Lessons from a research reactor director regarding ANSI/ANS-15.4
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Introduction
In April 2016, the Nuclear Regulatory Commission initiated an investigation that led to enforcement proceedings regarding my actions while employed as the research reactor director at Reed College. In the course of those proceedings, the director of the NRC Office of Enforcement made a finding that I had submitted incomplete or inaccurate information to the NRC in 2015. As part of the resolution we reached, I agreed to outline those events so that others can learn from my experience. I also offered to propose a redraft of ANSI/ANS-15.4, Selection and Training of Personnel for Research Reactors, with an aim of making the challenges I encountered less likely to recur for other research reactor directors.
During the spring of 2015, I was running the Reed Research Reactor without a reactor operations manager (ROM). (During this same time period, I also was attempting to care for an ailing parent out of state.) My very capable ROM had been hired by another program, and no qualified replacements who applied were willing to accept the salary offered.
As the Level 2 person (“individual responsible for reactor facility operation,” in the language of ANSI/ANS-15.4) and the designated reviewing official, I was responsible for both granting unescorted access to the reactor facility and certifying the medical fitness of operator license applicants. However, it became clear during the course of the investigation proceedings that the NRC identified issues with information provided concerning determinations of fitness for certain applicants.
The mental health of the candidates I advanced for licensure was the common thread in these investigations. ANSI/ANS-15.4 is the standard that governs the relevant determinations. Based on my experience attempting to reconcile the standard with the language of the medical professionals we retained to assist with these determinations, I have now proposed a revision of ANSI/ANS-15.4 that should make it easier for research reactor directors to communicate with the NRC about candidates who present potential issues in three categories:
- Prescription medication for anxiety and/or depression.
- Suicidal thoughts versus ideation and planning versus suicidal actions.
- Gender identity.
Background
A Level 2 is responsible for certifying the medical fitness of an examinee, reactor operator (RO), or senior reactor operator (SRO). To inform the Level 2’s decision, the examinee, RO, or SRO is required to have a physical completed by a physician. The physician uses the definitions in ANSI/ANS-15.4, Sec. 7, and a self-reported medical history provided by the candidate, RO, or SRO to complete their evaluation. The physician returns a signed certification that the individual is capable of operating a reactor. The process seems straightforward: a physician certifies, and the Level 2 follows the recommendation.
However, as society and medicine evolve, use of the standard has come to be interpreted differently by practicing physicians and by the NRC medical review officer. I presented a possible underlying cause of these diverging opinions at the 2015 Test, Research, and Training Reactor (TRTR) Annual Conference. In the presentation “Are you fit for duty?” (M. Krahenbuhl, D. Corey), we summarized the findings of the Minnesota Multiphasic Personality Inventory (MMPI) results for power plant operators and Reed College operators.
One of the findings is significant with respect to self-reporting mental health diagnosis and treatment: the data in the study indicated that the students at Reed are unusually forthcoming in comparison to power plant operators. For Dr. Corey and for me, as the research reactor director, this raises a challenge, because the students report potential ANSI/ANS-15.4 issues at a far higher rate than their counterparts at a nuclear power plant.
(See text of the proposed redraft of ANSI/ANS-15.4 submitted to the TRTR Working Group at the end note of this article, along with the current version in italics.)
Recommendations
- Have a succession plan and well-trained staff with enough redundancy that the departure of a single individual will not lead to problems if the position remains unfilled for nine months or a year.
- Retain an external, well-informed auditor annually, to help you avoid tunnel vision and isolation.
- Talk with NRC staff if you encounter, as I did, differing interpretations of the ANSI/ANS-15.4 medical certification and monitoring requirements. Document those conversations in writing so there is no doubt that you initiated such exchanges with the agency. Work to develop and maintain a strong working relationship with your inspectors and examiners, and do not assume that a long, productive history with their predecessors will carry forward until you establish a strong relationship anew.
- Adopt the revision to ANSI/ANS-15.4, which I have put forward to the National Organization of Test, Research, and Training Reactors 15.4 Work Group. This revision was drafted with the participation of a forensic psychologist, a forensic neuropsychologist, and an M.D. who is ethics director for a major medical institution.
The proposed revision to ANSI/ANS-15.4 would update the medical terminology used in the standard so that all involved in the process speak a common language. The changes in terminology are drawn from the standard texts those professions rely on in making such determinations: the current editions of the International Classification of Disease (ICD) and the Diagnostic and Statistical Manual of Mental Disorders (DSM).
The proposed revision would also give the medical professional advising you the discretion to determine which subtypes of the diagnostic categories noted might impair functioning and which would not be expected to impair functioning. These determinations are best left to medical professionals—specifically, physicians and doctoral psychologists—who have the requisite training and experience to understand the nuance of each subtype.
