ML20149B610

Trip Rept of 840323 Visit to INPO to Respond to INPO Concerns Re Training & Qualifications Rulemaking Package (SECY-84-76).Accreditation Team Rept on McGuire Station Read & Questions Answered

ML20149B610
Person / Time
Site:	Mcguire, McGuire, 05000000
Issue date:	03/28/1984
From:	Blumer A, Persensky J Office of Nuclear Reactor Regulation
To:	Booher H Office of Nuclear Reactor Regulation
Shared Package
ML082310270	List: ML20147E043 ML20147E230 ML20147E891 ML20149B547 ML20149B580 ML20149B610 ML20149B730 ML20149B865 ML20149B910 ML20149B916 ML20149C035 ML20149C100 ML20149C123 ML20149C204 ML20149C246 ML20149C262 ML20149C346 ML20149C469 ML20149C534
References
FOIA-87-787 NUDOCS 8404170634
Download: ML20149B610 (2)

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MAR 2 81984 gg - F MEMORANDUM FOR:

Licensee Qualifications Branch, OHFS FROM:

Alice H. Blumer Persor.nel Qualifications Section Licensee Qualifications Branch, DHFS J. J. Persensky, Section Leader Personnel Qualifications Section Licensee Qualifications Branch, DHFS

SUBJECT:

INP0 TRIP REPORT, MARCH 23, 1984 On March 23, 1984, J. J. Persensky and A. H. Blumer attended a meeting at INP0 to respond to INP0 staff concerns related to the training and qualifications rulemaking package (SECY-84-76).

In addition to participation in the meeting, we also read end asked questions about the Accreditation Team report on Duke Power's McGuire Station.

INP0 meeting attendees were:

Walt Coakley Bill Wigley Walt Guinn Dale Swazey Lee Adams Paul Manning Phil McCullough Although Ken Strahm did not attend the meeting, we did have a brief talk with him afterwards and received his infomal coments.

INPO Concerns about Rulemaking The~ major focus of INP0 concern was the proposed Regulatory Guide. The INP0 group stated several times that it would be better if we did not publish the Regulatory Guide.

Clearly, they believe that their own TSD Manual is sufficient and that our Guide would cause confusion and unnecessary activity within the industry to meet NRC requirements rather than self-generated improvement goals. We were told that industry is telling INP0 that if there is to be a rule, they will put their energies into meeting NRC requirements rather than pursuing INP0 Accreditation. This theme of describing NRC and INP0 paths as separate continued throughout our conversations at INP0 in spite of our reminders that the paths are not discretely different.

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A copy of the issues discussed at the meeting is attached. None of the issues discussed point to disagreement with the concept or logic of the contents of the proposed rule. Rather, it should be noted that the underlying concerns seem to be one or more of the following:

4 the implementation will cost too much; NRC's requirements will overshadow those of INP0 Accreditation; the rule will be overinterpreted because the Regulatory Guide will be seen as regulation, not guidance; I

the Guide gives too much detail, leading to impression that everything mentioned (e.g., JTA) is an absulute requirement; the certification requirement for contractors is unreasonable, the industry should not be asked to be responsible for contractor personnel; i

the record-keeping requirements, if not more thoroughly described, will be overinterpreted; personnel coverage for the rule is too broad.

At the conclusion of the meeting, we agreed to reread the Regulatory Guide with a view toward using clarifying examples to explain that a range of options is available in most phases of SAT depending on the circumstances.

In addition, we detennined that inclusion of more language like that used in the preamble to the rule mioht help clarify NRC intent.

McGuire Accreditation Report We were pleased to see that the report and its recomendations were consistent with the impressions we gained during our visit to McGuire to observe the Accreditation Team visit. There were no areas in which we noted a discrepancy between concerns voiced by team members and description of the McGuire program as presented in the written re,nort.

J

. Persensk, Section Leader

/sonnel Qualifications Section Licensee Qualifications Branch, OHFS r

M A.

. Blumer Personnel Qualifications Section Licensee Qualifications Branch, DHFS

Enclosure:

As stated t

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