Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant PersonnelML20090F966 |
Person / Time |
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Site: |
Palo Verde ![Arizona Public Service icon.png](/w/images/9/93/Arizona_Public_Service_icon.png) |
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Issue date: |
03/09/1992 |
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From: |
Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
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To: |
Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
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References |
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FRN-57FR537, FRN-58FR21904, RULE-PR-50, RULE-PR-52 161-04654-JML-G, 161-4654-JML-G, 57FR537-00018, 57FR537-18, AD80-2-036, AD80-2-31, AD80-2-35, AD80-2-36, NUDOCS 9203120007 |
Download: ML20090F966 (5) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML17313A9791999-05-20020 May 1999 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 ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML20081B5721995-03-0808 March 1995 Motion of Plains Electric Generation & Transmission Cooperative,Inc to Withdraw,W/Prejudice,Petition for Leave to Intervene,Request for Finding of Significant Change & for Antitrust Hearing & Comments.* W/Certificate of Svc ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML17310B1911994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Texas. W/Certificate of Svc ML17310B2041994-04-12012 April 1994 Petition to Intervene of Public Utility Commission of Tx ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data 1999-09-28
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20217E1551999-09-28028 September 1999 Comment Supporting Pr 10CFR50 Re Elimination of Requirement for Licensees to Revise ISI & IST Programs Beyond Baseline Edition & Addenda of ASME B&PV Code ML17313B0651999-07-30030 July 1999 Comment on Draft Rg DG-1076, Service Level I,Ii & III Protective Coatings Applied to Npps. ML17313B0161999-07-0101 July 1999 Comment on Draft Rg DG-1074, SG Tube Integrity. ML20196K5631999-06-29029 June 1999 Comment Supporting Proposed Rule 10CFR50.55a Re Elimination of 120-month Requirement to Update ASME Code ISI & Inservice Testing Program ML17313A9791999-05-20020 May 1999 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 ML20207D1591999-05-20020 May 1999 Comment on Proposed Rules 10CFR21,50 & 54 Re Use of Alternative Source Terms at Operating Reactors ML20205A4271999-03-18018 March 1999 Comment on Petition for Rulemaking PRM-50-64 Which Requested Greater Clarification by NRC Re Possible Financial Obligations of NPP Licensees as Reflected in NRC Final Policy Statement on Restructuring & Economic Deregulation ML17313A8521999-03-0505 March 1999 Comment Supporting Proposed Change to NRC Enforcement Policy.Suggested Rewording of Sections Provided ML17313A8191999-02-24024 February 1999 Comment Supporting Secy 99-007, Recommendation for Reactor Oversight Process Improvements, & Comments Provided by NEI & Regional Utility Group Iv.Offers Comments on NRC Approach to Using Performance Indicators in Assessment Process ML20198J4031998-12-11011 December 1998 Comment Opposing Proposed Rule 10CFR50 Re Requirement for Monitoring Effectiveness of Maint at NPPs ML20217B9761998-04-0909 April 1998 Comment Re Draft RG DG-1029, Guidelines for Evaluating Electromagnetic & Radio-Frequency Interference in Safey-Related Instrumentation & Control Sys ML20216A9091998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50.55a Re Industry Codes & Stds ML20217E8781998-03-27027 March 1998 Comment Supporting Proposed GL, Lab Testing of Nuclear- Grade Activated Charcoal ML17313A3361998-03-27027 March 1998 Comment Opposing Proposed GL Re Lab Testing on Nuclear-Grade Activated Charcoal. Believes That Proposed 60 Day Implementation Schedule Would Severely Challenge Resources of Limited Number of Qualified Vendors ML17313A2511998-03-0303 March 1998 Comment on Proposed GL 98-XX Re Yr 2000 Readiness of Computer Sys at Npps. ML20203L5521998-02-25025 February 1998 Forwards Comments on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20202E4251998-01-30030 January 1998 Comment on Draft RG DG-1070, Sampling Plans Used for Dedicating Simple Metallic Commercial Grade Items for Use in Npps. Draft RG Should Be Revised to Clarify That Alloy Analyzer Can Be Used Consistent W/Guidance in EPRI NP-5652 ML20199E0871998-01-17017 January 1998 Comment Opposing PRM 50-63A by Pg Crane Re Amending Emergency Planning Regulations to Require Consideration of Prophylactic Use of Potassium Iodide for General Public ML20202G4461997-12-0101 December 1997 Comment on Proposed Final Rule 10CFR50.Licensee Requests That Effective Date Be Delayed from 980101 to 0601,in Order to Provide Enough Time to Request & Obtain NRC Review of Exemption from Rule ML20212D1391997-10-17017 October 1997 