ML20235T870

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Rule Will Cause Career Stagnation & Animosity Among Operators

ML20235T870
Person / Time
Site:	Dresden
Issue date:	02/28/1989
From:	Goodin R COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00152, 53FR52716-152, NUDOCS 8903080507
Download: ML20235T870 (1)

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The Secretary of the Cm mission i'

U.S. Nuclear Regulatory Canmission Washington, DC 20555 Attention: D rketing and Service Branch I

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Dear Sirs:

I am writing to cmment on proposed rule changes to 10CFR l 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 res und to accidents or restore the reactor to a safe and stable condition. Neit ar 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 degree 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

, amount of time. The net result would be soc o!?ained by hiring and training degreed individuals with little operating experience, reducing the

, operating experience level of sos. This will block career advancsent at the l 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 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 should be enacted as rule. , . ~ . . _ . .

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