Resolution of Generic Safety Issues: Task I.A.2: Training and Qualifications of Operating Personnel (Rev. 6) ( NUREG-0933, Main Report with Supplements 1–35 )
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The objectives of this task were to: (1) improve the capability of operators and supervisors to understand and control complex reactor transients and accidents; (2) improve the general capability of an operations organization to respond rapidly and effectively to upset conditions; and (3) increase the education, experience, and training requirements for operators, senior operators, supervisors, and other personnel in the operations organization to substantially improve their capability to perform their duties.
ITEM I.A.2.1: IMMEDIATE UPGRADING OF OPERATOR AND SENIOR OPERATOR TRAINING AND QUALIFICATIONS
This item required all operating plant licensees and all license applicants to provide specific improvements in training and qualifications of senior operators and control room operators. The three parts of this item are listed below.
ITEM I.A.2.1(1): QUALIFICATIONS - EXPERIENCE DESCRIPTION
This NUREG-066048 item set specific experience requirements that were to be met by applicants for senior operator licenses by May 1, 1980. Applicants for senior operator licenses were required to have been a licensed operator for one year effective December 1, 1980.
CONCLUSION
This item was clarified in NUREG-0737,98 new requirements were issued, and MPA F-03 was established by DL/NRR for implementation purposes.
ITEM I.A.2.1(2): TRAINING
DESCRIPTION
This NUREG-066048 item set the following specific requirements:
(1) Effective August 1, 1980, senior operator applicants were required to have 3 months of continuous on-the-job training as an extra person on shift.
(2) Effective August 1, 1980, control room operator applicants were required to have 3 months training on shift as an extra person in the control room.
(3) Training programs were to be modified to provide: (a) training in heat transfer, fluid flow, and thermodynamics; (b) training in the use of installed plant systems to control or mitigate an accident in which the core is severely damaged; and (c) increased emphasis on reactor and plant transients.
CONCLUSION
This item was clarified in NUREG-0737,98 new requirements were issued, and MPA F-03 was established by DL/NRR for implementation purposes.
ITEM I.A.2.1(3): FACILITY CERTIFICATION OF COMPETENCE AND FITNESS OF APPLICANTS FOR OPERATOR AND SENIOR OPERATOR LICENSES
DESCRIPTION
This NUREG-066048 item required all applicants for operator and senior operator licenses, pursuant to 10 CFR 55.10(a)(6), 10 CFR 55.33(a)(4), and 10 CFR 55.33(a)(5), to be certified by the highest level of the corporate management of their respective plants. This requirement was effective May 1, 1980.
CONCLUSION
This item was clarified in NUREG-0737,98 new requirements were issued, and MPA F-03 was established by DL/NRR for implementation purposes.
ITEM I.A.2.2: TRAINING AND QUALIFICATIONS OF OPERATIONS PERSONNEL
DESCRIPTION
Under the TMI Action Plan,48 the NRC could require reactor licensees to review their training and qualification programs for all operations personnel. This was interpreted to include licensed and auxiliary operators, technicians, maintenance personnel, and supervisors. The review was to be conducted to examine existing practices in light of the safety significance of the duties of the operations staff. If the review determined that the existing practices adequately assured proper safety-related staff conduct, then documentation of the justification for this determination was required; this documentation did not require submittal to the NRC but was required to be maintained on site. If the review uncovered inadequacies, the licensee was required to upgrade the training and qualification practices to ensure adequate performance of operations personnel. The evaluation of this issue included the consideration of Item I.A.2.6(3).
PRIORITY DETERMINATION
To estimate the effect of training reviews on operator-error contributions to plant risk, a panel of PNL experts was assembled with considerable experience in reactor operations, utility training programs, and reactor plant systems. The panel included members with utility field experience and reactor operator licensing examiners. The judgments of the panel, as detailed below, were based on the two following considerations:64
(1) The potential effect of this issue was limited by its semi-voluntary nature, i.e., the judgment of adequacy was in the hands of the individual utilities. Furthermore, the existing Institute for Nuclear Power Operations (INPO) and NRC research work in task analysis dealt with generic routine operations. Plant-specific operation and operation under upset conditions were left to the individual utilities. This diluted the effectiveness of the task analysis efforts in providing the basis for the training and qualifications review.
Related issues which were supported by and, in turn, supported this issue were the conduct of plant drills and accreditation of training programs. While neither of these were directly required by the training and qualifications review, both could have been a part of the response and both would have had a positive effect on personnel performance.
(2) There was a wide variation among utilities in both the training programs and the performance of operations staff. In many facilities, there was much room for improvement. Therefore, while the potential effect of the training and qualifications review effort was limited, a significant overall reduction in safety-related human error for operations personnel was expected because of the wide margin available for improvement.
Assumptions
The PNL panel divided licensees into three groups:
(1) Minimally-Affected: These utilities had a good, effective training and qualification program and good operations personnel performance. They were to be minimally affected by this issue. The fractional population of this group was estimated to be 15% of the reactor licensees.
(2) Intermediately-Affected: These utilities' training and qualification programs and/or operations performance had room for improvement. This group, estimated to be 60% of the population, had to undergo improvements and, therefore, were affected by the issue.
(3) Maximally-Affected: These utilities had deficiencies in their training and qualification programs and in operations personnel performance. They would be significantly affected by this issue and major restructuring of programs were expected. This group was estimated to contain 25% of reactor licensees.
