ML20235S979

Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors.Both Alternatives Would Eventually Reduce to Nothing Reactor Operators Advancing to Senior Operator

ML20235S979
Person / Time
Site:	Dresden
Issue date:	02/27/1989
From:	Mohr T AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-53FR52716, RULE-PR-50, RULE-PR-55 53FR52716-00114, 53FR52716-114, NUDOCS 8903080096
Download: ML20235S979 (2)

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~89- FEB 27 A10:47 Thmas Mohr 5510 Dunham Fc '

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~The Secretary of the Connission U.S. Nuclear Regulatory Ccanission Washington, DC 20555 Attention:. Docketing and Service Branch

Dear Sirs:

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

I have been a_ Senior Reactor Operator and Shift Supervisor for 8 years. I hold a Bachelors Degree in Applied Physics. I am a Registered Professional Engineer in Illinois. Currently I am responsible for maintenance of mergency operating procedures at Dresden Station. 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 and stable condition. Neither 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 (S0s). 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 thcoselves in a position to make this type of conmitment for that-anount of tine. The net result would be S0s obtained by hiring e.1d 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 more difficult to find notivated people to fill both Auxiliary Operator (AO) and RO positions.

'Ib ensure the health and safety of the public arvi '" mihmew the capability of the operatina staf f to rosrwl to ecci<l< ti' < , 'v4 hiivt '

can take the place of advanced preparation. Pe<;ent upgroti -

hi m o < r or T operating procedures have resulted in bette.t transient v- in

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ities. Changes in operator regualification now emphasize a<llemirm 1" these procedures providing proficiency through practice. Energeir;y response is best implemented by the availability, to the operating staff, of.a well trained multi-disciplinary team familiar with all aspects of 89030B0096 890227 h n PDR PR PDR y (f 50 53FR52716 g.

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l' nuclear technology u.yporting the the staff in all ares of operation.

Both alternatives to the proposed rule change provide no-enhancanent of reactor safety. Both alternatives will reduce the experience level of Sos. Both alternatives will cause career stagnation and aninosity anong Ros and AOs. For these reasons neither alternative should be enacted as nale.

Thcznas )bhr SRO,BS,PE

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