ML20236A534
| ML20236A534 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 03/09/1989 |
| From: | Steinhardt C WISCONSIN PUBLIC SERVICE CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00182, 53FR52716-182, NUDOCS 8903170367 | |
| Download: ML20236A534 (8) | |
Text
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WPSC(414)433-1598 ' -
/D TELECOPIER (414) 433-1297 EA g g g 1993 WISCONSIN PUSUC SERVICE CORPORATION {
600 North Adams
- P.O. Box 19002 e Green Bay, WI 54307-9002 l '89 MAR 13 P4 :07 ,
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March 9, 1989 Secretary of the Commission Attention Docketing and Service Branch U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Docket 50-305 Cperating License DPR-43 Kewaunee Nuclear Power Plant Comments on Proposed Rulemaking for Education and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants (53FR52715, !
December 29, 1988) _
Wisconsin Public Service Corporation (WPSC) appreciates the opportunity to com-ment on the NRC's proposed rule regarding education and experience for Senior Reactor Operators (SR0's). WPSC believes this is an extremely important issue and encourages the Commission to carefully consider these, and all other com- ,
ments that the Commission may receive. i NEED FOR RULE !
The Commission has proposed two alternative rules which would require engi-neering expertise on shift either by requiring future SR0's to hold an engi-neering or science degree, or by requiring the senior person on shift to hold an .
SR0 and engineering degree. The Commission's intent in passing this rule is, ostensibly, to improve safety by enhancing the capability of the operating staff to respond to accidents. WPSC understands the Commission's intent in proposing this rule, but questions the technical basis for the requirements.
The Commission has proposed this rule without any factual basis or study which would indicate that merely upgrading the education requirements for SR0's, or providing engineering expertise on shift, will indeed enhance an operating staff's ability to respond to an accident. The only stated basis for these pro-posed requirements is that the Commission " believes" that these requirements will provide the desired enhancements; it appears that this entire rule, and the g31g367890309 50 53FR52716 PDR_
Secretary of the Commission March 9, 1989 Page 2 regulatory backfit analysis, are predicated on the questionable assumption that such an enhancement will result. In fact, as noted by the Commission in the supplementary information and in the additional views of Conunissioner Roberts, the studies which have been performed to date have either been inconclusive, or have concluded that such rulemaking could result in a decrease in safety.
WPSC helieves that this proposed rule may in fact have a negative impact on safety for several reasons; first, the rule may result in lowered morale among both licensed and non-licensed operators. l.owered morale, if left unchecked, results in less job satisfaction, and will eventually be evidenced in deteriorating performance and increased rates of attrition. Our belief on the negative effect the rule will have on operator morale is supported by an atti- l tude survey ur. der the auspices of the Qualification of Reactor Operators Group (QRO) (a 13 member utility group). KMC, Inc. initiated this attitude survey for I the QR0 to access the potential consequences of the promulgation of the Degreed SR0 rule. The findings were presented to the Commission in August, 1988, with the firm conclusion that the proposed rule was neither desirable nor needed; ,
the results presented indicated that promulgation of the proposed rule would, in fact, threaten quality operating standards by such factors as lower operator morale, higher personnel turnover rates, and a lower level of operating exper-tise on shift.
Secondly, this rule will likely reduce the number of potential applicants for >
operator positions, thus unnecessarily limiting WPSC's ability to select the most qualified individuals for said positions. Finally, it is anticipated that this rule will result in a change in the normal job progression through the operations group. The typical progression has been for the operators to start ,
in non-licensed positions, and gradually progress through the licensed operator i positions to supervisory positions both on and off shift. This progression is likely to be perturbed since it is unlikely that individuals with college degrees in engineering or science will accept non-licensed operator positions, or the licensed operator positions which require rotating shift work. This ,
disruption in progression is considered detrimental to the quality of operations !
since it has been WPSC's observation that the best control room operators and supervisors are those that have had the non-1 :ensed experience. The Commission's study (NUREG/CR-1750) drew the same conclusion. Consequently, upsetting this progression may have a negative impact on safety.
