ML20235V419
| ML20235V419 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/28/1989 |
| From: | Whittier G Maine Yankee |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00173, 53FR52716-173, GDW-89-75, MN-89-28, NUDOCS 8903100175 | |
| Download: ML20235V419 (5) | |
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EDISON DRIVE. AUGUSTA MAINE 04330. (207) 622 4868
'89 MP. -6 P12 :17 February 28, 1989 MN-89-26
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Secretary of the Commission United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Docketing and Service Branch
Reference:
License No. DPR-36 (Docket No. 50-309)
Subject:
Comments Pertaining to the Proposed Rule Making - Education and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants Gentlemen:
The objective of this proposed rule is to. upgrade the operating, engineering, and accident management expertise provided on shift by combining both engineering expertise and operating experience in either the senior operator function or shift supervisor function.
He believe that neither alternative will achieve the intended objective and, if either is implemented, will have an adverse effect on plant safety by reducing the overall experience level of plant operational staffs.
To our knowledge and as recognized in the Backfit Analysis, there is no proof that possessing a bachelor's degree or professional registration will improve an individual's performance as a nuclear power operator.
It is generally recognized that a preponderance of the subject matter included in a baccalaureate degree program is not applicable to improved operating or accident management skills.
Focusing on academic or professional credentials will inevitably divert our efforts from the real objective. Time spent pursuing non-applicable degrees and registration can be better invested in utility developed, operationally specific education and training.
In the short term, imposing this proposed rule will stifle the career aspirations of non-degreed operators and accelerate their leaving the industry.
Their replacements will have degrees but significantly less operating experience.
In the long term, developing and maintaining an acceptable level of operating experience on shift will be difficult.
He believe that degreed personnel will not make a long term commitment to shift operations work.
Their professional qualifications give them a wide range of career alternatives. He expect the attrition rate of degreed operators, especially ABET degree holders, will be higher than that of non-degreed operators.
This increased attrition rate will perpetuate the reduced experience level of operational staffs adversely affecting safety.
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1040L-RCC
Mn:IIe[anXee
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United States Nuclear Regulatory Commission Page Two Attention: Secretary of the Commission HN-89-26 In our opinion, training and education are not mutually exclusive.
Since the Three Mile Island incident the industry has developed exceptional training programs that include extensive engineering fundamental, plant design, and operations components.
In addition, most operating nuclear power plants have plant specific nuclear operations and plant design engineering expertise unavailable to most colleges.
If the Commission believes operators require additional knowledge, we can jointly identify it, the nuclear industry can train it, and the Commission can test for it as part of the operator licensing process. Work has already been undertaken by the industry to develop a fundamentals examination which could be used as an initial step in the Reactor Operator Licensing Process. Such a test specifically oriented to nuclear operations and engineering fundamentals would better satisfy the stated intent of this rule making than would an EIT examination, professional registration or a bachelors degree.
Specific responses to the questions contained in the Notice of Proposed Rule Making are enclosed as Attachment A.
Very truly yours, MAINE YANKEE n LM/
0')hOVS G. D. Whittier, Manager Nuclear Engineering and Licensing ARS:BJP c: Mr. Richard H. Hessman Mr. Hilliam T. Russell Mr. Patrick H.
Sears Mr. Cornelius F. Holden 1040L-RCC
M.DIEe InIlKee ATTACHMENT A CQLtifNTS ON OUESTIONS PERTAINING TO PROPOSED EDUCATION AND EXPERIENCE REQUIREMENTS FOR SENIOR REACTOR OPERATORS AND SUPERVISORS AT NUCLEAR P0HER PLANTS 1.
Which alternative is preferable assuming one will be selected?
Neither alternative is appropriate for rule making.
However, of the two alternatives Maine Yankee is better positioned to meet alternative one.
2.
What are the potential impacts of each of the alternatives on licensee staffir.g?
Alternative 1:
Since 1983, Maine Yankee has limited operator hiring to degreed applicants only. As a result, 71% of our Operations Department staff possess degrees and our first all degreed class earned R0 licenses in 1988. Considering the required training courses and proposed experierice requirements, the earliest these individuals could obtain SRO licenses would be 1990.
Alternative 2:
Despite our hiring practices, significant effort would be required for Maine Yankee to assure continued availability of qualified and experienced shift supervisors. Absent extraordinary action by the Maine Professional Engineer Registration Board, Maine Yankee would be forced to by-pass the current shift supervisors and their immediate SRO backups in favor of less experienced personnel with ABET accredited degrees.
