View source for PLA-3175, Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants

{{Adams
| number = ML20244E094
| issue date = 03/29/1989
| title = Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants
| author name = Keiser H
| author affiliation = PENNSYLVANIA POWER &amp; LIGHT CO.
| addressee name = Hoyle J
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000387, 05000388
| license number = 
| contact person = 
| case reference number = FRN-53FR52716, RULE-PR-50, RULE-PR-55
| document report number = 53FR52716-00243, 53FR52716-243, PLA-3175, NUDOCS 8904240293
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 9
}}

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gt             Pennsylvania Powcr & Light Company                                                        j Two North Ninth Street
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                                                                                                          '89 APR -6 A9 :57 Harold W. Keiser Senior Vice President-Nuclear                                                       lih 215/770 4194                                                                        GCCr.                   't   J Bib &
MAR M M Mr. John C. Hoyle, Acting Secretary U.S. Nuclear Regulatory Commission Washington, D.C.         20555
: Attn.: Docketing and Service Branch SUSQUEHANNA STEAM ELECTRIC STATION COMMENTS ON PROPOSED SENIOR OPERATOR DEGREE REQUIREMENTS                                                    Docket Nos. 50-387 PLA-3175              FILES R41-2/A17-11                                                 and 50-388

==Dear Mr. Hoyle:==

The Pennsylvania Power & Light Company (PP&L) appreciates the opportunity to provide comments as part of the " full public airing of views" concerning                                               '
proposed rulemaking on 10CFR Parts 50 and 55, Education and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants as published on December 29, 1988. It is PP&L's position that response to the proposed rule will provide the necessary information to allow the NRC to suspend all further rulemaking on this topic.
The commissioners may be deciding this important issue without the benefit of all the necessary information on Licensed Operator Training and the NRC licensed operator examination process. Operator Training throughout the industry contains a strong fundamental science and theory of operation component. The NRC has begun to administer national examinations on the                                                1 fundamental sciences involved in reactor operation to all Senior Reactor                                               '
Operator candidates. These examinations are based upon rigorous research by professional staff. They are ba: red upon the needs of the position.
All interected parties agree that reactor operations is a profession. Through the leadership of NUMARC and INPO and the dedication to the profession of incumbent Reactor Operators and Senior Reactor Operators we have made substantial improvements in reactor operations. Enhancing the capability of our operating staff to respond to accidents and to restore the reactor to a safe and stable condition after an accident is an important component in our continued efforts for improvement. Upgrading the operating, engineering, and accident management expertise of our entire organization is a goal of our ongoing training and development programs.
8904240293 890329 PDR      PR M )0 50 53FR52716           PDR                                                                                 l6.

l FILES R41-2/A17-11 PLA-3175 Mr. John C. Hoyle i
Imposition of degree requirements that are not based upon a recognized'need will not contribute to the protection of the health and safety of the public.;
Instead .they will undermine ongoing efforts at improving professionalism, demoralize operators, and divert the attention of operating professionals and training staffs from training specifically designed to upgrade operating, engineering, and management expertise on-shift toward more generalized educational topics.
Many utilities'have educational assistance programs-in place and cooperate with local colleges to provide courses for employees. Innovative programs have been established'through the cooperation of industry and the academic sector to meet specific educational needs of operations personnel. The University of the State of New York, Regents College Bachelor of Science Degree in Nuclear Engineering Technology and the University of Maryland's Bachelor of Science in Nuclear Science are. examples of attempts to make college degree programs available to operating personnel.
Therefore, it is PP&L's position that NRC suspend all further rulemaking on this topic.
We are particularly pleased to provide responses to your specific questions.
They are attached.
Very truly yours, o
H. W. Keiser Attachment cc: NRC Document Control Desk (ot tginal)
NRC Region I Mr. M. C. Thadani, NRC Project Manager Mr. F. I. Young, NRC Sr. Resident Inspector

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PP&L Comm nts -
Page 1 of 7.
: 1. Which alternative is preferable assuming one will be selected?                     4 Neither alternative could be considered preferable.- Neither has a basis.         4 Programs are ongoing to upgrade the expertise'of operating crews. A degree requirement could not be categorized as " preferable" for either alternative.
            - Alternative one continues the already discussed potential negative safety implication and the actual negative impact upon operator morale._ lts            !i application to all future SO's is not justified by any analysis.                  j Alternative twc is unworkable and even more poorly directed than alternative one. Personnel with the operations experience gained by promotion through non-licensed to RO to SRO positions would be excluded from the Shift Supervisor positions as a result of the ABET degree requirements. It is not possible for an on-shift operator to complete an ABET accredited degree while working.
It is possible for an on-shift operator to complete a degree provided the degree need not be from an ABET accredited program. ABET accrediting criteria only consider traditional university programs. Although ABETis considering accrediting criteria for non-traditional technology programs, approval is at best in the distant future. A!ternative two veill effectively exclude current operatioris personnel from the Shift Manager position.
L            Few on-shift operatierts personnel have rompleted degrees from ABET cccredited universities. Non-traditional educational programs available to shift operators are not ABET accredited. Unless ABET revises the criteria, they cannot become accredited. In Pennsylvania, and most states, an ABET accredited bachelor degree or four years of actual engineering experience is l
required to take the EIT examination.
The best alternative is to allow the industry to continue its efforts to improve reactor operations and staff qualifications without the encumbrance of this rulemaking. The standards that are in place at this time are supported by the i

