ML20235T838

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Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants
ML20235T838
Person / Time
Site: Dresden  
Issue date: 02/22/1989
From:
AFFILIATION NOT ASSIGNED
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00170, 53FR52716-170, NUDOCS 8903080494
Download: ML20235T838 (1)


Text

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/HJ 1-n -rf The Secretary of the Conmission U.S. Nuclear Regulatory Ccrmtission 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 the operating staff to respond to accidents or restore the reactor to a safe- -

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

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. My greatest c'bjection 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 tines 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 thanselves in a position to make this type of commitnent for that amount of time. The net result would be sos obtained by hiring and training de p ed individuals with little operating experience, reducing the operating experience level of Sos. This will block career advancanent at the RO level. This c'areer stagnation at the RO level will make it more difficult to find notivated 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 career stagnation and animosity anong ROs and AOs. For these reasons neither alternative shoul I to onacted as rule.

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