ML20235P179

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

ML20235P179
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	02/10/1989
From:	Leonard J LONG ISLAND LIGHTING CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00035, 53FR52716-35, VPNO89-020, VPNO89-20, NUDOCS 8903020125
Download: ML20235P179 (2)

Text

- -

1

• s

• ' ~

I

1 sa a cw6 -

/gg@ ( L G ISL_AND dlGHTING COMPANY y mm SHOREHAM NUCLEAR POWER STATI N j P.O. DOX 618, NORTH COUNYRY D A , N.Y.11792 l l

l CFrL I JOHN D. LEONARD,JR. 00cKi'b: < el.

VICE PRESIDENT. NUCLE AR OPE RATIONS 50b L' VPN 89-020 0 B89 Samuel J. Chilk, Secretary U. S. Nuclear Regulatory Commission Washington, DC 20006-2496 Comments on Proposed Rule 10 CFR Parts 50 and 55

Dear Mr. Chilk:

We have reviewed the proposed rule and submit the following comments. The format consists of answering the six questions addressed on page 52721 of the Proposed Rule Change:

Question 1. Neither alternative ensures safer plant opera-tion; both propose very restrictive criteria that would be difficult to meet within a reasonable time frame such as the four years suggested. If additional academic knowledge is required for the SRO, the NRC and utility industry should mutually agree on what academic enhancements need to be made to the presently accredited programs.

Question 2. Staff impact would be that few of the current operators would be able to meet the enhanced educational requirements prior to sitting for an SRO. This would leave only degreed engineers as a source for control room supervisors and they may not meet the experience factors such as operation at greater than 20% power for greater than one year. The ultimate impact would be stagnation of the operator's career paths and difficulty in finding degreed engineers who meet the requirements and are willing to work shifts. i Question 3. .i more appropriate transition period for each alternative is difficult to identify other than to say a longer period would be necessary. Four year degrees, particularly technical degrees, take longer than four years to complete if you are doing it part or three-quarter time. Few

(

8903020125 890210 53h52716 PDR [b

%: )

VPNOB9-020 Page 2 l Accreditation Board for Engineering and-Technology (ABET) accredited programs can be

-progressed on a part time basis and few will ]

accept transfer credits from academic programs previously completed by non-degreed operators..

Many engineering degree programs are now five years in duration. Professional Engineer (PE) l and Engineer In_ Training (EIT) programs are also time restrictive.  !

Question 4. A approach to consider both alternatives 1 and 2 would be an industry designed and accredited shift supervisor's technology course geared specifically to the control room.

Question 5. EIT status will not ensure safe operation and adequate accident mitigation. It should not become a benchmark for supervisory' adequacy. As suggested above, if enhanced educational creden-tials are required, an extensive supervisor's technology course geared specifically to the control room would be an acceptable alternative.

Question 6. Certainly experience requirements are most desirable. In alternative 1, the requirement for the SRO to function as an RO for one year at greater than 20% power is too restrictive because the most likely candidate to satisfy alternative 1 is a degreed engineer. This could require contract modifications with bargaining units and is an inordinate amount of time for the candidate to be away from other engineering duties.

In summary, both alternatives present significant problems to the operating plant. The use of degreed people only will impact the non-degreed people significantly. During the lengthy transition time, the lack of advancement for non-degreed personnel would impact morale and safety. The ability to upgrade non-degreed personnel is lengthy and full time enrollment in an ABET accredited program is not practical.

Very truly yours,

,- /s /

dkdM ((

Jdhn D. Leonard, Jr VicePresident-Nud.; ear Operations P:ck cc: S. Brown F. Crescenzo