Resolution of Generic Safety Issues: Task I.A.3: Licensing and Requalification 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) upgrade the requirements and procedures for nuclear power plants operator and supervisor licensing to assure that safe and competent operators and senior operators are in charge of the day-to-day operation of nuclear power plants; and (2) increase the requirements for initial issuance of licenses and for license renewals and provide closer NRC monitoring of licensed activities.
ITEM I.A.3.1: REVISE SCOPE OF CRITERIA FOR LICENSING EXAMINATIONS
DESCRIPTION
This NUREG-066048 item called for NRR to notify all operator license holders and applicants of the new scope of examinations and criteria for issuance of reactor operator (RO) and senior reactor operator (SRO) licenses and renewal of licenses. Simulator examinations were to be included as part of the license examination. As a result of Public Law 97-425, it was determined that additional staff work on the issue was required and a proposed rule for operator licensing was presented to the Commission in SECY-84-76.593 Approval of this rule was expected to effectively close out this item.
CONCLUSION
This item was clarified in NUREG-073798 and new requirements were established.
ITEM I.A.3.2: OPERATOR LICENSING PROGRAM CHANGES
DESCRIPTION
This NUREG-066048 item called for NRR to take the following actions:
(1) Develop and implement a plan to relocate Operator Licensing Branch (OLB) examiners at Nuclear Power Plant Simulator Training Centers or in Inspection and Enforcement Regions.
(2) Conduct a study of the staffing of the operator licensing program and the qualifications and training of examiners.
(3) Develop and implement a plan to report operator errors and to act on operator errors with respect to continuation of licensing.
In response to the above actions, the following were accomplished:
(1) The administering of examinations and issuance/renewal of operator licensing were transferred to Region III in FY 1982 and to Region II in FY 1983. As a result of these changes, all regions had operator licensing authority in FY 1984. NRR provided oversight and guidance, including examination procedures and criteria.88
(2) A study of the staffing of the operator licensing program and the qualifications and training of examiners was completed in November 1980 and documented in NUREG/CR-175O.89 Examiner standards were published in NUREG-1021.962
(3) A plan for reporting operator errors and for acting on operator errors with respect to continuation of licensing was developed in NUREG/CR-1750.89 However, after review of this recommended plan, DHFS/NRR concluded that no further action was required.440
CONCLUSION
This item was RESOLVED and no new requirements were established.956
ITEM I.A.3.3: REQUIREMENTS FOR OPERATOR FITNESS
DESCRIPTION
Historical Background
This NUREG-066048 item called for the staff to develop a regulatory approach to: (1) provide assurance that applicants for RO and SRO licenses were psychologically fit; and (2) prohibit licensing of persons with histories of drug and alcohol abuse or criminal backgrounds. The regulations were to be applied to all operating and future power plants.
A proposed rule addressing alcohol and drug use and the broader issue of fitness for duty of operating licensee personnel and contractors was forwarded to the EDO on April 16, 1982, with the concurrence of several NRC offices. The proposed Fitness for Duty Rule was issued for public comment in the Federal Register on August 15, 1982, with the public comment period extending to October 5, 1982. A final rule package was completed on December 1, 1982, and a final rule was expected to be published by April 1, 1983. The rule, when promulgated, would have required facilities licensed under 10 CFR 50.21(b) or 10 CFR 50.22 to establish and implement adequate written procedures to provide reasonable assurance that persons with unescorted access to protected areas of nuclear power plants, while in those areas, are not under the influence of alcohol, other drugs, or otherwise unfit for duty due to mental or physical impairments. Secondly, a proposed rule amending 10 CFR 73.56 regarding access authorization for nuclear power plants had not been completed, although a value/impact analysis in support of the proposed rule had been prepared. Staff studies of the issue were published in NUREG/CR-2075289 and NUREG/CR-2076.290
Safety Significance
There could be significant damage if impaired personnel were performing critical safety operations. Legal and institutional problems could limit a thorough implementation of the proposed program. Given that there was an adequate program implemented at all power plants and integrated into overall plant operations, the new program would reduce operator error which, in turn, would lower the risk associated with operation of the plants.