WPSC finds it incongruous that the Commission would proceed with this rule-making, which will have a significant impact on the careers of the large majority of currently licensed individuals, without sound technical basis, e against the conclusions of the studies it has commissioned and against the advice of the Advisory Committee on Reactor Safeguards.
In regard to the Commission's specific concern of enhancing the ability of the operating crew to respond to an accident, WPSC offers that this ability has been greatly enhanced since the accident at Three Mile Island. Operator training has been improved by the addition of specific training in accident and transient l analyses, increased emphasis on fluid flow and heat transfer, and plant-specific simulator training. Additionally, the Shift Technical Advisor (STA) position has been created to provide engineering expertise to each operating crew.
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Secretary of the Commission
, March 9, 1989 Page 3 Finally, the emergency operating procedures have been extensively rewritten to provide improved event-specific and symptom oriented procedures. WPSC believes that these improvements and changes have adequately addressed the concerns that the Commission had in this area. Nevertheless, WPSC feels that if the Commission still seeks additional improvement in this area, the proper approach would be to impose additional requirements in accident analysis (e.g., specific operator training requirements), or to require a degreed individual on shift, instead of the proposed rules.
Though the explicitly stated objective of the proposed rulemaking is to upgrade the operating, engineering, and accident management expertise provided on shift, WPSC believes that the Commission has a different, implicit, intent in promulga-tion of this rule. The Commission repeatedly states that this rule will enhaned the promotional opportunities of SRO's, and that a migration of shift super-visors upward into the plant management organization will contribute to improved plant safety. Based on the many references to this theme in the rulemaking, WPSC feels that this implicit intent may, in fact, be the Commission's primary motive in proceeding with this rulemaking. WPSC agrees with the Commission that such upward movement by shift supervisors does contribute to quality opera-tions and improved plant safety. In fact, WPSC has long practiced the policy of promoting operations personnel in the nuclear organization based on performance and merit. This has resulted in a significant number of senior managers with operations experience who hold, or have held, Senior Reactor Operator licenses. l Furthermore, WPSC has recognized the shift supervisor position as one of the !
most senior positions in the nuclear organization, in concert with the Commission's intent of recognizing this resource as a managerial position.
WPSC has also recognized the value that a fundamental understanding of plant operation has to the improved performance of its engineering staff.
Consequently, WPSC's policy has been to provide plant-specific training to all new members of the engineering staff via the STA training program, which is pat-terned af ter our operator training program. This has resulted in an increased number of personnel with either operations experience, or training, available for promotion in the organization.
On the basis of these practices, WPSC believes that it already complies with the Commission's intent in this area. Additionally, WPSc. believes that it is not unique, in that most other utilities have similar practices. Therefore, WPSC questions the need for specific rulemaking to encourage this type cf program.
Once again, however, if the Commission feels compelled to promulgate rulemaking '
which would result in the migration of SR0's into the off-shift management, WPSC feels that such rulemaking should specifically address this. For example, the Commission could proceed with rulemaking which would require operations experience for certain manager positions; a requirement which would have to be justified on its own merit. However, it must be emphasized that WPSC feels that this is unnecessary.
Finally, it is WPSC's understanding, through information disseminated at NRC regional meetings and workshops, that there are a number of NRC license examiners who are not degreed or not SR0 licensed. The Commission may gain l
valuable insight from these examiners regarding the necessity for and the l
Secretary of the Comraission March 9, 1989 Page 4 potential impact of this proposed rule. Additionally, if it is determined that
] the proposed rulemaking is necessary, it may also be necessary to require simi-lar levels of engineering knowledge and operational experience for NRC license examiners.
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Secretary of the Commission l March 9, 1989 Page 5 ,
l RESPONSE.TO QUESTIONS The Commission invited comment on six specific questions. The following provi-des WPSC's responses to these questions.
