NRC Generic Letter 1984-16
June 27, 1984
TO ALL LICENSEES OF OPERATING REACTORS, APPLICANTS FOR OPERATINGLICENSE, AND HOLDERS OF CONSTRUCTION PERMITSGentlemen:
SUBJECT: ADEQUACY OF ON-SHIFT OPERATING EXPERIENCE FORNEAR TERM OPERATING LICENSE APPLICANTS(Generic Letter 84-16)On June 14, 1984, the Chairman of the U. S. Nuclear Regulatory Commission,N. J. Palladino, sent J. H. Miller, President, Georgia Power Company, a letterin which the Commissioners presented their views on the subject of adequacy ofon-shift operating experience for near-term operating license applicants.This letter is enclosed and is applicable for near-term operating licenseapplicants.The June 14, 1984 letter accepted, with some clarifications, an Industry WorkingGroup proposal on this subject, presented to the Commission on February 24, 1984.Commissioners Gilinsky and Asselstine expressed individual views on the subject.In accordance with the Chairman's letter, March 31, 1985, is the latest date foruse of shift advisors. Beyond that date, utilities should plan to have sufficientoperating experience on-shift such that there no longer is a need to rely on theuse of shift advisors. We understand, of course, that circumstances may arise,beyond the control of the utility, which would mandate the use of advisors tocover one or more shifts, but these circumstances can be treated on a case-by-casebasis.The acceptance of these experience requirements by the NRC does not alter theguidance for eligibility, included in Regulatory Guide 1.8 and NUREG-0737, forRO and SRO licensing examination candidates. Further, acceptance of theIndustry Working Group proposal does not foreclose the development of any longterm requirements for crew operating experience.We understand that each utility is in possession of a copy of the IndustryWorking Group proposal of February 24, 1984. Copies are also available fromthe NRC Public Document Room.This letter contains no reporting requirement and is for information only.
Sincerely,Origimil 9ged bytobert A. forplef4 /EDarrell G. Eisenhut, DirectorDivision of Licensing
Enclosure:
Ltr of June 14, 1984*PREVIOUS CONCURRENCE SEE DATEORAB:DL* ORAB:DL* C:ORAB:DL* ELD* AD/SA:DL* D/DHFS9"'d-MFairtile:dm JZwolinski GHolahan FMiraglia HThompson DOssenhut6/21/84 6/21/84 6/21/84 6/22/84 6/22/84 6/25/84 6/Zt3848406270142.X , 'V :i .t.
June 27, l9TO ALL LICENSEES OF OPERATING REACTORS, APPLICANTS FOR OPERATINGLICENSE, AND HOLDERS OF CONSTRUCTION PERMITSGentlemen:
SUBJECT: ADEQUACY OF ON-SHIFT OPERATING EXPERIENCE FORNEAR TERM OPERATING LICENSE APPLICANTS(Generic Letter 84- )On June 14, 1984, the Chairman of the U. S. Nuclear Regulatory Commission,N. J. Palladino, sent J. H. Miller, President, Georgia Power Company, a letterin which the Commissioners presented their views on the subject of adequacy ofon-shift operating experience for near-term operating license applicants.This letter is enclosed and is applicable for near-term operating licenseapplicants.The June 14, 1984 letter accepted, with some clarifications, an Industry WorkingGroup proposal on this subject, presented to the Commission on February 24, 1984.Commissioners Gilinsky and Asselstine expressed individual views on the subject.In the Chairman's letter, March 31, 1985 is presented as an acceptable datebeyond which utilities should plan to have sufficient operating experienceon-shift such that there no longer is a need to rely on the use of shiftadvisors. We understand, of course, that circumstances may arise, beyondthe control of the utility, which would mandate the use of advisors to coverone or more shifts, but these circumstances can be treated on a case-by-casebasis.The acceptance of these experience requirements by the NRC does not alter theguidance for eligibility, included in Regulatory Guide 1.8 and NUREG-0737, forRO and SRO licensing examination candidates. Further, acceptance of theIndustry Working Group proposal does not foreclose the development of any longterm requirements for crew operating experience.We understand that each utility is in possession of a copy of the IndustryWorking Group proposal of February 24, 1984. Copies are also available fromthe NRC Public Document Room.This letter contains no reporting requirement and is for information only.
