ML20235P331

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

ML20235P331
Person / Time
Site:	North Anna
Issue date:	02/08/1989
From:	Neufer A AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00026, 53FR52716-26, NUDOCS 8903020179
Download: ML20235P331 (1)

Text

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February 8,1989 PROPOSED RULE - .

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Jg Secretary of the Commission (53 he W)H) u

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Nuclear Regulatory Commission Washington, D.C. 20555

'89 FEB 13 P4 :26 Dear Sir; I am commenting on the Notice of Proposed Rule Making on Degree RQgmentis for Ogerators, l 10 CFR Parts 50 and 55 " Education and Experience Requirements for EeniorghqctorDperators I and Supervisors at Nuclear Power Plants".

I am against both alternatives. On September 7,1988 the Commission rejected rulemaking '

which would have required SRO's to hold a degree. Chairman Zech acknowledged the rejection but asked for a compromise that would mandate a degree on shift.

Now that the compromise is out for comment,it is the same old thing in a different package.

The Commission should recognize this and reject it again.

I offer this suggestion - the present requirement for a degNed STA is working well. The shift is required to be complemented by an STA who is assigned to and rotates with that specific shift. I stress, that for the STA to be a viable solution to the degree problem, he must be part of the shift and rotate with a specific shift. The STA is a vital part of the shif t operating and accident c.ssesment team. The STA is not a Shif t Supervisor, but an independent assessor of plar.e operations, both normal and abnormal. The STA brings to the shift his specific analytical skills. These skills combined with the Shift Supervisor's indepth plant knowledge and leadership, make for the greatest degree of plant safety.

Utilities must recruit qualified individuals to fill the STA position. The STA must exhibit outstanding mechanical aptitude and a strong commitment to learn the great complexities of a nuclear power plant. He should receive training similar to that of an SRO but the requirement to be licensed should be waived.

STA recognition is something that does not come easy. It took many years for these individuals to prove themselves to be an asset in the control room operation organization. The STA has come to serve a very important role. These individuals have specific daily engineering duties and report on plant status. The STA also plays an active enoineerir.g role during emergency events. Their input and independent assessment are vital to plant stabilization and safety.

I am in agreement with your proposal to encourage utilities to promote operators to higher management positions and to provide programs for operators to obtain college degrees. The operator should be rerognized by the industry and receive college credit for what he has already learned and bun taught by real life experiences while operating a nuclear power plant.

It's time for the NRC,INPO, and NUM ARC to put their considerable prestige behind a movement to enable nuclear power plant operators to receive a BS degree for their extensive experience that will be recognized by all national accrediting bodies. A fully qualified SRO has at the very minimum,10 years of formal utility training behind him. There is nothing to be gained by replacing nuclear operators with degreed people. _

l Respectfully, -

Andrew G. Neufer SRO 8903020179 890200 North Anna Power Station R PDR S3 52716 Professional Reactor Operators Society Region 2 President bN -