ML20235T704

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Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants
ML20235T704
Person / Time
Site: Dresden  
Issue date: 02/22/1989
From: Facchina R
AFFILIATION NOT ASSIGNED
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00158, 53FR52716-158, NUDOCS 8903080432
Download: ML20235T704 (1)


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  • ""3s ue The Secretary of the Conmission U.S. Nuclear Regulatory Comnission Washington, DC 20555' Attention: Docketing and Service Branch

Dear Sirs:

I am writing to comment 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 conditibn. Neither alternative should be enacted as rule.

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_ My greatest objection to botih alternatives is that they.would

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eventualy reduce to nothing the number of Peactor Operators (ROs) advancing to Senior Operator (sos). Contrary to the tines stated in the

~ notite, 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 thanselves in a position to nake this type of conmitment for that amount 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 carmr advancement at the RO level. This career stagnation at the RO level will nake it nere difficult r

I to find nativated 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 tha experience level of Sos. Both alternatives will cause career stagnation anel animosity anong ROs and AOs. For these reasons neitbar alternative sleul 1 ho enacted as rule.

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