- 1. Which alternative is preferable assuming one will be selected? )
d RESPONSE: WPSC again emphasizes that neither alternative should be pro- /
mulgated. Nevertheless, if one must be selected, WPSC prefers alternative one, i which is to require future applicants for SR0 licenses to hold a degree in i science or engineering or engineering technology. This alternative is pre-ferable because it " grandfathers" current operators, thus minimizing the impact on existing operations staff, it allows for a non-ABET accredited degree.(see below), and because it is less prescriptive. Additionally, it should be noted that alternative two overlooks the fact that the senior manager on shift has many administrative responsibilities in addition to his technical respon-sibilities. In the event of an accident, the senior manager must ensure that notifications are made, that the emergency plan is properly and promptly imple-mented, and that the health and safety of the plant staff as well as the public is properly addressed. These responsibilities will,-at best, delay the manager and possibly prevent him or her from becoming intimately involved in the plant response. Therefore, if additional engineering expertise is required on shift, it may be more appropriate to require it in a subordinate or parallel position.
WPSC must voice concern over one additional issue. In 1984, WPSC initiated ,
delivery of an on-site accredited Baccalaureate Degree program in Nuclear Science for its operations personnel. The primary concentration of this program is comprised of specific courseware in the thermal, material and chemical scien-ces, and mechanical and nuclear engineering. The degree program is fully accre-dited by the Middle States Association of Colleges and Schools. Now, under the provisions of alternative two, WPSC's proactive efforts to provide quality, scientific and engineering education to its operations personnel (and the par-ticipant individual efforts) would be jeopardized since the baccalaureate program has not been accredited by the Accredition Board for Engineering and Technology (ABET).
- 2. What are the potential impacts of each of the alternatives on licensee staffing?
RESPONSE: It is difficult to project the impact given the uncertainty in the -'
various ways that a utility would have to comply with the rule. For example, one approach would be to continue to hire non-degreed personnel in non-licensed positions and provide them the opportunity to obtain a degree prior to applying for a Senior Operator license. Since this would result in a longer period of time between initial hiring and application for a senior license, personnel turnover might be expected to be increased, and more operators would have to be l kept in the organization to accommodate attrition. The expected result may be an increase in staff.
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Secretary of the Commission (
March 9, 1989 Page 6 A second approach would be to hire degreed personnel with the intent of licensing them for operations jobs. Since these personnel will still require operations experience, and since it is unlikely that they will be satisfied {
working as non-licensed operators, this will result in a number of new positions !
in the organization.
Therefore, either alternative would be expected to result in an increase in the number of personnel in the organization.
- 3. Regarding implementation of the alternatives, would there be a more appropriate transition period for each alternative than the one proposed?
RESPONSE: WPSC believes that the proposed 4 year transition period is too short; six years is a more realistic duration from initial hire, to on-shift experience, through training for SR0 examination. However, WPSC also believes that "grandfathering" is imperative to salvage the careers and the morale of existing licensed and non-licensed operators. WPSC recommends that a "grandfathering" clause be added to alternative two if alternative 2 is selected as the rule.
- 4. Alternative 2 provides for three different methods for demonstrating tech-nical credentials. Would some other method be desirable for this purpose?
Are there other alternative ways to demonstrate knowledge of appropriate i engineering fundamentals for people who may be ineligible to take the EIT examination?
RESPONSE: WPSC believes that the requirements for an EIT examination, for an ABET accredited program, or for a professional engineer license are too prescriptive. If rules must be promulgated, WPSC believes that a technical or science degree from an accredited institution, combined with a senior operator license (which would require specific training in accident diagnostics and ther-modynamic disciplines) would be sufficient to meet the Commission's stated objectives.
- 5. 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 two proposals in this notice? If such a requirement were in place, would it be necessary to require enhanced educational credentials for shift supervisors?
RESPONSE: No, WPSC believes that such a requirement should not be imposed. If the Commission wishes to test Senior Operator license applicants on topics covered by the EIT, it could do so with its senior operator license examination.
