ML20235T091

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Alternatives Provide No Enhancement of Reactor Safety & Reduce Experience Level of Senior Operators

ML20235T091
Person / Time
Site:	Dresden
Issue date:	02/22/1989
From:	Gulos J AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00116, 53FR52716-116, NUDOCS 8903080142
Download: ML20235T091 (1)

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The Secretary of the Conmission

- U.S. Nuclear Regulatory Cm mission Washington, DC 20555 '

4 Attention: Docketing and Service Branch

Dear Sirs:

I am writing to cmment 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 the operating staff to respond to accidents or restore the reactor to a safe

- and stable condition. Neither alternative should be enacted as rule.

My greatest objection to both alternatives is that they would eventualy reduce to nothing the number of Reactor Operators (ROs) advancing 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 degme while continuing to work on a rotating shift as an RO. Few people find themselves in a position to make this type of cmmitment 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. ThJs will block camer advancement at the RO level. This career stagnation at the RO level will make it nore difficult .

to find motivated people to fill both Auxiliary Operator (AO) and RO J positions. ,

1, Both alternatives to the proposed rule change provide no enhancment of reactor safety. Both alternatives will reduce the experience level of sos. Both alternatives will cause career stagnation airl eninosity among ROs and AOs. For these reasons neither alternative siv.*l le enacted i as rule.

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