ML20235S412

Comment on Proposed Rules 10CFR50 & 55 Re Educ of Senior Reactor Operators.Alternative 2 Preferable.Util Suggests That Neiter Be Imposed.Both Alternative Could Cause Immediate & long-term Impact on Plant Safety

ML20235S412
Person / Time
Site:	Rancho Seco
Issue date:	02/24/1989
From:	Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00133, 53FR52716-133, AGM-NPP-89-081, AGM-NPP-89-81, NUDOCS 8903070119
Download: ML20235S412 (2)

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SACRAMENTO MUNICIPAL fbl rg gyg) '

DISTRICT O 6 01 S Street, P.O. Box 15830, Sacramento CA 958524830,(916) 452 3211' AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA-

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. February 24, 1989 g

The Secretary of the Commission

' ' U.S. Nuclear Regulatory Commission Attn:. Docketing and Service Branch Hashington, DC 20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 COMMENTS ON PROPOSED RULE FOR EDUCATION OF SENIOR REACTOR OPERATORS L

Dear Sir:

.The: Sacramento Municipal Utility District' hereby submits its comments on the proposed rule concerning " Educational and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants."

If one of the alternatives is selected, it should be alternative 2; however, the District suggests that neither be imposed. Both alternatives essentially.

requirea' bachelor of science degree (BS) since the individual who is a Professional Engineer-without a BS is rare. Both alternatives could cause immediate and long-lasting impact on plant safety, staff morale, performance, .

staff levels, and experience levels.

Alternative 1 It would be difficult, if at all possible, within the specified four years, to simultaneously:

• Staff the plant with qualified Senior Reactor Operators (SR0s)

• Comply with SR0 requalification requirements, ILnA n

• Obtain a BS degree for those personnel actively pursuing an SR0 license.

A four-year period is inadequate to implement either alternative, particularly since it is unknown if sufficient degreed individuals would apply for positions as operators or if current operators would be willing to participate in an education program. These factors would vary significantly from site to site, depending upon local educational opportunities and community attitudes toward education. It could reasonably be expected to take six to eight years for the perceived benefits resulting from an education program for non-BS r

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Secretary of the Commission AGM/NPP 89-081 l There is no evidence that a BS degree is needed to perform the job of SRO, nor has there been any demonstrated safety benefit from such a requirement.

Conversely, the loss of experienced personnel from Operations due to the availability of alternate career paths to degreed personnel may have a negative impact on plant safety.

The new degreed operator positions would require higher pay than existing non-degreed positions. This could cause morale problems among non-degreed individuals and could lead to resentment, non-cooperation, and crew performance problems.

The overall crew operating experience could decrease, with an attendant decrease in degree of safe operations for two reasons. First, current non-degreed operators may leave rather than work in a job having no future.

Second, there may be increased turnover in all operator ranks as degreed personnel move through to other positions (a policy objective of the proposed rule) or leave as they find that their engineering expertise (for which they obtained their BS) is not used in operating the plant. A major contributing factor to safe and efficient operation is a stable Operations staff without excessive turnover. The District feels that both alternatives will adversely affect turnover.

Alternative 2 Entry level personnel, with or without a BS degree, do not become sufficiently experienced, SR0 licensed, and promoted to Shift Supervisor positions within four years. This progression normally requires approximately ten years of experience. Staffing senior shift management positions with personnel without this depth of experience could result in a significant negative impact on overall plant safety.

To summarize, the District feels that no increase in educational requirements is necessary. The two alternatives are not required.

Members of your staff with questions requiring additional information or clarification may contact Mr. Steve Crunk at (209) 333-2935, extension 4913.

Sincerely,

%C m Dan R. Keuter Assistant General Manager Nuclear Power Production cc: J. B. Martin, NRC, Walnut Creek A. D'Angelo, NRC, Rancho Seco '

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