If such a requirement were in place, WPSC believes that additional requirements for educational credentials would be unnecessary. Additionally, it should be noted that too much diversity exists among various states in regard to the requirements of EIT examinations to make such a rule equitable to all utilities.
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1 Secretary of the Commission March 9, 1989 Page 7
- 6. Independent of a degree requirement, is there a need for the experience requirements to be increased for the shift supervisor position? Are the proposed requirements called for in the two alternatives sufficient?
RESPONSE: As the existing regulations stand, WPSC believes that the three year l requirement specified in the proposed rules would provide an acceptable level of experience necessary to ensure safety for a non-degreed SR0/R0 candidate.
However, WPSC supports the requirements specified in ES-109 of NUREG-1021 for SR0 candidates with a 4-year degree in engineering or applied science. The so-l- called " instant SR0" provides a mechanism to select qualified degreed staff per-sonnel for certain operations positions.
Comments on Views of Commissioner Roberts WPSC applauds the comments of Commissioner Roberts. His comments provide a good l summary of WPSC's general position on the issue. In particular, WPSC agrees that it is inappropriate to attempt to accomplish the objective of providing personnel with operating experience in utility management by so severely pena-lizing the operators. WPSC would add that it should not be assumed that just because an individual has a degree, that individual.has the analytical skills for accident assessment or good managerial skills. Conversely, lack of a degree does not necessarily mean that an individual does not possess technical knowledge and analytical skills, or that the individual will not make a good mariager. WPSC believes the best policy to be one of promotion on merit, placing the individuals best suited for any given position in that position.
Regarding Commissioner Roberts' specific question regarding whether state registration boards will grant credit for operating experience as " acceptable professional experience", the answer is ambiguous, at best. Based on past prac-tice, it would appear that state registration boards would not accept operations experience in this regard.
Comments on Backfit Analysis WPSC offers the following general comments on the Commission's backfit analysis for this rule.
First, the entire justification of benefits is based on the presumption that this rule will provide an increase in safety, however unquantifiable. Yet, the Commission offers no basis for the presumption, and in fact, admits that most studies are inconclusive or even negative regarding the benefits of the rule. .-
WPSC feels that this is a significant flaw in the backfit analysis.
Secondly, WPSC feels that the result of this rule would most likely be an increase in staff, as explained in our response to question 2, above. This cost has not been addressed in the backfit analysis.
Thirdly, WPSC in particular would incur additional costs if alternative 2 was imposed because it would obviate the benefits of an existing program in place at WPSC. As mentioned previously, WPSC has implemented a program, at great cost, which provides operations eersonnel the opportunity to obtain a baccalaureate degree in nuclear science. This degree would not be accepted under alternative 2.
Secretary of the Commission March 9, 1989 Page 8 This discussion indicates that the backfit analysis performed by the NRC does not adequately address the costs of this proposed rule and overestimates the benefits of same. In WPSC's opinion, the rule is not cost justified.
Summary WPSC strongly believes that recent improvements in the qualifications and training of reactor operators and senior reactor operators, the existing requirements for engineering expertise on shift, and improvements in emergency operating procedures and emergency planning have adequately addressed the Commission's concerns regarding safety. Furthermore, WPSC believes that current industry practice regarding selection of management personnel has resulted in utility management possessing appropriate operational background, thus addressing the implicit concerns expressed in this rulemaking. Therefore, WPSC strongly encourages the Commission to permanently suspend this rulemaking. If the Connission is compelled to promulgate additional rulemaking in this area, WPSC suggests that a general requirement to provide a degreed SR0 on shift be considered. This would allow licensees to implement the rule in a manner best suited to each licensee.
As always, WPSC is available to discuss these comments in further detail with you.
Sincerely, C. R. Steinhardt Manager - Nuclear Power CSS /jms cc - Mr. Robert Nelson, US NRC US NRC, Region III US NRC, Document Control Desk 1
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