50 FR 43621
Engineering Expertise on Shift
text
Published 10/28/85
Effective 10/28/85
Commission Policy Statement on
Engineering Expertise on Shift
AGENCY: Nuclear Regulatory
Commission.
ACTION: Policy Statement on Engineering
Expertise on Shift.
SUMMARY:
This Policy Statement
presents the policy of the Nuclear
Regulatory Commission (NRC) with
respect to ensuring that adequate
engineering and accident assessment
expertise is possessed by the operating
staff at a nuclear power plant. This
Policy Statement offers licensees two
options for providing engineering
expertise on shift and meeting licensed
operator staffing requirements.
Option 1 provides for elimination of
the separate Shift Technical Advisor
(STA) position by allowing licensees to
combine one of the required Senior
Reactor Operator (SRO) positions with
the STA position into a dual-role (SRO/
STA) position. Option 2 provides that a
licensee may continue to uae an NRC·
approved STA program. with certain
modifications. while meeting licensed
operator staffing requirements.
IPPICTIW DATI: October Z8. 1985.
f'Olt flUllTHlll INl'OllllATION CONTACT:
Clare Goodman. Office of Nuclear
Reactor Regulation. U.S. Nuclear
Regulatory Commi11ion. Washington.
DC 20555. Telephone: 301/492-Ml!H.
SUPPLIMINTARY UWORllATION:
Background
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
could do to prevent the recutrence of the
same or a similar accident. 1hese
studies concluded, among other things.
that a number of actions should be
taken to improve the ability of shift
operating personnel to recognize.
diagnose, and effectively deal with plant
transients or other abnormal conditions.
To addre11 these recommended
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
a11e11ment advice to the Shift
Supervisor in the event of abnormal or
accident conditions. The STA was
required to have a bachelor's degree in
engineering or the eguivalent and
specific training in plant response to
transients and accidents. The STA
requirement was identified to licensees
via NUREG-0578 (July 1979) 1 and
NUREG--0737 (November 1980) and was
later mandated by plant-,pecific
Confirmatory Orders.
Concurrently. the NRC and industry
embarked on a longer-term effort aimed
at upgrading 1taffang levels and the
training and qualifications of the
operating staffs. improving the manmaehine
interface, and increasing
capabilitiea for responding to
emergencies. At the time the STA
requirement was imposed. it was
' NUREG-lerift reportl end other docwnentt
referenced In this notice are evaileble for l111peclion
or copyi111 fore fee In the NRC Public Documenl
ROOlll.1717 H Sll'fft NW. Walhl111ton, DC. The
Nport1 mey be pun:heaecl from the U.S.
Covei'ftment Prlntlna Offlc:e (GPOJ by calli111 mzt
21!--zolO or by wrtt11111he CPO. P.O. lox 3701Z.
Wa1hi111ton. DC 211111:S-70IZ. They IMY elao be
purchaMd from the National Technical Information
Service. U.S. Department of Commerce. 5285 Port
Royal Road. Sprinsfield. V ,\ Z2111.
intended that use of the dedicated STA
would be an interim measure only until
these longer-term goals were achieved.
These long-term initiatives
collectively reault in an improvement in
the capabilities and qualifications of the
shift crew and their ability to dia1Mae
and respond to accidents. Theae
initiatives include shift 1taffina
increases. training and qualiiir.ation
program improvements. hardware
modificatiom, emphasis on human
factors considerations. procedural
upgrades, and development of extensive
emergency response organization• to
auplent on-shift capabilities durina
abnormal conditions.
Draft Policy Statement
On July 25, 1983. the Commi11ion
published in the Federal Reai1tar (41 ,.
33781) a Draft Policy Statement on
Engineering Expertise on Shift to
reassert the Commi11ion's belief thut
engineering and accident assessment
expertise must be available to the
operating crew at all nuclear power
plants.
The Draft Policy Statement on
Engineering Expertise on Shift offered
licensees of nuclear power plants and
applicants for operating licenses two
options for meeting the staffing
requirements oflO CFR 50.54(m)f2) and
the requirement in NUREG--0737, Item
1.A.l.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.
Under Option 1, licensees that did not
want to combine the SRO and ST A
functions could continue wilh their
approved STA program in accordance
with the description in NUREG-o737.
"Clarification ofTMI Action Plan
Requirements."
Interested persons. applicants. and
licensees were invited to submit written
comments to the Secretary of the
Commi11ion. Following consideration of
the comments. the Commi11ion
amended the Draft Policy Statement. as
discu11ed in the following sections.