Possible Solutions
This issue had two components: the first involved initial access to protected areas of nuclear power plants and the second involved continuing fitness for duty once initial access has been granted. The proposed Fitness for Duty Rule, issued for public comment on August 15, 1982, was directed toward the second component of this issue, mandating behavioral observation programs for power plants licensed by the NRC. Behavioral observation was also a part of the proposed Access Authorization Rule directed toward the first component of this issue.
The second component of this issue dealt with limiting access of psychologically unstable individuals to vital plant areas. This component was expected to have a major cost impact on the industry because this access authorization program was comprehensive in that it was aimed at limiting the access to vital plant areas of disgruntled employees, psychologically unsuitable employees, as well as personnel under the influence of drugs or alcohol.
The access authorization program had the following three parts: (1) background search; (2) psychological assessment; and (3) behavior observation. The first two parts would occur prior to granting an individual an unescorted access authorization to protected and vital areas, and the last part would be an ongoing activity for individuals who have been granted an unescorted access authorization. The background check would examine an individual's past for unstable activities, a criminal record, credit problems, and previous employment problems. It was established by NRC personnel that data on psychological screening showed that 2% to 3% of white-collar workers were identified as unstable and, for blue-collar employees, the rate ranged from 7% to 10%. These figures provided the background for the assumptions made in the evaluation below.
PRIORITY DETERMINATION
This issue was assessed by PNL64 in consultation with a number of engineers with expertise in reactor operator licensing, reactor operations, utility field work, and general reactor safety areas.
Assumptions
The major result of this issue was assumed to be a reduction in operator error. For some utilities, this new system would result in some reduction in operator error whereas, in others, it would have no discernible effect. Based on engineering judgment, an average of 2% was arrived at by PNL to apply to all operating and future plants. Thus, this issue assumed the implementation of the access authorization system at all 134 plants, either under construction (63) or in operation (71), with average remaining lives of 28.8 years for 90 PWRs and 27.4 years for 44 BWRs. Thus, the total remaining life of the affected plants was [(28.8)(90) + (27.4)(44)]RY or 3,798 RY. Neither the implementation, operation, or maintenance of the solution would involve any changes in occupational dose.
For the analysis performed by PNL,64 Oconee-3 was taken as the 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 Estimate
All release categories were affected by this issue, but the principal Release Categories affected by the solution were 3, 5, and 7; the numerical calculations were based on these categories. The calculated64 reductions in core-melt frequency were 4 x 10-7/RY for PWRs and 1.8 x 10-7 /RY for BWRs.
Consequence Estimate
The dose calculations were based on a reactor site population density of 340 people per square-mile and a typical midwest meteorology. Based on the above core-melt frequency reduction and Release Categories, the total estimated public risk reduction was 16,000 man-rem. The occupational risk reduction for implementation, operation, and maintenance was zero.
Cost Estimate
Industry Cost: A value/impact analysis in support of the anticipated Access Authorization Rule had been prepared by the staff and industry cost estimates had been developed. These cost estimates, which were reviewed and accepted by the Atomic Industrial Forum (AIF), were as follows:
(1) For all operating plants, the implementation cost was $140,000/plant and included the preparation of plant and associated procedures ($33,000), licensee management and clerical staff ($63,000), training to implement the behavioral observation program ($34,000), and storage for files ($10,000). The total industry implementation cost for operating plants was $(140,000)(71) or $9.94M.
(2) For all future plants (at which none of the employees were to be grandfathered), the implementation costs were estimated to be $590,000/plant. In addition to the costs noted above for operating plants, this implementation cost included background investigations ($375,000), review process and appeals procedures ($36,000), increased file storage requirements ($30,000), and miscellaneous criminal checks with the FBI, etc. ($9,000). The total industry cost for future plants was ($590,000)(63) or $37.2M.
(3) The cost of operating of the access authorization system at each plant was estimated to be $300,000/year. This cost included background investigations for new people as a result of employee turnover ($94,000), professional management and clerical staff ($63,000), a review and appeal process ($67,000), refresher training for old supervisors ($19,000), training of new supervisors ($9,000), plan maintenance and updates ($8,000), file storage ($39,000), and criminal history checks with the FBI for new people ($2,000). The total industry cost for operation and maintenance of the access authorization system was ($0.3M/RY)(3,798 RY) or $1,140M.
