ML20235T906

Comment on Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements of Senior Reactor Operators & Supervisors. Requirement for Educ from Source Other than Industry Will Probably Cut Into Time Allotted for Training Now Received

ML20235T906
Person / Time
Site:	Rancho Seco
Issue date:	02/19/1989
From:	Cooper M PROFESSIONAL REACTOR OPERATOR SOCIETY
To:	NRC
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00142, 53FR52716-142, NUDOCS 8903080523
Download: ML20235T906 (4)

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Subject:

Proposed Rule on the E pp 9 9/gdnce ation and Exper Requirements

~ of Senior Reactor Operators and Supervisors at Nuclear g>ggs Al1 :12 Dent Commissioners,

'Lh v I om writing in. regard to the above mentioned subject nvNeter as. of member of the workforce the proposed rule effects most. Since i hold a Senior Reactor Operator license and not a degree from a college or university at this time, my position might seem biased by the requirements that wousd be placed on me if either alternative in the preposed rule is chosen. I am occutely owere of the link between the uselfare of the public and my ousn job security. I consider my view based on the concern for' safe operation of Nuclear Power Plants in this country as well as many years experience as on operator in the industry.

I om all in favor of getting a so called " higher" education and do plan to attempt to get n degree in the future. You can't survive in this bussiness if you dm*t like school. I joined the Navy seventeen years ago and have been in " school *' constantly since. This brings up my first concern. Although I like the idea of the industry having a hand in possibly helping us already inplace in getting a degree, there is one thing that use must consider. The

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requirement for an education from a source other than the industry will probably cut into the~ time allotted for the valuable training use now are recieving. It perhaps u>ill not be usise to rob Paul to pay. Peter.

I u>ill nous comment on the six questions of most concern according to the Federal Register / Uol. 53, No. 250 "Invitntion to Comment" section.

1. Question: 14hich Alternative is preferable assumsag one u>ill be selected?

Comment: Of the two alternatives the second comes closer to meeting the needs of the industry in promoting safe operation of Nuclear Power Plants. There is no evidence that Alternative 1 will " enhance the capability of the operating staff to analyze and respond to complex transients and occidents" as the NRC believes. I don't knous of any College program that specifically opproaches engineered systems from the aspect of operating and inter-relating components.14 hen it comes to operating a Nuclear Power Plant the whole is greater than the sum of the parts. On the other hand a better understanding of all the parts would help a Shift Supervisor inter-relate with engineering and other departments. This could be valuenble especingly during equipement and system testing.

2. Question: 14 hat are the potential impacts of each of the alternatives on licensee staffing?

Comment: Alternative 1 u>ill likely have less impact as for as keeping experience on shift. I believe this because the Crondfather clause will 1

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nilous thost usho' do not wish to attnin a dagram who are Shift Supervisors o

to stay in that posnion. Tha longsr n Shift Suptruisor hos bien in the industry ( and therefor the more experience he has ), the more likely it u>ill be that he u>ill not enre to go through the change in lifestyle that L

L Alternative 2 usould seguire. Lots of experience will leave 'the industry crenting a void that will be difficult to fill. Our present day STA's will probably fill in a lot of uncated positions. They may be good engineers, but _

it will take a lot more than that to make them good operators and you need to be good if you are going to guide others. Education is still not n complete substitute for experience.

A person who wishes to' go further into management will more than likely seek n higher eduention on his' own. These people ore usually self motivated and that's the people you usant in senior management anyway. I agree that people u>ith operating experience should move on up into senior management, but going through the back door is not the usny to make it happen. Just require it upfront that certain positions in plant management have some operatino experience and possibly hold an NRC license or certificate.

- 3. Question: Regarding implementation of the alternatives, would there be a more appropriate transition period for each nitemative than the one proposed?

Comment: The proposed transition periods seem appropriate if either niternative is selected.

