ML20235T136

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

ML20235T136
Person / Time
Site:	Dresden
Issue date:	02/22/1989
From:	Morrow G AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00119, 53FR52716-119, NUDOCS 8903080165
Download: ML20235T136 (1)

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The Secretary of the Comnission U.S. Nuclear- Regulatory Conmission Washington, DC 205551

-Attention: Docketing'and Service Branch Dear Sirs I am writing to corment on proposed rule changes to 10CFR Parts-50 and 55; Education and Experience Requirrsents for Senior Reactor Operators and Supervisors at Nuclear Power Plants.

It is my opinion that the alternatives p mposed will not further ensure the protectioq of the public nor will it enhance the capability of the operating staff! o t respond to accidents or restore the reactor to a safe -

and stable condit~1on.' Neither alternative should be enacted as rule. .

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My greatest objection to both alternatives is that they would eventualy reduce to nothing the nunter 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 mtating shift as an RO. Few people find themselves in a position to nake this type of conmitnent for that anount of tine. The net result xxild be sos obtained by hiring and training degreed individuals with little operating experience, reducing the operating experience level of sos. This will block career advancement at the RO level. This career stagnation at the RO level will make it nore difficult to find notivated prMple to fill both Auxiliary Operator (AO) and RO positions. ,

Both alternatives to the proposed rule change provide to enhancement of reactor safety. Both alternatives will reduce tha ex[erience level of sos. Both alternatives will cause career stagnation mvl anirosity anong Ros and AOs. For these reasons neitbar alternative . chew 3 e anacted as rule. j 1

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8903090165 890222 PDR PR 50 53FR52716 PDR h )()

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