Comment on Pr 10CFR55 Re NUREG-1021,Interim Rev 8, Operator Licensing Exam Stds for Power Reactors ML17312B4241997-04-23023 April 1997 Comment Supporting Draft Rg DG-1068 (Proposed Rev 3 to Rg 1.134, Medical Evaluation of Licensing Personnel at Npps) ML20134J9671997-02-0606 February 1997 Comment Supporting Proposed Rule 10CFR50, Draft Policy Statement on Restructuring & Economic Deregulation of Electric Util Industry ML20134N2521996-11-14014 November 1996 Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp ML20117E3871996-08-0707 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Mod to fitness-for-duty Program Requirements ML20113C6981996-06-24024 June 1996 Comment Supporting Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Cautions NRC Not to Adopt Rules That Are Too Restrictive & Could Lead to Premature Decommissioning ML20117P1261996-06-24024 June 1996 Comment on Proposed Rule 10CFR50, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors. Urges NRC to Approach Rulemaking Re Decommissioning Costs in Manner That Will Facilitate Federal Legislative Solution ML20095A8461995-11-28028 November 1995 Comment on Petition for Rulemaking PRM-50-62 Re Proposed Changes to 10CFR50.54.Util Endorses Industry Petition & Response Provided by NEI ML17311B2931995-11-27027 November 1995 Comment Opposing Draft NUREG/CR-6354, Performance Testing of Electronic Personnel Dosimeters. ML17311B1601995-08-31031 August 1995 Comment Opposing Review of Revised NRC SALP ML20087H7241995-08-16016 August 1995 Comment Opposing Proposed Rule 10CFR2 Re Comment on Revision of NRC Enforcement Policy ML20087H7331995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Standard Design Certification for ABWR Design & Standard Design Certification for Sys 80+ Design.Concurs w/ABB-CE Comments & NEI Recommendations ML20087H7501995-08-0404 August 1995 Comment on Proposed Rule 10CFR52 Re Std Design Certification for ABWR Design & Std Design Certification for Sys 80+ Design ML17311B0071995-06-27027 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Insp Detail Should Be Brief & Ref Previous Rept by Section or at Min IR Number ML20083N5031995-05-0505 May 1995 Comment on Proposed Rev to 10CFR50,app J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors. Proposed Rev Will Result in Highly Efficient Regulation ML20082P7461995-04-19019 April 1995 Comment Supporting Proposed Rules 10CFR170 & 171 Re Proposed Revs of NRC Fee Schedule for FY95 in Fr ML20082H0971995-04-10010 April 1995 Draft Policy Statement Re Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation ML17311A6691995-02-0202 February 1995 Comment Supporting Draft Rg DG-8014 (Proposed Rev 3 to Rg 8.13, Instruction Concerning Prenatal Radiation Exposure) ML20078H0671995-01-20020 January 1995 Comment Supporting NUMARC Position on Proposed Rules 10CFR20,30,40,50,51,70 & 72 Re Radiological Criteria for Decommissioning of Lands & Structures ML20077M5471995-01-0404 January 1995 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactor Proposed Rule ML17311A2461994-08-25025 August 1994 Comment on Draft Reg Guide (DG-1031), Monitoring Effectiveness of Maint at Npps. Term Maint Preventable Failure Needs to Be Defined & Compared to Term Maint Preventable Functional Failure. ML20062M4141993-12-27027 December 1993 Comment Supporting Petition for Rulemaking PRM-21-2 Re Procurement of Commercial Grade Items ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process ML17306B2461993-01-15015 January 1993 Comment Supporting in Part,Draft Reg Guide DG-1020, Monitoring Effectiveness of Maint at Npps. ML17306A9571992-09-0808 September 1992 Comments on Proposed Rev to Staff Technical Position on Radwaste Classification.Supports Rev ML20099E0621992-07-29029 July 1992 Comment Opposing Proposed Rule 10CFR50.63, Loss of All AC Power ML20090F9661992-03-0909 March 1992 Comment Supporting Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel ML17306A4501992-02-0404 February 1992 Comment on Draft Reg Guide Task DG-8007 (Proposed Rev 1 to Reg Guide 8.7) Re Instructions for Recording & Reporting Occupational Radiation Exposure Data ML20055F4531990-06-29029 June 1990 Comment on Proposed Rule 10CFR55 Re Operators Licenses Modified for fitness-for-duty.Rule Unnecessary & May Adversely Affect Morale of Licensed Operators ML19327B1631989-09-0707 September 1989 Comment on Draft Reg Guide, Assuring Availability of Funds for Decommissioning Nuclear Reactors. Recommends That NRC Should Not Attempt to Dictate Standardized Form of Decommissioning Trust Agreement ML20235V7101989-02-27027 February 1989 Comment Opposing Proposed Rule 10CFR50 Re Ensuring Effectiveness of Maint Programs for Nuclear Power Plants. Rule Will Not Improve Maint,Reliability or Safety of Arizona Nuclear Power Project Plants 1999-09-28
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161-04654 JML/GEC d
March 09,1992 a
Mr. Samuel J. Chilk, Secretary !
