ML18139A936

Comments on Draft NUREG-0731, Guidelines for Util Mgt Structure & Technical Resources. Qualification Requirements for Personnel Are Too Restrictive.Guidelines Should Permit Consideration of Equivalent Experience & Training

ML18139A936
Person / Time
Site:	Surry, North Anna
Issue date:	12/19/1980
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Vassallo D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0731, RTR-NUREG-731 1007, NUDOCS 8012290193
Download: ML18139A936 (4)

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VIRGINIA ELECTRIC AND POWER COMPANY

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Mr. Harold R. Denton, Director Serial No. 1007 Office of Nuclear Reactor Regulation NO/DWL:ms Attn: Mr. Domenic B. Vassallo, Chief Docket Nos. 50-280 License Qualifications Branch 50-281 Division of Human Factors Safety 50-338 U.S. Nuclear Regulatory Commission 50-339 Washington, D. C. 20555 License Nos. DPR-32 DPR-37 NPF-4 NPF-7

Dear Mr. Denton:

COMMENTS ON NUREG-0731:

GUIDELINES FOR UTILITY MANAGEMENT STRUCTURE AND TECHNICAL RESOURCES In response to the NRC '.s request, Vepco has reviewed the September, 1980 draft of NUREG-0731, "Guidelines for Utility Management Structure and Technical Resources." Although Vepco has several comments to offer for consideration, it is difficult to adequately address the many important provisions of NUREG-0731 which incorporate by reference the provisions of other unfinalized and unapproved documents which are also out for comment. Because NUREG-0731 relies so heavily upon many other documents, including ANSI 3. 1, "Standards for Qualification and Training of Personnel for Nuclear Power Plants" (December 6, 1979 draft); ANSI 3. 2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" (Draft 5, June 1980); Regulatory Guide 1.8, "Personnel Qualification and Training" (Proposed Revision 2, September 1980); and Regulatory Guide 1.33, "Quality Assurance Program Requirements" (Proposed Revision 3, June 1980) Vepco recommends that the next draft of NUREG-0731 not be .issued for review and comment until the outstanding issues raised in these other documents are resolved. We believe that such a procedure would eliminate confusion and non-productive iterations and would ensure consistent treatment of .similar issues in all documents which aoi/

are applicable to utility management structures and technical resources.

. .s In addition to urging that the NRC not finalize NUREG-0731 until the reference documents are finalized, Vepco request the Commission to consider the Company's additional general and specific comments set forth below:

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1. In the routine and emergency operation organizational structures presented, the title of "Manager" is used frequently (example, Figure 1). It is recommended that titles such as "Supervisor",

"Superintendent", "Director", and/ or "Coordinator" be used, where appropriate, in ord~r to clearly de~ignate the chain of command.

e e Mr. Harold R. Denton 2 VIRGINIA ELECTRIC AND POWER COMPANY TO There should be only one "Manager" position to which the overall responsibilities for routine operations and accident mitigation efforts are assigned.

2. In general, the qualification requirements for personnel are too prescriptive and unnecessarily restrictive. The guidelines should permit consideration of equivalent experience and training. It is imperative that well-qualified people are not excluded from serving in various positions because they do not have the prescribed educational backgrounds. For . example, Tables* 2 and 3 contain requirements, particularly academic degrees, which are far too specific. There must be general provisions for equivalent experience in lieu of a formal college degree.

To limit a licensee's choice of personnel by adherence to these simplistic rules of qualification may deprive utilities of the services of highly experienced and well--qualified individuals. This could, potentially, be .detrimental to the health and safety of the public. In addition, by this approach, the person filling any of these positions may feel overqualified for routine operations or unable to advance due to unattainable qualification requirements, thereby gaining little professional satisfaction and leading to low morale and high turnover rates. Therefore, we suggest that the training column in Tables 2 and 3 be deleted. The specification of required experience levels and the judgment of company management of an individual's qualifications for each area of expertise are sufficient to ensure availability of qualified off-site personnel.

3. NUREG-0731 states that "a reasonable period of time, probably on the order to two years, must be allowed for utilities to make necessary staffing changes and other arrangements." Reasonable acceptance criteria must be promulgated to allow time for utilities to meet the more stringent proposed requirements. Utilities may require substantally more than two years to fully comply with the NUREG-0731 guidelines. Clarification or guidance is needed from the NRC as to what level and schedule of compliance is acceptable.

