Adequacy of On-shift Operating Experience for near Term Operating License Applicants (Generic Letter No. 84-16)

                                UNITED STATES
                       NUCLEAR REGULATORY COMMISSION 
                          WASHINGTON, D, C. 20555 

                               June 27, 1984 

TO ALL LICENSEES OF OPERATING REACTORS, APPLICANTS FOR OPERATING LICENSE, 
AND HOLDERS OF CONSTRUCTION PERMITS  

Gentlemen: 

SUBJECT:  ADEQUACY OF ON-SHIFT OPERATING EXPERIENCE FOR NEAR 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 
letter in which the Commissioners presented their views on the subject of 
adequacy of on-shift operating experience for near-term operating license 
applicants.  This letter is enclosed and is applicable for near-term 
operating license applicants. 

The June 14, 1984 letter accepted, with some clarifications, an Industry 
Working Group 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 for use of shift advisors. Beyond that 
date, utilities should plan to have sufficient operating experience on-shift 
such that there no longer is a need to rely on the use of shift advisors. We
understand, of course, that circumstances may arise, beyond the control of 
the utility, which would mandate the use of advisors to cover one or more 
shifts, but these circumstances can be treated on a case-by-case basis. 

The acceptance of these experience requirements by the NRC does not alter 
the guidance for eligibility, included in Regulatory Guide 1.8 and 
NUREG-0737, for RO and SRO licensing examination candidates.  Further, 
acceptance of the Industry Working Group proposal does not foreclose the 
development of any long term requirements for crew operating experience. 

We understand that each utility is in possession of a copy of the Industry 
Working Group proposal of February 24, 1984. Copies are also available from 
the NRC Public Document Room. 

This letter contains no reporting requirement and is for information only. 

                              Sincerely,  


                              Darrell G. Eisenhut, Director 
                              Division of Licensing 

Enclosure: 
Ltr of June 14, 1984  



8406270142 

.

                               UNITED STATES
                       NUCLEAR REGULATORY COMMISSION
                          WASHINGTON, D.C. 20555 

                              June 14, 1984 

Mr. J. H. Miller, President
Georgia Power Company 
P. O. Box 4545 
Atlanta, Georgia 30302 

Dear Mr. Miller: 

The Commission appreciates the efforts you and the other members of the 
Industry Working Group put forth in developing the proposal you presented to
us on February 24, 1984, to assure the adequacy of on-shift operating 
experience for near-term operating license applicants. The level of utility 
participation in developing and supporting this proposal clearly reflects 
the needed degree of involvement by senior utility management to assure 
sound implementation. 

The industry proposal recognizes that the use of shift advisors to 
supplement plant experience depends upon the adequacy of the training of 
advisors and their integration into the shift crew. It is particularly 
important where advisors are used that there is a management commitment to 
(1) provide plant specific training for shift advisors which includes plant 
procedures, technical specifications, plant systems, and where available, 
time for use of a plant simulator, and (2) training for the remainder of the 
shift crew on the role of advisors. Furthermore, the industry proposal 
recognizes the desirability of phasing out the use of shift advisors as soon 
as is practically achievable, but proposed no specific date for terminating 
the use of advisors. 

The Commission accepts the Industry Working Group proposal with the 
following clarifications: 

With regard to the shift crews that meet the industry experience proposal: 

     1.   The Hot Participation Experience tabulated in your slide 5 should 
          be at a large, same type plant. 

     2.   The use of an SRO-licensed STA to satisfy the Hot Participation 
          Experience is acceptable provided that the STA serves as a member 
          of the shift. 
.

Mr. J. H. Miller                     -2- 

With regard to the use of shift advisors: 

     1.   The shift advisors that have at least one year on shift as a 
          licensed SRO at an operating plant of the same type are 
          acceptable. Proposals to utilize an individual as an advisor who 
          has only an RO license will be evaluated on a case-by-case basis 
          to assure that an appropriate level of knowledge and supervisory 
          experience has been accumulated. 

     2.   The utility-administered examinations for advisors should include 
          both oral and written examinations. If no plant-reference 
          simulator is available, a board of at least three individuals, 
          qualified at the SRO level, should conduct the oral examination. 

     3.   The utility should provide the NRC with a list of certified 
          advisors and their qualifications. The NRC staff should be 
          notified one month prior to their release from the plant to which 
          they are assigned. 

