ML20235T696

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants

ML20235T696
Person / Time
Site:	Diablo Canyon, 05000273
Issue date:	02/21/1989
From:	David S PACIFIC GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00145, 53FR52716-145, NUDOCS 8903080427
Download: ML20235T696 (3)

Text

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A m sE PacificGasandElectricCo pa o n u m L Q* [

hoNyhowerPlant i

R0. Box 56

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Avila Beach. CA 93424 805/595 7351

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February 21, 1989 00Cm - <<

Secretary of the Commission U.S. Nuclear Regulatory Commission-Washington, D.C. 20555 Attention: Docketing and Service Branch

Dear Sirs:

This. letter is written in response to the Nuclear Regulatory Commission's proposed rule on Education and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants. My opinions are similar to many of those expressed by operators and supervisors at this utility as well as by others. Specifically, Commissioner Roberts' views published in the Federal Register on December 29, 1988 (53 FR 52721) regarding the " negative impact on operator morale" and "significant potential for negative safety implications" warrants serious consideration by the Commission.

My first intention was to write to the Commission to say that I believe that the proposed rule making, and Alternative 1 in particular, would be a mistake if adopted by the Commission. I would have listed my arguments which were similar to those of so many others. But I could see that my letter would be just another letter critcizing the Commmission's shortsightedness and theorizing on the potential negative effects the new rule would have on the industry. So instead I have decided on a different approach. I would like to tell you the effect that Alternative 1 will most likely have on me, if adopted. Also, over the past several years, there has been the impression among operators of an ever increasing influx of retired senior naval officers into the ranks of the NRC. Along with them they have brought a military type attitude which they would like to see imposed on the nuclear utility industry. In order that those individuals may better understand the basis for my comments, I am including a .'

brief summary of my background.

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l PDR PR SO 53FR52716 PDR.

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Page 2 I spent eight years as a Machinist Mate in the Nuclear Navy; 2 1 years in school, 2 years as an SIW prototype instructor and 4 years on the USS Permit, SSN 594. I. received numerous awards, letters of recognition and letters.of commendation. I was selected as Permit Sailor of the Year 1978, 1979, and 1980, Squadron 3 Sailor of the Year 1980 and Submarine Force Pacific-Fleet Sailor ofEthe Year 1980. I passed-the Chief's Exam, was selected by the board and frocked to MMC (SS) in 1980. I elected to leave the Navy and was discharged in January 1981.

I was hired by Pacific Gas and Electric Company in June 1981 where I am presently employed as a Control Operator at Diablo Canyon Power Plant. I received my Reactor Operator License in June 1985 and have stood watches as a Reactor Operator on both Units 1 and 2 for the past 3 1/2 years. Since the proposed rule allows for "grandfathering" those persons who hold a RO license 4 years following the effective date of the rule, I have time to move to Senior Control Operator and obtain a Senior License.

Then the rule would not effect rme and the question becomes moot.

But assuming I do not receive a Senior License and prefer instead to operate the plant as a RO for several years, then the proposed rule, if adopted, would have a major effect.

I enjoy my job, I enjoy operating a nuclear power plant and I have not become bored with the job the way some others have. I feel that it takes years of operating experience to really know a plant well. Although I feel that I would make a good Senior Operator, I have allowed myself to be bypassed for that position by several operators junior to me so that I may continue to gain the knowledge that comes from standing watch as a Reactor Operator. I feel I have brought with me to this position the same personal qualities which earned me top evaluations in the Navy. My annual evaluations by my supervisors here at PG&E confirm this belief.

The bottom line is this. I have two years of college. I intend to continue to be a Reactor Operator for the next several years.

If the proposed rulemaking is adopted, it will effectively block my career path. Taking college courses in my spare time in order to obtain a degree is not a possibility I will consider. I sacrificed 8 years of family life to serve in the Navy, I will not make the same sacrifice again. Once I reach the point where I feel it is time to move beyond being a RO, if the path to Senior Operator is blocked by this rule, then I will leave the industry. It is that simple. I realize that one individual leaving a utility will make very little difference. The plant will continue to operate and my departure would hardly be noticed. But with me would go 20 plus years of nuclear plant operating experience. And if a number of individuals make the same decision, then the effect becomes considerable. To lose qualified, highly trained, experienced individuals for the sake l

of having degreed Senior Operators would, in the words of the Peer Advisory Panel, (SECY 82-162), " result in a decrement in overall performance and thus impair public safety."

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Page 3 In reaching your' final decision, please' consider what will be best for the. industry.~and the health and: safety of the public.and not what will be perceived as looking the best in-the. eyes of the public.

Sincerely, bhw bb STEVEN-ALAN DAVID' Control Operator Diablo Canyon Power-Plant.

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