From the estimates for these groups, weighted composite estimates were derived. NUREG/CR-280064 shows the safety benefit estimated by the panel for each of the groups and also gives the weighted averages.
The values given in NUREG/CR-280064 are in terms of percent changes. For inclusion into the value/impact score formula, they were converted to other measures. The reduction in human error was transformed into the resulting reduction in risk, as measured by change in probabilistic risk exposure (man-rem/RY). The change in annual ORE was also transformed from percent improvement into man-rem/RY.
The reduction in risk was developed by examining the quantitative impact on accident event frequencies of human error rates in key scenarios. The reduction in human error translated into a reduction in accident frequency. No additional reduction due to accident mitigation was assumed. The values given in NUREG/CR-280064 were used for the best estimate of improvement: 17% for operator error and 28% for maintenance.
Frequency Estimate
This issue centered around operator and maintenance training programs to improve personnel performance. The issue related generically to both BWRs and PWRs and, ideally, the risk reduction attributable to its resolution was estimated by selecting a representative plant of each type. However, maintenance and operator performance essentially impacted accident sequences in the risk equations. The calculations were performed for one representative PWR and inferences drawn for all reactors. The Oconee-3 (a RSSMAP PWR) plant risk equations developed in NUREG/CR-1659,54 Vol. 4, were used for this analysis.
It was assumed that the 17% reduction in operator error could be applied directly to elements containing an operator error frequency and the 28% reduction could be applied directly to maintenance variables. This assumption introduced some error in the maintenance contribution because some maintenance operations on nuclear systems have fixed times associated with cooldown and preparation, etc., in addition to the actual hands-on time for maintenance that would be subject to improvement through training. Maintenance done properly the first time also reduces the frequency of maintenance outage and downtime for proper repairs at some future date. Thus, fixed time periods in maintenance outages are indirectly reduced over the long run with improved maintenance performance simply because the need for maintenance may be reduced, except for systems that undergo preventive maintenance at set intervals.
Consequence Estimate
It was assumed that the resolution applied to all plants existing and planned, as given in NUREG/CR-2800, Appendix C.64 This represented a total of 4,000 RY of operation (143 plants with an average remaining life of 28 years). Implementation of the solution would provide a reduction of 9 man-rem/RY. For all plants, assuming a typical midwest-type meteorology and an average population density of 340 people per square-mile at U.S. reactor sites, the total public risk reduction was estimated to be 122,400 man-rem.
Cost Estimate
Industry Cost: In estimating the costs to industry of implementing and operating under the resolution of this issue, the PNL panel divided the industry once again into three categories; these groups and their estimates are shown in NUREG/CR-2800.64 The cost for implementation was the product of the number of plants and the cost/plant: (143)($0.335M) or $48M. The operation cost was the product of the number of plants, the average remaining life, and the annual plant cost: (143)(28)($0.16M) or $640M. Thus, the total industry cost was $(640 + 48)M or $688M.
NRC Cost: The NRC cost to implement the resolution was taken from NUREG-0660.48 This called for 1.1 man-years of NRC effort which was equivalent to $110,000. The annual NRC effort through OIE to review the justification documentation and new training programs was estimated to be one man-year or $100,000/year. Over the lifetime of the completed and planned reactors, this cost was estimated to be $2.8M. Therefore, the total NRC cost was $[0.11 + 2.8]M or $2.9M.
Total Cost: The total industry and NRC cost associated with the possible solution was $[688 + 2.9]M or approximately $691M.
Value/Impact Assessment
Based on an estimated public risk reduction of 122,400 man-rem and a cost of $691M for a possible solution, the value/impact score was given by:
Other Considerations
It was estimated that, with improved training, the operational doses could be reduced by 2.4 x 105 man-rem for 143 plants over the average remaining plant life. Including the occupational dose reduction (2.4 x 105 man-rem) in the above equation would increase the value/impact score to 524 man-rem/$M. PNL calculated64 the occupational risk reduction for accident-related ORE to be 880 man-rem.
CONCLUSION
Because of the extensive number of sequences considered to be affected by this issue, the base case risk was high with a calculated range from 60 to 73 man-rem/RY. Based on the potential reduction in public risk and ORE, the issue was given a high priority ranking (see Appendix C). However, in June 1985, the Commission recognized that the industry had made progress in developing programs to improve nuclear utility training and personnel qualification. As a result, the Commission adopted a Policy Statement on Training and Qualifications which made the training accreditation program managed by INPO the focus of training improvement in the industry.777 Thus, this item was RESOLVED and no new requirements were established.
ITEM I.A.2.3: ADMINISTRATION OF TRAINING PROGRAMS
DESCRIPTION
This NUREG-066048 item required the staff to develop criteria and procedures to be used in auditing training programs, including those provided by reactor vendors, and to increase the amount of auditing. Specifically, NRR was expected to: (1) audit training programs to ensure training was formalized and, eventually, in conformance with accreditation; (2) conduct cold operator licensing certification at simulators; and (3) pending accreditation, require certain instructors to be SRO-certified.
CONCLUSION
Elements (2) and (3) were implemented and were incorporated into the Examiner Standards and Inspection Procedures. The issue of training audits was addressed by the Commission's Policy Statement966 on Training and Qualification of Nuclear Power Plant Personnel which endorsed the INPO-managed accreditation program.956 Thus, this item was clarified in NUREG-073798 and new requirements were issued.