Sincerely,Darrell G. Eisenhut, DirectorDivision of Licensing
Enclosure:
Ltr of June 14, 1984*PREVIOUS CONCURRENCE SEE DATEORAB:DL* ORAB:DL* C:ORAB:DL* ELD* AD/SA:DL* D/DHFS D/DLMFairtile:dm JZwolinski GHolahan FMiraglia HThompson DEisenhut6/21/84 6/21/84 6/?1/84 6/22/84 6/22/84 6/25/84 6/ /84B0 AloeVw 011VS.7 June 27, 34TO ALL LICENSEES OF OPERATING REACTORS, APPLICANTS FOR OPERATINGLICENSE, AND HOLDERS OF CONSTRUCTION PERMITSGentlemen:
SUBJECT: ADEQUACY OF ON-SHIFT OPERATING EXPERIENCE FORNEAR TERM OPERATING LICENSE APPLICANTS(Generic Letter 84- )On June 14, 1984, the Chairman of the U. S. Nuclear Regulatory Commission,N. J. Palladino, sent J. H. Miller, President, Georgia Power Company, a letterin which the Commissioners presented their views on the subject of adequacy ofon-shift operating experience for near-term operating license applicants. Webelieve the information contained in this letter to be informative and shouldbe forwarded to all interested parties, thus we are sending this letter to you.This letter is enclosed.The June 14, 1984 letter is in response to an Industry Working Group proposalon this subject, presented to the Commission on February 24, 1984. Specifically,note the varied opinions on the guidance as expressed by the individual viewsof Commissioners Gilinsky and Asselstine. However, the Commission believesthat the industry proposal with the given clarifications will provide reasonableassurance of adequate on-shift operating experience pending any furtherrulemaking the Commission might choose to undertake.The acceptance of these experience requirements by the NRC does not alter theguidance for eligibility, included in Regulatory Guide 1.8 and NUREG-0737, forRO and SRO licensing examination candidates. Further, acceptance of this proposalis not intended to foreclose any long term requirements for crew operatingexperience which the staff may develop for Commission consideration that wouldapply to operating plants.We understand that each utility is in possession of a copy of the IndustryWorking Group proposal of February 24, 1984. Copies are also available fromthe NRC Public Document Room.This letter contains no reporting requirement and is for information only.
Sincerely,Darrell G. Eisenhut, DirectorDivision of Licensing
Enclosure:
Ltr of June 14, 1984 4LORAB: OT ORA14, C:ORAB:D R EL " AD/ I D/DHFS D/DLMFairtile:dm JZwolinski GHolahan FMir6Wa HThompson DEisenhut6/ /84 6/I4/84 6/lk/84 6/P6 84 6/g0 .36/ /84 6/ /84 CHAUNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 2055AIRMAN June 14, 1984Mr. J. H. Miller, PresidentGeorgia Power CompanyP. 0. Box 4545Atlanta, Georgia 30302
Dear Mr. Miller:
The Commission appreciates the efforts you and the othermembers .of the Industry Working Group put forth in developingthe proposal you presented to us on February 24, 1984, toassure the adequacy of on-shift operating experience fornear-term operating license applicants. The level of utilityparticipation in developing and supporting this proposalclearly reflects the needed degree of involvement by seniorutility management to assure sound implementation.The industry proposal recognizes that the use of shiftadvisors to supplement plant experietce depends upon theadequacy of the training of advisors and their integrationinto the shift crew. It is particularly important whereadvisors are used that there is a management commitment to(l) provide plant specific training for shift advisors whichincludes plant procedures, technical specifications, plantsystems, and where available, time for use of a plant simulator,and (2) training for the remainder of the shift crew on therole of advisors. Furthermore, the industry proposal recognizesthe desirability of phasing out the use of shift advisors assoon as is practically achievable, but proposed no specificdate for terminating the use of advisors.The Commission accepts the Industry Working Group proposalwith the following clarifications:With regard to the shift crews that meet the industryexperience proposal:1. The Hot Participation Experience tabulated in yourslide 5 should be at a large, same type plant.2. The use of an SRO-licensed STA to satisfy the HotParticipation Experience is acceptable providedthat the STA serves as a member of the shift.