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i PP&L Comments Page 2 of 7-
   ;                              NRC staff and the industry. If the commissioners feel that additional criteria should be imposed a task force of educators, NRC representatives, and industry experts should develop the new criteria.
2, What are the potentialimpacts of each of the alternatives on licensee staffing?
h Alternative one would require the addition of 'at least six additional operator positions to allow assignment of operators to attend college classes in order to complete the degree in a reasonable period of time. To allow for the expected rate of resignations of operators after receiving their B.S. degree the addition of twelve positionsis reasonable. An additional educational r
advisor / tutor would also be needed to guide students and coordinate on-site and off-site courses to meet degree requirements.
                               . Alternative two would require utilities to recruit engineers with degrees from ABET accredited universities, who would adapt favorably to shift work, and would remain in the Shift Supervisor or Shift Manager positions for an extended period of time. There are two major staffing problems caused by this alternative.
e There are many factors that are considered in the selection of an individual for Shift Supervisor positions. These include leadership, management skills, technical knowledge, operational experience, and aptitude for the specificdemands of the position. The additional requirement of a degree from an ABET accredited program will eliminate most candidates currently being developed for the Shift Supervisor position and upset the rating system for those characteristics.
The standards for the non-education characteristics will, by necessity, be lowered to allow a sufficient number of degreed personnel to be included in the pool of candidates. The majority of knowledgeable industry personnel involved in degreed supervisor discussions have commented thatthe benefits gained by the imposition of a degree requirement would be overcome by the losses in availability of more qualified but non-degreed individuals. The outcome will be a degradation of reactor safety

4 PP&L Comments Page 3 of 7 as a result of a decrease in technical expertise normally developed through experience.
e  Most utilities have found it difficult to attract and retain high quality, degreed individuals in rotating shift positions for extended periods of time. At least seven years of training and experience are required to develop an adequate Shift Supervisor. There is great potential for
        ,         engineers to leave the Operations group in seven years or less. Non-degreed Shift Supervisors are near their maximum learning and prestige level in that position. Degreed engineers can reach that level without the rigors of shift work. Money seems to motivate non-degreed individuals to remain on shift work, but it appears to have little influence upon degreed engineers.
: 3. Regarding implementation of the alternatives, would there be a more appropriate transition period for each alternative than the one proposed?
Yes, a more realistic time period would be seven years for either alternative.
Concerning alternative one, this would allow some on-shift operators time to complete courses needed to for a college degree. A full-time student normally requires four years to earn a bachelor degree. An adult would require as many as ten years to complete the entire degree program on a part-time basis. The seven year time frame includes the assumption that college credit would be awarded for parts of the utility's training program.
I' For alternative two the seven year implementation period would allow time for the utilityto recruit non-operators with degrees from ABET accredited programs, give them operating egerience in the plant, train them as RO, assign them to licensed duties as RO, train them as SRO, assign them to SRO duties, and provide the coaching and counseling needed to become a Shift Supervisor.                                                                                          !
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: 4. Alternative two provides for three different methods for demonstrating technical expertise with educational credentials. Would some other                                   j j            alternative method be desirable for this purpose? Are there other alternative l
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PP&L Comments Page 4 of 7 ways to demonstrate knowledge of appropriate engineering fundamentals for people who may be ineligible to take the EIT examination ?
The methods identified in this alternative would be appropriate if the supervisor were doing engineering analysis, design, or architectural work.
However, such methods are not appropriate for Senior Reactor Operators or Shift Supervisors. The EIT examination judges a developing engineer. The        l r        examination design attempts to determine the knowledge needed for a career as a professional engineer. There is no evidence that suggests that a   j college degree, a Professional Engineer's license, or the EIT examination is a valid predictor of success for SRO or Shift Supervisors.
i An alternative that would establish educational credentials based upon an analysis of the staff supervision job responsibilities could be developed.
Under this alternative a task force of educators, NRC professional staff, and industry representatives would analyze the duties and responsibilities of the staff supervision positions and recommend appropriate credentials depending upon the need identified.
Criteria could include:
e an engineering degree as stated in alte: native 2 e other BS degrees e    the core science courses from engineering degree programs e enhanced training ornevere accidents e enhanced management training e    national Shift Supervisor Training Programs The NRC already has in place an appropriate alternative to the EIT examination. The generic fundamentals examination administered as part of the operator licensing process provides the alternative. The NRC has performed a systematic analysis of the SRO position and published the Knowledae and Abilities Cataloa for Nuclear Power Plant Operators: Boilina Water Reactors, NUREG 1123 and the Knowledae and Abilities Cataloa for Nuclear Power Plant Operators: Pressurized Water Reactors, NUREG 1122.
These documents provide "the basis for development of content-valid