ITEM I.A.2.4: NRR PARTICIPATION IN INSPECTOR TRAINING
DESCRIPTION
Based on NUREG-0660,48 the NRR licensing and human factors staff was required to provide supplemental instruction to the OIE inspectors as an addition to the previously established OIE inspector training program. The purpose of such instruction was to focus the inspectors' attention on problems associated with human factors. With such training, it was expected that the inspectors would become more sensitive to such problems and, hence, more apt to initiate corrective action and thereby improve plant safety in this area. This would provide a means of responding to the TMI-related concern on human factors problems for plant operations staff.
The principal benefit to be derived from NRR participation in OIE inspector training was the improvements the inspectors would gain from enhanced training. This training would increase inspector awareness in human factors and personnel-related problems. In areas such as emergency procedures reviews, routine operational practices and hardware-to-human interface deficiencies could be found by inspectors and corrected. The potential significance of this issue was explored by a panel of PNL experts that included three reactor operator license examiners with utility field experience in training as well as general reactor safety.
The panel envisioned that the solution to this issue would be the addition of one week of instruction in human factors to the OIE inspector training course. The staff from NRR would participate in the instruction but would probably rely on a qualified consultant to conduct the majority of the instruction. It was assumed that the principal target of the training would be the resident inspectors. The potential effect of the training upon the OIE review of emergency procedures, plant hardware, and routine practices could be significant, but the overall effect was thought to be limited because of two factors: the short exposure of the inspector to human factors training, and the indirect nature of the safety benefit. That is, a marginal improvement in inspector awareness could result in some corrective actions which would result in some safety improvement. The separation between initial action and the safety benefit complicated assessment of the effectiveness of the proposed resolution of the issue.
PNL estimated64 a human-error rate reduction of 2% for operators and maintenance personnel (operations staff assumed most likely to affect plant safety). This was an overall industry-wide estimate; some isolated actions could be highly significant. PNL estimated the cost for this additional training to be about $1,000.
Capabilities of inspectors could clearly be improved through the proposed training. There would be an indirect effect on risk, since better-trained inspectors would identify more cost-effective improvements in plant operations. However, there was no reasonable way that the magnitude of the safety significance and cost of the improvements could be estimated quantitatively. This additional training would enhance the capabilities and thus contribute to the effectiveness and efficiency of the NRC in performing its regulatory safety mission. Thus, this training proposal was determined to be a Licensing Issue.
CONCLUSION
This Licensing Issue was resolved in September 1983 with the regionalization of the operator licensing function which provided for training and guidance of the regional operator licensing personnel.956
ITEM I.A.2.5: PLANT DRILLS
DESCRIPTION
The intent of this TMI Action Plan48 item was to upgrade operator training by requiring operating personnel to conduct plant drills during shifts. Normal and off-normal operating maneuvers would be simulated for walk-through drills on a plant-wide basis. Drills would also be required to test the adequacy of reactor and plant operating procedures. This was an effort to reduce the risk of off-normal operating conditions by improving the capability of operators and supervisors to understand and control complex reactor transients and accidents, and also to improve the general capability of an operations organization to respond rapidly and effectively to upset conditions.
PRIORITY DETERMINATION
Assumptions
It was assumed that the frequency of a core-melt incident was 5 x 10-5/RY, based on WASH-1400.16 Also, it was assumed that operator error accounted for 50% of these events, but plant drills would improve operator performance by 2%. In addition, it was assumed that the release associated with a core-melt was the value averaged over the probabilities of the WASH-140016 accident categories for PWRs and BWRs and weighted by the number of PWRs (95) and BWRs (48). This resulted in a total of 2.4 x 106 man-rem/accident. The average remaining plant life was assumed to be 28 years.
Frequency Estimate
Based on the assumptions above, the reduction in the core-melt frequency resulting from plant drills was calculated to be (0.02)(0.50)(5 x 10-5)/RY or 5 x 10-7/RY.
Consequence Estimate
For 143 affected plants with an average remaining life of 28 years, the public risk reduction was estimated to be (5 x 10-7/RY)(2.4 x 106 man-rem)(28 years)(143 reactors) or 4,805 man-rem.
Cost Estimate
Industry Cost: The industry resources required for implementation were estimated to be one man-month/plant. This was the estimated personnel requirement associated with the utility staff time for attendance at the drill, preparation by staff and management, and staff time dedicated to the dissemination of insights gained from the drills. At a cost of $100,000/man-year and with 4.33 weeks/month, this yielded a cost of $8,333/plant. For the 143 affected plants, the cost was estimated to be $1.2M.
The industry resources required annually to participate in the plant drills were estimated to be 2 man-months/plant and included drill attendance, preparation before the drill, and dissemination of information afterward; this cost was $16,660/RY. For the 143 affected plants, this cost was $2.38M/year. Over the average remaining life of 28 years, this cost was estimated to be $67M.
Thus, the total industry implementation and operational cost was $(1.2 + 67)M or approximately $68.2M.
NRC Cost: The total NRC cost to implement the resolution of this issue included NRC staff labor and services of a contractor. Since the activities of the NRC staff and the contractor were to some degree interchangeable, no attempt was made to provide separate estimates so that the total implementation cost was estimated to be $300,000. The annual cost to the NRC was also estimated to be $300,000; again, this was assumed to contain some mixture of staff and contractor expenses. Over the average remaining life of 28 years, the operational cost was estimated to be $8.4M. Therefore, the total NRC implementation and operation cost was $(8.4 + 0.3)M or $8.7M.
