ML20235T795

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants.Both Alternatives Do Not Provide Enhancement of Reactor Safety

ML20235T795
Person / Time
Site:	Dresden
Issue date:	02/22/1989
From:	Kapchinske M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00148, 53FR52716-148, NUDOCS 8903080479
Download: ML20235T795 (1)

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The Secretary of the Conmission U.S. Nuclear Regulatory Ccmnission .

Washington, DC 20555 :

Attention: Docketing'and Service Branch

Dear Sirs:

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

Itismy.1!inion that the alternatives proposed will not further ensure the protecti jofthepublicnorwillit'enhancethecapabilityof the operating staff o respond to accidents or restore the reactor to a safe -

armi stable condit.ior Neither alternat.ivo should be enact.ed as rule. .

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- My greatest. objection to both alternatives. is that tiny would eventualy reduce td nothing the number of Reactor Operators (R0s) 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 nake this type of conmitment for that anount of time. The net result would be 50s obtained by hiring and training degreed individuals with little operating experience, reducing the operating experience RO level. This careeg;1evel of sos.

stagnation atThis will block the RO career level will make advancement at the it more 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 redoce the experience level of sos. Both l alternatives will cause carear staanation arvi aninosity anong Ros and AOs. For these reasons neitbar alternative .=ho@l to anacted as rule. N . .

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