ML20045F784

Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Opposes Rule

ML20045F784
Person / Time
Site:	Seabrook
Issue date:	06/18/1993
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR29366, FRN-59FR5934, RULE-PR-55 58FR29366-00003, 58FR29366-3, AE39-2-049, AE39-2-49, AE39-2-50, NYN-93093, NUDOCS 9307090010
Download: ML20045F784 (2)

Text

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• SeeorPe!. ~s 03874 Teleonene (6031474 9521 hhffh u % f

- J Facsimne (603)474-2987 Energy Service Corporation .g3 ~' " ,

~ 3' Ted c. Feigenbaum Sonict Ace President and

?ief Nuclear Officer NYN- 93093 J une 18,1993 -h Secretary United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch

Reference:

Facility Operating License No. NPF-86. Docket No. 50 443 S uoj e ct : Comments on Proposed Rule to Amend 10CFR55 (Operators Licenses)

Gentlemen:

North Atlantic Energy Service Corporation, as the operator of Seabrook Station, is ,

pleased to have this opportunity to comment on the proposed amendment to 10CFR55 l (58FR29366). The amendment would delete the requirement that each licensed operator at power, test and research reactors pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6-year license as a prerequisite for renewal.

North Atlantic generally supports this change since it would allow both the NRC and the facility to more effectively allocate its resources. The NRC would be in a bet:er pasition to direct its efforts toward its main oversight and inspection mission. The facility, likewise, would be freed of the administrative and regulatory burden of assisting the NRC in conducting the examinations and would, therefore, also be better able to concentrate on its main mission of training. This rule change would also be in line with the goals of the NRC's Ret;ulatory Review Group to eliminate requirements that unnecessarily restrict a licensee's flexibility in meeting NRC requirements and t.nsuring continued safe operations.

North Atlantic, however, believes that much of these gains would be lost by the requirement to submit all annual operating tests or comprehensive examinations to ;h NRC at least thirty days prior to conducting the tests or exams. For most licensees, this would require the submittal of six different examinations given to the six operating crews. More importantly, it would create a choke point in the training and examination schedule and enter uncertainty in the process. To make a submission to the NRC thirty days before the exam, the licensee would realistically have to target completion at least sixty days prior.

Once submitted, the licensee would naturally be reluctant to make changes since they would require additional s bmittals and possibly even postponement of the examinations.

Since the requalification program must be reviewed and approved by the Commission, and the Staff will review the examinations on an audit basis, the thirty-day submittal is totally unnecessary. It will do little, if anything, to facilitate the NRC's oversight capaN':ty.

It will however, create a resource loading concern for the licensee and require that the training and testing cycle schedule be built around these submissions. Any questions or concerns that the Staff has can, and should be. resolved during the NRC program audit and their normal oversight not just before the culmination of the entire training cycle. At that 9307090010 930618 PDR PR a member of the Northeast Utilities system x 53 58FR29366 PDR h() lh

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United States Nuclear Regulatory Commission June 18,1993 Attention: Docketing and Service Branch Page two point, the time and energies of the training staff should not be distracted by a deadline that

• has no bearing on what they are trying to accomplish. This aspect of an otherwise beneficial rule change needlessly complicates the training and examination cycle and thereby detracts from it and should be removed.  !

If you have any questions on this matter or would like to discuss it further, please  ;

contact Mr. Anthony M. Callendrello, Licensing Manager, at (603) 474-9521. extension 2751, 4

Very truly yours, ,

, fb - l Ted C. Feigenbaum r c

r TCF:J B H /a ct cc: Mr. Thomas T. Martin  !

Regional Administrator l U. S. Nuclear Regulatory Cummission [

Region I [

475 Allendale Road l King of Prussia, PA 19406 ,

l Mr. Albert W. De Agazio, Sr. Project Manager  !

Project Directorate 1-4 +

Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Noel Dudley NRC Senior Resident inspector P.O. Box 1149 Seabrook, NH 03874 ,

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