ML20235T966

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

ML20235T966
Person / Time
Site:	Dresden
Issue date:	03/01/1989
From:	Palanyk T AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00159, 53FR52716-159, NUDOCS 8903080542
Download: ML20235T966 (1)

Text

-

1. O, OcnT W8R0 POSED Rd. R r

DD

.. g 5 Ph GM/bj

'89'. MR -1 A9 :27 Reue S. 0.4%y);-

7,,F & L :

i 9 i

00Cri nM 7ao kg,g j

t/

Jo Is,r l//

The Secretary of the Comission U.S. Nuclear Regulatory Canmission Washington, DC 20555 Attention: Docketing and Service Branch

Dear Sirs:

I am writing to coment 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 res. pond to accidents or restore the reactor to a safe

~

^

and stable _ condition. Neither alternative should tie ' enacted as rule.,

~

~

My greatest objection to both alternatives is t' hat they would eventualy reduc ~e 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 commitment 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. This will block career advancment at the RO level. This career stagnation at the RO level will make it nere difficult 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 the experience level 'of sos. Both alternatives will cause career stagnation arvi anhnosity among ROs and AOs. For these reasons neither alternative sho W to anacted as rule.

/

. 5' fe

[

/

SCA t-Omtb,

P 8903080542 890301 PDR PR 50 53FR52716 PDR

._______________--_-___________--________________a