ML20212P644

Forwards Recipient to President Reagan Opposing Proposed Rules 10CFR50 & 55 Re Degree Requirement for Senior Operators

ML20212P644
Person / Time
Issue date:	08/27/1986
From:	Ingram F NRC OFFICE OF PUBLIC AFFAIRS (OPA)
To:	Sandhoefner M AFFILIATION NOT ASSIGNED
References
FRN-51FR19561, RULE-PR-50, RULE-PR-55 NUDOCS 8609030217
Download: ML20212P644 (9)

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- Je Me. Mike Sandhoefner 3837 North 100th Avenue Omaha, Nebraska 68134

Dear Mr. Sandhoefner:

The White House has referred your letter to President Reagan to the Nuclear Regulatory Commission for reply. In turn, I am having a copy sent to the Office of the Secretary for inclusion in the record of the proposed rulemaking on degree requirements for senior operators at NRC-licensed commercial nuclear ~

power plants.

Sincerely, 4 W Frank Ingram Assistant to the Director Office of Public Affairs CC: Docketing & Service Branch, SECY

• W/ Copy Incoming.

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2. Mike Sandhoerner_i__.:

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Joj / Nordi tvuth Avenue Omaha, Nebraaka 68134 July 13,1986

Dear Sirs:

This is in regard to ". Degree Requirements for Senior Operators at Nuclear Power Plants." Federal Reatster Volume 51, Number 104, Friday,

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May 30,1986, pages 19561-19565.

l am presently a licensed reactor operator; docket "55-40128, license '0P-42071; at the Fort Calhoun Nuclear Power Plant which is located north of Omaha, Nebraska.

I am a high school graduate, spent six years In the nuclear Navy, and was attached to the U.S.S. Puf fer (SSN-652) for four years. I was an Electricians Mate 1st class petty officer, and was quallfled Engineering ,

Watch Supervisor / Engineering Duty Petty Of ficer.

I do not feel a degree should be necessary for any licensed person, as college does not teach you how to run a nuclear power plant. I have been going to night school for three and one half years at the University of Nebraska Omaha campus, and have at least five more years to go to obtain my degree, while being a husband, father, operator, ana attempting to maintain my license, let alon? upgrade to a senior reactor operator license.

Comments

1. No, January 1,1991 1s not a feasible deadline, there should be no deadline, as this policy should not come to be " law"

3. No, I have been going to night school for three and one half years, and have least five years of night school to go to obtain my degree.

Going to school fulltime requires four years (minimum) to obtain an engineering degree, yet this policy would only allow four years (going part-time assuming a person has a reactor operators license, is working forty hours per week of rotating shif t work, maintaining a reactor operators license, et al. I have been going to  ;

night school already, whereas many (If not most) other licensed j operators have no college credit, and would require 120+ credit 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, which would require them to be full-time students to accomplish this. It would be physically impossible for a typical reactor operator to obtain a degree by January 1,1991.

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6. No, present training is adequate.

11. No

12. There should be no cut-of f date, as this policy should never come to pass.

14. It would totally and completely undermine any operator morale presently existing. It would basically say that operators are needed, but not wanted unless they have a degree, and this is more and more beginning to resemble the United States Navy nuclear prograra, yet a vast majority of nuclear plant operators got out of the Navy to get away from overregulation, and the Inability to -

become Engineering Officer of the Watch (no degree), too raany people telling the operators what is required to due to become an operator. Yet the people making the policles/ decisions / exams are not, and were not, operators themselves.

Only a person more knowledgeable, experience 0, and licensed should be directing a licensed operator what to do, requirements needed to be an operator, etc., yet this unfortunately, and sadly, is not the case.

People with very little or no experience as an operator, actually running a plant, make up the policies with little or no regard as to how it will affect the people actually doing the job.

17. I feel a degree requirement would be the straw that broke the camels back. It is hard for me to want to stay in a job where I must annually pass an exam, where as no other Industry / Job in the United States is required to do so. Not degreed doctors, lawers, etc. It could cause experienced people ( the persons actually running the plants) to say that it is not worth the pain and effort it takes to earn a decent living.

