NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses

Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses

ML20056F538
Person / Time
Site:	Duane Arnold
Issue date:	08/12/1993
From:	Keith Young IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR29366, FRN-59FR5934, RULE-PR-55 58FR29366-00041, 58FR29366-41, AE39-2-087, AE39-2-87, NG-93-3257, NUDOCS 9308300044
Download: ML20056F538 (2)

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1 lowa Electric Light and R.wer Company 93 F 20 lc:::47 '

August 12, 1993 i NG-93-3257 -

l Mr. Samuel J. Chilk, Secretary Office of the Secretary of the Commission U. S. Nuclear Regulatory Commission Attn: Docketing and Services Branch j Washington, DC 20555 l 1

Subject:

Duane Arnold Energy Center 1 Docket No: 50-331 l Op. License No: DPR-49 Comments on Proposed Rulemaking:

Operators' Licenses

Reference:

58 Federal Register 29366, dated May 20, 1993 File: A-105

Dear Mr. Chilk:

On May 20, 1993, the Nuclear Regulatory Commission published a proposed revision to 10 CFR Part 55, Operators' Licenses. The NRC requested comments on its proposal to delete the requirement that each licensed operator pass a comprehensive requalification written examination and an operating test conducted by the NRC during the term of the operator's 6 year license as a prerequisite for license renewal. This letter respondE to that request.

Iowa Electric Light and Power Company fully supports the proposed rule change and agrees with the NRC's opinion stated in the Federal Register that the proposed rule change will reduce regulatory burden on licensees and will improve operational safety at nuclear facilities.

The main benefit we see will stem from removing the requirement ,

for NRC administered requalification exams. This will reduce I burdens on licensees by (1) eliminating costly duplication and shipping of training material used to develop the examinations to the NRC and NRC contractors, (2) reducing time and travel expenses of licensee personnel who work with the ilRC to develop exams, and (3) reducing NRC fees for NRC time spent administering examinations and related contractor costs. We feel that the NRC's estimate of $820k for annual cost savings to facility licensees is reasonable based on our experience and the assumption that the costs are evenly distributed over 100 nuclear plants.

We also agree with the NRC's conclusion that operational safety e10 )

9308300044 930812 inergy center

• 3277 DAEC Road

• Palo. Iowo 52324 379/8517611 f PDR PR  !

SS 5BFR29366 PDR \

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i Mr. Samuel J. Chilk )

August 12, 1993 i NG-93-3257 l Page 2 {

will be improved by more effective allocation of its resources to [

perform on-site inspections of facility requalification  !

examinations and training programs. Under the existing  ;

regulations, as the industry matures, the number of licensed  ;

operators who require NRC administered exams will stabilize at a lower number, yet the utilities and NRC would have to expend  !

nearly the same amount of resources to conduct fewer exams. We feel these resources would be more effectively utilized in NRC ,

inspections of facility programs and examinations.  ;

If you have any questions on the above, please contact me at i (319)851-7229.

Very truly yours, ,

i lb,

~

0ll7 a Keith D. YoMng ,

Manager, Nuclear Licensing i

KDY/PMB/pjv' (

I cc: P. Bessette L. Liu ,

L. Root J J. Franz R. Pulsifer (NRC-NRR)  :

John B. Martin (Region III) l NRC Resident Office  !

DCRC l l

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