4. Question: Altemative 2 provides for three different methods for demonstrating technical expertise usith educational credentials.14ould some other metxod be desirenble for this purpose? Are there any alternative ways to demonstrate knowledge of appropriate engineering fundamentals for people usho may be ineligible to take the EIT examination?

Comment: I don't know enough about EIT certificates or state pE licenses to comment intelligently on what would be good alternatives. I con imagine however, that such requirements may limit the transfer of experienced people to neus pinnts if we ever get into the mode of building plants ngnin.

5. Question: Should a requirement be imposed requiring all senior operators to pass an Engineering in Training (EIT) or equivalent examination as a measure of basic technical expertise in addition to, or instead of, the tuso proposnis in this notice? If such a requirement were in place, would it be necessary to require enhanced educational requirements for Shift Supervisors?

Comment: I don't think the degree requirement is neccessary so this would be adding insult onto injury. A measure of expertise in our field is ones operating secord. possing tests and getting ones name on a list u>ill not prove one to be o good operator.

6. Question: Independent of the degree requirement, is there a need 2

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. U% UWh) lL (for the Gxp;rienca requirements, to be incrans d for tha shift supervisor ,

pozition? Ara tha propossd requirements collId for in tha' two olttrnativas sufficient? - )

Comment: I do think that the present Requirements for a Shift

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Supervisor are locking. At present an SRO con step into a Shift Supervisor

. slot without much more than n little time in his present position. I think that

' for someone to be n Shift Supervist he should have accumulated some experience in _ all the aspects of plant operations. As well as a time requirement ( say a period of two or three years as an $RO ) there should be considered a check list of. accomplishments the individual should have that proves the persons experience level. Some people have' lots of experience, but all on the some things. Such accoraplishments should be things like participating in a refueling outage, and taking the pinnt to various operating modes so many times. I feel strongly that in order for a Shift Supervisor to be on effective leader he must be the link between the operating crew and plant management and therefor o intergral part of plant management.14e give this fact a lot of prioity at our plant yet the Shift Supervisors do not get management and supervisory training that would help us do the job a whole lot better.

The present time (experience) requirements as well as those pinnned are in need of revising. l*ll state again that education is not a complete substitute for experience. To have less of a time requirement for someone usho has gone to college to pick up a piece of paper is not promoting safety. In talking with Engineers at the plant I have often asked how much of the education they recieved at college are they applying to their jobs. I am usually surprized to find how little it is, it is even less so with the STA's.

That is why I say I know of no college courses that cover the aspects of operating equipement and systems and how they inter-relate with each other. There is no logic therefore in allowing degreed individuals to have less of n experience requiremnet.

please allow me to conclude my comments now by summarizing my position. Foremost is the fact that there is no evidence that supports the NRC position that degreed individuals would be able to handle occidents and transients better. If you want to study this point further, why don't you survey the operators of nuclear plants and determine if those who hold degrees have been able to mitigate transients better.

The experience that is pushed out of the industry by altemntive 2 could never be replaced by any amount of education. The only benifit I could see coming from this alternative is a better communication between Shift Supervisors and pinnt engineers which could be benificial during maintenance  ;

and testing activities. This benifit would not outweigh the loss of experience. I l'm not so sure either that it will be advisable to get rid of the extra set of eyes and insight now provided by the STA. This position should not be ,

i thrown away lightly.  !

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g- vu.euww ou, ouvv-The training usa rcci va and should bn rccieving leads us to respond to plant conditions as they occur to placa tha plant in as sofs a condition as possible. That is the u>ny our procedures are unitten these days since use j got aujoy from the event orientated opproach that led the Tiil operators l dou>n the uxong path in '79. Let's not step backu>nrds by having the 1

l operators think again in the event orientated mode. It is operating experience that tells the operator whether the plant is responding as it )1 should.

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Thankyou for allou>ing me this opportunity to comment. Safety is of j concern to us all and our Number 1 priority.

Sincerly, -

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f1ichael D. Cooper Shift Supervisor Rancho Seco N ' # Region U presisident

[9GR7 professional Reactor operator Society 4

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