U. S, Nuclear Regulatory Commission ATTN: Docketing arid Service Branch Washington, DC 20555
Dear Mr. Chilk:
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1,2, and 3 Docket Nos. STM 50 528/529/530 Response to Request for Comments Concerning Training and Qualification of Nuclear Power Plant Personnel (57 FR 537 dated January 7,1992)
Ble;_92 053-92J The enclosure to this letter provides the comments of Arizona Pubth Service Company (APS) in response to the request of the U.S. Nuclear Regulatory Commission regarding 57 FR 537, a proposed rule in which applicants and holders of a license to operate a nuclear power plant are required to establish, implement, and maintain a training program based on a systems approach to training.
APS appreciates the opportunity to comment on this proposed rule and would welcome the opportunity to meet with the Commission or Staff to discuss this issue further.
Sincerelf, h 1L%
WFC/MEP'3EC Enclosure cc: A. C. Gehr A. H. Gutterman 9203120007 920309 PDR PR 50 57FR537 PDR y) 5 i D
RESPONSE TO REQUEST FOR COMMENTS CONCERNING TRAINING AND QUALIFICATION OF NUCLEAR POWER oLANT PERSONNEL (57 FR 537 DATED JANUARY 7,1992)
161-04654-JML/GEC March 09,1992 RESPONSE TO REQUEST FOR COMMENTS CONCERNING TRAINING AND QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL (57 FR 537 DATED JANUARY 7,1992)
Arizona Public Service Company (APS) considers the proposed rule to be a positive step towards endorsing the systems approach to training (SAT) process that utilities have implemented to meet accreditation standards of the National Academy for Nuclea.
Training (the Academy). As the rule indicates, the impact should be minimal if the population to be included within the scope of the rule truly represents our accredited training population. However, wording such as "On-site technical staff and managers" as well as " Electrical maintenance personnel" and " Mechanical maintenance personnel" raise concerns as to the exact makeup of these groups vis-a-vis our presently accredited programs.
A time frame of 180 days for implementation seems reasonable if the scope of the rule is fully embraced within the utihty's accredited training and quah'ication program.
However, if additional programs or populations are really intended, then this time frame may be inadequate. Allowing this rule to be met by programs which are not accredited raises concerns as to future changes in the scope of the rule.
Following are several specific comments and/or questions on various parts of the proposed rule for clarification of exact impacts of the rule on present and future training programs:
The Background section states that "From the NRC's monitoring of industry training programs since the 1985 policy statement went into effect, the NRC has concluded that these programs have been generally effective in ensuring that personnel have qualifications commensurate with the performance requirements of their job." The "
term " generally effective"is not a complimentary description of the industry training program. The Staff indicates in the Discussion that other approaches to the rulemaking were not evaluated in detail, and no evidence exists that other approaches would provide greater protection of the public's health and safety.
Why, then, does tN Staff endorse the SAT process if there is belief that there is still room for improvement?
The Discussion of Proposed Rule section incluoes a tabulation of the elements of the SAT process. This tabulation differs slightly from the traditional elements of analysis, derivation, design, implementation, and evalucion.
The Discussion of Proposed Rule section states that " licensed Operators, such as control room operators and senior control room operators, are not covered by this rule. They will continue to be covered by 10 CFR part 55 for both initial and requalification training." The regulations in 10 CFR 55.59(c) can be met by either paragraphs (c)(1) through (c)(7) of that section, or, in part, by a program 1 of 3
161-04654-JML/GEC March 09,1992 dcieloped by using the SAT approach. The proposed training rule is more limiting in that it only allows one method of meeting the requirements.
