ML20205T298
| ML20205T298 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 04/02/1987 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Brockman K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GL-87-07, GL-87-7, NUDOCS 8704070260 | |
| Download: ML20205T298 (3) | |
Text
._
10CFR55 gth,cagna Electric & Gas Company A.
co um g g29218 Nuclear Operations SCE&G AMC%
April 2, 1987 4
Mr. Kenneth E. Brockman U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30323
Subject:
V.C. Summer Nuclear Station Docket No. 50/395 License No. NPF-12 Generic Letter No. 87-07
Dear Mr. Brockman:
In response to the March 19, 1987, letter from Mr. H.
R.
Denton, South Carolina Electric & Gas Company (SCE&G) has reviewed the revisions to Operator Licensing - 10CFR55 and Conforming Amendnients (Generic Letter No.
87-07) and submits the following subjects and related questions for consideration at the April 9, 1987 public meeting to be held in Atlanta.
I.
The requirements for the facility licensee to identify the need for an operator license is mentioned in four (d) different places.
50.74(a)
Notification of Reassignment 55.31(a)(4)
Application for License 55.55(a)
Termination if facility licensee determines the license is no longer needed.
55.57(b)(3)
Renewal of Licenses The implication is that the facility licensee is expected to identify positions in the organization beyond those specified in the Technical Specifications for which an NRC Operator License is considered necessary for the incumbent to satisfy the job requirement.
QUESTIONS:
1.
Is it the intent of the NRC that the facility licensee identify organizational positions beyond those required by Technical Specifications as needing an NRC Operator License?
2.
If so:
i 4
a.
How are these positions identified?
b.
What are the expected criteria for identifying these positions?
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Mr. Kenneth E. Brockman April 2, 1987 Page 2 c.
Must the incumbent be licensed?
d.
If the incumbent is transferred, will the license be terminated?
e.
If the incumbent fails to maintain a valid NRC license, is the facility licensee expected to transfer the individual to another position?
II. A systems approach to training (SAT) is defined and mentioned in several places.
Mr. Denton's letter implied that this is different from the INP0 Training Systems Development (TSD) process used for INP0 accreditation.
OUESTIONS:
1.
Generic Letter 87-07 only requires INP0 accreditation for NRC approval while Mr. Denton's letter requires that the training program be both accredited and based on a SAT process.
Which is the governing document?
2.
If the facility certifies the training program as being based on the SAT process will NUREG 1220, " Training Review Criteria and Procedures," audit findings and comments be considered violations of 10CFR55?
3.
If the facility does not certify their training programs:
I a.
When must FSAR Chapter 13 be revised? Mr. Denton's letter was not clear in this area if the facility elects not to certify the training program?
b.
Will a change to FSAR Chapter 13 (to satisfy new 10CFR55
)
requirements) be considered a decrease in the scope of an approved operator requalification program requiring prior NRC approva1 in accordance with 10CFR50.54(1)?
Will the NRC be prepared to approve or disapprove FSAR Chapter c.
13 changes within the 60 days allowed for implementing 10CFR55 requirements?
d.
What amount of detail will be required on a License Application, Form NRC-398?
Mr. Kenneth E. Brockm:n April 2, 1987 Page 3 If you have any specific comments on these questions, please contact Mr. Ken W. Woodward, Manager, Nuclear Operations, Education & Training at 803-345-1915 (Ext. 5100).
Very truly yours, N
D.A. Nauman KWW/ DAN:dgb Enclosures c:
J. G. Connelly, Jr.
O. S. Bradham M. B. Williams K. W. Woodward A. M. Paglia, Jr.
NPCF File
.