Total Cost: The total industry and NRC cost associated with the possible solution was $(68.2 + 8.7)M or $76.9M.
Value/Impact Assessment
Based on an estimated public risk reduction of 4,805 man-rem and a cost of $76.9M for a possible solution, the value/impact score was given by:
CONCLUSION
Based on the above value/impact score, the ranking of this issue would have been low to medium. Because the risk may have been estimated to be well on the conservative side, the issue was given a low priority ranking (see Appendix C). However, ongoing work by DHFS/NRR on the subject was completed in July 1985 and published for information only as NUREG/CR-4258.800 Thus, this item was RESOLVED and no new requirements were established.801
ITEM I.A.2.6: LONG-TERM UPGRADING OF TRAINING AND QUALIFICATIONS
ITEM I.A.2.6(1): REVISE REGULATORY GUIDE 1.8
Items I.A.2.6(1), I.A.2.6(2), I.A.2.6(3), and I.A.2.6(5) were combined and evaluated together.
DESCRIPTION
Historical Background
Item I.A.2.6 of the TMI Action Plan48 called for the long-term upgrading of training and qualifications of operations personnel. The specific paragraphs of this item in NUREG-066048 called for a revision of Regulatory Guide 1.8,226 (ANSI/ANS 3.1),253 in order to incorporate short-term requirements into this issue and any other changes resulting from a national standards effort. Also, it was stated that more explicit guidance regarding exercises in simulator requalification programs would be included in the regulatory guide (Recommendation 8 of SECY-79-330E251) as would qualifications of shift supervisors and senior reactor operators [NUREG-0585,174 Recommendations 1.6(1) and (2)]. In addition, based on the NRC staff review of NRR-80-117,252 recommendations were to be made to the Commission and Commission decisions factored into the regulatory guide or regulation changes. Moreover, appropriate revisions to 10 CFR 55, Operator Licenses, were to be recommended for action by the Commission in order to incorporate the applicable short-term changes plus requirements based on Commission action on SECY-79-330E251 for mandatory simulator training for applicants for licenses (Recommendation 4); mandatory simulator training in requalification programs (Recommendation 7); NRC administration of requalification examinations (Recommendation 9, as modified by the Commission); and mandatory operating tests at simulators (Recommendation 11).
Finally, the Nuclear Waste Policy Act of 1982 (Public Law 97-425, Section 306) authorized and directed NRC to promulgate regulations or guidance for the training and qualification of civilian nuclear power plant personnel. A task force was formed within NRC as a result of this bill. As part of the task force objectives, Items I.A.2.6(1, 2, and 3) were to be addressed.
Safety Significance
A public risk reduction was anticipated as a result of a reduction in core-melt frequency which follows from a reduction in operator error rates. Reduction in operator errors was expected to result from the upgraded training and qualifications which formed the assumed resolution of this issue.
Possible Solutions
The upgrades were assumed to include an increase in time spent in simulator operation, both in training and in requalification. The simulator time was assumed to improve in quality as well as quantity. Emphasis on improvements on the operators' diagnostic capability was felt to be especially important in contributing to a reduction in core-melt frequency. Furthermore, the enforcement activities in terms of NRC-administered examinations and OIE inspection of training programs were likely to emphasize the value of this long-term training and qualification of reactor operators.
PRIORITY DETERMINATION
The numerical assessment of this issue was conducted by PNL staff64 with experience in reactor operator licensing, reactor operation, and general reactor safety, in consultation with General Physics Corporation. General Physics Corporation provided utility training services and had significant experience in reactor simulators, providing procurement and startup assistance, operation and maintenance services, and simulator modifications.
Assumptions
It was assumed that the resolution of this issue would take the form of upgrading utility training and qualification programs that would represent a major enhancement of the training and qualification programs.
It was noted that many of the TMI Action Plan48 items associated with operator training were interrelated and it was, therefore, difficult to assess them independently. For example, this issue was related to I.A.4.1 which addressed the improvement of simulators and provided for more realistic modeling of a plant, whereas this issue, [I.A.2.6(1,2,3,5)], dealt with training improvements, including the enhanced use of existing simulators. Either issue, by itself, would improve operator performance; however, there could have been significant overlaps in improving operator performance if both items were implemented. Even though it was recognized that the total improvement would be less than the sum of the individual contributions when each is assessed separately, the extent of any overlap was not identified here.
Based on engineering judgment, it was estimated by the PNL panel that the resolution of this issue would result in a 30% reduction in operator error rates. The number of plants to which this issue was applicable was assumed to be 95 PWRs and 49 BWRs with average remaining lives of 28.5 years and 27 years, respectively.
For the PNL analysis,64 Oconee-3 was selected as the representative PWR plant. It was assumed that the fractional risk and core-melt frequency reductions for the representative BWR (Grand Gulf-1) would be equivalent to those for the representative PWR. Therefore, the analysis was conducted only for a PWR, but the fractional risk and core-melt frequency reductions were also applicable to a BWR. The dose calculations were based on a reactor site population density of 340 people per square-mile and a typical midwest meteorology was assumed.