It would end up with more people with less experience running the nuclear plants, which is non-conservative in its approach to the safety and health of the general public, as you can not teach a person experience, it is a time consuming process.

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18. I do not f eel having a second control room operator with a technical degree would enhance professionalism or esprit de corps, It would do the exact opposite and widen the gap between degreed /non-degreed personnel.

19. As a licensed operator presently aggressively pursuing a college degree, it is my opinion, it sould be each individuals own decision as to whether or not to go to college.

For married people (like myself), it adds a great amount of stress and anxiety to the marriage, due to the time involved for classes and study. This now causes problems in the marriage, causing the operator to come to work with his personal problems on his/her

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mind which could have detrimental effects on the operators performance in the job function which could hinder his/her ability to operate the plant safely, due to this added stress.

20. No, some plants may be staffed with individuals who have no desire ( or due to age, late thirties and older) to attend college and may not wish to get a degree.

It is about time to think of the nuclear plants' licensed operators as human beings, as we think of everyone else. The general public does not get too alarmed when one, two, three or more people die in automobile accidents, as happens everyday somewhere In this great nation of ours, because driving seems an acceptable risk, as is flying, swimming, smoking, alcohol usage,111egal drug usage, etc. Instead of continually changing the regulations at the expense of billions and billions of dollars to the taxpayers, it is time to educate the public about nuclear power, how a plant operates, is constructed, the safety systems and training by the persons operating the plants, also about the intrinsic safety of nuclear power versus the other forms (i.e. Coal / fossil fuels), etc. It is time now to save the nuclear power industry In this country or lose it as a inexpensive, reliable,and safe alternative of electrical

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production.

Respectfull ,

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Michael J. Sandhoefner

page4 xc. President Ronald Reagan

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United States Nuclear Regulatory Commision Senator E. Zorinsky Congressman H. Daub Mr. B. Reznicek Mr. W. Jones Mr. R. Andrews

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Faderal Regist:r / Vol. 51. No.104 / Friday. M y 30. 1986 / Prepos:d Rulzs

_ 19561 c:nduct all or o pcrtion cf th2 cther Ro:m at 1717 H Stre:t NW.,

i duties that need to be. performed at a Washington. DC. baceturesta degree in engmeenng.

federal animal quarantine station. engineenng technology. physical Pon rusrrwan imponesarioW CONTACT; science, of a professional engineer's This document requests comments concerning whether the Department F. H. Rowsome. Office of Nuclear license. Option 2 penmts continuation of Reactor Regulation. U.S. Nuclear the separate STA who rotates with the should take action to contract with Regulatory Commission. Washington.

private firms to conduct auch activities. shift and holds a baccalaureate degree DC 20555. Telephone: (301) 492-4813. or equivalent and meets the entena as Done et Washmaton, DC. this 27th dsy of May 19et SUPPLEufMTARY INFoRuATION:

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l K. Atwelt, Background CO The Commission a:so encouraees the Deputy Adnnrustratar. VotennaryServices. De issue of a de c equi ments shift superusor to serve in the' dual. role

[nt Doc. 66-12119 Filed 5-2S ee: 8:45 sto] positson. and the STA to take an active emme coes s" concern of the Nuclear Regulatory role in shift activities.

Commission (NRCl. In July 1979. -Th0-2 The current advanced notice ef 1.essons 1. earned Task Force Status proposed rulemaking is intended to Report and Short Term NUCLEAR REGULATORY extend the current level of engineering COMMISSION Recommendations." expertise on shift. as desenbed in the made specthe recomm(NURECA578)s endations for a Commission's Policy Statement on to CFR Parts 50 and 55 Shift Technical Advisor (STA) to Engineenng Expertise on Shift (50 FR provide engmeenng and accident 43d21) and to enture senior operators Degree Requirement for Senior assessm.nt expertise dunng other than have operatir:g expenence on a Operators at Nuclear Power Plants normal opera tmg conditions. On October 30.1979, the NRC notified all commercial nuclear reactor operating at Actacy: Nuclear Regulatory greater operating nuclear power licensees of the ' " hot" operating than twenty percent power, e.g..

