ML20235T825

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Proposed Rules Provide No Enhancement of Reactor Safety

ML20235T825
Person / Time
Site:	Dresden
Issue date:	02/28/1989
From:	Theesfeld T AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00151, NUDOCS 8903080491
Download: ML20235T825 (1)

Text

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. The Secretary of the Ccmaission U.S. Nuclear Regulatory Ccanission

Washington, DC120555

" Attention: Docketing and Service Branch

Dear Sirs:

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

I It'is my opinion that the alternatives p.vemed will not further ensure the p.vlection of the public nor will it enhance the capability off 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 (S0s). 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' le find thanselves in a position to make this type of canmitment for t anount of time. 'Ihe net result would be 50s obtained by hiring and : _ . . ..

training 4 ed individuals with little operating experience, reducing the operating experience level of S0s. This will block career advancement at the RO level. 'Ihls career stagnation at.the RO level will make it nere 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 e rience level of Sos. Both alternatives will cause career stagnation and an ity anong Ros and AOs. For these reasons neither alternative should be enacted as rule.

m asuui.,

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