ML20235N547
| 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: |
| References | |
| FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00030, 53FR52716-30, NUDOCS 8903010278 | |
| Download: ML20235N547 (3) | |
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- The Secretary of the Commission, Q
U.S. Nuc! car Regulatory Commission,;
L Washington, D.C. 20 i55 e
f A'ITN: Docketing and Service Branch i
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' 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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1 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 other altemative ways to demontt:ste Lnowledge of approprate enginceting fundamentals for j
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?
(2) 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
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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 ' ere in place, would w
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?
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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 capable but he is not a true member of the academia sociuy. He daesn't fitin. He s
is like,a ROTC person in the presence of Naval Academy people.
OUR VOTE IS NO ON YOUR PROPOSALS.
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