Mr. J. E. Miller-2-With regard to the use of shift advisors:1. The shift advisors that have at least one year onshift as a licensed SRO at an operating plant of thesame type are acceptable. Proposals to utilize anindividual as an advisor who has only an RO licensewill be evaluated on a case-by-case basis to assurethat an appropriate level of knowledge and supervisoryexperience has been accumulated.2. The utility-administered examinations for advisorsshould include both oral and written examinations. Ifno plant-reference simulator is available, a board ofat least three individuals, qualified at the SROlevel, should conduct the oral examination.3. The utility should provide the NRC with a list ofcertified advisors and their qualifications. The NRCstaff should be notified one month prior to theirrelease from the plant to which they are assigned.Based upon operating experience, intormation submitted byindividual utilities since the February 24, .1984 meeting, itappears that use of shift advisors may be required only at oneplant now anticipating fuel load after March of 1985. Further,we understand that this utility is making plans to obtainnecessary operating experience for its licensed operators priorto fuel load. Accordingly, it appears that March 31, 1985would be an acceptable date beyond which utilities should planto have sufficient operating experience on shift such thatthere no longer is a need to rely on the use of shift advisors.We understand, of course, that circumstances may arise, beyondthe control of the utility, which would mandate the use ofadvisors to cover one or more shifts, but these circumstancescan be treated on a case-by-case basis.The Commission believes that the industry proposal with theabove clarifications will provide reasonable assurance ofadequate on-shift operating experience pending any furtherrulemaking the Commission might choose to complete. The Commis-sion is therefore issuing a generic letter to all licenseeswhich outlines this policy. The acceptance of these experiencerequirements by the NRC does not alter the guidance for eligi-bility, included in Regulatory Guide 1.8 and NUREG-0737, for ROand SRO licensing examination candidates. Further, acceptanceof this proposal is not intended to foreclose any long term Mr. J. H. Miller-3-requirements for crew operating experience which the staff maydevelop for Commission consideration that would apply tooperating plants.Commissioner Asselstine adds:I disagree with two aspects of the Commission's decisionon the matter of shift experience requirements. first, Ido not believe that the "hot participation experience"element in the industry proposal is adequate. I wouldonly eliminate the requirement for a shift advisor if onelicensed senior reactor operator on the shift has at leastone year's prior experience as a licensed SRO at a similarplant. Without at least that amount of prior operatingexperience on the part of the shift crew, it seems prudentto me to require a shift advisor with that level ofexperience. Second, I believe that the matter of shiftexperience requirements should not be handled by means ofa generic letter but rather should be the subject of aCommission policy statement. In my view, the Commissionshould have prepared a proposed policy statement on thesubject and should have sougWt industry and public commenton it.Commissioner Gilinsky adds:Every recipient of this letter should understand its fullimplications. In pressuring the Commission to accept afeeble approach toward shift experience requirements at afew plants nearing operation, the industry is jeopardizingits long standing safety record. I do not think I have tounderline what that means.I would remind you that the original NRC staff proposal --that at least one member of a shift have one year ofprevious licensed operating experience -- was very modest,as any experienced shift supervisor will tell you. It isalso feasible -- I have attached an NRC staff memorandumon the number of experienced operators available. Thesuggestion that it is sufficient for the most seniorperson on shift to have six months of "hot participation",of which only six weeks need be at power, is simplyridiculous. The Commissioners who approved this approachmay not realize what they have done, but you do. It saysto me the industry is not yet capable of policing itsmembers.