Commission. expenence (Generic short. term STA requirements,i.e that STAS should be on shift by January Letter 64-16). This Advance Notice of .

Action: Advance notice of proposed Proposed Rulemaking is the result of a rulemakm.g. 1980. and that thev.should be fully trained by January 1981. In November Commission decision to constder an summany:De Commission is amendment to its regulations (Parts 50 1980. "ClanEcation of ThU Action Plan considering an amendment to its Requirements."(NUREC-0737). and 55) and to obtain comments on the provided further details to licensees contemplated action to upgrade the regula tions to require, aner January 1' levels of operating. angineering, and 1991, that applicants foelicenses as s regarding implementation of the STA accident management expertise on shift.

Senior Operator of a nuclear power pogtzon.

plant hold a baccalaureate degree in e quahm of wors were Conastreet Poucy *=*=-at engineering or the physical sciences also addressed by the 1979. " Lessons

• He Commission also intenda to from an accedited laatitution. Other Learned Task Force."(NUREC-osa5}. prepare a concurrent pohey statement baccalaureate degrees from an the 1980 Rogovin report. "I'hree Mile Island: A Report to the Commissioners which will encourage nuclear power accredited instituti ma be accepted plant licensees,i.e owner operators, to:

and to the Pub!!c."(NUREC/CR-1240). 1. Implement personnel policies that h"n p 1ulema a on is due and the 1982. " Report of the Peer A vis ry Panel and the Nuc ear emphasize the opportunities forlicensed to a Commission decision to enhance operators to assume positions of g yeye;s og engineerms and accident Regulatory Commission on Operator management expertise on shift.no Qualifications."(SECY 82-182).* The increased management responsibility:

2. Develo ograms that would current requirement. for candidates with consensus among these was that greater a baccalaureate degree, of two years of technical and academic knowledge enable currenJY licensed senior tesponsible nuclear power plant among shift operenng personnel would [,'

operating expenence, would be be beneficial to the safety of nuclear c'o'll8 d'8#*e d amended to require et least one of the power planta. 3. Obtam college credit for two years of operating expenence be On October 28.1985. the NRC appropnate nuclear power plant training with a similar commercial nuclear published in the Federal Register (50 FR and work experience through 43821) a final policy statement on arrangements with the academic sector.

reactor operstmg at greater than twenty )

percent power. engmeenng expertise on shift. Option 1 Discussion of the Policy Statement allows an caTE Comment period expires July 29. mdividual to serve in the cornbmed The purpose of the contemplated 1986.

Senior Operator / Shift Technical rulemaking is to upgrade the operstmg.

Comments received after this date Advisor (SO/STAJ role holding either a ands '

will be considered if it is practical to do [8*",""g;9 p, t s p d,d by 8'

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, so. but assurance of consideration cannot be given except as to comments g gu te re e need

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combimng both engmeenng expertise and operstmg expenence in the senior received on or before this date. omc. by calbas non m.mso or by wnnna to e. operator function. This is being done to u s. covernm.ni Pnnums omo p.o. sam aroar.

Anonssama Send wntren comments or **'h'nston, oc:: cots-ran2. copi.e may it o be further ensure the protection of the suggestions an the proposed rulemakmg health and safety of the public by havmg ta the Secretary of the Commission. U.S. 'N,'$",*p",,*,*$'j"j$$'32,. p""j* personnel on shift with enhanced 3

1 Nuclear Regulatory Commission, Royal Road. Sonnafleid. VA 221st. A copy te qualificalion3.  !

e+adabie for msn.cnon and/or copytas for a fee in )

Washington. DC 20555. Attention: de NRC Public Docwneni Room. trtr H Street The NRC is concerned that operator l qualifications to deal with accidents Docketing the comments and receivedService may be Branch. Copies of **h*$Qan7cen.ne Lanerbeyond sa.te design are basia conditions warrant  !

examined at the NRC Pubhc Documant ...o.bi .: the rate Pubue H str i.Nw.w wseian, oc. cocumises no.es ei trir improvement. Operator training programs and related emergency I