Frequency Estimate
Based on the affected accident sequences and the parameters affected by the possible solution, the original core-melt frequencies of 8.2 x 10-5/RY for PWRs and 3.71 x 10-5/RY for BWRs were calculated to be reduced by about 16%.
Consequence Estimate
The associated reduction in public risk was 31 man-rem/RY for PWRs and 37.4 man rem/RY for BWRs, resulting in a total public risk reduction of 132,600 man-rem for all plants.
Cost Estimate
Industry Cost: The resolution of this issue was assumed to be a major enhancement of the training and qualification programs. The programs would have to be upgraded in order to meet the requirements of INPO accreditation. These requirements were assumed to be far-reaching and required significant effort on the part of utility training staffs. The amount of effort would vary among the utilities, depending on the existing state of their programs. The effort to implement the program was estimated by the PNL panel to require 10 to 20 man-years of effort at each plant. The mean value was expected to be shifted toward the lower end since, at the time of this evaluation, many utilities were improving their training programs. A 12 man-year effort was taken as the mean estimate.
Operation under the upgraded programs would require enhanced training activities and more operator time in training; the training staff was estimated to require three additional people. It was assumed the major cost of additional operator time could be estimated from increased time at simulators. It was estimated that 40 hours of simulator time would be added to operator training and requalification. For 20 operators/year passing through these programs, this was equivalent to 800 additional hours. It was further assumed that operators could be trained three at a time on the simulator and that simulator time could be acquired for $600/hour. This additional simulator cost was estimated to be $160,000/year. The industry costs were estimated as follows:
(1) Implementation
(12 man-years/plant)(143 plants)($100,000/man-year) = $173M
(2) Operation and Maintenance
(a) Labor
Training Staff = (3 man-year/RY)(52 man-weeks/man-year)
= 156 man-weeks/RY
Operators = (800 man-hour/RY)/(40 man-hours/man-week)
= 20 man-weeks/RY
Thus, the total labor was 176 man-weeks/RY.
(b) Simulator Time (Operators)
(800 man-hours/RY)/(3 man-hours/simulator-hour) = 267 simulator-hour/RY
Therefore, the industry cost/plant-year for operation and maintenance was given by:
For all affected plants, the total industry cost for operation and maintenance was ($500,000/RY)[(49)(27) + (95)(28.5)]RY or $2,000M.
The total industry cost for implementation, operation, and maintenance of the solution was then $(173 + 2,000)M or $2,173M.
NRC Cost: The NRC effort to implement the resolution of this issue would be significant. It was estimated in NUREG-066048 that 5.4 man-years plus $259,000 would be required. At the time of the evaluation of the issue, some of the development activities had been completed; however, much work remained to be done. The remaining effort was estimated to be 4.5 man-years and $100,000.
The operational activities of the NRC would include reviews of training program, increased inspection, and additional examination. The annual labor for reviews and inspections was estimated to be equivalent to 3 man-years. The principal addition in examinations was assumed to be NRC conduct of a portion of requalification examinations. It was assumed that the NRC would conduct 25% of the requalification examinations and that 20 operators would be requalified at each plant every year. It was estimated that one man-month was required for each plant based on the assumption that the five (25% of 20) operators selected for NRC examination at each plant would be tested at the same time. NRC costs were estimated as follows:
| (1) Implementation | |
| Staff Labor + Other Costs | |
| = (1.4 man-week/plant)($1,600/man-week) + ($100,000/144 plants) | |
| = $3,386/plant | |
| Total cost for all affected plants was ($3,386/plant)(144 plants) or $488,000. | |
| (2) Review of Maintenance and Operation | |
| (a) Review and Inspection = (3 man-year/yr)(52 man-wk/man-yr)/144 plants | |
| = 1.08 man-wk/RY | |
| (b) Examination = (1 man-month/RY)(3.7 man-wk/man-month) | |
| = 3.7 man-wk/RY | |
Thus, the total time spent was 4.78 man-wk/RY.
The cost/plant-year for the review of operation and maintenance was (4.78 man-week/RY)($1,900/man-week) or $9,088/RY. For the 144 affected plants, this cost was ($9,088)[(49)(27) + (95)(28.5)] or $36.6M.
Thus, the total NRC cost for implementation, operation, and maintenance was $(0.488 + 36.6)M or $37.1M.
Total Cost: The total industry and NRC cost associated with the possible solution was estimated to be $(2,173 + 37.1)M or $2,210M.
Value/Impact Assessment
Based on an estimated public risk reduction of 132,600 man-rem and a cost of $2,210M for a possible solution, the value/impact score was given by:
Other Considerations
The total occupational risk reduction was associated only with accident avoidance inasmuch as there was no dose associated with implementation or maintenance of the solution. With a dose of 20,000 man-rem associated with accident cleanup and with the calculated reductions in core-melt frequencies of 1.3 x 10-5/RY and 5.9 x 10-5/RY for PWRs and BWRs, respectively, the total occupational dose reduction associated with accident avoidance was calculated to be 860 man-rem.
CONCLUSION
Although the value/impact score was low, this issue was given a high priority ranking because of the large potential public risk reduction (see Appendix C). Resolution of the issue included the consideration of Items I.B.1.1(6,7) regarding changes to Regulatory Guide 1.8.226
In November 1986, SECY-86-3481043 was submitted to the Commission with recommended revisions to Regulatory Guide 1.8226 to endorse ANSI/ANS 3.1-1981 for the positions of shift supervisor, senior operator, licensed operator, shift technical advisor, and radiation protection manager. These revisions to Regulatory Guide 1.8226 were subsequently approved by the Commission and published in May 1987.1044 Thus, this issue was RESOLVED and new requirements were established.1045
ITEM I.A.2.6(2): STAFF REVIEW OF NRR 80-117
This item was evaluated in Item I.A.2.6(1) above and, in accordance with an RES memorandum,437 was RESOLVED. No new requirements were established.