Mr. J. H. Miller-4-I do not agree with the way the advisor issue is beinghandled, in particular the decision of the Commission notto require that advisors pass the equivalent of thetwo-day NRC SRO examination. I am not at all impressed bythe two hour quiz administered by the utility seeking anoperating permit. There are cases, and this is one ofthem, where going half-way is worse than doing nothing.Rather than have advisors whose knowledge of the plant isin question, it would be better to have no advisors atall. Inexperienced supervisors may well disregard theirtraining to follow the advice of an advisor installed bythe NRC. If the advisor does not know the plantspecifications and limitations, we could get into serioustrouble.Finally, the Commission's disregard of its existingregulation on operator experience at new plants, 10 CFR55.25(b), and its General Counsel's advice on that point,does not encourage respect for the system of safetyregulation. Neither does the Commission's promulgation ofa major policy decision by means of an informal letterwhich three Commissioners vote4.not to discuss in public.Thank you again for your efforts toward resolving this issue.
Sincerely,Nunzio J. Palladino
Enclosure:
Memo dtd. 3/8/84from W.J. Dircksto Cmr. Gllinsky(per Cmr. Gilinsky'sadditional views)
A. 1UNITED STATESS 0 .NUCLEAR REGULATORY COMMISSIONWASHINGTON. 0. C. 20555Attached per CommissionerGilinsky's added commentsMEMORArNDUP' -?: Cc ner GilinskyFROM:-- viiliai J. DircksExecutive Director for Operations
SUBJECT: LIErNSED OPERATOR POOLThe s_:af has developed the enclosed responses to the questions youasked in your Karch 2, 1984, memorandum. The responses include our bestestimate f-oc Infomnation in the Operator Licensing Tracking System (OLTS).William J. DircksExecutive Director for Operations
Enclosure:
As Statedcc: Chair-ar FailadinoCommissioner RobertsCommiss;.oner AsselstineCon.m1issiorner BernthalOGCOPESECY RESPONSES T0COMMISSIONER GI!LINSKY'S QUESTIONSON LICENSED OPEIRATOR POOLS1. How many Senior Reactor Operator (SP.O) licenses have been issued inthe history of the NRC7ResponseIt is not Dossible to determine exactly how many SRO or RC licenses havebeen issued in the history of NRC. The Operator Licensing TrackingSystem (OLTS) was not initiated until 1982. Hard copy files were usedbefore OLTS. The Privacy Act requires that record retention periods beestablished and maintained. Since the four year retention period forsome of the earlier licenses has elapsed, the hard copy files of inactiveoperators were destroyed or purged of information prior to initiationof OLTS. These files cannot be recovered.The totals that are indicated in OLTS as of March 5, 1984, are 4,505SRO's and 3,231 RO's. This includes both power and non-power reactors.We estimate that approximately 6O' cf. the licenses are for powerreactors. Particularly for older dockets, the information in OLTS isdifficult to verify; However, we consumer these fioures to beconservative estimates. There may be as many as 2,000 more operators andsenior operators whose files have been purged. I hope this informationis sufficient for your needs. For additional information to begenerated, special programs will have To be developed or a hand count ofthe Regional dockets performed, delaying our work on upgrading thecapability of the OLTS. This could ultimately cause delays in futurerequests.2. How many Reactor Operator (RO) licenses have been issued?ResDonseSame as Question 1.3. How many SRO's have held a license for more than one year?ResponseOf the licensed SRO's 1,040 have held a license for more than one year,but have not had the license renewed. This number does not includeSRO's and RO's whose licenses have been renewed (Question 5).