19562 Federal R;gister / Vol. 51. No.104./ Friday. May 30, 1988 / Propos:d Rules

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' operating procedures. generally do not baccalaureate degree from an licensees (utilities) and the nuclear c:nsider accident conditions beyond accredited college or university. industry to provide incentives and in dequate core cooling.There is In the past the NRC has accepted - management opportunities for sos as gen:r t consensus that well qualified " equivalents" to the baccalaureate well as improving the engineenng operators can substantially mitigate the degree. The equivalents were based capabilities of the on shift crew. The SO effects of~ severe acciderits. The Industry upon specialized utility training or other with a degree and shift operating Degraded Core Rulemaking Program work expenence. For the contemplated expenence can become a valuable llDCOR) industry group for example, rule. equivalency would not be personnel resource for the utility. one has developed arguments that operators acceptable to the NRC in lieu of a who combines shift operational could substantially reduce the risk degree. Because the Commission is not management experience with the prop: sed by these conditions. The NRC in a position to evaluate the academic potential for greater management is considenng the need for more equivalency of utility traming. it responsibility. Re policy statement will -

extensive severe accident training and encourages academic institutions to encourage licensees to provide that emergency operatmg procedures as well allow course credit for such equivalency career path, as enpneenng qualifications for senior based upon work expenent e or A regulatory analysis and a backfit operators. specialized traming. Thus the proposed assessment wdl be developed after the The policy statement on enair eering concurrant policy statement would

, comments are received and evaluated.

espertise on shift (October 28.1983. 50 encourage enforts to have the tramm8 pner to notice of the proposed FR 43021) provided an interim way of accepted by the colleges for partial rulemakmg and coccurrent policy aCh :ving more. engmeenng capsbility credit toward fulfilling the requirement statement.

on shift. Essentially the NRC is moving of an accredited degree.

from intenm requirements which The degree requirement would not invitation to Comment provide engineering capability fcr apply to licensed reactor operators Comments regarding the proposed accident conditions (the STA), to (ROs). Howes er. the proposed rule are encouraged. Comments on the requinns engmeering capability, and concurrent policy statement would contemplated rule are solicited in regard -

nuclear power plant operating encourage degrees for ROs. The to expenence in the same individual (the Comm ssion believes a degree

, 1. Is January 1.1991, a feasible SO). requirement on shift. along with the deadline for requinns senior operators ThI contemplated rulemaking action concurrent proposed policy statement to be degreed and licensed, and if not. '

would require that all applicants for a will not only enhance public health and what should the deadline be?

$enior Operator (SO) License after safety, but will also. provide a route for 2. What the implementation and Janurry 1.1991. must have a promotion by sos. operation costa of the contemplated rule baccstaureate degree in engineering. The cut off date of January L 1991. for application for an SO license by to utilltI" ""uld be?

engineering technology or the physical Assunung regular shift rotation, sciences from an accredited university indiWduals who are not degreed is could the typical SO obtain an or c:llege. Other baccalaureate degrees chosen for three reasons. First. it will engmeeting or technical degree prior to from an accredited institution may be allow operators now in training accepted on a case.by. case basis, sufficient time and notica to complete a I'UU8#I I* I"I degree before application. Second. It 4. What type of engineering degree Drgres equivalency will no longer be should not cause undue hardship on w uld be appropriate, e.g. nuclear, accepted. A baccalaureate degree in electrical, mechanical industrial, etc?

another subject area would be operators who are now in the process of

5. What has been the industry's acceptable if the utility (licensee) preparing and training for the senior certifies that the applicant has operator license. Third. licensees are experience in securing college-demonstrated high potential for the SO encouraged by the Policy Statement on equivalent credit for nuclear power position. Engineenng Expertise on Shift (Optiort plant training and/or work expenence?