With the benefit of that professional determination, each Level 2 should recognize that they are responsible for interfacing with the NRC. The Level 2 must be in good communication with both the medical professionals and the regulatory staff about the conditions of concern so that the agency is adequately apprised of the potential risk and the mitigating measures that provide reasonable assurance of continual professional performance and reliable public safety. We need both the agency and the public to have confidence in what we do.
Conclusions
At the TRTR 2019 Annual Conference, the NRC stated that 5 percent of the NRC is under the age of 30 and 45 percent are able to retire today. Most of us and most of the NRC staff grew up in a society in which even an admission of depression or anxiety could be considered shameful and a sign of weakness. Our new operators have grown up during a time when the discussion and treatment of mental health is accepted, and openness is encouraged as a healthy way to develop and thrive.
Over my 27 years in the TRTR community, I have been outspoken, active, and optimistic. I have served our country in many capacities, not the least of which involved Joint Coordinating Council for Radiation Effects Research inspections in Russia (for which I was arrested by the Russian government) and providing security at the nuclear facility during the 2002 Winter Olympics. I love this industry and am committed to its growth. We need to engage the next generations of students to ensure the future of nuclear research and nuclear energy. Interest at your facilities should be growing, new technology emerging, and new engineers and scientists graduating—ready to take this industry to a new and exciting level. To accomplish that, we need to meet the new generations where they stand, rather than expecting their mental health to mirror that of our parents.
Melinda Krahenbuhl holds a Ph.D. in chemical/nuclear engineering and has worked at the University of Utah, Dow Chemical, and Reed College.
Proposed revisions for ANSI/ANS-15.4, “Selection and Training of Personnel for Research Reactors”
Note: Text in bold is proposed new text to be added. Strikethrough text is proposed text to be deleted. The endnotes give explanations to the suggested revisions; they are not meant as part of the standard’s text itself.
7.1.1 General aspects
The primary responsibility for assuring that qualified personnel are on-duty rests with Level 2. The health requirements set forth herein shall be considered to determine the physical condition and general health of the individual in order to perform certain assigned duties as determined by Level 2. Each requirement should be considered in the context of the certain assigned duties of the individual at the particular facility as related to the consequences of health-induced operational errors endangering public health and safety. The licensee shall retain a licensed physician or doctoral psychologist, or both, to conduct such medical examinations as are necessary to evaluate whether operators and candidates for operator licensure are medically qualified for the duties of operator. The licensee shall provide this standard to each medical examiner conducting such an evaluation on its behalf and also shall provide each medical examiner with the job description and duties of the operator position for which the evaluation is being conducted. It is the responsibility of the Level 2 to assure that the designated medical examiner shall be conversant with this standard.
2007 version of 7.1.1:
The primary responsibility for assuring that qualified personnel are on-duty rests with Level 2. The health requirements set forth herein shall be considered to determine the physical condition and general health of the individual in order to perform certain assigned duties as determined by Level 2. Each requirement should be considered in the context of the certain assigned duties of the individual at the particular facility as related to the consequences of health-induced operational errors endangering public health and safety. The designated medical examiner shall be conversant with this standard.
2016 version of 7.1.1 [identical to 2007 version]:
The primary responsibility for assuring that qualified personnel are on-duty rests with Level 2. The health requirements set forth herein shall be considered to determine the physical condition and general health of the individual in order to perform certain assigned duties as determined by Level 2. Each requirement should be considered in the context of the certain assigned duties of the individual at the particular facility as related to the consequences of health-induced operational errors endangering public health and safety. The designated medical examiner shall be conversant with this standard.
7.2.1 Basis of requirements
The physical condition and the general health of research reactor operators shall be such that they are capable of properly carrying out licensed activities under normal, abnormal, and emergency conditions and are able to perform the associated tasks. Conditions that can cause incapacitation include and are not limited to conditions such as heart disease,i brain injury, neurological disease, mental disorder, diabetes, fainting spells, impaired hearing or vision, and effects of medication.
Many of the conditions indicated above may be accommodated by restricting the activities of the individual, requiring close surveillance of the condition, imposing a medical regime, or requiring a second individual without such restrictions to be present when the individual in question is performing certain assigned duties. As a minimum, the second individual shall be able to shut down the reactor and summon competent help.
2007 version of 7.2.1:
The physical condition and the general health of research reactor operators shall be such that they are capable of properly carrying out licensed activities under normal, abnormal, and emergency conditions and are able to perform the associated tasks. Conditions that can cause sudden incapacitation such as coronary heart disease, stroke, epilepsy, mental disorder, diabetes, fainting spells, impaired hearing or vision, and effects of medication are most serious in solo operation but shall be considered at any research reactor.