The total industry cost for the possible solution was $[9.94 + 37.2 + 1,140]M or $1,187M.
NRC Cost: Further development and issuance of the proposed plan was estimated to take 1.5 man-years; at a rate of $100,000/man-year, the cost for this effort was $150,000. The review and modification of the utilities' implementation plans was estimated to take 1.5 man-years. For the 134 affected plants, this amounted to 0.6 man-week/plant. At a cost of $2,270/man-week, the implementation cost was $182,500. Review of the operation and maintenance of the possible solution was estimated to require 1 man-week/RY for all plants. At a cost of $2,270/man-week, the total operation and maintenance of the solution was $8.6M. Thus, the total NRC cost for the possible solution was $[0.15 + 0.1825 + 8.6]M or $8.9M.
Total Cost: The total industry and NRC cost associated with the possible solution was $(1,187 + 8.9)M or $1,196M.
Value/Impact Assessment
Based on an estimated public risk reduction of 16,000 man-rem and a cost of $1,196M for a possible solution, the value/impact score was given by:
Other Considerations
It was estimated by cognizant NRC personnel that the Fitness for Duty Rule would have a negative cost impact on operating licensees in the long run. The staff estimated that initial licensee burden to develop written procedures required by the rule would be approximately 1,200 man-hours over a six-month period at a total cost between $50,000 and $75,000, if no fitness for duty program existed at a licensee's facility. While utilities such as TVA claimed that alcohol abuse alone cost them approximately $18.5M annually, fitness for duty programs of the type envisioned by the Fitness for Duty Rule were expected to save costs through quicker identification of employees not fit for duty and through assisting these employees, in whom considerable resources had been invested, in returning to high levels of productivity.
Nationwide, absenteeism due to alcohol and drug abuse cost U.S. industries an average of $300 annually for every worker. Alcohol drug-abusers lose an additional 25% of their productive time when on the job, at an average annual cost to U.S. industries of approximately $2,900/abuser. At the time this issue was evaluated, the total annual cost to U.S. industries was between $12 Billion and $15 Billion. Wrich, in "The Employee Assistance Program; Updated for the 1980's," Hazelden, 1980, reported that U.S. industries received a return of $10 in decreased absenteeism, accidents, and increased productivity for every dollar spent on fitness for duty.
CONCLUSION
Although the estimated risk reduction was 16,000 man-rem and the value/impact score was only 13.4 man-rem/$M, this issue was given a high priority ranking (see Appendix C) because of its advanced state of completion.
On October 24, 1984, the Commission notified the staff that it would not promulgate a rule on fitness for duty for a minimum of two years but would issue a policy statement on the subject. A proposed policy statement was submitted to the Commission in SECY-85-21.963 In a separate action, a notice withdrawing the final Fitness for Duty Rule was submitted to the Commission in SECY-85-21A.964 The proposed policy statement (SECY-85-21963) was reaffirmed by the staff in SECY-85-21B.965 In recognition of the industry's efforts in establishing fitness for duty programs, the Commission approved a Policy Statement967 in July 1986. Thus, this issue was RESOLVED and no new requirements were established.956
ITEM I.A.3.4: LICENSING OF ADDITIONAL OPERATIONS PERSONNEL
DESCRIPTION
Historical Background
This NUREG-066048 item sought to upgrade the operations performance in nuclear power plants by imposing licensing requirements upon other operations personnel in addition to ROs and SROs.
Safety Significance
It was possible that, by undergoing licensing, personnel such as managers, engineers, and technicians would be better qualified and less likely to commit errors in performing their functions.
Possible Solution
A study could be undertaken to determine which, if any, personnel should be licensed. Licensing would then be required by the NRC for those additional personnel.