Sufficient flexibility in the acceptance criteria must be provided to allow a reasonable, but timely, transition by utilities to meet the more stringent proposed quidelines.

4. Who determines when and by what means the utilities can eliminate the Shift Technical Advisor* (STA) function? Guidance is needed in this area dealing with an acceptable alternate approach to the STA function and acceptance criteria for the transfer of STA responsi-bilities to the operating shift personnel.

5. The technical requirements of a composite shift crew (Section II.A.2.d(2)) are the sum of the qualifications and training of the shift personnel. The licensed operators and the Shift Technical Advisor bring to each shift the required technical capability.

Additional technical expertise is available to shift operators through both on-site and off-site technical personnel. Therefore,

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e e Mr. Harold*R. Denton 3 VIRGINIA ELECTRIC AND POWER COMPANY TO the section dealing wi.th on-shift technical requireiµents should be deleted, and any changes in on-shift technical qualifications should be included in the specific training for the shift positions.

The on-shift technical qualifications section requires that main-tenance expertise be available oil-site on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day basis.

Typically, maintenance expertise is available via call-out on a 24-hour basis but is not "on-site" at all times. Clarification is needed for this requirement. This clarification should also indicate the type of maintenance expertise being discussed (i.e., mechanical, electrical, instrumentation and control, etc.).

6. The guidelines for accident conditions contained in NUREG-0731 require actions to be taken and manning levels to be achieved within specific and restrictive time limits. Consideration must be given to the type of emergency, technical expertise of on-site personnel and those in the immediate vicinity, and geographic location of the plant from the home office before requiring off-site personne1 to be on site within a specified period of time. Many utility corporate offices are over two-hour distances from their operating nuclear plants and therefore could not meet the requirements to have all people on site within that time. We recommend the deletion of specific time limits for accident conditions manning from NUREG-0731 and, where time limits are required, that they be consistent with emergency plans which are reviewed by the NRC Staff on a case-by-case basis.

The time limits to meet the manning requirements during accident conditions do not start at the same point in time for all actions.

Namely, some actions are required to be complete by a specific time after the determination of an accident, others after the time of notification of the accident. Vepco believes that it would be wise to establish a common starting point in time for all action require-ments to avoid having "two clocks" to follow. Again, we emphasizes the . necessity that time limits be consistent with emergency plans which are reviewed by the NRC Staff on a case-by-case basis.

7. We agree that an individual should not be required to work more than 14 consecutive day at extended hours without having two consecutive days off. There are times when an individual could work 14 cons*ecu-tive days, but not at extended hours. Experience has shown that 14 or more consecutive days at normal working hours is not deleterious to health and safety of the public (Settion ILA.2.d. l . j .4).

8. In Section III.A.l.b, the limitations regarding working hours should be suspended for accident situations. In general, it is felt that compliante with the stated limitations would be met, how-ever, on a case-by-case basis, it may be desirable or necessary that certain individuals exceed the proposed working hour .limita-tions in the interest of the health and safety of the public. Such special cases should require the approval of the Emergency Director (Plant Manager or his designee) and should not be complicated by a violation of regulatory policies.

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e e Mr. Haro1d R. Denton 4 VIRGINIA ELECTRIC AND POWER COMPANY TO .

9. The Near Term requirements for the relief of management personnel initially staffing the emergency organization should be extended from 8 to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. It may not be

• in the best .interest of the accident mitigation effort to - change command personnel until the accident situation has stabilized. Eight hours may not be sufficent time to organize the emergency response teams, a.ccess the accident situation and perform responsive .actions to mitigate the accident and stabilize plant conditions.

Additionally, continuity of knowledge - is an important factor to consider during the initial phases of an accident situation. It is suggested that a staggered relief approach be utilized to assist in an orderly transition of command personnel. This suggested approach would most likely extend the duration of the initial shift duties, for some, but would limit suth extended duty to only a few indivi-duals .

10. .Availability of 20 .ANSI qualified health physics technicians per shift is excessive for environmental monitoring. A total of 10 h~alth physics technicians per shift, 3-5 of which are ANSI quali-fied, is more appropriate and would allow all health physics functions to be carried out (Section III.B.4.d).

We appreciate the opportunity to comment on this draft of NUREG-0731 and will offer comments on its supporting documents as appropriate.

Very truly yours,

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• ~. R. Sylvia.,

Manager - Nuclear Operations and Maintenance

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