ML20045H374

Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses.Proposed Change Would Eliminate NRC Requirement to Conduct & Supervise Individual Operator Requalification Exams During Term of Opeerator 6-yr License

ML20045H374
Person / Time
Site:	Vermont Yankee
Issue date:	07/09/1993
From:	Sedano R VERMONT, STATE OF
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR29366, FRN-59FR5934, RULE-PR-55 58FR29366-00008, 58FR29366-8, AE39-2-054, AE39-2-54, NUDOCS 9307200143
Download: ML20045H374 (2)

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10%d l3 '" v;.j STATE OF VERMONT 93 fi DSPARTMENT OF PI'BLIC SERVICE 120 STATE STREIR MONTPELIER, VT 05620 2601 TEL.: (802) 828 2811 FAX: (802) 828 2342 TTY /TDD (VT): 1800-734-K390 July 9, 1993 Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Docketing and Service Branch

Subject:

Comments on Proposed Rule, Operators' Licenses, (58 FR 29366, May 20, 1993)

The following are comments on the proposed rule change for Operators' Licenses referenced above. The Federal Register notice provides the opportunity for comment and we ask that the following be considered. We urge that the proposed change be reconsidered, at least for the Vermont Yankee Nuclear Plant.

Were it not for the regulation presently in place, we believe the health and safety of the people of Vermont could have been effected adversely.

The proposed change would eliminate the requirement far the Nuclear Regulatory Commission (NRC) to conduct and supervise individual operator requalification examinations during the term of an operator's 6-year license. Instead, requalification examinations would be the sole responsibility of the facility licensee.

In February, 1991, the Vermont Yankee Nuclear Plant was inspected in accordance with the existing regulation and found to have a failed licenced operator requalification (LOR) program.

See Inspection Report 50-271/91-02 (OL) and Confirmatory Action Letter I-91-007. As outlined in the inspection report, the failed LOR program was a result of NRC grading of operator crew requalification performance; if licensee grading had been used, the LOR program would not have been considered a failed program.

Thus, it was specifically.because the NRC conducted individual requalification examinations that Vermont Yankee's failed LOR program was detected. Without this NRC responsibility, its unclear whether the resulting beneficial corrective actions would have occurred (facility NRC inspections had not identified the failed LOR program).

9307200143 930709 PDR PR 55 5BFR29366 PDR S)O

Part of the basis for the proposed rule is not accurate, at least for Vermont Yankee. In the Backaround for the proposed rule the following is stated (58 FR 29366):

" Pilot requalification examinations were conducted in August through December of 1991 ... In conducting the pilot examinations, the NRC examiners and the facility evaluators independently evaluated the crews and compared their results. The results were found to be in total agreement...The performance of the facilities' evaluators during the pilot examinations further-confirmed that the facility licensees can find deficiencies, and remediate and retest their licensed operators' appropriately."

While the pilot requalification examinations found agreement between NRC and facility examiners, just six months earlier at Vermont Yankee, lack of agreement in the same area was clearly documented. Therefore, this background statement should be reconsidered, at least for Vermont Yankee.

We consider having a failed LOR program to be a serious occurrence, potentially affecting the people of our state. With -

the proposed rule change in effect, we do not have confidence that Vermont Yankee's failed LOR program would have been detected '

and corrected. Therefore, we urge that you reconsider and rescind the proposed change.

Sincerely, i i A )-)fc[/~

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Richar P._Sedano Commissioner State Liaison Officer 4'

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