The Discussion of Proposed Rule section states that " Periodic evaluations of the overall training programs are being done within the four-year industry accreditation cycle. The Commission expects the above practice to continue in conformance with this rule." This implies that this accreditation cycle will remain at four years, effectively limiting the flexibility of the Academy to modify the accreditation process over time. For example, it would seem to be contrary to the rule to expand this accreditation period beyond four years. This could effectively pass on the administration of the accreditation program to the NRC, in which case, the existence of the Academy could be redundant.
~
The Discussion of Proposed Rule section states that "It will be the responsibility of the facility applicant or licensee to ensure that a!! personnel, licensee and contractor, within the scope of the proposed rule have qualifications commensurate with job performance requirements for those tasks for which they are assigned."
The word " contractor" is used in a manner that could significantly expand the applicable population. APS fully agrees that all personnel should be qualified for the work they perform; the concern is that this could be interpreted as a requirement for all contractors (both long-term and short-term) to complete the accredited program.
The Discussion of Proposed Rule section states that "An applicant or licensee could also comply with the requirements of the proposed rule without being accredited."
This statement appears to deflate the purpose of maintaining accredited programs if applicants or licensees do not need accreditation to meet the rule. Also, it establishes a framework for the rule to exceed the accredited programs defined by the phrase " . . . the following nuclear plant personnel: ." ,
The Vendor-Developed Programs subpart of the Discussion of Proposed Rule section states "However, it is important to note that vendor training programs are not governed by the proposed rule and that the licensee is ultimately responsible for ensuring that personnel are qvalified." Has the NRC established acceptance criteria for this expectation to provide guidance io licensees? Would evaluation criteria be derived from NUREG-12207 Proposed Section 50.120 states "(b) Requirements. Each nuclear power plant applicant, by (180 days after the effective date of the rule) or 18 months prior to fuel load, whichever is later, and each nuclear power plant licensee, by (180 days after the effective date of the rule), shall establish, implement, and maintain a training program derived from a systems approach to training as defined in 10 CFR 55.4."
The implementation period stated in the proposed rule for those plants, including PVNGS, with training programs accredited by the Academy appears to be reasonable. If, however, the resolution of comments on this proposed rule 2 of 3
161-04654 JML/GEC March 09,1992 i
establishes a training program that exceeds the current scope of the Academy accredited program, the 180-day schedule may not be sufficient for adequate implementation of the rule.
Proposed Section 50.120 states that "The training program must provide for the raining and qualification of the following nuclear power plant personnel: .
(4) Instrument and control technician (5) Electrical maintenance personnel . . (6) Mechanical maintenance personnel . . . " The term " instrument and control technician" identifies a clearly definable group of personnel at a plant site; however, the terms " electrical maintenance personnel" and " mechanical maintenance personnel" could encompass a larger and very diverse group.
Replacing the term " personnel"in the rule with a more narrowly defined term (such as " currently within the accredited population") would alleviate potential interpretations during implementation of the rule.
Proposed Section 50.120 states that "The training program must provide for the training and qualification of the following nuclear power plant personnel:
(9) On-site technical staff and managers This differs from the currently accredited population as defined by the Academy. The Academy currently accredits training for " technical staff and technical staff managers." The proposed rule could be interpreted to include ALL on-site managers. This could expand the population and include positions for which a training program has not been developed by a formal SAT. Additionally, the technical staff program (as currently accredited) is a generic program and not position-specific for the variety of positions within the technical staff population, and is not formally developed using an SAT. Left to interpretation, this could lead to the development of several additional position-specific training programs.
Proposed Section 50.120 states that "The training program must be periodically
- evaluated and revised as appropriate to reflect industry experience as well as changes to the facility, procedures, regulations, and quality assurance requirements. The training program must be periodically reviewed by licensee managernent for effectiveness." Although APS does not prcpose that this periodicity be specifically stated in the rule, has the Staff envisioned a maximum acceptable period for these evaluations and reviews?
Proposed Section 50.120 states that " Sufficient records must be maintained and kept available for NRC inspection to verify the adequacy of the program." Has the Staff established guidance regarding the scope and extent of " sufficient," and are there any retention periods unique to these records?
In addition to the above comments, APS endorses the comments provided by the Nuclear Management and Resource Council.
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