ML20235S837

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

ML20235S837
Person / Time
Site:	Dresden
Issue date:	02/27/1989
From:	Ciuffini L COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00124, 53FR52716-124, NUDOCS 8903080038
Download: ML20235S837 (1)

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' The -Secretary of the Conmission

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. U.S. Nuclear Regulatory Conmission Washington, DC 20555 Attention: Docketing and Service Branch ~

Dear Sirs:

I am writing to connent on proposed rule changes to 10CFR Parts 50 and 55; Education and Experience Requirements for Senior Reactor Operators and Supervisors at Nuclear Power Plants.

It is my opinion that the alternatives proposed will not further ensure the protection of the public nor will it enhance the capability of L

.e the operating staff to respond to accidents or restore the-reactor to a safe J -

and stable conditich. Neither alternative should be enacted as rule.

. My greatest objection _to both alternatives is that they would -

eventualy reduce to nothing the number of Peactor Operators (ROs) advanding to Senior Operator (sos). Contrary to the times stated in the notice, it typicaly would take an RO 7 to 8 years to obtain a BS degree while continuing to work on a rotating shift as an RO. Few people find themselves in a position to make this type of ccnmitment for that anount of time. The net result would be sos obtained by hiring and training degreed individuals with little operating experience, reducing the operating experience level of sos. This will block career advancement at the RO level. This career stagnation at the RO level will m de it more difficult to find motivated people to fill both Auxiliary Operator (AO) and RO positions.

Both alternatives to the proposed rule change provide no enhancement of reactor safety. Both alternatives will reduce the experience level of sos. Both alternatives will cause carear stagnation and animosity anong ROs and AOs. For these reasons neitbar alternative shou 1*l to anacted as rule.

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