S .4. How imany RO's have held a license for more than one year?ResDonseOf the licensed RO's, 1,457 have held a license for more than one year,but nave not had the licenses renewed.5. How many SRO and RO licenses have been renewed at least once?ResponseOf the licensed SRO's and RO's, 1,703 SRO's and 823 RO's have had theirlicenses renewed at least once.
..1INDUSTRY WORKING GROUPArizona Public Service CompanyATTN: Mr. J. R. BynumDirector, Nuclear OperationsP. 0. Box 2166Phoenix, Arizona 85036Arizona Public Service CompanyPalo Verde --1ATTN: Ron YoungerOperations SuperintendentP. 0. Box 2166Phoenix, Arizona 85036Carolina Power & Light CompanyATTN: Mr. J. A. JonesVice Chainman411 Fayetteville StreetRaleigh,. North Carolina 27602Carolina Power & Light CompanyShearon HarrisATTN: Mr. Al CutterVice President, Engineering & LicensingP. 0. Box 1551Raleigh, North Carolina: 2760ZCleveland Electric Illuminating CompanyATTN: Mr. Murray R. EdelmanVice President, Nuclear GroupP. 0. Box 5000Cleveland, Ohio 44101Cleveland Electric Illuminating CompanyPerry Plant SB 307ATTN: Mr. M. D. LysterPlant Superintendent10 Center RoadPerry, Ohio 44081Commonwealth Edison CompanyATTN: Mr. Cordell ReedVice PresidentP. 0. Box 767Chicago, Illinois 60690Consumers Power CompanyATTN: Mr. Russell B. DeWittVice President -Nuclear Operations1945 West Parnall RoadJackson, Michigan 49201 Consumers Power CompanyMidlandATTN: Mr.. Joseph F. FirlitGeneral Plant Manager3249 East Gordonville RoadMidland, Michigan 48640Detroit Edison CompanyATTN: Mr. Harry TauberGroup Vice President2000 Second AvenueDetroit, Michigan 48226Detroit Edison CompanyFermi 2ATTN: Mr. Wayne H. JensVice President Nuclear Operations6400 North Dixie HighwayNew Port, Michigan 48166Duke Power CompanyATTN: Hal B. Tucker, Jr.Vice PresidentNuclear ProductionP. 0. Box 33189Charlotte. North CarolinaDepartment28242Duquesne Light CompanyATTN: Mr. E. J. WooleverVice President, BeaverRobinson PlazaBuilding 2, Suite 210Pennsylvania Rt. 60Pittsburgh, Pennsylvania 152(Valley II Project05Duquesne Light CompanyBeaver Valley 2ATTN: Mr. Joseph F. ZagorskiStation SuperintendentP. 0. Box 4, New Training Bldg.Shippingport, Pennsylvania 15077Georgia Power CompanyATTN: Mr. Doug DuttonVice President-Project ManagementP. 0. Box 4545Atlanta, Georgia 30302 Georgia Power CompanyVogtleATTN: Mr. George Bockhold, Jr.General Manager, Vogtle OperationsP. 0. Box 4545Atlanta, Georgia 30302gulf States Utilities CompanyATTN: Mr. Jim DeddensVice President -River Bend Nuclear GroupP. 0. Box 2951Beaumont, Texas 77704Gulf States Utilities CompanyRiver BendATTN: Mr. W. H. OdellDirector, Nuclear TrainingP. 0. Drawer 220St. Francisville, LA 70775Houston Lighting & Power CompanyATTH: Mr. George A. Oprea, Jr.Executive Vice PresidentP. 0. Box 1700Houston, Texas 77001Houston Lighting & Power CompanySouth Texas ProjectATTN: Mr. Gary HelgesonReactor Operations SuperintendentP. 