is structured to allcw cifferent means for ensuring that the plant operating staff has adecuate engineering and accident assessment expertise. l Policy Statement .

The Ccrmissicn continues to stress the impcrtance of providing engineering ano accident assessment expertise on shift. The term " accident assessment" is cefined as immediate actions needed tc be taken while an event is in progress. This Pelicy Statement does not require any changes in the formal education and training of operators and senior operaters not expected to fulfill the dual-role SR0/STA position.

The intent of this policy guidance may be satisfied by either of the options described below. The Commission prefers a combined SR0/STA position (Option 1). In addition, in the long term, the Commissicn would prefer that the STA be combined with the Shift Supervisor position.

Either Cptien 1 or Option 2 may be used on each shift. A utility may use Option 1 on scme shifts and Option 2 on other shifts, or may use the same cption en every shift. If Option .1 is used for a shift, then the separate STA position may be eliminatec fcr that shift.

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Option 1: Combined SR0/STA Position s This cption is satisfied by assigning an individual with /

the fcilowing qualifications to each operating shift crew as one of.the SR0s (preferably theShiftSupervisor)requiredby10CFR50.54(m)(2).(1j:

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a. Licensed as a senior operator on the nuclear pcwer unit (s) to which assigned, and c%

b. Completien of e+44wr of the folicwing training and educational requirements .((H_crM ):

(1) Feets the STA criteria of f4UREG-0737, Item I.A.l.1, and cne of the following educaticr.a1 alternatives:

(a) Bachelcr's degree in engineering frem an accredited instituticn; (b) Professional Cc-s-s uja . L n.: ./

Engineer's

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P g'. A f r. .. ~ s t *- r . a (c) Suceetsftt4-comp % tion of-th&Engineee-in-Training-(EIT) curintti:n;-

(d) Bachelor's degree in engineering technolcgy (BET) frcm an accreditec institution, includir.g course work in the physical, mathematical, and/or engineering sciences; (e) Bachelor's degree in a physical science frem an accredited institution, including course work in the physical, mathematical, and/or engineering sciences; or

?f) Eccesr#pr-cu.;pietion vi the technic:1 pert 4enW bacheler's degree n :nginccrir.g cr engineering technology i

're" an accredited irstittiivn. The technice4-portion-should be comprised cf ccacses in the physical, mtitecatical, ard c r g P.;. . :3 ::i: :::;

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2) Four yea of experience as license ope at r at an erating nuclear pc plant and s ce ful empletic. of INP0 accredi d STA nd SR0 rainin regra . The ograms d scri di the IN 0 G del nes "Nuclea P er Plant hit Te nical Adv or:

Reco .endations for iticn escriptic Qualifi ation Educati'n, ar Tr ining," a either " 'R Contro Rcc per tor, S io Co rol Room Ope tor, and Shift pe isor ualificat " ar accepta to satisfy the equirements for STA SR0 tra ing. '

is not the idance to r uire wh complete ytentof his olicy at pers nn Si or 0 trainin, ograms pri r to r accre itation INP0 be requ d to repeat h traini subse en to ';P0 accr ita ion, ex pt f partippation n c ntinuin train 1 . The it ms added to e prcgrams Va result of\ ccreditytion wo , d be ir.c[uded in the I

next training /cf le.

Opticn 2: Continued Use of STA Pcsition This cption is satisfied by placing on each shift a dedicated Shift

• Technical Acviser (STA) who meets the STA criteria of NUREG-0737, Item I.A.l.l. The STA should assume an active role in shift activities. For example, the STA shculd review plant legs, participate in shift turnover activities, and maintain an awareness of plant configuration and status.

The Ccmmission reccgnizes that several years may be required to meet this policy guidance. For the interim period, continuation of an STA program that meets the guidar.ce of NUREG-0737, Item I.A.1.1 is acceptable. Licensee proposals different than the two cotions described abcve will be considered by the staff on a case-by-case basis.

To eliminate the STA position, a licensee of an operating reactor shculd apply for a mcdification tc its license and an applicant for an cperating license should modify its Final Safety Analysis Report to reflect elimination of the STA position and a ccr.vnitment to provide a required SR0 on shif t with the qualifications described in Option 1 above.

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NRC will accept a utility's modificaticns if it finds that the prepcsal meets the intent of this Policy Statement. On a case-by-case basis, utilities with multi-unit sites with dual-licensed SR0s will ensure that an adequate number of licensed staff are available and that engineering expertise can be provided when n. ceded. It is the intent of this Policy Statement to ensure that adequate engineering and accident assessment expertise is possessed by the plant operating staff.

Dated at Washington, DC, en this day of , 1985.

For the Nuclear Regulatory Commission, Samuel J. Chilk,,

Secretary of the Commissicn.

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