Based upon operating experience, information submitted by individual 
utilities since the February 24, 1984 meeting, it appears that use of shift 
advisors may be required only at one plant now anticipating fuel load after 
March of 1985. Further, we understand that this utility is making plans to 
obtain necessary operating experience for its licensed operators prior to 
fuel load. Accordingly, it appears that March 31, 1985 would be an 
acceptable date beyond which utilities should plan to have sufficient 
operating experience on shift such that there no longer is a need to rely on 
the use of shift advisors. We understand, of course, that circumstances may 
arise, beyond the control of the utility, which would mandate the use of 
advisors to cover one or more shifts, but these circumstances can be treated 
on a case-by-case basis. 

The Commission believes that the industry proposal with the above 
clarifications will provide reasonable assurance of adequate on-shift 
operating experience pending any further rulemaking the Commission might 
choose to complete. The Commission is therefore issuing a generic letter to 
all licensees which outlines this policy. The acceptance of these experience
requirements by the NRC does not alter the guidance for eligibility, 
included in Regulatory Guide 1.8 and NUREG-0737, for RO and SRO licensing 
examination candidates. Further, acceptance of this proposal is not intended 
to foreclose any long term 
.

Mr. J. H. Miller                     -3- 

requirements for crew operating experience which the staff may develop for 
Commission consideration that would apply to operating plants. 

Commissioner Asselstine adds: 

     I disagree with two aspects of the Commission's decision on the matter 
     of shift experience requirements. First, I do not believe that the "hot
     participation experience" element in the industry proposal is adequate.
     I would only eliminate the requirement for a shift advisor if one 
     licensed senior reactor operator on the shift has at least one year's 
     prior experience as a licensed SRO at a similar plant. Without at least
     that amount of prior operating experience on the part of the shift 
     crew, it seems prudent to me to require a shift advisor with that level 
     of experience. Second, I believe that the matter of shift experience 
     requirements should not be handled by means of a generic letter but 
     rather should be the subject of a Commission policy statement. In my 
     view, the Commission should have prepared a proposed policy statement 
     on the subject and should have sought industry and public comment on 
     it. 

 Commissioner Gilinsky adds: 

     Every recipient of this letter should understand its full implications.
     In pressuring the Commission to accept a feeble approach toward shift 
     experience requirements at a few plants nearing operation, the industry
     is jeopardizing its long standing safety record. I do not think I have 
     to underline what that means. 

     I would remind you that the original NRC staff proposal that at least 
     one member of a shift have one year of previous licensed operating 
     experience -- was very modest, as any experienced shift supervisor will
     tell you. It is also feasible -- I have attached an NRC staff 
     memorandum on the number of experienced operators available. The 
     suggestion that it is sufficient for the most senior person on shift to 
     have six months of "hot participation", of which only six weeks need be 
     at power, is simply ridiculous. The Commissioners who approved this 
     approach may not realize what they have done, but you do. It says to me 
     the industry is not yet capable of policing its members. 
.

Mr.  J. H. Miller                    -4- 

     I do not agree with the way the advisor issue is being handled, in 
     particular the decision of the Commission not to require that advisors 
     pass the equivalent of the two-day NRC SRO examination. I am not at all
     impressed by the two hour quiz administered by the utility seeking an 
     operating permit. There are cases, and this is one of them, where going
     half-way is worse than doing nothing. Rather than have advisors whose 
     knowledge of the plant is in question, it would be better to have no 
     advisors at all. Inexperienced supervisors may well disregard their 
     training to follow the advice of an advisor installed by the NRC. If 
     the advisor does not know the plant specifications and limitations, we 
     could get into serious trouble. 

     Finally, the Commission's disregard of its existing regulation on 
     operator experience at new plants, 10 CFR 55.25(b), and its General 
     Counsel's advice on that point, does not encourage respect for the 
     system of safety regulation. Neither does the Commission's promulgation
     of a major policy decision by means of an informal letter which three 
     Commissioners voted not to discuss in public. 

Thank you again for your efforts toward resolving this issue. 

                              Sincerely, 


                              Nunzio J. Palladino 

Enclosure: 
Memo dtd. 3/8/84 
 from W.J. Dircks 
 to Cmr. Gilinsky 
 (per Cmr. Gilinsky's 
 additional views)
.