ML19316B066

Requests Concurrence That Operating Training Program Is Equivalent to Extra Man Concept or Background Studies to Justify Arbitrary Requirement.Reply Requested by 800701

ML19316B066
Person / Time
Site:	Point Beach
Issue date:	06/04/1980
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
TASK-1.A.2.1, TASK-2.B.4, TASK-TM TAC-44188, TAC-44189, TAC-44538, TAC-44539, NUDOCS 8006110271
Download: ML19316B066 (2)

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O Wisconsin Electnc powracnuesur 231 WEST M!CHIGAN, MILWAUKEE,WISC0f. IN 53201 June 4, 1980 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C. 20555

Dear Mr. Denton:

DOCKET NOS. 50-266 AND 50-301 QUALIFICATIONS OF REACTOR OPERATORS POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 Your letter of March 29, 1980 promulgated revised criteria for improvements in operator training. Part A.2 of Enclosure 1 to that letter specifies that candidates to be administered an examination for a senior operator license or control room operator license shall have served three months of shift training as an extra man on shift. Whi'le your letter states that some requirements will be established through rulemaking proceedings, it appears that the requirements of A.2 of Enclosure 1 are to be imposed on August 1, 1980 without such a proceeding. The purpose of this letter is to request further information and clarification pertaining to this new requirement.

Your March 29 letter refers to an Enclosure 9 to a September 13, 1979 letter from Darrell G. Eisenhut which in Part A(3) provides a recommendation for such a three-month extra man l on shift criteria. However, neither that latter document or your i March 29 letter provide any basis or refer to any studies which justify the new criteria. The purpose of the criteria is to improve the operator licensing program; while we have no objection to such a goal, we do not agree that serving as an extra person on shift is the only or even preferred method to do so.

We believe that the operator training program which has been in use at our Point Beach Nuclear Plant for many years i l

has proven to be effective in producing well qualified operators.

This program has provided that reactor operator candidates serve on shift as auxiliary operators and that most senior reactor  !

I operator candidates, including all of those becoming operating r.

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Mr. H. R. Denton June 4, 1980 supervisors, serve on shift as licensed control operators prior to taking SRO license examinations. The program has provided plant personnel with the shift operational familiarity that is probably the need perceived in the Staff recommendation. Also, our historical program has additional advantages beyond the extra man on shift concept in that the individuals are performing actual, hands-on operations for which they are responsible and not just observers of others' activities. Our candidates generally spend more than three months in these positions and as such the three-month requirement of the new criteria is not of significant concern.

What is of concern to us is the idea that the only way to become trained is by functioning as a non-productive extra man. This not only complicates the problems of properly staffing a nuclear plant at times of personnel shortages but also can be de-motivating to the type of individual we seek to attract for licensed operators. Since this extra on-shift person could not be assigned any operational duties, sitting on a stool in an out-of-the-way corner of the control room is hardly conducive to learning and motivation. It is to be emphasized that what is being objected to is requiring a candidate who is already a shift operating person to spend additional time as an extra person on shift. It may not be objectionable to require non-operating people to spend time as extra or subordinate level operations staff on shift to qualify for licenses, although there is still the question concerning the motivational aspects of such non-productive activity.

In summary, we believe that our program has demonstrated its effectiveness and request your concurrence that it is at least equivalent if not superior to the extra man concept. If you do not concur, it is requested that we be provided with whatever background studies that have been made by the Commission to justify what appears to be an arbitrary requirement. In anticipation of your August 1 requirement, your reply by July 1 will be appreciated.

Very truly yours, s/

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C. W. Fay, Director Nuclear Power Department

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