PP&L' Comments -
Page 5 of 7 licensing exarninations for Reactor Operators (RO's) and Senior Reactor Operators (SRO's)."
3 LThe NRC has already established the technical and engineering knowledge -
required for SRO and Shift Supervisor positions through this analysis. The current licensing examinations are based upon the results of this research.
The artificial imposition of a college degree, a Professional Engineer's license, q or an EIT examination is unwarranted and unsupported by either reason or
                                                                      . research. The process currently in use by the NRC provides the best available method of demonstrating knowledge of engineering fundamentals because it is based upon the SRO/ Shift Supervisor position itself and not upon an .
engineering education.
: 5. Should a requirement be imposed requiring all senior operators to pass an Engineer 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?
l No. An EIT or equivalent examination must not be imposed. To do so would result in improper discrimination against the individual without an engineering education. An EIT or equivalent examination would be appropriate if the individual were a candidate for an engineer position. The EIT or equivalent would not be valid as a selection instrument for SRO or Shift Supervisor.
As stated in our response to question number 4:
The NRC already has in place an appropriate process to demonstrate knowledge of engineering fundamentals. The NRC has performed a systematic analysis of the SRO position and published the Knowledae and Abilities Cataloa for Nuclear Power Plant Operators: Boilina Water Reactors. NUREG 1123 and the Knowledae and Abilities Cataloa for Nuclear Power Plant Operators: Pressurized Water Reactors. NUREG 1122.
These documents provide "the basis for development of content-valid
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i-PP&L Comm:nts .
Page 6 of 7:
licensing examinations for Reactor Operators (RO's) and Senior Reactor Operators (SRO's)."
The NRC has already established the technical and engineering knowledge required for SRO and Shift Supervisor positions through this analysis. The current licensing examinations are based upon the results of this research. The artificialimposition of an EIT examination or a college degree are unwarranted and unsupported by reason or research data.
The process currently in use by the NRC provides the best available method of demonstrating engineering fundamentals.
: 6. Independent of a degree requirement,is there a need forthe experience requirement to be increased for the Shift Supervisor position? Are the proposed requirements called for in the two alternatives sufficient?
Three years of oper& ting experience for an SRO is sufficient providing one .
year is " hot" operating experience as an RO. No credit should be allowed for time spent in initial training for RO or SRO. Requalification Training           -!
completed as part of a' cyclic training schedule should be counted.
Three years of experience for Shift Supervisor or Shift Manager is not sufficient. At least six years of experience in nuclear plant operation including' Operations, Engineering, Maintenance, and Training should be completed. Two of these six years should be completed "at the controls" or directly supervising licensed operations with an RO or SRO license, as appropriate. One year of these two years of direct operations shoulo be in a       i
                                                                                        " hot" condition. Time spent in initial training for RO or SRO should not be included in this six years. Requalification Trainireg completed as part of a cyclic training schedule should be counted.
Two years of nuclear experience for licensing as a Reactor Operator is insufficient. The three' year requirement should be retained.

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PP&L Comm::nts Page 7 of 7 Responses to Commissioner Roberts' cuestions.
           ' 1. How accessible are ABET accredited engineering programs?
They are not accessible to working adults at nuclear pc,wer plants. All require on-site i.ttendance at the college or university. ABET does not accredit non-traditional engineering or technology programs.
: 2. Which states allow registration and/or classification as an EIT without an ABET accredited program?
in Pennsylvania, for classification as an EIT or permission to take the EIT
               - examination, a candidate must either:
e    have been graduated from or have senior status in an ABET accredited Engineering or Engineering Technology Degree Program or e have four years of state registration board approved engineering
: experience. Board approval requires the development of knowledge and skill approximating an ABET accredited college degree.
Nuclear plant operations experience does not meet board approval requirements.
: 3. _ Will state registration boards grant credit for operating experience "as acceptable professional engineen ... to practice engineering?"
i The Pennsylvania registration board will not accept operating experience.           )
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