ML20198M244

Informs of Mit Opposition to Proposed Amend Which Would Require Licensees to Prepare,Proctor & Grade Written Exams for Individuals Applying for Operator Licenses.Rejection of Proposed Amend,Urged for Listed Reasons

ML20198M244
Person / Time
Site:	MIT Nuclear Research Reactor
Issue date:	10/23/1997
From:	Bernard J MASSACHUSETTS INSTITUTE OF TECHNOLOGY, CAMBRIDGE
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-64FR19868 AF62-2-037, AF62-2-37, NUDOCS 9710290004
Download: ML20198M244 (2)

Text

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I NUCLEAR REACTOR LABORATORY hj%Te_E#

$ f AN INTERDEPARTMENTAL CENTER OF MASSACHUSETTS INSTITUTE OF TECHNOLOGY -

JOHN A. BERNARD 138 Albany Street, Cambridge, MA 021394296 Activata Analysis D+ rector Telefax No. (617) 253-7300 coolant (Aemistry D,rictor of Reactor Operations Nuciear Mediene Principal Research Engineer Tet No.(617) 253-4202 Reactor Engineenng October 23,1997 l

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: l>ocument Control Desk

Subject:

RIN 3150-AF62, " Initial Licensed Operator Examination Requirements" Gentlemen:

The Massachusetts Institute of Technology is opposed to the adoption of the proposed amendment that would requim licensees to prepare, proctor, and grade the written examinations and prepare the operating tests that the NRC currently uses to evaluate the competence of individuals applying for operator licenses.- While MIT recognizes that the proposed rule would only affect power reactors and hence have no direct impact on the research mactor that is operated by MIT, MIT nevertheless feels that the proposed change is detri mental. Our reasons are as follows:

1. The administration of exams to determine competency for the receipt of an initial license in most professions is normally performed by an independent agency. Examples include the

' medical, legal, professional engineering, and health physics professions. There is goed

. reason for this practice and the proposed rule would represent a very substantial deviation _j

' from it. V

2. _ The proposed rule, if adopted, would undermine public confidence in the regulation of nuclear activities. This loss of confidence would extend to all reactor operations, not merely power plants.

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3. The preparation and administration of initial licensing exams by an independent agency k serves as a quality assurance chec!: on the entire training process at each licensee.

Adoption of the proposed mie would undermine that independent check and over time quite possibly result in the ingrowth of undetected weaknesses in training programs.

4. The administration of initial licensing exams to operator candidates by an independent agency fosters a sense of professionalism in the candidates. It makes the candidates realize that they have both a responsibility to their employer and also a larger responsibility to the nuclear community as a whole. If individual employers prepare and administer the exams, then the candidates' sense of responsibility to the community as a whole will be greatly lessened.

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U.S. Nuclear Regulatory Commission

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> - Forthe above reasons, we would urge that the proposed amendment be rejected.

Sincerely, l

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John A. Bernard, Ph.

Director MIT Nuclear Reactor Laboratory

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. JAB /CRM

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'cc: USNRC - RegionI-ProjectScientist Radiation Safety Branch.

= USNRC - Region I- Senior Project Manager Nuclear Power Reactor and Decommissioning Projects Directorate 4"

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