ML20235T790

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Establishment of Programs for Operators to Earn Degress Would Be Expensive

ML20235T790
Person / Time
Site:	Callaway
Issue date:	02/20/1989
From:	Nowell W AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00143, 53FR52716-143, NUDOCS 8903080474
Download: ML20235T790 (2)

Text

h

~

m e,'

w /

f.

000KET M 20 POSED RU d

Q[')Q klb 3

,, a .

February 20 -1989:

' Eidif '

a lY ~ WadeLD.-Nowell -

~89 TEB 28 All:1Ot R- 2300'McGuire Lane.

Columbia,'"Mo. 65202. .

v"

' ~ vFF..s . . . - .w

. 00CK&S ,

' W.tv. ' @ f

. Secretary'of.the Commission ~

.U.S. Nuclear Regulatory Come.ission Washington, D.C.~20555 '

N -Gentlemen:

-I would like'to offer the following comments regarding the proposed' rule:

.on Education:and Experience Requirements-for Senior Reactor Operators and-

. Supervisors at. Nuclear' Power Plants. I feel'that the imposition of-a degree requirement lfor senior operators.or shift supervisors / senior man-agers would have.anadverselimpact on your stated objective of enhanced - c plant safety. . Nuclear. plant operators alr'eady work in a fish' bowl. .

The. initiation of.this proposed rule can only result in'a further. lowering.

cof morale. The blocking of promotion paths will increase the difficulty.

in recruiting-quality; personnel in.the lower operations' positions.- This

, . dilution of operating expertise will be'further. complicated by a higher turnover rate as qualified' operators take more a'dvantage of other oppor-tunities. -An engineering _ degree does not guarantee,~and is no substitute for, good leadership ability. An ability that is especially important during rapidly changing plant conditions. In addition, the best' shift

. supervisor / manager cannot effecectively mitigate the consequences of an accident.without the support of knowledgeable and experienced subordinate personnel to carry out assigned tasks in a timely manner.

The establishment of programs to allow current operators to earn degrees

.vould'be,very expensive and time consuming for utilities to undertake.

Assuming there is an " accredited institution" within a reasonable distance, it'would take.an operator several years.to obtain a' degree on his own time.

This would also compound the hardships already imposed on family life by shift work. The goel of. operators having " sufficient understanding of ~

basic engineering principles, and detailed knowledge of nuclear design and-operation" does~not necessarily require a full engineering degree. A basic curriculum of engineering courses could be taught on site and be more cost efficient for utilities in terms of time and money. This combined

.with current accredited training programs should meet the desired goal.

Due to competition from qualified individuals in other departments, the degree requirement would not likely have a significant impact on the number of senior operators promoted to upper plant management. There is a sufficient number of current degreed senior operators to fill these promotional opportunities.

e O474 0 .

w- Oga os/0 i

7 "4 I,, .a n ' / ' ' i

' N f ,.

'i

&'d e,s

.m ,

y

> 7 g=,

~.

+ : ;;

g . Thank,you for.your; consideration'of these comments.

. .o

7. , 3,

. Sincerely,.

f-

. Wade'D..Nowelli

Operating Supervisor,

- Callaway Nuclear Plant'.

~

a. e, i__ii t

.f l

l,.

.l l

l l

l 5

's e...- -._-.._m__._____m_ . . . _ . _ _ _ . . _ . , _ _ _ . _ _ _ _ _ _ . . . _ _ _