PLA-2726, Comment Opposing Proposed Rules 10CFR50 & 55 Re Rulemaking to Enhance Levels of Engineering & Accident Mgt Expertise on Shift
| ML20154E196 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 09/25/1986 |
| From: | Keiser H PENNSYLVANIA POWER & LIGHT CO. |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20151A314 | List: |
| References | |
| FRN-51FR19561, FRN-51FR49561, RULE-PR-50, RULE-PR-55 51FR19561-00159, 51FR19561-159, PLA-2726, NUDOCS 8809160253 | |
| Download: ML20154E196 (11) | |
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SEP 2-Mr. Sa " .1k, Secretary U.S. Nu. ..slatory Comission l Vashir -wa .c. 20555 Atta. Docketing and Service Branch SUSQUEEJN4 STEAM ELECTRIC $^?ATION COMMENTS ON PROPOSE SENIOR OPERATOR DECREE REQUIREMINTS Docket Nos. 50-387 PLA-2726 FILE R41-2/A17-11 50-388 -
Dear Mr. Chilk:
Pennsylvania Power and Light Company has the following comments on the advance notice of proposed rulemaking (ANPRH) for 10CTR50 and 55 relatal to degree requirement for senior operators at nuclear power plants. This letter includes comments which address the questions / concerns identified in the ANPRM and those of Comissioners Thor.as M. Roberts and James K. Asselstine.
,C,ENERAL COMMENTS PP&L opposes this advance notice of proposed rulemaking. It is our opinion that rulemaking which imposes formal educational requiretents an senior operators would have a net negative impact on the safe operation of a nuclear power plant. This is based on the belief that, if promulgated, this rulemakiss vould nentually result in s less experienced operator at all levels (both licensed and non-licensed) since cape.ble and experienced cperatcra would leave the operations department due to a leek of viable career path; nor could highly inocivated individuals be recruited for the operator positions. Additionally, degreed engineers would probably use the senior operator position as a "stepping stone" to enhance their career opportunities, thus making the senior operator position a transient one.
Although the ANPRM states a consstisus (of NRC spensored studies following the TMI accident) indicated thac greater technical and acadese knowledge for operators vould be beneficial; PP&L believes this is being achiaved through the STA progtta. Vs see no benefit in renoving the STA position and replacing
, it with the degreed S0 position.
l If a degreed senior operator position on shift is to be required. PP&L suggests an alternative be considered where a shif t management position is created that would oversee operational activities associated with all units on a site. This position would be in addition to the existing shift organization and would be lil,ed by a degreed individual who holds a senior operators certification. All other senior operators on shif t would not be required to 4/ M Wh' ' , -f2 D SEP 3 01986 M* % by ca ni . . . . . . , , , , '."'.*_* .* _*
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Page 2 SSES PLA-2726 SEP 2 51986 '12' "" -2/AM-11 Mr. Samuel J. Chilk hold a degree. We believe this alternative would satisfy the Commission's concerns, while preserving the existing shif t structure. It also allows a non-degreed operator the opportunity to progress to the senior level thus maintaining a highly competent contingent of operators on shif t. he shift management position has as added advantage in that a degreed individual vould, in an emergency situation on a backshif t, immediately assume the highest emergency plan position. In addition to having a degreed individual in charge, this vould maintain the integrity of a highly experienced shif t operating staff.
Comments to the specific guestions identified in the ANPRM are addressed below.
ANPRM QUESTIONS -
- 1. Is January 1,1991, a feasible deadline for requiring senior ope stors to be degreed and licensed, and if not, what should the deadline be?
Comment January 1,1991 is not a feasible date. Any implementation date would have to be tied to the effective date of the regulation, otherwise utill:tes vill be forced to implement the ANP31 inmediately (i.e. degreed 10 candidates would be required for the ne ,c RO training class) in order to meet the proposed effective date of January 1,1991. As proposed this ANPRM vill immediately eliminate current non-licensed operators (presently non-degreed) from consideration for the 50 position. A more reasonable date for implementation would be seven years following the effective date of rulemaking. This will allow any current licensed and non licensed operators the opportunity for advancement to the S0 position without a baccalaureate degree. See comment to question 3 regarding the ability of an 10/50 c*btaining a degree by January 1,1991.
