ML17313A979

Comment Opposing Draft Reg Guide DG-1084, Qualification & Training of Personnel for Nuclear Power Plants. as General Comment,Util Believes That Many of Proposed Changes Will Limit Ability to cross-train Mgt Level Personnel

ML17313A979
Person / Time
Site:	Palo Verde
Issue date:	05/20/1999
From:	James M. Levine ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-64FR15190, RTR-REGGD-01.008, RTR-REGGD-1.008, TASK-*****, TASK-RE 64FR15190-00001, 64FR15190-1, NUDOCS 9906150249
Download: ML17313A979 (8)

Text

CATEGORY 2 REGULAL'ORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9906150249 DOC.DATE: 99/05/20 NOTARIZED: NO DOCKET 0 FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi 05000529 STN-50-530 Palo Verde Nuclear Station, Unit 3; Arizona Publi 05000530 AUTH. NAME AUTHOR AFFILIATION LEVINE,J.M. Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME 'ECIPIENT AFFILIATION Rules & Directives Review Branch (Post 920323)

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SUBJECT:

Comment opposing draft reg guide DG-1084, "Qualification &

Training of Personnel for Nuclear Power Plants." As general A comment, util believes that many of proposed changes will limit ability to cross-train mgt level personnel. T DISTRIBUTION CODE: DS09D COPIES RECEIVED:LTR l ENCL I SIZE: E TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Nota.ce;Reg G 6

NOTES:STANDARDIZED PLANT 05000528 Standardized plant. 05000529 0 Standardized plant. 05000530 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL, ID CODE/NAME LTTR ENCL INTERNAL R 01 1 1 'MSS/IMOB T8F5 1 1 OGC/DR 15-B-18 1 1 . RES DIR 1 1 RES/DST 1 1 EXTERNAL: NRC PDR 1 1 D M

N NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 6 ENCL 6

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Generating Station Nuciear pt>>enter, AZ acus .a@4 jp'02-04286-JML/DGM/RAS May 20, 1999 Rules and Directives Branch Office of Administratiort U. S. Nuclear Regulatory Commission 2120 L Street NW.

Washington, D.C. 20655-0001

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

Units 1, 2 and 3 Docket Nos. STN 50-528/629/530 APS Comments on NRC 'raft Regulatory Guide DG-1084 "Qualification and Training of Personnel for Nuclear Power Plants" Attachod please find APS'~rnments on draft regulatoiy guide DG-1084 for your consideration. These comments respond to the NRC's solicitation for comments posted in tite Federal Register ort March 30, 1999 (64 FR 15r190). In addition to the specific comments enclosed, APS endorses the comments being submitted by the Nudear Energy Institute (NB).

As a general cornrnent, APS'tdlit:ves that many of the proposed changes will limit our ability to cross-train management level personnel without any commensurate improvements in the safe and reliable operation of our fat:ililies. APS is-not taking arty actions as a result of these proposed changes to Regulatory Guide 1.8 and therefore there are no regulatory commitments within this submittal.

Please contact Mr. Daniel G. Marks at (602) 3934492 if you have any questions or would like additional information regarding this matter.

Sincerely, JMLlDGM/RJH/RAS/tfh M&4v Enclosure

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E.W. Merschoff M. B. Fields J. H. Moorrnan lNPO Records Center 99061502M'90S20 PDR RKQQD OX. 008 C PDR ~l

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Rules and Directives Branch, USNRC APS Comments on Oratt r uIde-1084 Attachment page 1 of 2 APS Cornrnents on Draft Regulatory Guide DG-1084 "Qualification and Training of Personnel for Nuclear Power Plants" e ulato Position C.1.1 Section2 Definitio a "rclatodex ei1snce" APS'omment is that the proposed replacement wording to "related experience" Is unwarranted.

Specifically. manager level personnel, as stated in the standard, 'provide coordination and direction for major program areas and provide coordination among groups." Aps recognizes the Importanr~ of coordination and direction among all managerial levels, as weil as, front-tine workers. Likewise, APS realizes the significant role mangers have on the safe oporotion of the plant. APS heliaves, and has implemented, Job rotations to develop and enhance the skills and understanding of our managers viith related expuiience. APG'ystematic approach to training, Including on-the-job training, combined with related experience, ensures these rotations are accomplished in a safe manner and that tiw intent of the regulatory guidance is met. The proposed change could limit APS and other utilities'bility to cross - train management level personnel without any comparable gain In nucleai safety.

Eegg~itory Po tionC,2.6 Section 4.3 Middle Mana er L vei APS'omment is that the proposed change to this section Is unwarranted.

Slmi(ar to the position taken above, APS believes that management personnel gain enormous benefit through rotational assignments and the accompanying discipline specific training gained through Job rotafinns. Accordingly, APS agrees with the standard as it is currently written which allows management level personnel to be selected for posltioris whon the individual is provided with a staff nf Individual{s) whose qualifications meet the selected middle manager qualification.

Re uiato I'ositionC.2.1 Sectlons4.11.2 Ex e ience8ubstitutionforEducation.

APS'omment is that a regulatory position be taken that allows "Related experience may be substituted for education at the rate of 6 semester credit hours for each year of experfence up to a maximum of 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of credit,"

This proposal increases the maximum from the value of 60 credit hours in the standard to 80 credit hnurs. This would permit the baccalaureate level educational requirement to be achieved by substitution, provided the experience is in the appropriate technical subjects relevant tn the posiiinn to be filled. Unless the staff can demonstrate a correlation exists between nuclear safety and a baccalaureate degree, there does not appear to bo ony regulatory basis to require a baccalaureata degree as a qualication requirement to meet the NRC staff's acceptable methodology for compliance with 10 GFR Port 50, section 60.120.

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Rules and Directives 8ranch, USNRC APS Comments on Draft guide-1 084 Attachment page 2 of 2 Rta APS'omment ts that a regulatory position be taken to ctarify the definition of "education" in the standard.

The definition currently states, "Successful completion of the requirements established by an accredited oduc3tlonal institution." Specifically. we recommend a ciarmcation that states, "This includes successful completion of the requirements of a program derived from a systerasetic approach to training accrodited aa meeting the program requirement~

by an organization such as INPO," In the absence of a regulatory position, the definition is ambiguous. Just as conventlviial educational Institutions are accrcdltcd by recognized accrediting organizations, selected APS training programs are accredited by INPQ. The accreditation criteria ai'e sound. It is not unnew stood lf such training may be substituted as "related technical training" for substitution purposes.

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