Comments on the Draft Policy Statement
A total of 34 responses were received
and evaluated. The public comments
related primarily to the combined SRO/
STA position. The following discussion
hishliaht• the major points raised in the
comments and the resolution of thoH
comments. 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 f.,r
public inspection and copying for a fee
at the NRC Public Document Room al
1717 H Street NW., Washington. DCJ
Of the 34 letters received. 18 includell
support for the flexibility provided by
the Policy Statement. The major points
made in the public comments were as
follows:
1. Support for the Policy Statement:
2. Opposition to combining the
functions of the SRO and the STA;
3. Opposition to a bachelor's degree
requirement for the SRO/STA position:
4. Recommendation that equivalency
to a bachelor"s degree be further
defined:
5. Concern that a bachelor's degree
requirement for the SRO/STA position
would result in a higher turnover rate
and potentially blocked career paths for
operators: and
6 Reference to a proposPd b11chclrir's
degree requirement for the Shift
Supen·isor. believed to be currently
under NRC consideration.
A general description of the majot
public comments and responses to these
are as follows:
1 Support for the Policy Statement-
Eighteen commenters 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 SRO/STA Position-
Four individual commenlers stated
that there is a possibility that the person
in the di1al-role position would function
as an additional operator in the event of
an abnormal occurrence instead of being
u\'ailable to pr&l.!ide.the en~ineerlng and
accident asse11ment expertis1!
necessary in these circumstance·s. ln
response. the Commission notes it is the
intent of the Policy Statement that the
person in the dual-role position have
specific training in accident BBsessment
and provide that expertise during an
abnormal occurrence. The staffing level&
required by 10 CFR 50.54(m)(2). which
became effective January 1, 1984,
increased the number of operators and
Senior Operators on shift after the initial
STA position was required. This
increase in shift personnel would allow
the SRO/STA to provide both accident
assessment expertise and to analyze
and respond to off-nonnal occu1Tences
when needed. Experience has shown
that an STA. who is also an SRO. is
better accepted by the ahift crew.
Therefore. the assessment and direction
by an SRO/STA in an off-normal event
might be better accepted by the crew
than aueBSment and advice by a
separate STA.
3. Opposition to a Bachelor's Degree for the SRO/STA Position-
Se\·eral commentere felt that the
person who filled tbe SRO/STA position
should not be required ta hD\"e a
bachelor·a degree. The Commission
notes that since Nl.TREG-o731. Item
l.A.1.1, specified that the STA should
have a bachelor's degree or the
equivalent in a tcientific or engineerina
discipline, the degree requirement is not
new. Thia continun to be the
educational requirement for a dedicated
STA. However. the educational
rr.quirement1 for the dual-role (SRO/
STA) position have been chanpd to
allow the indMdual to meet one of four
educational alternatives.
4 Rccomme.1dation that F.qufrolt!11cJ to a Bachelor's Dt:gree Be Further Defined-
Many commenter& atated that the
equivalency option& were too restrictive
or req11ired clarification. In response. the
Commission notes that a bachelor'&
degree ir. engineering ia no· longer a
basic requirement but ia one of four
f!ducational alternatives. The term
"equh·alent" baa been deleted.'
Changes related to educational
alternatives are summarized below:
• Most states require a bachelor's
degree in engineering and several years
of engineering experience for an
indh·idual to sit for the Profe11ional
Engineer (PE) examination. A few atates
still allow an individual without formal
education but many years of practical
enginer.ring experience and training to
sit for the eumination. However. this
option is becoming available leH often
Hence, this alternative allows
individuals who do not have a de(!ree
but have successfully completed the PE
examination to meet one of the
educational altemattwa of Option 1.
• Other bachelor's desreea
determined to be acceptable
alternatives are a bachelor'• degree in
engineering technology from an
accredited institution or a bachelor's
degree in a physical acience from an
accredited institution. These degree
programa are acceptable provided that
they include coune worlt in the
physical. mathematical. ot: engineering
sciences. These requirements are
intended to ensure that the individuul
has substantial knowledge and
undentanding of the phyaical and
mathematical sciences and the
principles of engineering.
• The Commi11ion hu deleted the
educational alternatives that allow for
succe&&ful completion of the technical
portion of an engineering degree
program and the successful completion
of the Engineer-tn-Trainins (EIT)
examination. The Commi11ion't1
objective is to enhance engineering
expertise on shift throUBh more stringent
educational requirement& for the
indi\'idual filling the dual-role position.