- 2. What the implementation and operation costs of the contemplated rule to utilities would bet Comment l
Operational Costs - If this rulemaking is promulgated, it can be expected that utilities will af ford RO's the opportunity to obtain a baccalaureate degree. n is being the case, the utility would have to replace the 10 obtaining an education for app oximately two to three years, nia replacement cost in terms of experience and knowledge of plant can be expensive. Also, newly degreed people, if used,
- traditionally have a high turnover rate from their first few jobs.
His vill result in a decrease in operator experience and an increase in operator training expenses.
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Fage 3 SSES PLA-2726 SEP 2 5 $86 File R41-2/A17-11 Mr. Samuel J. Chilk Implementation Cost - The actual costs associated with a
- baccalaureate degree to the utility can be substantial. Expenses borne by the utility for each degree include: tuition costs, salary, living expenses, and miscellaneous costs (i.e. books, lab fees) as well as the costs associated with a replacement RO. An estimated annual cost to obtain a degree for one 50 is $100.000. If this rulemaking is promulgated. PP&L expects to have four SO's in school per year for the duration of our license. The total cost to PP&L as the result of this rulemaking could exceed $14 million.
- 3. Assuming regular shif t rotation, could the typical 50 obtain an engineering or technical degree prior to January 1, 19917 Comment -
No. A typical Senior Operator would require a minimum of ten (10) years to obtain an engineering or technical degree. Logistics of obtaining degrees for current SO's would be difficult. Degreed courses are not normally readily available to SO's. Although a few lover level degreed courses are available at the utilities' nuclear training center, most upper level degreed courses are not available nor are these courses normally available by correspondence.
Additionally, shif t, work would make attendance at college' courses difficult. January 1, 1991 would not provide sufficient lead time.
- 4. What type of engineering degree would be appropriate, e.g., nuclear, electrical, mechanical, industrial, etc.?
Comment If a degree is requiro for the S0 position an engineering degree while preferred is not mandatory. Individuals in this position vould still be required to complete Senior Reactor training programs and NIC examinations. Therefore, an acceptable iniividual with any baccalaureate degree who satisfactorily completes the required utility training prograas would be an acceptable RO/SO candidate.
This individual would also possess those characteristics obtained from the educational process.
The attributes that define a "good" operator are evaluated during the already established rigorous licensing program. These attributes; interpersonnel relationships leadership, dexterity, performance
- under stress, etc. are not/can not he correlated to a specific ey; i of degree (1st the making of a "good" operator is not degree dependent). Successful completion of PP&L's licensing program adequately prepares the individual to hold an 50 license at the Susquehanna SES; consequently, the requirement of a specific degree is not necessary.
Page 4 SSES PLA-2726 SEP 2 5 886 File R41-2/A17-11 nr. Sa=uel a. Chilk
- 5. What has been the industry's experience in securing college-eluivalent t credit for nuclear power plant training and/or work experience?
C:nnment Approximately fifteen (15) industry organizations, both utility and vender / suppliers, have gained college credit for some of their nuclear power plant training courses. Typically 20% to 30% of the technical courses in a degree could be completed through industry courses with equivalent credit recommendations. However, this credit is normally limited to lover level degreed courses. Courses available at PP&L that can be applied to a baccalaureate degree include in part, the licensed operator science and plant systems courses, the STA cour.ns and the plant simulator courses. PP&L's ~
training center at the Susquehanna SES has obtained 66 hours7.638889e-4 days <br />0.0183 hours <br />1.09127e-4 weeks <br />2.5113e-5 months <br /> of college credit. Of this, approximately 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> would be awarded to an individual completing our S0 program.
- 6. Should there be similar (operating) experience requirements for one-of-a-kind advanced reactors?
Comment Yes. Advanced reactors vill require experienced r.anagers and operators just as much as the current nuclear generating f acilities.
Experience requirements should be enforced. The proper scaffing of a one-of-a kind advanced reactor is of paramount importance. PP&L recensends obtaining the best qualified people available and subjecting them to a rigorous training progran.
- 7. What are the combined impsets of requiring two years of responsible nuclear poser plant experience, the degree requirements, and one year "hot" operating requirement for the position of S07 Comment The combination of these requirements will greatly decrease the available pool of manpower for senior reactor operator positions.
