ML19317H516

Discusses NUREG/CR-1280 Re Power Plant Staffing.Util Has Neither Unlimited Funding Nor Unlimited Supply of People to Implement Sys Which Navy Has Developed.Lists TMI-related Aspects Which Have Been Overlooked

ML19317H516
Person / Time
Site:	Point Beach
Issue date:	06/05/1980
From:	Suttner T AFFILIATION NOT ASSIGNED
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-CR-1280 NUDOCS 8006120307
Download: ML19317H516 (6)

Text

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15615 St. Hwy 42 Two Rivers, WI 54241 June 5, 1980 Mr. Harold R. Denton, Director -

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Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D.C. 20555

Dear Mr. Denton:

NUREG/CR-1280 After reviewing the subject report on power plant staffing, I should like to submit my comments on the document. This report gives the impression to many individuals who have perused it, that after being out of the Navy for 20 years and working for a public utility, that we would not particularly return to the Navy. I am presently a licensed Reactor Operator at the Point Beach Nuclear Plant and have been employed at this facility since 1969. In the 11 years since my employment at the plant, I have seen a heavily regulated industry become a myraid of regulations upon regulations. Some of these regulations have been good and the industry has benefited from them. Others, unfortunately appear to be a case of the Commission overreacting to a few professional " anti-everything" types. Prior to my experience at the Point Beach plant, I was a lineman for 8 years after completing a 6-year tour of duty in the U. S. Air Force.

I am also a officer in I.B.E.W. 2150 and from that point of view am concerned about the effects of this document on labor /

management relations.

1. A utility has neither the unlimited funding nor the unlimited supply of people to implement systems which the Navy has developed. Many nuclear plant Senior Operators are ex-nuclear Navy. If these individuals had been satisfied with the .

Navy's methods, they would have remained in the Navy. No utility can survive the turnover rates of the armed services, and apparently, the individuals preparing this document  !

have failed to recognize that personnel in the civilian nuclear power industry cannot be forced to remain in their jobs against their will. Such practices which are employed I in the military, if inposed upon private industry, would obviously eliminate an individual's free choice to determine his employment.

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2. At Point Beach Nuclear Plant in the Maintenance Group, for example, people are trained to top Repairman levels in all skills and then they advance into specialization in a particular skill or skills. As the workload increases, more s people are employed and trained in a formalized progression 4b 9'

. system. It is my opinion that the utility, not the NRC i 28 00612 0 M .

Mr. Harold R. Denton June 5, 1980 is.in the best position to determine the numbers and qualifications of personnel who are needed to accommodate the work burden; rather than to be regulated by the NRC into adding unnecessary, additional personnel.

Although I utilized the Maintenance Group as an example, it should be pointed out that personnel in all aspects of nuclear plant operation and maintenance are carefully selected through the use of sophisticated testing routines, trained to appropriately performed required work activities, and retrained to maintain their proficiency levels. It is patently absurd to require an individual such as a qualified machinist with 20 years of experience to take a

" technician" test to maintain his rating. This formal testing technique which NUREG/CR-1280 implies would be mandatory _would relegate " craftsmanship" to " paperwork" besides requiring the addition of many extraneous people at the cacility.

3. In Section IV.D.7 & 8, it is my recollection that the Institute of Nuclear Power Operations may be the appropriate organization to receive, disseminate and distribute industry-wide information.

4. I advocate the use of simulators as a training aid. However, coordination is required between the reactor vendors and an organization such as INPO, or among the utilities themselves to arrange for such training. Such training programs could, of course, be reviewed by NRC to ensure quality of content and practicability prior to implementation.

5. In Item II.E.3, the writer fails to recognize that Navy personnel have voluntarily enlisted and have oathed to serve their country for a specified period of time; failure to fulfill the oathed commitment resulting in court martial and dishonorable discharge. ~

l It should also be pointed out that many Navy enlistees join 1 that agency directly after graduating from high school and l these individuals have not, for the most part, ever held l jobs. The Navy turnover rate-is high, and I therefore, would note ths.t if the Navy life was all that desirable, the l turnover should be much lower. Unlike the Navy, a utility cannot possibly continue to effectively function on a 70%

turnover rate every 5 to 6 years. The tr-ining costs alone would obviously bankrupt the utility.