ITEM I.A.2.6(3): REVISE 10 CFR 55
This item was evaluated in Item I.A.2.6(1) above and, as a result of the Nuclear Waste Policy Act of 1982 (Public Law 97-425), was determined to be covered in Item I.A.2.2.438
ITEM I.A.2.6(4): OPERATOR WORKSHOPS
DESCRIPTION
Historical Background
On the basis of NUREG-0660,48 NRR was required to develop a Commission paper on training workshops for licensed personnel. NUREG-0585,174 the source of this issue, states that the intent of the issue was to conduct seminar-type workshops to exchange information on operations experience between the NRC and licensees and among licensees. This would assist in the improvement of operator performance and in improvements to reactor regulation, both resulting in improved safety. The proposed requirements would have one representative for each shift at each unit attend such a workshop annually.
Safety Significance
It was expected that there would be two potential pathways to improved safety benefit that would emerge from this issue: (1) improved operator performance through the sharing of safety-related experiences; and (2) the effect of improved regulation arising out of interaction between the operators and the NRC attending the workshops. The second pathway was considered to be a second-order effect and very difficult to quantify. Therefore, it was assumed that all the benefit would be derived through the reduction in operator-error rates.
PRIORITY DETERMINATION
Assumptions
It was assumed that major gains in reactor safety would come through the improvement in operator performance, i.e., a reduction in their error rates. There was also a pathway to improve safety by means other than human performance through improved regulations developed from operator input at the workshops. The latter would be extremely difficult to quantify so that only the human error rate-reduction pathway to improved safety was treated.
A panel of PNL experts was assembled and included staff that conduct operator licensing examinations, staff with experience in reactor operations, reactor safety and risk assessment, and the staff responsible for the conduct of the operator feedback workshops for NRR. This panel produced the estimates that formed the basis of this analysis. The analysis was based on the following additional assumptions:
(1) Applicable Plants: 95 PWRs and 48 BWRs.
(2) Selected Analysis Plant: Oconee-3 - representative PWR. It was assumed that the fractional risk and core-melt frequency reductions for the representative BWR (Grand Gulf-1) would be equivalent to those for the representative PWR. Therefore, the analysis was conducted only for a PWR, but the fractional risk and core-melt frequency reductions were also applied to a BWR.
(3) Affected Accident Sequences and Base Case Frequencies: Most sequences were affected. The affected sequences and the base case frequencies are shown in NUREG/CR-2800.64
(4) Affected Release Categories and Base Case Frequencies: All release categories were affected by the resolution. The original base case frequencies were used as given below.
| Oconee-3 | Grand Gulf-1 |
| PWR-1 = 1.10 x 10-7/RY | BWR-1 = 1.09 x 10-7/RY |
| PWR-2 = 1.00 x 10-5/RY | BWR-2 = 3.35 x 10-5/RY |
| PWR-3 = 2.86 x 10-5/RY | BWR-3 = 1.44 x 10-6/RY |
Frequency Estimate
The PNL panel estimated64 the most likely reduction in human error rates for operators due to the conduct of the proposed workshops would be 3%, assuming that the workshops were conducted in the manner perceived, i.e., to focus on data-gathering for the NRC. This reduced the amount of time that could be devoted to inter-licensee sharing of operational experiences which would have had a more direct effect on safety-related operational performance in the plants. The possible reduction ranged from 1% to 10%. If the focus could have been shifted toward the inter-licensee exchange of operational experiences, the most likely reduction in error rate would shift upward; however, it was not expected to exceed 10%.
Consequence Estimate
Based on the PNL estimates and calculations64 and assuming a typical midwest-type meteorology and an average population density of 340 people per square-mile at U.S. reactor sites, the public risk reduction was estimated to be 7,140 man-rem for 143 plants with an average remaining life of 28 years. The occupational dose reduction was minor at a calculated value of 46 man-rem.
Cost Estimate
Industry Cost: The industry resources required for implementation were estimated to be one man-month/plant. This was the estimated personnel requirement associated with the trial workshops that were being conducted. It included utility staff time for attendance at the workshop, preparation by staff and management, and staff time dedicated to the dissemination of insights gained at the workshop. At a cost of $100,000/man-year and with 4.33 weeks/month, this yielded a cost of $8,333/plant. For the 143 affected plants, this cost was estimated to be $1.19M.
The industry resources required annually to participate in the training workshops were estimated to be the same as those for implementation, i.e., one man-month/plant, which included workshop attendance, preparation before the workshop, and dissemination of information afterward. This was equivalent to $8,333/RY. For 143 plants, this cost was estimated to be 143 man-months/year or $1.19M/year. Given the average remaining life of the plants, the operational cost was $33.3M. Therefore, the total industry cost associated with the solution to this issue was $34.5M.
