ML20235N503

Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants

ML20235N503
Person / Time
Site:	Fermi
Issue date:	02/07/1989
From:	Farrell S DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00060, 53FR52716-60, NUDOCS 8903010250
Download: ML20235N503 (2)

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,l February 7, 1989 suCer.- ,y The Secretary of Commission U.S. Nuclear Regulatory Commissior.

Washingt.on D.C. 20555 Atta: Docketing and Service Branch w

Dear Sirs:

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I have reviewed the proposed amendment to 10 CFR Parts 50 and 55 ,

regarding the education and experience requirements for senior reactor l operators and superv.isorn at nuclear power plants. The following are my comments on this issue.

Under the first alternative, the NRC has picposed that operating, engineering, and accident management expertisc would be upgraded by j requiring that all Senior Reactor Operators (ERO's) have a bachelor's g degree'in engineering, engineering, technology, or the physical sciences from an accredited university or college. While enhanced educational credentials of shift operating personnel cannot be '

faulted, I don't believe that a bachelor's degree should be mandated as a requirement for receiving a SRO license. Operating experience, j however, is fundamental to performing the duties of a SRO. .

If the proposed first alternative were to be adopted, it could very ,

possibly inhibit the career progression of the reactor operatoro  !

(RC's), and ultimately result in lower morale and setivation among )

them. Given the rotating shift schedule of the RO position, the proposed four year time span following the effective date of the ruling would not be sufficient for a Jto to earn a bachelor of science j degree. This could lead to a higher turnover rate within the 50 ranks j due to the lowered morale as well as problems with the recruitment. of a qualified and motivated operations personnel. The net result would be less experienced operating personnel on-shift and an impairment, rather than an improvement, of overall nuclear safety. j l

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[ h' Continued February 7, 1989 l l

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i The second alternative would require that the shift. supervisor have  !

enhanced educational credentials and experier!ce; the enhanced j credentials could be a bachelor's degree from a program accredited by j the Accreditation Board of Engineering and Technology (ABET), a i professional engineer's license (PE) issued by the state government, l or a bachelor's degree and a.n Engineer-In-Training (EIT) certificate, j Again, let me stress that the value of operating experienec, far j exceeds that of a bachelor's degree with regard to an operating I

staff's ability to analyze and respond to cotaplex transients and accidents.

I believa that the proposed rule is not necessary and would luipos~e )

hardship in the reactor and senior reactor operators' career progression. To obtain the enhanced educational credentials, an f individual would need to enroll in an ABET accredited program to earn a bachelor degree or educationally prepare for the EIT or PE ]

S examination. Again, since shift work inhibits attending these colleges or universities, this becoises a block to meeting these j enhanced requirements. It should also be noted that because of taiG block, nany nuclear operations personnel have enrolled in other, non-traditional paths to a degree such as the New York Regents Nigelear /

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Engineering Technology program. Ho,<ever, this particular degree program, along with other :such non-traditional progthms, has not been ,

ABET accredited and therefore, would not fulfill the proposed l requirements. [

If enacted, the secorA alternative would impact the pool of resources from which to recruit personnel with the proven abilities and motivation to be effective shift supervisors. And, since no evidence exists which supports the need that an ABET accredited BS degree, FE license, or EIT certificate is necessary for job performance, the enactment of such a ruling would lead to a decline in overall safety and performance. {

To summarize, I believe that the enhanced educational requirements of l

both of the proposed alternatives are unfounded. They would lead to a higher operatw turhover rate, hindered career progression and resultant lowered morale, and possible degradation of the protection of the health and safety of the public. Emphasis on experience requirements as well as the initial and requalification training of reactor and senior reactor operators is the only means to upgrade the on-shift expertise of nuclear power plants.

Sincerely yours,

_/ t Reactor Operator Fermi 2 Nuclear Power Plant l The Detroit Edison Company l

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