ML20078A049

Comment on NUREG-1122,rev 1 Re Technical Catalog for Nuclear Power Plant Operators Who Operate PWR Reactors

ML20078A049
Person / Time
Site:	Beaver Valley
Issue date:	01/12/1995
From:	George Thomas DUQUESNE LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-59FR61905, RTR-NUREG-1122 59FR61905-00001, 59FR61905-1, NUDOCS 9501240263
Download: ML20078A049 (2)

Text

,

. Egant ccWx

. Duquesnel@tcompany :=pgerys- -

Sh ppingport, PA HiOf tP000 i

• fh (412) 393-5206 .

%Ofg Iz/z/Sy

%"'" ~s ;g N' 7;"f,y ) 23 l'. -

GEORGE S THOMAS Dwisson Vice President h8k/f'

• i/d

• f UN*2*o.m.on o huary 12, 1995 Chief, Rules Review and Directives Branch Division of Freedom of Information and Publications Services Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

NUREG-1122, Revision 1: " Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors" Duquesne Light Company (DLC) is responsible for the operation o,f Beaver Valley Power Station Units 1 and 2. DLC is submitting the attached comments on revised NUREG-1122, Revision 1, " Knowledge and Abilities Catalog for Nuclear Power Plant Operators: Pressurized Water Reactors." NUREG-1122 was developed to assist operator licensing examiners in the development of content valid written and operating examinations to administer to reactor plant operators and senior operators. The Knowledge and Abilities (K/A) catalog has been revised to resolve inconsistencies in content, to incorporate evolutionary changes in the operator licensing program, and to recognize a revised definition of an operator's tasks within facility licensee's organizations.

Thank you for the opportunity to comment on this issue. If you have any questions concerning the attached comments, please contact Mr. T. W. Burns, Director of Training, (412) 393-5719.

.- ' si-Sincerely,-

-97b George S. Thomas 9501240263 950112 PDR NUREG 1122 C PDR

i . 1

\

l . Attschment Comments on Draft NUREG-1122 Revision 1 GAD 3ric Knowledaes and Abilities Section

. .2.1.1 is a broad statement that encompasses many of the other K/As in this'section. 'It could be deleted.

2.1.2 through 2.1.33 would have different. importance ratings depending on the system to which they lwere being applied.

Therefore, they should not be generic, but should be listed and  ;

rated separately for each system in the catalog.  ;

2.3.7 is not a task performed by operators at the Beaver Valley 1' Power Station. The Health Physics Department performs this task. This should be investigated further to see if other.

utilities perform this task in a similar manner; if so, this task I could be deleted. .

I J

I - 2.4.10 is too broad for the importance rating to be valid. All-Alarm Response Procedures are not of equal safety significance.

It could be deleted since system Ability A2.will address Alarm Response Procedures separately for each system.

- 2.4.11 is too broad for the importance rating to be valid. All ,

Abnormal Operatinu Procedures are not of equal safety j significance. A 1ormal Operating Procedures 'are covered  ;

separately in tbn Abnormal Plant Evolution section; therefore,  ;

! 2.4.11 could be deleted.

I I

! - 2.4.24, 2.4.25, and 2.4.27 are redundant to the Abnormal Plant l Evolution section and could be deleted.

Plant Systems Section Most of the systems in the catalog need an Ability that addresses manual operation and/or monitoring the system from outside the control room in addition to Ability A4, which is to manually operate and/or monitor the system from the control room.

i Emeraency and Abnormal Plant Evolutions Section Knowledges EK2 for Emergency Plant Evolutions and AK2 for Abnormal Plant Evolutions are too general. They should specify which components are important for the specific evolution.

- -- .-