The creenplated rule would apply 6. Should there be sinular expenence

1) to move toward a dual. cole SO/STA requirements for one-of.a. kind only ts the $v. I.bwd sos or position. Furthermore. operators who othtrwise fully qualified applicants prior are licensed as sos prior to January 1. advanced reactors?

ta january 1.1991. would be exempt 1991. would be " grandfathered." The 7. What are the combined impacts of from the degree requirement. Licensed proposed rule would only allow one re, requiring two years of responsible reactor operators (ROs) would not be examination for SO applicants who nuciear power plant expenence. the requirsd to have a degree. apply for a license just prior to January degree requirements. and one year " hot" Current senior operators and senior 1.1991. This would prevent essentially operating requirement for the position of eptrator applications accepted by the unqualified individuals (without SO?

NRC prior to January 1.1991, would be degrees) from applying just to " beat" the '8. Should the contemplated degree

" grandfathered" with regard to the deadline. requtrement for senior operators be contemplated rule. it is recognized that The contemplated rule also requires supplemented with or replaced by "grandfathering" current sos could one year of " hot" operating experience intensive focused training requirements result in undegreed sos for an extended for a degreed SO after January 1.1991. in severe accidents for nuclear power period of time. This is simply a continuation of current gant operators?

The proposed concurrent policy NRC established policy to provide 9. What are the appropriate critena statement will encourage previously engineering and accident expertise on for assessing a utility's certification that licensed sos to obtain degrees. it is the shift. It is essential that the SO know an individ_al with a baccalaureate intent of the present advance notice of and understand plant operations as well degree in other than engineering or the proposed rulemaking to specify that as the theoretical, academic, and physical sciences has " demonstrated senior operator license applications accident management aspects of the high potential" for the SO position?

frceived after January 1.1991. would not position. 10. What are the implications of this b2 accepted by the Commission unless The concurrent policy statement is contemplated rulemaking on decisions the license application holds a planned as a way of encouraging concerning future reactor designs?

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c Fed:r:1 Register / Vol. 51. No.104 / Ftidq. May 30. 1986 / PropreId Rul:s 195G3 6

15. [Ch:irmin Palladins beli;v:s] th:t 18. Presently on] degreed engine:r is ,

pit. Should the NRC require required 13 be within to minut:s ef the i specialized training in severe reactor the attached Table [1] correctly accidents beyond inadequate core identifies the present control room staff control room or a member of the control as well as that envisioned by the room staff. the STA or the combmed j cooling and/or require extension of emergency operating procedures into the ANPRM by 1991 and after 1991. Should SRO/STA. respectively. While requinry; l other alternative control room staffing a second controlroom operator to have realm of more severs accidents instead

' requirements be considered? a technical degree may enhance of or in addition to baccalaureate degrees? What are the implications of 16.TMlimprovements in centrol room cperator organizational status. l the work by IDCOR for the capabilities and staffing have been professionalism and espnt de corps wri:

qualifications. training. and err.ergency undartaken by the indust.y. i.e.. STNs a second degreed engmeer cign:ficamly operating procedures for licensed have been added. detailed control improve operator performance be> ond reactor operators and senior operators? design reviews have been undertaken, the STA or combined SRO/STA

12. What is an appropnate cut-off date safety parameter display systems have improvements? Will these impros ements for allowing only one re. examination for been metalled. emergency operating become apparent in the short term or the those SO applicants without a degree procedures have been improved. and the I "8 f*I who apply for a license just prior to combined SO/STA position has been

19. What is the industry view abcut january 1.19917 approved by policy.To what extent have these improvements been availability of new college graduates 13.The proposed rule would require who can be trained in nuclear pon er an 50 applicant to have a bacca'. aureate effective?

degree in engineering or the physical 17. Requiring SO's in the control room plant operation or about the fe.uM';.

scences from an accredited university to have a technical college degree will of having present plant operator > pursue have an impact on RO's and AO's. and obtain a technical cctiege derce?

or college. What should be the sppropnate definition (e g., Department especially with regard to a career path - 20.Should there be a numencallimit of Education. ABET. etc.) for "an for these personnel.To what extent will on the total number of grandfathered" eccredited university or college?" the SO requirement drive out capable SO's at any particular plant?

p 14. What immediate impact will the- operators. and result in high personnel

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contemplated rule have on operator turnover and instability in the morale 7 workforce?

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