0. Box 1700Houston, Texas 77001Illinois Power CompanyATTN: Mr. D. P. HallVice President500 South 27th StreetDecatur, Illinois 62525Kansas Gas & Electric CompanyATTN: Mr. Glenn L. KoesterVice President, Nuclear201 North Market StreetWichita, Kansas 67201 Kansas Gas & Electric CompanyWolf CreekATTN: Mr. Paul E. TurnerManager, Nuclear Training201 North Market StreetWichita, Kansas 67201Long Island Lighting CompanyATTN: Mr. M. S. PollackVice President-Nuclear175 East Old Country RoadHicksville, New York 11801Long Island Lighting CompanyATTN: Mr. James W. Dye, Jr.Senior Vice President175 East Old Country RoadHicksville, New York 11801Long Island Lighting CompanyATTN: Mr. Jack NotaroChief Operations Engineer175 East Old Country RoadHicksville, New York 11801Louisiana Power & Light CompanyATTN: Mr. L. V. MaurinVice President-Nuclear Operations142 Delaronde StreetNew Orleans, Louisiana 70174Louisiana Power & Light CompanyWaterford 3ATTN: Mr. Ross P. BarkhurstPlant ManagerP. 0. Box BKillona, Louisiana 70066Mississippi Power & Light CompanyATTN: Mr. Jack B. RichardSenior Vice President-NuclearP. 0. Box 1640Jackson, Mississippi 39205Niagara Mohawk Power CorporationATTN: Mr. Gerald K. RhodeSenior Vice President300 Erie Boulevard WestSyracuse, New York 13202 Niagara Mohawk Power CorporationATTN- Mr. Thomas E. LempgesVice President, Nuclear300 Erie Boulevard WestSyracuse, New York 13202Pacific Gas & Electric CompanyATTNf: Mr. James 0. SchuylerVice President, Nuclear77 Beale StreetSan Francisco, California 94106Pennsylvania Power and Light CompanyATTN: Mr. Bruce D. KenyonNuclear Operations2 North Ninth StreetAllentown, Pennsylvania 18101Philadelphia Electric CompanyATTN: Mr. W. T. UllrichSuperintendent2301 Market StreetPhiladelphia, Pennsylvania 19101Public Service Company of New HampshireATTN: Mr. George S. ThomasVice President, Nuclear ProductionP. 0. Box 330Manchester, New Hampshire 03105Public Service Electric & Gas CompanyATTN: Mr. R. A. UnderitzVice President, Nuclear80 Park Place, Room 816 MPNewark, New Jersey 07101Public Service Electric & Gas CompanyHope Creek Generating StationATTN: Mr. Roger S. SalvesenGeneral ManagerP. 0. Box 236Hancocks Bridge, New Jersey 08038Tennessee Valley AuthorityATTN: Mr. H. G. ParrisManager of Power500A Chestnut Tower IIChattanooga, Tennessee 37401 Tennessee Valley AuthorityWatts BarATTN: Mr. William T. CottlePower Plant SuperintendentP. 0. Box 800Spring City, Tennessee 37381Texas Utilities Generating CompanyATTN: Mr. R. J. Gary. ExecutiveVice President & General Manager2001 Bryan TowerDallas, Texas 75201Texas Utilities Generating CompanyComanche PeakATTN: Mr. J. C. KuykendallManager, Nuclear Operations2001 Bryan TowerDallas, Texas 75201Union Electric CompanyATTN: Mr. D. F. SchnellVice President -Nuclear'P. O. Box 149 -St. Louis, Missouri 63166Union Electric CompanyATTN: Mr. E. K. DilleExecutive Vice PresidentP. 0. Box 149St. Louis, Missouri 63166Union Electric CompanyATTN: Mr. Steve MiltenbergerManager, CallawayP. 0. Box 149St. Louis, Missouri 63166Washington Public Power Supply SystemATTN: Mr. 0. W. MazurManaging Director3000 George Washington WayP. 0. Box 968Richland, Washington 99352Washington Public Power Supply SystemATTN: Mr. Robert GlasscockManager, QA3000 George Washington WayP. 0. Box 968Richland, Washington 99352