ML20235T739

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

ML20235T739
Person / Time
Site:	Monticello, Prairie Island, 05000000
Issue date:	02/23/1989
From:	Larson C NORTHERN STATES POWER CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00166, 53FR52716-166, NUDOCS 8903080450
Download: ML20235T739 (3)

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j Monticello Nuclear Generating Plant Docket No. 50-263 License No. DPR-22 Prairie Island Nuclear Generating Plant Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Comments on Proposed NRC Rule on Education and Experience Requirements for Senior Reactor Operators and Supervisors

Reference:

Federal Register, Volume 53, No. 250, December 29, 1989 l

Proposed NRC Rule, " Education and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants" Northern States Power Company appreciates the opportunity to review and comment on the proposed NRC rule related to education and ex-perience requirements for senior reactor operators and supervisors at nuclear power plants published in the Federal Register on December 29, 1988. We have the following comments to offer:

Need for Proposed Rule The proposed rule is not needed. As many commentors noted in response to the Comrnission's advanced notice of proposed ruie-making on this iuue, many a.spects of the rule will have a nega-tive impact on overall plant reliability and safety of operation.

j The vast majority of the negative comments offered in response to the advanced notice of proposed rulemaking remain valid and have not been fully addressed in the proposed ruie.

Alternative 2 - The Preferred Option if a Final Rule is Issued If the Commission concludes that a Rule ic necessary, and specifies one acceptable method for upgrading education i

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- February 23, 1989-Northem States Power Company y

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experience requirements, then Northern States' Power Company be-

-lieves;that Alternative 2,Las described in the notice accompany-ing thefproposed' rule,- is the' preferred alternative.'-

We have two.relatively m'inor suggestions for improving Alterna-tive 2, however, which will add. flexibility to the new rule.

.First Proposed Change to Alternative 2

- J Revise a' portion of paragraph 50.54(m)(ii)(C) to read:

...A bachelor's degree in engineering or science from an accredited. college or. university; a' professional engineer-license issued.by a state government; or a bachelor's degree

'in a non-scientific field from.an accredited' collegeor university and an Engineer-in-Training (EIT)' certificate that indicates one has passed an examination administered by a state or other recognized authority....

i Reason-for Proposed Change:

This change would clarify the-language and allow a-bachelor's degree in science to meet the degree requirement of the rule.

We believe that a degree in any scientific discipline, combined.

.with'the intensive training in engineering fundamentals included in the. Senior Reactor Operator Training Program, is' reasonably equivalent to a bachelor's degree in engineering or the knowledge necessary to obtain an EIT certificate.

This is also consistent-with the degree requirements for engineering watch officers'in the. naval' nuclear propulsion program.

To implement this new requirement, utilities will seek to provide-degree opportunities for employees on site, or at nearby colleges and universities.. Engineering degree programs are generally limited.to on-campus programs at large institutions which are-remote from the plant sites. On-site programs that result in a degree in' science are feasible, however, and severel utilities

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already have such programs.

Second Proposed' Change to Alternative 2' Revise portions of paragraph 50.54(m)(ii)(D) to read:

must have at least three years of experience at a nuc-lear power plant, of which at least one year must be as a licensed control room operator cr. senior licensed member of the plant engineering and technical support staff, for a power reactor operating at greater than twenty percent power....

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Szerstcry of th2 C mmincien February 23, 1989 Northem States Power Company Page'3~

' Reason'for. Proposed Change:

This change will. permit members of the plant engineering and technical support staff who hold Senior Reactor Operator Licenses to hold the position of senior site manager.

At many sites, - the position of control room operator; is not

'available to members of utility' management or.the site engineer-

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ing and' technical support = staff. This. change will permit highly.

qualified management and technical support personnel to qualify for the position of' senior site manger.

Senior site. managers will,be, carefully seleeted by utility man-agement. Having earned an NRC. license, and having served in a plant management or technical. support role, provides assurance j.

that~an individual possesses the experience needed to fill the role of senior site manager.

-Please contact us if you have-any questions related to our comments on the proposed NRC~ rule on education and experience requirements for -

-senior operators:and supervisors.

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l C E Larson-Vice President Nuclear Ceneration c: Members of.the-Commission Chairman Lando W Zech, Jr Commissioner Kenneth M Car l

Commissioner James P.Curtiss Commissioner Thomas M Robertu Cotamissioner Kenneth C Rogers Nuclear Management and Reserarces Council Attn: Mr Byron 14ra, Jr.

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