PRIORITY DETERMINATION
Assumptions
It was estimated that the effects of resolution of this issue would be minimal for many utilities since there were existing practices that went a long way toward ensuring that qualified and trained individuals were in responsible positions. It was assumed that additional licensing requirements would produce some improvement by assisting in the screening of potentially poor performers from the operations staff. The net effect was estimated to be equivalent to a 2% reduction in human error rates for reactor operators and maintenance personnel.64
Frequency Estimate
Based on the 2% reduction in human error rate, the Oconee 3 (representative PWR) risk equation parameters were adjusted. All Accident Sequences except V were assumed to be affected and all Release Categories were affected. The reduction in core-melt frequency for Oconee 3 was calculated to be 1.4 x 1O-6/RY. The reduction in core-melt frequency for Grand Gulf 1 was then calculated by assuming that the fractional core-melt frequency reduction for the representative BWR would be equivalent to the fractional reduction for a PWR. Therefore, since the Oconee-3 fractional reduction was 0.017, the core-melt frequency reduction for Grand Gulf-1 was calculated to be 6.3 x 10-7/RY.
Consequence Estimate
The corresponding reduction in public risk for Oconee-3 was calculated to be 2.4 man-rem/RY and the public risk reduction for Grand Gulf-1 was calculated to be 2.7 man-rem/RY. The total risk reduction for each type of plant was given as follows:
PWRs: (28.5 yrs)(95 reactors)(2.4 man-rem/RY) = 6.5 x 103 man-rem
BWRs: (27 yrs)(49 reactors)(2.7 man-rem/RY) = 3.6 x 103 man-rem
Therefore, the total risk reduction for this issue was 1.01 x 104 man-rem.
Cost Estimate
Industry Cost: It was assumed that the required additional effort to license the majority of the operations personnel at a plant would be roughly equivalent to the existing licensing efforts for ROs and SROs; this was estimated to be $250,000/plant. For operation, industry would have to provide new training staff, staff time for training and exams, and administration; this was estimated to be $50,000/RY. Therefore, the total industry cost was $250M.
NRC Cost: To implement the solution, qualification criteria, licensing exams, and procedures would have to be prepared and would be a major undertaking. The implementation cost was estimated to range from $20M to $50M; for analysis purposes, $35M was used. To operate with the new licensing requirements, 50 additional staff members would be required at a total cost of $5M/year. To perform the annual operational needs of the program, funds would be needed for travel, publications, etc. This was estimated to be an additional $2M/year. Therefore, the total NRC cost was approximately $240M.
Total Cost: The total industry and NRC cost associated with the possible solution was $(250 + 240)M or $490M.
Value/Impact Assessment
Based on an estimated public risk reduction of 10,100 man-rem and a cost of $490M, the value/impact score was given by:
Uncertainty
Because the estimate of the value/impact score relied heavily on the estimated value of the possible reduction in human error rate, the effective improvement could vary significantly.
Other Considerations
DHFS/NRR had been pursuing this issue and the Commission concluded181 that licensing of managers should not be required. The other portion of the issue (i.e., licensing of other personnel - engineers, maintenance personnel, etc.) was still under study and was to be concluded in FY 1983.
CONCLUSION
Although the value/impact score was low, the potential risk reduction was considered and this issue was given a medium priority ranking (see Appendix C). However, in February 1985, the staff determined that there was insufficient evidence to support the licensing of additional plant personnel.778 Thus, this item was RESOLVED and no new requirements were established.
ITEM I.A.3.5: ESTABLISH STATEMENT OF UNDERSTANDING WITH INPO
DESCRIPTION
As part of the overall evaluation of the TMI incident, it was determined48 that a statement of understanding was needed to address the mutual intent of NRC and INPO concerning the extent to which NRC should review or rely upon training, certification, and other INPO activities. Consideration was also to be given to providing alternative mechanisms for industry to inform NRC of its general progress on needed safety reforms. It was intended that the statement of understanding would provide a basis for evaluation of any safety reforms or programs. Since there was no direct risk that could be attributed to this issue, it was considered to be a Licensing Issue.
CONCLUSION
A Memorandum of Agreement148 between INPO and NRC was issued in April 1982; however, it did not specifically address training and certification. Following further revision, the EDO agreed594 with the Coordination Plan for NRC/INPO Training-Related Activities (Appendix Four to the Memorandum of Agreement) in November 1983. With the issuance of the Memorandum of Understanding, this Licensing Issue was resolved.
REFERENCES
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