Many of the conditions indicated above may be accommodated by restricting the activities of the individual, requiring close surveillance of the condition, imposing a medical regime, or requiring a second individual to be present when the individual in question is performing certain assigned duties. As a minimum, the second individual shall be able to shut down the reactor and summon competent help.
2016 version of 7.2.1 [identical to 2007 version]:
The physical condition and the general health of research reactor operators shall be such that they are capable of properly carrying out licensed activities under normal, abnormal, and emergency conditions and are able to perform the associated tasks. Conditions that can cause sudden incapacitation such as coronary heart disease, stroke, epilepsy, mental disorder, diabetes, fainting spells, impaired hearing or vision, and effects of medication are most serious in solo operation but shall be considered at any research reactor.
Many of the conditions indicated above may be accommodated by restricting the activities of the individual, requiring close surveillance of the condition, imposing a medical regime, or requiring a second individual to be present when the individual in question is performing certain assigned duties. As a minimum, the second individual shall be able to shut down the reactor and summon competent help.
7.2.2(1)(a) Mental alertness, with behavioral and emotional regulation and stability,
2007 version of 7.2.2(1)(a):
Mental alertness and emotional stability,
2016 version of 7.2.2(1)(a) [identical to 2007 version]:
Mental alertness and emotional stability,
7.2.2(2) Freedom from incapacity. The examinee shall be free from a predisposition for incapacity for duty, as determined by a designated medical examiner who shall be a licensed physician or doctoral psychologist acting in consultation with the Level 2, arising from any of the following:
(a) Mental impairment,
(b) Neurological impairment, or
(c) Any condition, habit, or practice that might result in suddenii incapacitation.
2007 version of 7.2.2(2):
(2) Freedom from incapacity. The examinee shall be free of any of the following conditions that are considered by the designated medical examiner and Level 2 as predisposing to incapacity for duty:
(a) Mental or physical impairments,
(b) Any medical, surgical, or other professional treatment,
(c) Any condition, habit, or practice that might result in sudden or unexpected incapacitation.
2016 version of 7.2.2(2) [identical to 2007 version]:
(2) Freedom from incapacity. The examinee shall be free of any of the following conditions that are considered by the designated medical examiner and Level 2 as predisposing to incapacity for duty:
(a) Mental or physical impairments,
(b) Any medical, surgical, or other professional treatment,
(c) Any condition, habit, or practice that might result in sudden or unexpected incapacitation.
7.2.3(5) Mental condition. An established clinical diagnosis as described in the current edition of the International Classifications of Disease - XX F Mental, Behavioral, and Neurodevelopment Disorders (ICD-11 F01-99)iii and/or the Diagnostic and Statistical Manual of Mental Disorders, fifth edition (DSM-5) shall be evaluated to determine whether it clearly and directly negatively impacts or limits those mental, emotional, behavioral, and cognitive abilities, behaviors, and skills necessary for the continuous safe and competent discharge of duties and responsibilities. Specific diagnostic codes are listed when appropriate; however, the designated medical examiners, who shall be licensed physicians or doctoral psychologists in consultation with the Level 2, shall use their professional judgment when making determinations of mental health conditions of operators and shall identify the extent to which essential job functions may be negatively impacted.iv The following conditions should be so evaluated:
(a) Any psychological or mental condition that could cause impaired alertness, impulse control, judgment, or sensory or motor ability. Significant emotional or behavioral problems that have been identified and that impact essential job functions shall require thorough clinical evaluation that may include psychological testing and psychiatric evaluation. Operators that have established ongoing care for a clinical diagnosis shall provide written confirmation from a licensed mental health professional detailing treatment including rehabilitation, psychotherapy, and prescription medication used to treat the symptoms of the psychological or mental condition,
(b) A personality disorder that is severe enough to have repeatedly manifested itself by overt bizarre, disruptive, or similar acts, unless the condition has been relieved and certified as stable and resolved. Personality disorders that qualify are ICD-11 F60-63 and F65-F69. Operators that have established ongoing care for a clinical condition shall provide written confirmation from a licensed physician or doctoral psychologist detailing treatment, including rehabilitation, psychotherapy, and/or prescription medication. Otherwise, the disorder shall be disqualifying for all operations,
(c) History of suicidal plans, gestures, or attempts, ICD-11 R 45.851, shall be disqualifying for all operations,
(d) History of psychotic disorders, ICD-11 F20-29, Schizophrenia, schizotypal, delusional, and other mental disorders that clearly impact mental, emotional, behavioral, and cognitive abilities, behaviors, and skills necessary for the continuous safe and competent discharge of duties and responsibilities shall be disqualifying for all operations,
(e) Alcohol Use Disorder, unless treated and corrected, shall be disqualifying for all operations,
