ML20235N547

Undated Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Neither Alternative Acceptable or Needed

ML20235N547
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	02/09/1989
From:	Chesnutt W, Morgan R, Taylor AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
Shared Package
ML20235N540	List: ML20235N538 ML20235N547
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00030, 53FR52716-30, NUDOCS 8903010278
Download: ML20235N547 (3)

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A  : The Secretary of the Commission, Qe '

U.S. Nuc! car Regulatory Commission,;

L Washington, D.C. 20 i55 f

i A'ITN: Docketing and Service Branch  ;

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p. ' Dear Sirsi a

This is a response to your proposed rule on education and experience for Senior Reactor Operators and Supervisors at nuclear power plants.

1. Which alternative is preferable assuming one will be selected? '!

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, Neitheris a'cceptabl6 or needed. Having a degree will do nothing to enhance the sdfety of the public or plant during any ubnormal plant evolutions. Plant knowledge and e sperience is what is needed j rmd we have tMt n@v.  ;

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2. What are the potentialimpacts of each of the alternatives on licensee staffing?  ;

-l Having a degree requiremet will'put a roadblock on the Auxiliary Operator and Reactor Operator, 1 advancement. It will put an extra burdeu ca the plant operators to train engineers with no operating 1

. ability or experience to replat.e themselves as operators. The morale will be lower than it is already J at most stations.  !

Getting a degree paa tane while working shift work is to big a burden on the ope:ator and his' family. The rewaals of getting a degree this way would be to small ip companson to the time and effort expended. .

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3. Regardi ig implerrientation of the altematives, would there be a more appmpriate transitica period for each alternative than the one pioposed?

, There is la need for adier alternative. However, you could hire degreed people then train them I and taake then the SIA.'s. This would give you the enhancement of an engineering degree on shift..Jt.would also reliwe the S.O. and S.S. of the responsibilities of having a degree and let them run the plant. If a S.O. or S.S. watted to get a degree that would be his prerogative, but do not make it a requirement for thejob. .

'4. Altemative (2) provides for three different methods for demonstrating technical expertise with educational credentials . Would some other method be desirable for tlus putpose? Are there j

other altemative ways to demontt:ste Lnowledge of approprate enginceting fundamentals for people who may be ineligable to take the E.I.T. exammation? 1 (1) We have people who received &grees using (A.B.E.T4 who believe it was a total waste '!

of time. The instructen werejust pessing time, using outdated material and grading on a curve. If that's what it takes to get a degree why do all operators have to get an 80 or hbove to pass a test?

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When would a professional engineer, who is any good et all, give up a day job making more money and workiilg less hours than an operator. He would have to give that up for the priviledge of being a nuclear plant operator on i,hiftwork.

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(3) A Bachelors degree in a non-technical field but with an E.I.T. 2s::ued by the state would be useless. Someone from the Lvy Nuclear Power Progran would be 100% more useful to an operadng plant shan this person. Why doesht the NRC tell us what we need I to know about engineen,ng to run a plant safely and we willleam it. There is no need to

- go to college to leam basket weaving along with enginee ing.

5. Should a requirement be impoced requiring all senior operators to pass an engineering in l training (E.I.T.) or equivalent exam as a measure of basic technical expertise in addition i to, orinstead of, the :wo propotals in this notice? If such a requirement w' ere in place, would it be necessary to require enhanced educational credentials for shift supervisors?

Wh9 would submit the (E.I.T.) exam? A group of people from the state who are professional '

engkeers who know abiolutely nc. thing about operating a nuclear power plant? What good would this bc? l i

Just how much more knowledge do you think the Shift Supervisor needs? He already has the  !

experience, has probably been through the Navy Nuclear Program and several years of NRC t training involving TMI backfy, heat transfer, thermodynamics, reactor physics and every other program someone <bemed necessary. I don't think he needs the addhional burden of more miscellaneous trairdag.

6. Independent of a degree requirement, is there a r ed for the experience requirements to be l increased for the stift supervisor position? Are the proposed requirements called for in the tv c alternatives sufficient?

To answer the first question. NO. The second question. The alternatives are not needed.

As to piemotional. enhancement. If you think the utilities are going to take a shift supervisor

• who is qualified in all of the present requirements of shift and put him in a managerial position you are sadly mistaken. This man has come up through the ranks, worked for years in the trenches,is very smart and capables but he is not a true member of the academia sociuy. He daesn't fitin. He  ;

is like,a ROTC person in the presence of Naval Academy people.

OUR VOTE IS NO ON YOUR PROPOSALS.

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