ML20235T701

Comment Opposing Proposed Rules 10CFR50 & 55 Which Require Degrees of Senior Operators & Shift Supervisors.Both Alternatives Would Contribute to Lower Morale Among Reactor Operators

ML20235T701
Person / Time
Site:	Callaway
Issue date:	02/17/1989
From:	Sampson S AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00141, 53FR52716-141, NUDOCS 8903080431
Download: ML20235T701 (3)

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,. 0 .gg FEB 28f MUOB . J The Secretary'of the Commissioner

, i 'U.S.--Nuclear Regulatory Commission J.% . , ; -

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L washington, D.C. 20555 d^% gt To whom it may concern,

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The1following are'my comments to those six. areas that the ;i

USNRC,hasErequested' comments ~on, for the proposed rule change- H

_tof10CFR50.and 55, whichLwould require' degrees.of either all

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. senior.. operators or shift supervisors. j cl.. Neither: alternativeis preferred. The NRC;hasn't- .j Demonstrated?that there is.a real need for additional degrees

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on shift. :From a personal' standpoint,.I would prefer ,

alternative-2. ,My.. company >would.then send me to college solI could obtain an; ABET degree.

2. Both alternatives would-be contributors to one or-more ofu

, Ithe.following:

a. -lower. morale among reactor operators'without-degrees

.whose; natural career path would be blocked.

b.- reduced operating _ experience on shift as senior

. operators with' degrees move to other positions in i management.

c. :overall reduction in safety as. senior licensed personnel leave shift and as reactor operators leave shift for. positions that provide a promotion path to management.

d. experienced operators, RO and SO will leave the Operating Department, or the nuclear industry, rather than be encumbered with additional education that is seemingly unneeded.

3.- The comment is made at least twice in the proposed rule that four years, " allows personnel sufficient time and notice to complete a degree". I am in the process of' completing the requirements for a B.S. in Physics. I started in September of '

1980jand will graduate in May of 1989. I have attended every fall and spring semester except for the fall of 1984 when Callaway was going through power ascension testing. In addition, I have attended school three summers during that time. Each semester I have taken at least six credit hours and several semesters took nine credit hours. As it has taken me eight and one half years to achieve this degree, I don't see how the NRC can come to the conclusion that it can be done in 8903080431 890217 P 5 53 52716 PDRf h ]

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j Page 2 only four years. It seems as though the implementation period should be longer to acccunt for real time.

4. I thought that in order to show' technical' expertise as a senior operator, I went through the licensing process'which culminated'in my receiving, from the USNRC, a senior license!

What other technical expertise are we looking for? I am taking the last course I need in order to graduate from college and I have yet to'take a course that could be beneficial to me, while'trying to mitigate an accident. The r remise of .this statement as written in the federal registe. is' flawed:in that technical expertise, in a nuclear reactor control room, isn't demonstrated with educational. credentials. Technical expertise is demonstrated every day on the job by how one acts or reacts, to prevent occurrences that come his way. How one foresees ..

situations, plans for them and then when they come, how he then uses his plan to combat what has happened, is technical-

-expertise. This' technical' expertise.is not taught in a

-university, one learns it through experience and training.

-This is what I have attempted to do.since entering nuclear

-power generation in August of 1964. In Missouri an individual cannot sit-for a'PE or EIT examination unless he already has an ABET degree. I.would be at a disadvantage compared to SO's in other-states that do not have such restrictions.

5. I do not feel that having senior operators pass an EIT exam

'is going to add'to their abilities to protect the health and safety of the public. Rather than a degree requirement, it would be more prudent for.the NRC to require those individuals in the Shift Supervisor position, to have a specific curriculum ,

designed to enhance their accident mitigating expertise.

6. . I believe that_the shift supervisors at our country's nuclear plants should be our-most experienced operators.

Contrary to.this, my utility and others have been promoting licensed STA's and non-licensed engineers into the control room j supervisor position. This process bypasses the pool of j experience we have in the Operations Department, that being the l reactor operators and equipment operators. This pool of l experience does not get tapped for management positions, as ]

long as this situation is allowed to continue. If we required all senior operators to have degrees or just.the shift supervisors to have them, are the degreed personnel going to hire in at. entry level positions and work their way up the ranks? I think not. The proposed experience requirements need to be greatly strengthened. The proposal is to require one year as reactor operator and three years total operating experience. This can be easily gotten with very little real l

operating experience garnered. For instance, take the example of the maintenance planner who gets his reactor operator license and then stands his qualification watches, which are

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only seven'per calendar quarter._ At the end of this-l -individuals one year of be~ing a licensed reactor operator he-

.would'have stood a total of only twenty eight, eight hour 1 watches. Are_we now saying that this individual is ready for a senior operator exam, due to his' experience as a reactor _

operator? I think.not. I believe this is exactly what could

, happen if a much' tighter restriction is not adopted. . "one year as the reactor operator on duty, with no other concurrent duties assigned. One year is defined as at least 2000 working hours." This would now ensure that this' year as-a reactor operator.is a real year of operating experience.

^' I am opposed to either of the listed alternatives and.have been for some time. 'The perception of being better qualified because a. person has an engineering degree, is:just that, a perception that has no basis in fact. Where is the data that supports-the claim, that the adoption of this change to 10CFR50 and 55 would enhance the. health and safety of the public? The safety record of commercial nuclear power plants in-the United.

States is one of=the finest in the history of the industrial-

-era. I am concerned that this change would mean less safety rather than more. Thank you for your time.

Sincerely, A

Stephen E. Sampson Shift Supervisor Callaway Nuclear Plant P.O. Box 620-Fulton, MO 65251 (314)'676-8234 l

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