(f) Substance Use Disorder of drugs other than alcohol, tobacco, or ordinary caffeine-containing beverages, as evidenced by nonprescribed habitual use of the drug, unless the condition is treated and corrected. Otherwise, abuse shall be disqualifying for all operations;
2007 version of 7.2.3(5):
(5) Mental condition. An established history or clinical diagnosis of any of the following:
(a) Any psychological or mental condition that could cause impaired alertness, judgment, or motor ability. Clinically significant emotional or behavioral problems shall require thorough clinical evaluation that may include psychological testing and psychiatric evaluation,
(b) A personality disorder that is severe enough to have repeatedly manifested itself by overt bizarre, disruptive, or similar acts, unless the condition has been relieved and certified. Otherwise, the disorder shall be disqualifying for all operations,
(c) History or threat of suicide attempt shall be disqualifying for all operations,
(d) History of a psychotic disorder shall be disqualifying for all operations,
(e) Alcohol abuse or dependence, unless treated and corrected, shall be disqualifying for all operations,
(f) Abuse of drugs other than alcohol, tobacco, or ordinary caffeine-containing beverages, as evidenced by nonprescribed habitual use of the drug, unless the condition is treated and corrected. Otherwise, abuse shall be disqualifying for all operations;
2016 version of 7.2.3(5) [identical to 2007 version]:
(5) Mental condition. An established hhistory or clinical diagnosis of any of the following:
(a) Any psychological or mental condition that could cause impaired alertness, judgment, or motor ability. Clinically significant emotional or behavioral problems shall require thorough clinical evaluation that may include psychological testing and psychiatric evaluation,
(b) A personality disorder that is severe enough to have repeatedly manifested itself by overt bizarre, disruptive, or similar acts, unless the condition has been relieved and certified. Otherwise, the disorder shall be disqualifying for all operations,
(c) History or threat of suicide attempt shall be disqualifying for all operations,
(d) History of a psychotic disorder shall be disqualifying for all operations,
(e) Alcohol abuse or dependence, unless treated and corrected, shall be disqualifying for all operations,
(f) Abuse of drugs other than alcohol, tobacco, or ordinary caffeine-containing beverages, as evidenced by nonprescribed habitual use of the drug, unless the condition is treated and corrected. Otherwise, abuse shall be disqualifying for all operations;
7.2.3(6) Medication. Any medication taken in such a manner or dosage that the taking or temporary delay of taking would be expected to result in high likelihood of suddenv incapacitation.
2007 version of 7.2.3(6):
(6) Medication. Any medication taken in such a dosage that the taking or temporary delay of taking might be expected to result in high probability of sudden incapacitation.
2016 version of 7.2.3(6) [identical to 2007 version]:
(6) Medication. Any medication taken in such a dosage that the taking or temporary delay of taking might be expected to result in high probability of sudden incapacitation.
Additionally, the following appendix is recommended for inclusion in ANSI/ANS-15.4.
APPENDIX: The following DSM-5 diagnoses include subtypes of disorder that reasonably could or would impair the essential mental, emotional, behavioral, and cognitive capacities required to safely and effectively dispatch relevant job duties. Each category of disorder listed here contains subtypes that might or might not reasonably impair functioning, depending on type and severity; this determination is best left to the examining clinician(s).
- Neurodevelopmental disorders;
- Schizophrenia spectrum and other psychotic disorders;
- Bipolar and related disorders;
- Depressive disorders;
- Anxiety disorders;
- Obsessive-compulsive and related disorders;
- Trauma and stressor-related disorders;
- Dissociative disorders;
- Sleep-wake disorders;
- Disruptive, impulse-control, and conduct disorders;
- Neurocognitive disorders;
- Substance-related and addictive disorders;
- Paraphilic disorders;
- Medication-induced movement disorders;
- Personality disorders.
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i“Heart disease” is a more comprehensive term, in that it includes coronary artery disease and also heart failure and rhythm problems that can cause incapacitation.
iiThe standards committee should determine whether the qualification “sudden” is necessary. There is a subjectivity element to this which can be argued—similar to “urgent” versus “emergent.”
iiiICD-11 will not be implemented until 2022.
ivThis recommended change places the burden for determining licensed operator medical qualification on the designated medical examiner (a licensed physician or doctoral psychologist) “acting in consultation with the Level 2.” The responsibility for ensuring that the medical examiner is “conversant with [the ANSI/ANS] standard” continues to rest with the licensee (typically via the Level 2), as provided in Sec. 7.1.1, “General aspects.” If this approach is considered and adopted by the standards committee, Sec. 7.1.1 should clarify that it is the sole responsibility of the licensee to ensure that the medical examiner fully understands (1) the requirements of the ANSI/ANS standard and (2) the nature and assigned duties of the licensed operator, as determined by the Level 2. The proposed change to Sec. 7.1.1 is intended to provide that clarity.
vSee endnote ii, above, addressing the necessity of the qualification “sudden.”