ML20059K245

Submits Comments on RO Vs SRO Licensing & High Failure Rate on RO & SRO Exams at NPR Facilities

ML20059K245
Person / Time
Site:	University of Wisconsin
Issue date:	11/03/1993
From:	Cashwell R WISCONSIN, UNIV. OF, MADISON, WI
To:	Weiss S Office of Nuclear Reactor Regulation
References
NUDOCS 9311150239
Download: ML20059K245 (2)

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November 3, 1993 Dr. Seymour H. Weiss I

U. S. Nuclear Regulatory Commission

, Office of Nuclear Reactor Regulation q Washington, DC 20555

Dear Sir:

i At the October 1993 NRC Seminar at the TRTR meeting you requested

feedback on RO versus SRO licensing at NPR facilities. In

addition, Marvin Mendosa called our facility last week asking for comments on the high failure rate on initial RO and SRO exams at NPR facilities. Since I feel the items are related I include comments on both subjects.

We believe the SRO and RO functions are separate and distinct _at our facility. We do not wish to license a person as a SRO j without significant reactor operating experience. While we realize that many of the SRO functions we require are not specifically stated as SRO functions in Part 55, they are vital to operational safety and defined in our procedures. For instance, approval of irradiations (even though the requirements are very specifically stated in procedures) is reserved for SRO licensed persons. Failure of an irradiation container is a significant safety event for us, having potential personnel exposure and public release consequences. Approval of experiments as routine or modified routine requires an experienced individual to evaluate the experiment. Experiment malfunctions or failures also have potential personnel exposure and public release consequences. We use extensive, detailed procedures for operation and maintenance activities. Such procedure use allows management oversight and assures that safety requirements are always met. We allow a SRO to make changes in these procedures, but require strict adherence for ROs.

At our facility, RO candidates are typically undergraduate students who are quite young, perhaps as young as 18. We do not believe any quantity of classroom training can provide the basis for such a person to make the decisions required for experiment approval or for responses to emergencies. Mature judgement and experience come from practice and observation of good practices, not just training. For that reason, our abnormal and emergency procedures require RO immediate actions to shut down the reactor and notify a senior operator who is required to be readily available by phone or pager, if not in the facility. All recovery actions are directed by a SRO.

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While we realize that some facilities routinely license

• irsxpe*rienced people at the SRO level, we do not.

We understand that some facilities license all operators at SRO level, but we do not. We believe the distinction between RO and SRO is necessary in order to provide proper management control.

It appears to us that some in the commission, in particular operator licensing, do not believe these distinctions exist. We see examination questions which require memorization of information that is provided in procedures or posted at work locations. I feel this interferes with the most efficient management control that I possess- the ability to change a procedure observed.

and expect limits contained therein to be immediately persons who memorize procedure limits or steps are likely to perform the step or apply the limit he remembers, rather than carefully reading the procedure. We see questions on RO exams on activities or decisions which are beyond the scope of activities of RO personnel at our facility. We understand that other facilities require more of RO level personnel during i abnormal or emergency conditions because of the lack of distinction between RO and SRO. We do not agree with this concept, nor do we think NRC should enforce this concept by asking SRO level questions of our RO candidates.

I hope this response is useful to you. Please let me know if I can supply further information.

Very truly yours, aw

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R. J. Cashwell Reactor Director l

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