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Mr. Harold R. Denton June 5, 1980

6. In Section VI, the premise that shift supervisors should be required to possess college degrees, is unreasonable.

The recently " technical advisor" requirement provides the requisite " degree expertise", with the shift supervisor being akin to the. military "NCO". The services utilize and rely upon their NCO's for operational needs, not their

" shave-tail" junior grade Lieutenants. Although additional training and education may be desirable for shift super-visor level individuals, the " college graduate" requirement effectively eliminates the opportunity for a licensed Reactor Operator to advance. This lack of advancement oppor-tunity in nuclear power will obviously force qualified RO's to seek employment in conventional plants or to leave the power industry altogether.

Another " chief" on an operating shift is a waste of both talent and money. It would furthermore serve to demotivate other members of the shift who will effectively be denied the opportunity for promotion.

The practice of four-hour shifts as used by the Navy causes a more difficult situation than the industry's current eight-hour shift system. It should be remembered that on a submarine or surface ship, the personnel can be considered to be a " captive audience" -- they have nowhere else to go.

In the civilian workforce, nuclear plant personnel have their families and other outside interests. Most civilians don't feel they belong to the Company seven days per week, nor 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, as is the case in the service. The four-on, four-off shift scheduling concept will require that nuclear plant operating staffs will have to be doubled as a minimum. With the resources of the available labor pool declining, it is questionable whether the nuclear industry will be able to obtain qualified people to staff the plants.

7. In Items 3, 4 and 5, while some input from the NRC might be desirable, the evaluation and selection of individuals "

, for nuclear power plants should be performed by the utilities.

A utility does not have the military's privilege of obtaining personnel and subsequently evaluating their suitability for

' nuclear operations.

8. In Item 9, what is the purpose of training programs with annuc1 retesting if not to prove a comprehensive level of knowledge? This comment is an insult to RO's and SRO's in the industry.

9. Under Item 10, all the. licensing exams I have been involved in or have observed have required a startup and shutdown of the reactor.

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-Mr. Harold R. Denton June 5, 1980

10. Items 11, 12, 13, 15, 28, 40, 25, 46, 47, 48, 49, and 50 can all be addressed by a good training program and can be effectively coordinated.

11. .In Item 23, it should be pointed out that the so-called

" college man" can fail a number of courses, either retake .

them or possibly substitute for others, and still receive a degree. The NRC is relying on more on the formalized paper than the technical expertise achieved to obtain the degree.

. 12. Items 19, 28, 29, 30-43, 49 and 50 all consider only one plant, one utility and one vendor. The entire industry should not be painted as being identical to a singular case.

All of us have learned lessons from TMI, but it should be recognized that there are substantial design differences between plants, as well as substantial variances in methods of selecting and training personnel. I believe the NRC has overreacted in bowing to the pressures initiated by a few outspoken critics.

It is my opinion that a number of important TMI-related aspects have been overlooked. They are as follows:

1. NRC credibility has been shaken. Over-regulation is not the answer-to restore credibility.

2. The NRC overreaction by regulation has served to decrease morale throughout the industry.

3. Mandating additional inspectors and other non-productive i

auditors into nuclear facilities will increase the pro-ductivity and morale problems.

4. Pride and confidence in nuclear power by the general popu-lace will not return until such time as the NRC, the ~

utility and the industry stops knee-jerk overreaction to situations, and instead pauses to evaluate and then decides upon a prudent, conservative course of action.

5. The question of competency and qualifications of NRC employees has not been addressed. Certainly the " regulators"

should be exactly that. They need not be adversaries, nor

!~ should they be working "with" the utilities. By definition, the regulators should be capable of. understanding the simple concept that different plant designs cause different problems,

and that all plants need not be regulated into oblivion as it the past (Browns Ferry) and present (TMI) situations.

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, _ _ _ .- _m__. . . .. ._ .

Mr. Harold R. Denton June 5, 1980

6. If the NRC attempts to impose the Navy program onto private utilities, this over-regulation will probably signal the death knell of civilian nuclear power. The justification for NRC existence will likewise be questionable.

Very truly yours, Thomas A. Suttner l

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