ML20235P127

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

ML20235P127
Person / Time
Site:	Kewaunee
Issue date:	02/13/1989
From:	Hoppe G WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00041, 53FR52716-41, NUDOCS 8903020109
Download: ML20235P127 (2)

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J February 13, 1989 h kbS  : g.U 2405 Josten Park Drive Green Bay, WI 54311 89 FEB 17 P1 :51 Secretary of the Commission US Nuclear Regulatory Commission on ..

, Washington, D.C. 20555 Docs ., o Attn: Docketing and Service Branch

Dear Sir:

I wish to comment on the proposed rule that would be added to 10CFR Parts 50 and 55 concerning degree requirements for Senior Reactor Operators and Shift Managers.

y' I am a Senior Reactor Operator, currently holding a Shift Supervisor's position at the Kewaunee Station.

I read the proposed rule with much interest and resulting in much apprehension and confusion. I simply don't understand how an individual holding a degree is going to enhance public health and safety. I believe quite the opposite to be true.

First of all, an individual with a degree is going to demand significantly higher wages to cope with the stress that inexperience brings, along with the unaccustomed stresses of a person new to shiftwork. This will result in costing the utilities more money.. Secondly, if I were degreed, I would want to put nly two or three years in the position to get the notation on my resume, then get out and move on. This, by the way, is the attitude of many of the degreed engineers we have on site. This kind of attitude and lack of experience is going to enhance public health and safety?

What a degreed individual in a Shift Manager's position would get for you is instant credibility. A degreed individual would probably look better to someone not knowing the depth of training we get.

As for a line of promotion from the Control Room to the Board Room, our Company already promotes those individuals who have taken the time and effort i to get their degrees and their SR0's. I feel very secure knowing my concerns are dealt with in a knowledgeable manner. l I like my job. I have over six years in the position of Shift Supervisor.

Because I don't have a degree, I can devote my time to the issues at hand j rather than spending time obtaining a degree and jockeying for position to i get in line for a promotion. Obtaining a degree at this time in my life ]

would simply not be feasible.

Before being promoted to Shift Supervisor, I spent eight years as a Control Room Operator and before that I participated in virtually every phase of the start-up of the plant from the time the first breaker was closed. I also watched as the plant was being built and followed progress of system after system being placed on line.

8903020109 890213 PD9 PR 50 53FR52716 PDR

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February 13, 1989 Page 2 I have seen many problems and how problems were resolved. I shared with our neighbors in celebrating 10 years on the line, remembering the gratitude the Company continues to show for its employees. We all have shared in the glory when we received high SALP ratings from the NRC and INP0's Award of Excellence.

I *eally don't understand how a degreed individual on shift is going to enhance professionalism. Yes, I hear about some of the other plants which you folks have had to come down hard on for displaying non-professional behavior. Seems to me, though a degree on shift will have nothing to do with lessening these instances. Positive management initiatives will.

From my perspective, what the NRC would lose by this rulemaking would out-weigh the benefits gained. You would lose something very valuable in this industry - experience. I feel strongly that, because of environmental concerns, our country is going to have to change its energy policy and bring the new generation of nukes on the line within the next 10 or 20 years.

One more mishap would seriously threaten that evolution. Let's keep our plants safe - this proposed rule must go!

Additionally, I invite any of the Commissioners to come to Kewaunee, sit along side me as I- go through my 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> on shift. Come along to requalification class with us and stand along side of us as we work through our scenerios on the Simulator. Stay with us for a couple of six-week cycles. Watch us work together as a team. I'd like any of you to point out how we are non-professional after that time and how a degreed person would be better qualified to run the shift.

Kewaunee will be going into its 14th refueling cycle soon. Its management policies have worked well for over 18 years. We have made this world we live in a little better place to live by delivering low cost, efficient, reliable, pollution-free energy to the citizens of Wisconsin.

We want to keep it that way!

WW Y hf Glenn W. Hoppe Shift Supervisor Kewaunee Nuclear Power Plant i

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