ML20235P403

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Rules Provide Needless Demoralizing Effect on Reactor Operators

ML20235P403
Person / Time
Site:	Cook
Issue date:	02/09/1989
From:	Baker K AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00038, 53FR52716-38, NUDOCS 8903020213
Download: ML20235P403 (2)

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The Secretary of the Commission ,

U.S. Nuclear Regulatory Commission Washington DC.20555 ATTN: Docketing and Service Branch February 9, 1989 RE: Comments Regarding the Proposed Ruling Requiring Degrees for Senior Reactor Operators, as Published in the FEDERAL REGISTER, Volume 53, No. 250.

I urge that the proposed ruling referenced above not be adopted. It will not only provide a needlessly demoralizing effect on our present Reactor Operators, but could also most assuredly lead to negative safety benefits.

Based upon my 25 years of experience in the nuclear industry, I feel making a degree a prerequisite for an SRO License will not provide any incremental increase in reactor safety. What is needed is to make the SRO position in the Control Room a highly desirable position which attracts highly motivated, intelligent people with an aptitude for operations and shift work. The more knowledgeable and experienced these individuals are, the less the likelihood of a nuclear accident. Additionally, it requires a number of years of experience to be a fully effective Shift Supervisor.

As I understand the proposed ruling, one of its designs is to establish a career path for the Reactor Operator up into the hierarchy of the company. Making this job a stepping stone to only be filled by a person for a few years is in error, as he or she will not get the necessary seasoning to be fully effective. In addition, there is a potential that less-than-competent people will reach their ultimate level of incompetence at the Shift Supervisor level, and will fulfill the " Peter Principle," thereby filling these positions with people who cannot advance any further.

The nuclear industry must attract the best and most competent candidates to fill these jobs, and not simply make the positions into pipelines to fill other needs. I would suspect that, if you look at the overall operating records of the various utilities, you will find those having senior, experienced on-shift supervision with significant years in their positions doing better than those regularly rotating people in these positions on a short-term basis.

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4 Secretary of the Nuclear Regulatory Commission February 9, 1989 Page 2 I am convinced that I speak for the majority of nuclear industry professionals when I state my conviction that a degree requirement for Senior Reactor Operator licensees is not only unnecessary, but in fact may impede the effective execution of duties and responsibilities essential to the efficient and safe operation of a nuclear generating facility. I strongly appeal to the Commission to reconsider mandating that a senior-licensed operator hold an engineering degree.

Kenneth R. Baker Operations Superintendent KRB/pk l

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