NRC-89-0041, Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Ruling Could Inhibit Career Progression & Lower Morale

Comment Opposing Proposed Rules 10CFR50 & 55 Re Education & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Ruling Could Inhibit Career Progression & Lower Morale

ML20235N518
Person / Time
Site:	Fermi
Issue date:	02/17/1989
From:	Sylvia B DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-89-0041, CON-NRC-89-41, FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00072, 53FR52716-72, NUDOCS 8903010262
Download: ML20235N518 (3)

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February 17, 1989 I!!C-89-0041 The Secretary of the Commission U. S. !bclear Regulatory Comnission

'Nashington, D. C. 20555 )

Attention: Docketing and Service Branch '

3eforences: 1) Fermi 2 MIC Docket !!o. 50-341 lHC License No. IFF-43 i i

2) Propoced hilo- on EdJOai. ion and Experience Requirencnts for Senior Reactor Operators and Supervisor 0 at Ibclear Power Plants, k (Federal Register, Vol. 53, No. 250, dated Thursday, December 29, 1988)

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Subject:

Fermi 2 Response to the Proposed Pale Regarding Education and Experience Requirements for Senior Reactor Ooerators and Supervisors ut Ibelcar Power Plants The following are Ferui 2 conments on the tclear Regulatory Cor:rainsion's Procosed Rule on Rlucation an3 Exoerience Requirements for Senior Reactor Operators and Superviscrc at !bclear Powet Plants.

The Fermi 2 lbclear Operations and_tbclear Training organir.ations have reviewed the proposed changes to 10CFR Par ts 50 and 55 and feel that l the prouosed amendnents are unfounded. I UMer the first alternative, the NIC has proposed that operating, engineering and accident nanagennnt exoertise wou)d be upgraded by requiring that all Senior Reactor (perators (SRoc) have a bachelor'c degree in engineering, engineering technology or the phycical sciences from an accreditcd university or college. While enhanced educational credentials of phift operating personnel cannot be faulted, it is not l felt that a bachelor's degree should be mandatal as a requirement for a receiving an Plto li .ence. Operating excerience, howe'ec:r, is funda:a'nta'. M the requirements of performing the dutted of a SRO.

If the proposed first alternative were to be adoptcd, it may inhBit the career progression of the reactor operators (RO), and ultimately result in lower morale and nntivation arrong them. Given tae rotating 8903010262 890217 I

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T The Secretary of.the Commission L February 17, 1989 ,

MC-89-0041 4 lj Page 2 ,,.

shift schedule of the RO posit' ion, the proposed four year time span ~

following %e effective _ date of the ruling would be insufficient for a Do to receive a bachelor of science degree. This could lead to a

' higher turnover rate within the RO ranks due to the. lowered morale as well as problems with the recruitment of qualifie6 -and enativated '

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.cperations personnel. The net result would be less experienced 1 operating personnel on-shift and an inpairnent, rather than improvement, of overall nuclear safety.

The second alternative would reqaire that the shift supervisor 'or senior manager have enhanced educational credentials and experience; the enhanced credentials could be a bachelor's degree from a progre -

1 accredited by: the Accreditation Board for Engineering and Technology (ABUT), a professional engineers (PE) license ' issued by a state government,' or a bachelor 's degree and an Cngineer-in-Training (EIT) certificate. Again, it is inportant to strtiss the opinicn that the value of operating experierce far exceests that of a bachelor's degree i with regard to e. operating staff's ability to analyze and respond to "

conplex transients and accidents.-

Fermi 2 believes that the proposed rule is not necessary and would

'inpose hardship in reactor and senior reactor operator career J progression. To cbtain the enhanced educational credentials, an individual would need to enroll in an ABET accredited program to earn a bachelor degree or- educationally prepare for the EIT or P3 examination. Again, since shift work inhibits attending nost colleges-or universities, this becomes a block to meeting these ennanced educational requirements. It should also be noted that because of this block, many nuclear operations eersonnel have enrolled in other, non-traditional paths to earn a degree such as the New York Regents tbclear Engineering Technology degree. This particulsr degree program, a?.ong with other such non-tr,a3itional programs, has not been ABET accredited.

If enacted, the second alternative would inpact the pool of tesouruos from which to recruit personnel with the proven abilities and notivation to be effective shift supervisors, and, since no eviderce exists which supporta the need that an ABET accredited BS degree, PE license, or E1T certificate is noressary for job performance 4 the enactrent of such a ruling would result in a decline in overall performance and safety.

The underlying concern of the proposed ruli g appsats to be that operator qualifications to deal with = vere Eccidents warrant improvement ender the premise that well qualified operators can substantially mitigate the consequences of severe a:cidents. Detroit E31 son would like to suggest that rather than the proposed rule l

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The Secretary of;the Commission y February-17, 1989 10C 0041 Page 3.

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makingi consideration should be given to expanding / upgrading existing licensed operator training programs to provide the desired, Itore  !

extensive severe accident training. This traditional training can be provided to senior operators or the Shift Technical Mvisor. The I action Lis already being discussed as part of the Severe Accident Manage:1nt actions and so separate rulemaking is not necessary.

If you have any questions, please contact Mr . Arnold caufmann et (313) 586-4213.

Sincerely,

, O') l t cc: Mr . A. B. Davis Mr. R. C. Knop .

Mr. W. G. Rogers I Mr. J. F. Stang i

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