5 Concern that a Bachelor's Degree Requirement Would Result in a Higher Turnover Rate and a Potentially Blocked Career Path for Shift Employees-
Several commenters expressed
concern that degreed individual& would
leave for other poaitiom in the plant.
contributing to a hish turnover rate on
shift. Another concern of commenten
was that career paths to tlie senior
operating positions would be bloc:kcd
for those indh:idullls without degrees. In
response, the Commi&Sion notes that
individuals may move to other positions
within the utility. However. this can be
viewed as desirable since ii would
increase the number of employees with
valuable operating experience in o!he1
posi lions a I the u tilily.
The only positions which mar not l>C'
available for individuals without a
degree would be the STA or the SRO/
STA position. The career path lo olhe·
senior operating positions remains
available.
6. Reference to a Proposed Bar.l1elm .. s Degree Requirement for the Shift Supervisor-
A few commenters on the Federal
Register notice toolt the opportunity to
comment on whether & b!lchelor"&
degree should be required for specific
positions in the operating staff of
nuclear power plants. and in particular.
for the Shift Supervisor's po11ition.
The Final Policy Statement on
Engineering Expertise on Shift does not
addre11 the i11ue of requiring a degrt:e
for the Shift Supervisor. Early in 1984.
the staff conaidered a "Proposed
Rulemakina Concerning Requirements
for Senior Managera" in SECY-M-106.
This proposed rulemaking would hi.ve
required that an additional degreed.
SRO-lice~ individual be assigned to
each shift of a nuclear power plant-who
would be responaible for manqerial
direction of all plant functions including
chemistry, health phyaics, maintenance.
operationa. secwity. aDd technical
services. Following aeveral meetings
"•Ith the staff and industry
representatives, the Commission
concluded that this proposed rulemaking
was not warranted: therefore. it wa& not
approved. One of the primary base& for
the propoaad senior manager rule v.-11s
the need to provide engiaeering
expertise to the shift crew. which is ;,l&o
the primary objective of this PoliCl'
Statement.
Developmmt al Final Policy Statement
As a result of the analysis of public
comments, the Commission clarified the
educational alternatives of the dual-role
(SRO/STA] position. The revisions to
the Draft Policy Statement resulted in
SECY-&1-355. a draft Final Policy
Statement on Engineering Expertiae on
Shift.
The main difference between the
Draft Policy Statement and SECY-M-
355 concerned tbe educational
qualifications for the dual-role position.
The Draft Policy Statement required. of
the person filling the dual-role poaition.
a baccalaureate degree in engineering or
related sciences or one of three
equivalents to the degree. SECY-84-355
required a bachelor'• degree in
engineering from an accredited
institution or one of five 1tcceptable
altematives to the engineering degree.
The staff met with the CommiBBionera
on November 5, 1984, to discuss SECY-
84-355. As a result of that meeting, the
Commissionera directed the staff to
coordinate the Policy Statement on
Engineering Expertise on Shift with the
Nuclear Utilitiea Management and
Human Reaourcea Committee
(NUMARC). Another draft Final Policy
Statement, SECY-85-150, was the result
of the CommiBBionera' direction. staff
analysis. rasolution to public comments,
and staff coordination with NUMARC.
The majority of the Commission
approved a veraion of the Policy
Statement in SECY-85-150 with change•
In the educational alternatives.
Furthermore. the Commiaaion haa
deleted an item from SECY-85-150.
which allowed for college-level training
instead of formal college education for
the dual-role position. The objective of
the Commission is to enhance
engineering expertise on ahift throush
more atringent educational requirements
for the individual filling the SRO/STA
position. The educational alternatives in
this Final Policy Statement require a
bachelor'• degree in engineering,
engineering technology. or physical
science from an accredited institution.
or a PE license obtained through
succeuful completion of the PE
examination.
Finally, although this Final Policy
Statement includes an option which
allows for the continued use of the ST A
position, as did the Draft Policy
Statement. the former encourases
licensees to work towards having the
STA asaume an active role in shift
activities.
While it is the Commission's
preference that licensees move toward
the dual-role (SRO/STA) position,
continuation of an approved STA
prosram remains an acceptable option.
The Commission acknowledae• that
some licensees may prefer the dedicated
STA position for a number of reasons.
The Commission also recognizes the
advantages or integrating the
qualifications and training of the STA
into the licensed operating staff.
The separate views of Commi11ioner
Thomas M. Roberts on this Policy
Statement follow;
I am in .a11reement with the majority'•
Intent that operators lhould be -u trained
and qualified lo perform their dutie1.