NRC Cost: The NRC cost to implement the resolution of this issue was estimated to be $0.3M and included NRC staff labor and services of a contractor. Since the activities of the NRC staff and the contractor were to some degree interchangeable, no attempt was made to provide separate estimates. The annual cost to the NRC was also estimated to be $0.3M; again, this was assumed to contain some mixture of staff and contractor expenses. Over the average remaining plant life, the operational cost was estimated to be $8.4M. While not specific, these estimates for implementation and operation were firmly based on the experience of conducting the trial workshops. Therefore, the NRC implementation and operation cost was estimated to be $8.7M.
Total Cost: The total industry and NRC cost for the possible solution was estimated to be $(34.5 + 8.7)M or $43.2M.
Value/Impact Assessment
Based on the estimated public risk reduction of 7,140 man-rem and a cost of $43.2M for a possible solution, the value/impact score was given by:
Other Considerations
The accident avoidance cost was estimated by calculating the product of the change in accident frequency (
F) and the estimated cost to the utility of a major accident (A); the latter term was estimated to be $1.65 Billion. Thus, the cost/plant-year was estimated to be:
PWRs: (F)(A) = (7 x 10)($1,650M)/RY = $1,200/RY
BWRs: (F)(A) = (3.2 x 10)($1,650M)/RY = $530/RY
The total cost for all plants was the product of the cost/plant-year, the number of plants (N), and the average remaining life (T) of each type of plant:
(NT)(
F)(A) = $(95)(28.5)(1,200)M + $(48)(27.0)(530)M = $3.9M
CONCLUSION
Because of the extensive number of sequences considered by PNL to be affected by this issue, the base case risk was high at a calculated range from 60 to 73 man-rem/RY. With a value/impact score of 165 man-rem/$M and an estimated risk reduction of 7,140 man-rem, this issue was given a medium priority ranking (see Appendix C).
The staff conducted three workshops and a mail survey in order to evaluate the effectiveness of both mechanisms for obtaining feedback to the NRC from utility operating staffs. The results of these two approaches were documented in NUREG/CR-3739802 and NUREG/CR-4139,803 respectively. The staff concluded that both feedback mechanisms proved to be effective methods of gathering data from operations personnel and did not recommend conducting workshops or surveys on an annual basis; it was preferable to use such mechanisms judiciously when a real need existed.804 Thus, this item was RESOLVED and no new requirements were established.
ITEM I.A.2.6(5): DEVELOP INSPECTION PROCEDURES FOR TRAINING PROGRAM
This item was evaluated in Item I.A.2.6(1) above and, in accordance with an OIE memorandum,379 was RESOLVED. No new requirements were established.
ITEM I.A.2.6(6): NUCLEAR POWER FUNDAMENTALS
DESCRIPTION
Historical Background
This NUREG-066048 item called for NRR to develop requirements for the inclusion of nuclear power fundamentals in the instruction given to reactor operators. This arose out of a concern174 that the 12 weeks of fundamentals training that were being given to operators were insufficient.
Safety Significance
Safety issues that deal with operator training can affect public risk by improvements in the operator safety-related performance. This can lead to a reduction in core-melt frequency and a reduced probabilistic risk.
Possible Solution
The additional nuclear power fundamentals training would add 4 weeks to the training period.
PRIORITY DETERMINATION
In order to assess this issue, a panel of experts was assembled from the PNL staff. This panel was comprised of members experienced in reactor operator licensing, reactor operations, utility field work, and general reactor safety areas. The results of the PNL assessment are contained in NUREG/CR-2800.64
The PNL panel felt there had been significant progress across the industry in the area of instruction in nuclear power fundamentals since the issuance of NUREG0585174 in 1979. Further increase in emphasis on fundamentals was felt to be unlikely to improve operator performance. The trend in operator licensing examinations was to stress operational knowledge and de-emphasize fundamentals. This supported the view that further fundamental training would not add to plant safety.
Frequency/Consequence Estimate
The PNL panel felt that the existing level of instruction in nuclear power fundamentals was adequate. Further emphasis on fundamentals was viewed as not likely to improve operator safety performance. Therefore, there would be no measurable public risk reduction associated with the possible solution to this issue. The PNL panel also saw no reduction in occupational dose associated with the implementation of the solution.
Cost Estimate
Industry Cost: It was assumed that 20 operators would complete the training course each year at every plant. In addition, one full-time instructor was assumed to be required. This yielded 80 man-weeks for the operators and 44 man-weeks for the instructors, or 124 man-weeks/plant overall each year. To implement this practice, an effort equivalent to one year of operation (124 man-weeks) was estimated to be required.
NRC Cost: Implementation of the solution was estimated48 to take 0.4 man-year or approximately 18 man-weeks; no added costs were estimated for operation. The review of the additional instruction could be contained in the existing routine function thereby causing no added expense.
Value/Impact Assessment
Based on the judgment that there would be no risk reduction resulting from this issue, the value/impact score was zero.
CONCLUSION
In view of the fact that it was believed that the existing level of instruction in nuclear power fundamentals was adequate for reactor operators, further emphasis on fundamentals as required by this issue was viewed as not likely to improve operator safety performance. With the resulting value/impact score of zero, this issue was DROPPED from further consideration.
ITEM I.A.2.7: ACCREDITATION OF TRAINING INSTITUTIONS
DESCRIPTION
Historical Background
Based on the requirements of NUREG-0660,48 this item required NRR to complete a study to establish the procedures and requirements for NRC accreditation of reactor operator training programs. The resulting study was to be developed into a Commission paper describing the various options for accreditation.