Tids would cause major personnel problems, and reduce on-shift supervisor experience levels without any perceived increase in on-shift capability.
3.
Regarding implementation of the alternatives, would there be a more appropriate transition period for each alternative than the one proposed?
Either alternative as proposed will adversely impact plant safety by reducing operational staff experience levels and operator morale.
This impact can be minimized by extending the implementation period and implementing the change through hiring and attrition.
Based on our plant experience, the minimum time required for newly hired degree personnel to obtain a SRO license through the normal operator progression is six (6) years. An additional two years of on-shift supervisory experience before appointment to shift supervisor is typical. Realisti: ally, a complete transition in ten (10) years is optimistic but possible.
4.
Alternative 2 provides for tbrt. different methods for demonstrating technical expertise with educational credentials. Would some other method be desirable for this purpose? Are there other alternative ways to demonstrate knowledge of appropriate engineering fundamental for people who may be ineligible to take the EIT examination?
l 1040L-RCC
Maine 5anKee
, The Backfit Analysis, Paragraph 3, states that the proposed rule is intended to assure operators have sufficient understanding of basic engineering principles and detailed knowledge of nuclear design and operation to appropriately respond to situations that have not been previously covered in training sessions.
Implicit in this statement is the assumption that training alone is not sufficient because it is impossible to cover every eventuality during training and that only especially certified colleges can effectively develop this capability.
To the contrary, training and education are not mutually exclusive. Since the Three Mile Island incident the industry has developed exceptional training programs that include extensive engineering fundamental, plant design, and operations components.
In addition, many colleges would be hard pressed to match the detailed nuclear operations and plant design engineering and instructional expertise available to most operating nuclear power plants.
If the Commission believes operators require additional knowledge then the Commission should identify it and test it as part of the operator licensing process.
Work has already been undertaken by INP0 to develop a fundamentals examination to be used as an initial step in the Reactor Operator Licensing Process.
Such a test specifically oriented to nuclear operations would better satisfy the stated intent of this rule making than would an EIT examination.
5.
Should a requirement be imposed requiring all senior operators to pass an Engineering in Training (EIT) or equivalent examination as a measure of basic technical expertise in addition to, or instead of, the two proposals in this notice? If such a requirement were in place, would it be necessary to require enhanced educational credentials for shift supervisors?
No to both questions.
Demonstrated ability is superior to any credentials.
The current licensing process, industry training and qualification programs, and the extensive use of control room simulators afford sufficient assurance that each operator candidate has demonstrated ability before being licensed.
6.
Independent of a degree requirement, is there a need for the experience requirements to be increased for the shift supervisor position?
Ar.' ch proposed requirements called for in the two alternatives sufficient?
Nuclear plant management in the exercise of their regulatory, legal, and financial responsibilities must assure their plants are operated by fully qualified personnel. Arbitrary minimums imposed on the entire industry cannot adequately account for the variations in personnel capabilities in each company. Management certification and the current NRC licensing examination process should be the only criteria for selection as shift supervisor.
1040L-RCC
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i Maineyanicee COM ENTS ON C0MISSIONER ROBERTS OUESTIONS 1.
How accessible are ABET accredited engineering programs?
The University of Maine, Orono is the only ABET accredited institution in the State of Maine accredited to award engineering and engineering technology bachelor degrees.
The University is 100 miles from Maine Yankee.
?..
If the PE or EIT options are selected, which states allow registration and/or classification as an EIT without an ABET accredited degree?
The Maine Board of Professional Engineer Registration requires an EIT applicant to hold a degree from an approved curriculum or a high school diploma and 8 years of experience. An approved curriculum is defined as those accredited by the Accreditation Board for Engineering and Technology (ABET) or approved by the State Board.
3.
In light of the fact that states require work experience to be registered as a PE and, with a non-accredited engineering or related degree, often require work experience to be classified as an EIT, will state registration boards grant credit for operating experience as " acceptable professional experience... of a grade and character indicating that the applicant may be competent to practice engineering"?
The Maine Board will review each application on a case by case basis. As yet we have no experience with plant operators applying for consideration.
4.
If credit is granted for operating experience, does this experience have to be acquired after receiving a degree?
Based on the Board's willingness to accept a high school diploma and eight (8) years experience, when a degree is obtained appears inconsequential.
1040L-RCC