However. this policy. by requirina that an
Individual have both an SR.O license and a
BS degree in enaineering or related ICience or
have passed the PE examination prior to
assuming the combined STA/SRO duUe1,
places inordinate confidence In "academic"
credentials. Strinldns)y abaent frolll lhe
policy are the apecif"ic aldlla or abilitiel
needed to perform tbote duties. Thaa. lhe
Commiaion bu pMtpoaad the quution of
what those skill• should be and bow they
should or could be achieved and
demonstrated. This leave1 me no choice but
to vote qainat the modificatio111 proposed to
the Polley Statement on Engineering
Expertise on Shift. By eliminatiq alternatives
to a bachelor's degree for lndividual1 wtlo
would otherwile occupy the dual role. the
Commi11ion would be ignoring the
compellina arguments made in public
commenta and the staff'• proposal for
nexibillty. We would be impo1lna our
solution without addre11ina the benefltl that
will be eliminated by not allowing ftexlbility.
Thia leaves the utilitiet with little incentiYe to
change from the current poaitlon. which 11
allowed by Option 2. Since a majority of the
CommiNion haa already determined that
improvement from the current program -1d
be desirable, the Commiuion 1hould provide
aome 111echani1m to move toward
Improvement. The proposed 1tatement, 11
modified. does not provide that mechanism,
and we provide no justification for overrldtns
the 1taff's evaluation of the beneftts that the
ftexibility would bring.
Policy Statement
The Commission continues to 1tre11
the importance of providing engineerina
and accident aue11ment expertise on
shift. In this Policy Statement, "accident
assessment " means immediate actions
needed to be taken while an event is in
progress. This policy Statement does not
reqllire any changes in the fonnal
education and training of operators and
Senior Operators not expected to fill the
dual-role SRO/STA position.
The intent of this policy pclance may
be satisfied by either of the optiona
described below. The Commiaaion
prefers a combined SRO/STA position
(Option 1). In addition. in the long term,
the Commission would prefer that the
STA be combined with the Shift
Supervisor in the dual-role position.
Either Option 1 or Option 2 may be
used on each shift. A utility may uae
Option 1 on some ahifta and Option Z on
other shifts, or may uae the same option
on every shift. If Option 1 ia used for a
st1ift, then the separate STA position
may be eliminated for that ahifL
Option 1: Combined SRO/STA Position
Thia option ia aatiafied by •uisnins
an individual with the following
qualif1Cationa to each operatina abift
crew ea one of the SRO. (preferably lhe
Shift Superviaor) required by 10 CFR 50.st(m)(2)(i):
a. Licensed as a senior operator on the
nuclear power unit(s) to which aasigned.
and
b. Meets the STA training criteria of
NUREG--0737, Item I.A.1.1, and one of
the following educational ahemativea:
(1) Bachelor'• degree in engineerill8
from an accredited institution:
(2) Prof eaaional Engineer's licenae
obtained by the aucceasful completion of
the PE examination:
(3) Bachelor'• degree in engineering
technology from an accredited
institution. including course work in the
physical mathematical. or engineering
sciences; or
(4) Bachelor's degree in a physical
science from an accredited institution.
including course worlt in the physical.
mathematicaL or engineering sciences.
Option 2: Continued Use of STA Position
Thia option is 1Btisfied by placing on
each shift a dedicated Shift Technical
Advisor (STA) who meets the ST A
criteria of NUREG-G787, Item I.A..1.1.
The ST A should a11ume an active role
in shift activities. For example, the STA
should review plant logs. participate in
shift turnover activities. and maintain an
awareness of plant configuration and
status.
Licensee proposals different than the
two options described above will be
considered by the staff on a caae-bycue
basil. To eliminate the STA
position. a licensee of an operating
reactor should apply for a modification
to its license and an applicant for an
operating license should modify its Final
Safety Analysis Report to reflect
elimination of the STA position and a
commitment to provide a required SRO
on shift with the qualifications
described in Option l above.
NRC will accept a utility'•
modifications if it finds that tbe proposal
meets the intent of this Policy
Statement. NRC will review. on a caaeby-
caae basis. multi-unit sites with duallicenaed
SRO• to ensure that an
adequate number of licensed staff are
available and that engineering expertise
can be provided when needed. It is the
intent of this Policy Statement to ensure
that engineering and accident
aueaament expertiH is possessed by
the plant operating staff.
Dated at Washlnpin. DC. on this 22 day or
October. t985.