Regrettably many good and competent operators may choose to leave or be forced out of the operator progression line due to degree requirements. The experience requirements are very important and should be maintained. The degue requirements are arbitrary and not
, supported by research data.
As a practical matter, for those units in extended outages of 6 months or greater, requiring "hot" experience vill exacerbate the ability to add people to shif t and f rustrate an individual who is ready to receive the SO license but lacks experience.
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Page 5 SSES Pl.A-2726 SEP 2 51986 File M1-2/A17-11 Mr. Sa=uel J. Chilk
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- 8. Should the contemplated degree requirement for senior operatois be supplemented with or replaced by intensive focused training requirenants in severe accidents for nuclear power plant operators?
Comment Comprehensive training programs focused on severe accident prevention and mitigation should replace the degree requirements for SO's.
PP&I,'s RO and SO training and retraining programs already include such severe accident scenarios as station blackout events, ATVS events, multiple core damage transients, etc. and are structured such that additional severe accidents, as they are identified, are incorporated into these training programs. This training is known ta increase reactor safety where as the addition of a baccalaureate -
degree has not. These programs and training are being continuously improved by additional inkstry initiatives such as revising the IDC01 individual plant evaluation (IPE's) methodology and upgrading the EPG's to Revision 4.
- 9. What are the appropriate criteria for assessing a utility's certification that an individus1 vith a baccalaureate degree in other than engineering or the physical sciences has "demonstrated high potential" for the S0 position? -
Comment An individuals potential for the 50' position should not be based on any baccalaureate degree but rather on job ;erformance and aptitude.
Utility nuclear training progrs=s include tour distinct categories:
nuclear theory, plant systems, operation (to include simulator training and plant transients) and in-% ant training activities.
Based on acceptable performance of these criteria no degree is necessary for the 50 position. Hovrver, in response to the specific question, an individual with any br.ccalaureate degree would be an acceptable 10/50 candidate. Comp'etion of PP&L's INPO accredited program would certify his ability to hold a 50 license.
- 10. What are the implications of this contemplated rulemaking on decisions concerning future reactor designs?
Comment If presulgatec', this ANPRM vould have to be vaived for future reactor designs. As proposed the requirement for "one of the two years of operating esperience be with a similar commercial nuclear reactor..."
is not possible.
- 11. Should the NRC require specialized training in severe reactor accidents beyond inadequate core cooling and/or require extension of emergency operating procedures into the realm of more severe accidents instead of or
Page 6 SSES RA-2726 SEP 2 51986 File R41-2/A17-11 Mr. Samuel J. Chilk in addition to baccalaureate degrees? Wat are the implications of the work by 1DCOR for the qualifications, training, and emergency operating procedures for licensed reactor operators and senior operators?
Comment NRC should consider increased trainit.g for certain EOF /TSC persocnel in severely degraded core accident scenario's.
Subsequent to TMI, emergency operating procedures (EOP's) were revised to reduce their complexity and number, plus incorporate certain minimum strategies. Requiring additional procedures for such low probability events will negate these gains and culminate in a condition adverse to safety. Utilizing 1DCOR st individual plants, -
IPE's are being developed that define plant specific .
characteristics / actions that can be utilized in training EOF /TSC and operationa personnel to mitigate the effect and reduce the probability of these type accidents.
- 12. What is an appropr'iate cut-off date for allowing only one re-examination for those 50 applicants without a degree who apply for a license just
. prior to January 1, 19917 Comment An acceptable cut-off date for allowing one re-examination would be six years af ter implementation of any ri.'.emaking. Because the NRC presently limits the number of operator licensing examinations given to each plant per year, utility scheduling required for an 50 re-examination, based on present NRC examination scheduling, is approximately two years.
- 13. The proposed rule would require an 50 applicant to have a baccalaureate degree in engineering or the physical sciences from an accredited university or college. Wat should be the appropriate definition (e.g..
Department of Education, ABET. etc.) for "an accredited university or colleget" Comment If a baccalaureate degree is required it should be from a regionally accredited university or college such as the Middle States or
' southern States accrediting agencies or from the Accrediting Board for Engineering and Technology (ABET). Rovaver. ABET accreditation is not required. n e best candidate to be "degreed SRO' is an operator with experience as an RO or SRO. The selected college progran should allow the operator to earn hi degrec hile working vbenever possible or during brief sabbaticals from his nomi job.
