ML20235S540

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Questions Ability of Proposed Rule to Achieve Objective

ML20235S540
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/24/1989
From:	PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00127, 53FR52716-127, NUDOCS 8903070169
Download: ML20235S540 (3)

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David W. Cockfield Vice President, Nuclear

~ '89 FEB 27 P2 :49 i

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D . y, 1 February 24, 1989 [

Trojan Nuclear' Plant Docket 50-344 License NPF-l'

./ l Secretary of the Commission Attn: Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Sir:

Comments on Proposed Educational and Experience Requirements Rule (53 FR 52716)

On December 29, 1988, the Commission published for comment (53 FR 52716) its proposed rule [ Title 10, Code of Federal Regulations, Parts 50 and 55 (10 CFR 50 and 55)) to require additional education and experience require-ments for senior operators and supervisors. Portland General Electric (PGE) is pleased to provide the following comments on the proposed rulemaking.

While we endorse the stated motivation behind the proposed rulemaking of  :

protecting public health and safety by enhancing the capability of.the operating staff to respond to accidents, we question the ability'of the proposed rule to achieve that objective. In fact, we believe the proposed rule would do just the opposite. The following forms the basis for that conclusion:

• Shift experience levels lowered due to probable higher turnover rates of degreed operators (Reference 1).

• Morale lowered because the career growth of a non-degreed operator is limited (Reference 1).

• A focused training program is more effective than a college degree for enhancing accident response (Reference 2).

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. Operator performance will suffer with imposition of a formal degree requirement without evidence that the degree is necessary to do the job (Reference 3).

I 8903070169 890224 53 52716 PDR 121 SW Salmon Street. Port:and. Oregon 97204 .

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'r' WMMM Secretary of the Commission February 24, 1989 Page 2 Imposition of the proposed. rule which has received such overwhelmingly negative comments from the industry in the past will, in our opinion, detract from our ability to maintain an experienced and motivated staff.

Such a staff is essential for safe and reliable operation.

In addition, we endorse Nuclear Management and Resource Council's (NUMARCs) letter of January 27, 1989 requesting that the comment period be extended for an additional 30 days. The reason for our endorsement.is that we do not have sufficient information to argue the pros and cons of Alternative 2 of the proposed rule. Our preliminary views are that the number of programs accredited by the Accreditation Board for Engineering and Technology (ABET) in our location may be quite limited. Also, Alternative 2 may create much of the same objectives we have expressed above for Alternative 1. We need further time to adequately substantiate our suspicions.

Sincerely, y i c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear plant

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' Trojan Nuclear. Plant' Secretary of the; Commission Docket . 50-344 February ' 24, 1989 License NPF-1 Attachment REFERENCES f=

1. "An Attitude Survey of Nuclear Power Operations. Personnel on the Degree Requirement for Senior Reactor Operators", contained in-letter from KMC, Incorporated to the NRC, dated August 10, 1988.

2. " Operator Response to Incidents, A Prohibitive Risk Perspective", '

contained in letter from'KMC, Incorporated to the NRC, dated September 29, 1986.

3. " Report of the PEER Advisory Panel and the Nuclear Regulatory Commission on Operator Qualifications" (SECY 82-162).

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