ML20235N697

Comment Opposing Proposed Rules 10CFR50 & 55 Re Proposed Degree Requirement.No Specific Data to Indicate That Rule Will Improve Plant Safety Exists

ML20235N697
Person / Time
Site:	Kewaunee
Issue date:	02/10/1989
From:	Buraczewski S WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00080, 53FR52716-80, NUDOCS 8903010355
Download: ML20235N697 (1)

Text

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2-10-:89 Secretary, US Nuclear Regulatory Convaision ~89 FEB 23 A10:03 i Washington, DC ATTN: Docketing and Service ,:p a ,,

DOCKEi v?! '

COMMENTS ON PROPOSED DEGREE REQUIREMENT MC i

Part 3 of the NRC's own backfit analysis says it all. "It is not feasible to j quantitatively evaluate the change in rl;sk to tre public as a result of the '

proposed rule. That is, the effect of the 80 or Shift Supervisor on the probability and consequences of an accident, and the change in the probability and consequences of an acciGent as a result of requiring eithet the so to have a bachelor's degree or the Shift Supervisor to have enhanced educational credentials in ont known. The CommisalgLbelieves that requiring degrees for S0s or enhanced educational credentials for Sh!ft Supervisors will contribute to the goal of having 50s or Shift Supervisors who have operational experience and technical and academic knowledge that d ould __ improve their performance as operators and possibly oper. career paths from which they may have been excluded in the past. The S0s or Shift Supervisors with enhanced educational credentials should be able to respond hatter to off normal incidents."

It would seem that the Commission is in the minority la their belief. As noted in the background section of this propond rule, the vast majcrity of comments to the Commission in regard to the ANPR.i (May 30, 1986) were negative. In fact those comments from OPERATORS, the individuals directly affected by this proposed rule, indicated that Public Health and Safety would be adversely affected because if they were in a situation of having a degree and a license, they would make '

every effort to get off shift work and thus experience level oc shift would be, adversely affected. No one should kid themselves that theory knowledae ateut design of components as taught in advanced schooling can replace the u n knowledge _of what was actually designed into a plant. Knovledae of the real desian can only come from olant soecif,R_.tgehnical trainina and exoerience.

With the majcrity of coments against the proposed rule and with no specific data to indicate that the rule will hpyayL plant safety, it would ceem that the Commission is trying to force this issue for reasons other than those it claims.

By doing this it is putting unnecessary stral; on the Licensed Operators at facilities nation wide. These vary operators have indicated their rejection of the proposed rule (See comments from the Professional Reactor Operator Society).

This action on the part of the Commission nay itself result in a reduction in the healtu and safety of the public. Of course this statement has no more qnntitative proof than the commissions belief that a degree will be beneficial.

Sincefely, #

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S.M.Buraczew Senior React r Oper or Kevaunee Nucle ant 9903010355 890210 PDR PR 50 53FR52716 PDR p

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