College degree programa that are flexible enough to accremidate
- Working adult must be developed and accepted. Universi:y and college
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b Page 7 SSES Pl.A-272 6 SEP 2 51986 rite a41-2/Ai7-il Mr. Samuel J. Chilk programs with AEE7 accreditation are developed for full-t'ime undergraduate students on campus. Thus the requirement of ABET accreditation could provide an insurmountable obstacle to the best candidates for this "degreed SR0" position.
- 14. What immediate impact will the contemplated rule have on operator morale?
Conument This rule vill be devastating to all current licensed and non-licensed operators' morale. Operators are competent people who feel the imposition of a degree requirement after they have proven their ability to safely operate the plant is a challenge to their competency. This rulemaking vill be viewed as an additional "paper" "
qualification requirement which will block the advancement pathway to a 50 license. As a result competent operators vill leave the operations departmant for positions with better advancement opportunities. It can also be expected that remaining operators will harbor some animosity towards those operators that have obtained degrees. This will definitely affect operators "esprit de corps" and result in a less effective operator.
- 15. (Chairman Palladino believes) that the attached Table (1) correctly identifies the present control room staff as well as that envisioned by the ANPRM by 1991 and af ter 1991. Should other alternative control room staffing requirements be considered?
Cotanent Tes. The Commission should consider an alternative staffing concept which would require only one degreed S0 on a shift. This concept would establish a seniot. shift manager (management position) who is responsible for operational issues on both units. All other existing 50 positions on shif t would remain non-degreed (see general comments). Another option the Commission should consider would maintain the current STA program, as is. This program now provides additional technical expertise on shift.
- 16. TMI improvements in control room capabilities and staffing have been undertaken by the industry, i.e., STA's have been added, detailed control design reviews have been undertaken, safety parameter display systems have been installed, emergency operating procedures have been improved, and the
, combined SO/STA position has been approved by policy. To what extent have these improvements been ef fective?
Comment The current system of Shif t Technical Advisors provide expertise on shif t that assists in the decision-saking process. Because the STA does not have direct operational control of the plant, he is better
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Page 8 SSES PLA-2726 SEP 2 51986 File R41-2/A17-11 Mr. Sa=uel J. Chilk able to evaluate plant concerns from a technical perspect'ive than is the 50 who's primary responsibility is eb safe operation of the plant. At PP&t, one degreed STA is int @ ated into each shif t. He rotates with that shif t, participates shif t turnover activities, reviews plant logs, maintain an awareness of plant configuration including operating conditions and planned activities. The STA also participates in shift retraining activities as part of normal shif t rotation.
The post TMI EOF's are simple symptom based procedures that define a r.inimum strategy to follow for accident mitigation. They incorporate tasic engineering vhich provides the best estimate response versus FSAR DBA response of the plant ar d operation. With the new E0P's operators are much better prepared than before ntI. Additionally, "
E0P's have had extensive peer review and therefore benefit from vide expertise and experience. SPDS has become a very effective emergency management tool because of its ability to reduce the amount of information available to a few specific parameters, plus its trending ability.
- 17. Requiring S0's in the control rooit to have a technical college degree vill
, have an impact on R0's and AO's, especially with regard to a career path for these personnel. To what extent vill the 50 requirement drive out capable operators, and result in high personnel turnover and instability in the workforce?
Comment At many nuclear plants the operations workforce already exhibit a high turnover rate. This is of ten caused by rotating shif t work and the necessity to work veekends and holidays. The imposition of this rule will cause greater dissatisfaction on the part operations personnel. Many good and competent operators may choose to leave or be forced out of the operator progression line due to degree requirements.
Elimination of the non-degreed S0 vill foreclose the operator's progression to management. Consequently, long term career advancement would be limited for present licensed and non-licensed operators. This will result in operators bidding out of operations to other plant organizations (maintenance, chemistry, health physics) so that they may eventually advance to management positions.
- 18. Presently one degreed engineer is required to be within 10 minutes of the control room or a member of the control room staff, the STA or the combined SR0/STA, respectively. While requiring a second control room operator to have a technical degree may enhance operator organizational status, professionalism and esprit de corps. will a second degreed engineer significantly improve operator performance beyond the STA or combined SRO/STA improvements? Will these improvements become apparent in the short ters or the lang ters?