Safety Significance
There were two aspects to the safety benefit of this issue: (1) the reduction of public risk through the improvement of operator performance, which was expected from the improved training accreditation; and (2) a reduction in occupational exposure, primarily for operators who often supervise maintenance or perform other duties in radiation zones. However, some reduction in routine occupational exposure could also be expected for other operations personnel as a result of the increased awareness by the operators.
Possible Solution
In order to assess this issue, a panel of experts was assembled from the PNL staff. This panel was comprised of members experienced in reactor operator licensing, reactor operations, utility field work, and general reactor safety areas. The panel envisioned the resolution of this issue as the formation of an accreditation board consisting of representatives from the NRC, industry, and academia. This board would develop and apply criteria for accreditation including training programs of utilities, university-related programs, and independent training institutions. While theoretically applying to training for all operations staff, the PNL panel felt the existing thrust was focused on reactor operators. Therefore, this assessment was made assuming only operators would be affected.64
PRIORITY DETERMINATION
Assumptions
The views of the PNL panel included an awareness of the fact that, at the time this issue was evaluated, some training programs were very near to accreditation. Either through association with the universities or through other means of providing high quality instruction, these programs would be likely to acquire accreditation from the board easily. Other training programs were not so well prepared for accreditation and may have required significant effort and expense to upgrade them. Some savings may have been gained for multi-unit sites by sharing costs.
Therefore, the resolution of this safety issue was assumed to be an improvement in operator performance. For some utilities (approximately 10% of the total), this issue essentially had no effect because: (1) their existing training programs would be accredited with little effort; and (2) the quality of their programs was sufficiently high that accreditation would result in no discernible improvement in their operators' performance. Other utilities were expected to see varying degrees of improvement. Those with training programs that were below the accreditation standards were to be brought closer to the high quality enjoyed by the outstanding utilities. Overall, the effect on operator human error was estimated to be a reduction of 10% across the affected portion of the industry. The detailed assumptions for this analysis were as follows:
(1) Applicable Plants: 90% of all plants - 43 BWRs and 86 PWRs, or 129 plants.
(2) Selected Analysis Plant: Oconee-3 - representative PWR. It was assumed that the fractional risk and core-melt frequency reductions for the representative BWR (Grand Gulf-1) would be equivalent to those for the representative PWR. Therefore, the analysis was conducted only for a PWR, but the fractional risk and core-melt frequency reductions were also applied to a BWR.
Frequency/Consequence Estimate
Based on the PNL analysis64 and assuming a typical midwest-type meteorology and an average population density of 340 people per square-mile at U.S. reactor sites, the estimated public risk reduction was 26,180 man-rem.
Cost Estimate
Industry Cost: The PNL panel estimated64 the one-time industry cost to implement the change initially to be in the range of $0.1M to $1M/reactor. Those plants with training programs closer to accreditable status would enjoy the smaller costs. The best estimate for the average plant was taken to be $0.3M. Operation under the accreditation program was estimated to cost between $0.05M and $0.25M/plant annually for additional funding to maintain an accredited training program; the best estimate was $0.1M/plant annually. The following is a breakdown of the industry cost:
(1) Implementation: Approximately 3 man-years ($300,000/plant) to: (1) review accreditation standards; (2) compare the existing utility practices with the developed standards; and (3) plan the necessary upgrades and implement the program upgrades to fulfill the accreditation requirements. For 129 affected plants, this cost was estimated to be $39M.
(2) Operation and Maintenance: $100,000/plant-year for: (1) the time invested by the staff in upgraded training (increased course time, quality, etc.); and (2) instruction upgrade (time, quality, etc.). For 129 affected plants with an average remaining life of 28 years, this cost was estimated to be $360M.
Thus, the total industry implementation, operation, and maintenance cost for the possible solution was estimated to be $399M.
NRC Cost: The NRC cost to implement the accreditation was estimated to be $0.635M which was equivalent to 330 man-weeks to: (1) accredit, predicated on the possibility that INP0 accreditation would not be forthcoming; and (2) develop accreditation standards and regulations for adoption by the industry. The annual operational cost to the NRC was estimated64 to be $100,000 or one man-year for additional OIE efforts to ensure industry maintenance of standards (at all plants). For an average remaining plant life of 28 years, this operation and maintenance cost was estimated to be $2.8M. Thus, the total NRC cost for a solution to this issue was $3.435M.
Total Cost: The total industry and NRC cost associated with the possible solution was $(399 + 3.435)M or $402.4M.
Value/Impact Assessment
Based on an estimated public risk reduction of 26,180 man-rem and a cost of $402.4M for a possible solution, the value/impact score was given by:
Other Considerations
The industry accident avoidance cost was estimated by PNL64 to be $14M. The occupational risk reduction was estimated to be 22,170 man-rem resulting from accident avoidance (170 man-rem) and from operation and maintenance of the solution (22,000 man-rem).
CONCLUSION
Although the value/impact score was low, this issue was given a medium priority ranking (see Appendix C) because of the magnitude of the potential public risk reduction. However, in June 1985, the Commission recognized that the industry had made progress in developing programs to improve nuclear utility training and personnel qualification. As a result, the Commission adopted a Policy Statement on Training and Qualifications which made the training accreditation program managed by INPO the focus of training improvement in the industry.777 Thus, this item was RESOLVED and no new requirements were established.
REFERENCES
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