ML20134N252

Comment on Draft RG DG-1012,proposed Rev 3 to RG 1.8, Qualification & Training of Personnel for Npp

ML20134N252
Person / Time
Site:	Palo Verde
Issue date:	11/14/1996
From:	Krainik A ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-61FR52977, RTR-REGGD-XX.XX, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 102-03811-AKK-K, 102-3811-AKK-K, 61FR52977-00001, 61FR52977-1, NUDOCS 9611260234
Download: ML20134N252 (4)

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//IV.ijIpfyg ~ myse O'A & /276 Arizona Public Service Company /

j PALOVERDE NUCLEAR GENERATINgSTATioN5 O g S P.O. BOX 52034

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102-03811-AKK/KR s

, November 14,1996

Rules Review and Directives Branch, DFIPS

{ Office of Administration U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 i

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Reference:

Draft Regulatory Guide DG-1012, September 1996

Subject:

Palo Verde Nuclear Generating Station (PVNGS)

, Units 1,2, and 3 i

Docket Nos. STN 50-528/529/530 l Comments to Draft Regulatory Guide DG-1012 4

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' Arizona Public Service Company (APS) on behalf of PVNGS Units 1,2, and 3 submits

. the enclosed comments to the draft Regulatory Guide DG-1012 (proposed Revision 3 ,

to Regulatory Guide 1.8, " Qualification and Training of Personnel For Nuclear Power  !

t Plants"). We appreciate the opportunity to comment on the proposed revision to

. Regulatory Guide 1.8 and the Staff's consideration of our comments.

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If you require additional information or wish to discuss the comments, please contact John C. Velotta, Director, Nuclear Training Department at (602) 393-1785. '

Sincerely, I 4

Angela K Krainik, Department Leader Nuclear Regulatory Affairs AKK/KR/kr Enclosure l

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ENCLOSURE i 1

COMMENTS ON DRAFT REGULATORY GUIDE DG-1012 i QUALIFICATION AND TRAINING OF PERSONNEL

FOR NUCLEAR POWER PLANTS

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COMMENTS ON DRAFT REGULATORY GUIDE DG-1012

QUALIFICATION AND TRAINING OF PERSONNEL l FOR NUCLEAR POWER PLANTS The following comments correspond to the numbered sections and titles used in Section C. REGULATORY POSITION of DG-1012.

2.2 Section 4.1.4. Trainina.

Section 6.2.2 of ANSI /ANS-3.1-1993 is intended to be the recommended process for specific positions not identified in section 4.1.4. The suggested replacement to section 6.2.2 for independent review personnel refers to using a task list as the foundation for comparing an individual's experience and ,

knowledge in order to provide specialized training. However, this suggested i replacement is describing the systematic approach to training (SAT), the process {

in section 6.2.1 for which section 6.2.2 is designed to be an alternative. An i alternate process needs to be developed. I 2.3 Manaaers' Trainina.  !

This section should remain consistent with section 4.3.1 Training. Managers of training programs do not need to have the same knowledge in the technical area (s) that their training programs address. For example, maintenance training  ;

programs for instrumentation and control technicians, electrical maintenance personnel, and mechanical maintenance personnel can be managed effectively by a person who does not demonstrate the knowledge in each of these three maintenance areas. Another example would be a single manager for the I combination of chemistry and radiation technician training programs. To require the manager to demonstrate knowledge in the technical area (s) could subordinate the more important qualifying characteristics of effective leadership skills and a high level of knowledge of training technology to the lemr need. it may be overly restrictive, inhibiting innovation. Maintaining a tre%g staff with knowledge in the technical area is sufficient.

2.4 Section 4.2.2. Operations Manaaer.

The specified special requirements should be only applicable to the first management level above the Operations Shift Supervisors.

2.5 Section 4.3. Middle Manaaer Level.

To require that the middle manager meet the qualification requirements described for their position could in some cases subordinate the more important qualifying characteristics such as effective leadership skills, a high level of

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b l knowledge of training technology, etc. to lesser characteristics. It may be overly restrictive, inhibiting innovation. - Maintaining a staff with knowledge in the technical area may be sufficient in selected cases.

[ 2.7 Section 4.3.3. Radiation Protection Manaaer (Middle Manager Level). l l It is recommended that the term " professional-level experience" be defined.

i f 2.8 Section 4.4.6. Radiation Protection (First Line Supervisor Level).

} 'Section 4.4.6 should remain as is. Each supervisory candidate should be  !

i evaluated on an individual basis. Otherwise, characteristics such as effective i leadership skills could be relegated to lesser significance in favor of experience.  !

i 2.9 Section 4.5.1. Reactor Ooerator.

$ This additional qualification to the 0.5 year on-site experience should not be j incorporated. Other experience alternatives could be applicable. The training

program which is based on SAT as described in section 6.2.1 provides the j knowledge, skills, and abilities to perform effectively as a reactor operator.

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[ 2.10 Section 4.5.5. Quality Control. and Section 4.5.6. Quality Assurance.

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The reference should not be replaced by NOA-1-1983, as this standard is applicable to design and construction, not to the operating phase of nuclear j power plants.

t 2.12 Section 4.7. Indeoendent Review Personnel.

i j The reference to ANSl/ANS-3.2-1988 should be retained because it is the most i recent revision to the standard and incorporates industry experience.

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Addition Nmment not addressed by DG-101

! TFe Special Requirement (2)(a) of section 4.4.2 is not required. The training

. prc. gram based on the SAT as described in section 6.2.1 provides the knowledge, skills, and abilities to perform effectively as a senior reactor i operator. Other experience is equivalent. Examples include experience as a

!- shift technical advisor or operator training instructor.

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