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Page 9 SSES PLA-2726 SEP 2 519o6 File R41-2/A17-11 Mr. Samuel J. Chilk Comment -
A degreed S0 will not improve operator performance markedly. There is no correlation between a formal education (degree) and a licensed operators performance. Since the licensed 50 bas already been well trained in nuclear plant operations and has years of experience, it is unlikely that an SO would utilize his formal education (degree) experience. The 50 needs to be an individual vbo has many years of nuclear plant operating experience, has developed superior leadership abilities and has the respect from RO's he supervises. These are not necessarily the attributes required for an individual required to evaluate technical issues. In response to THI, utilities were required to add an STA position and have an SRO in the control room at all times. To date there is no substantiated evidence indicating ~
i this action has increased operational performance. However, evidence is available which indicaten that enhanced training does improve operator performance. If this rulemaking is prosulgated, the STA program, functions and technical expertise will be eliminated.
The operation of two large boiling water reactors requires years of experience. Normally a unit operates on-line in a steady state condition or is in a shutdown configuration. During these periods a SO needs years of experience to properly fulfill the demands of the position. It is doubtful that a degreed individual would remain in the position long enough to obtain this experience. This individual would find that the long duration between challenging events would be unchallenging and routine. Imposing an additional degreed inexperienced position will not result in the safe efficient generation of electricity.
- 19. What is the industry view about availability of new college graduates who can be trained in nuclear power plant operation or about the feasibility of having present plant operators pursue and obtain a technical ecliege degree?
, Comment l College graduates could probably be recruited and trained for
- operations work; however, they would not be satisfied with shif t i
work. Obtaining nuclear plant experience for a RO/SO license would l
i be difficult for a new college graduate. If promulgated, this rulemaking can be expected to eventually lead to a "less experienced" l
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licensed operator. Years of operating experience can not be taught; I
therefore, the college graduate is not the best licensed operator candidate. yinally, many would use the 50 position as a etapping stone to better career opportunities.
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- 20. Should there be a numerical limit on the total number of "grandfathered" S0's at any particular plant" Comment There should be no limit on the total number of SO's grandfathered.
COMMISSIONERS QUESTIONS The following comments are submitted per the request of Connaissioners Thomas M. Roberts and James K. Asselstine.
Connaissioner Thomas M. Roberts Questions
- 1. The extent that a formal degree requirement for senior operators is related to job performance.
Coeunent There is no anticipated correlacion between a baccalaureate degree for SO's and job performance. Experience, comprehensive utility training and proven dompetence at the A0 and RO position are much more important.
- 2. Will requiring a baccalaureate degree for senior operators enhance public health and safety?
Comment PP&L believes a reduction in quality operatious personnel can be anticipated if this rulemaking is promulgated (see comment to question 17) which any result in a not decrease in public health and safety.
- 3. iihat negatite safety implications may result from this proposal.
Comment If implemented, this ANFRM vill probably result in a loss of experienced SO's and a decline in morale and quality at both the A0 and 10 positions. This vill result in a lower overall experience level on shift.
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i Commissioner James K. Asselstine Questions
- Comment on an alternative method for upgrading the engineering knowledge and understanding of reactor theory needed by licensed sector reactor operators...
Consent PP&L believes the concept is sound; hovaver, an industry standard of this type would require developmant by an industry organization such as INPO at utility management dirtetion. PP&L understands the INPO accreditation program has evaluated mothede to upgrade operator engineering knowledge which has addressed sone of Commissioner Asselstine's concerns. A schedule for implementation of any additieral programs that would be developed could not be estimated at this tina. -
In conclusion FP&L opposes this ANPRM because it will negatively affect operator morale at all levels, be very expensive in terms of manpower and implementation cost, will not enhance operator performance, and could conceivably have a negative af fect on the public's health and safety.
' We appreciate this opportunity to commant on the advanced notice of proposed rulemaking.
Vs .7 truly yours.
H. W. Keiser Vice President-Nuclear Operations cci M. J. Campagnone NRC Bethesda L. R. P11sco NRC Senior Resident d
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