PLA-3744, Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners

Comment on Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant.Expresses Concerns of Potential for Inconsistent & Inappropriate Application by Individual NRC Inspectors & Examiners

ML20094J903
Person / Time
Site:	Susquehanna
Issue date:	03/09/1992
From:	Keiser H PENNSYLVANIA POWER & LIGHT CO.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-57FR537, FRN-58FR21904, RULE-PR-50, RULE-PR-52 57FR537-00021, 57FR537-21, AD80-2-042, AD80-2-36, AD80-2-40, AD80-2-42, PLA-3744, NUDOCS 9203160246
Download: ML20094J903 (5)

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• 2151774 5151 N 0 91992 92 tmR 11 P4 32 Harold W. V4:ser y Setuor V1ce Prescent-Nuclear i {'f;;,7h 215/774 4194 0 gup Mr. Samud J. Chilk, Secretary U.S. Nuclear Regulatory Commission (

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Attn.: Docketing and Service Branch Washington, D.C. 20555 SUSQUEllANNA STEAM ELECTRIC STATION COMMENTS ON PROPOSED RULE ON TRAINING & QUALIFICATION OF NUCLEAR POWER PLANT PERSONNEL Docket Nos. 50-387/NPF.14 PLA 3744 FILES R412/A12d1 and 50 388/NPF 22

Dear Mr. Chilk:

Pennsylvania Power & Light Company is providing the attached comments on the " Training and Qualification of Nuclear Power Plant Personnel" proposed rulemaking (57FR537) for your consideration.

Although PP&L does not believe that formalized rulemaking in this area is required because of the successful industry programs cunently in place, we recognize that to comply with the April 1990 DC Circuit Court of Appeals decision, rulemaking in this area is unavoidable. We also recognim nat the proposed rulemaking is performance based in focus and attempts to parallel industry training and qualification activities. However, as with any rulemaking we are concemed that there may be a potential for inconsistent and inappropriate application by individual NRC inspectors and examiners and therefore implementation needs to be carefully monitored.

, Attached are a r. umber of specific comments to the proposed rulemaking.

PP&L appreciates the opportunity to comment on the proposed rule.

Very truly yours, H, W. Keiser Attachment 9203160246 920309 PDR PR 50 57FR537 PDR  % p 3I 6

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- 2- FILES R412/A17-Il PLA 3744 3 Mr. Samuel J. Chilk cc: NRC Document Control Desk (original) .

NRC Region !  ;

Mr. G. S. Ihrber, NRC Resident inspector ,

Mr.J. J. Raleigh, NRC Project Manager  !

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SPECIFIC COhiblEMES l

1. Paragraph; 50.120 (b)(9)

Change On site technical staff and managers to On site direct Encineering support oersonnel.

This change will make the rule consistent with the National Academy for Nuclear Training approach to Engineer Training. Existing words add training requirements for an undermed " manager" category of station personnel.

2. The same change noted in (1) above should be made under " Discussion of Proposed Rule". (see attached FR page 538)

3. The second paragraph under " Actions Proposed in Response to the Court Decision" (see attached FR page 538) could be interpreted as requiring a job and task analysis for cach position at each licensed facility. The following sentences should be added: Various appIpaches to_identifyinc training needs are utilized. These training needs " analyses" may be completed through cococrative ceneric industry efforts and applied. .as appropriite. at individual facilitiet 4 Under " Discussion of Proposed Rule" (see attached FR page 538) item number 4 concerning auditing programs, either delete the phrase "and associated programs" or list i the programs that need to be "readily audited." Without identifying what associated programs are to be included, inadequate guidance is available to facilides or inspectors.

5. The eighth paragraph under " Discussion of the Proposed Rule" states (see attached FR l page 539) "these evaluations are normally completed within a three to six week period following completion of the training program" and " periodic evaluations of the overall l training programs are being done within the four year industry accreditation cycle."

Although both of these statements are generally correct, their inclusion in the document could codify them and inhibit future improvements.

The systematic approach to training specifies an evaluation' step but many effective i~ evaluation approaches and time frames are acceptable.-- Suggest rewording this section as followsi These evaluations are normally oerformed after completion of the training program. Periodic evaluations of the overall training programs are beine done wititi1Lths industry accreditation program, .

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f ut Federal Resister / Vol. 57. No. 4 / Tuesday, lanuary 7.1992 / Proposed Rules  ;

1 De em~ a.d ran ehi sagd 10 who perform operaung. mamterience, was selected became it has the ,

FI'R cart so to remure tramma cronsms and technical support activities: following charactensucs. '

be eern ea imm a avar. mane andvnta (2) Use a systems approach to (1) Tretrung content and des $n are olmb reem= remur manta. trammg: dented from sob performance Current mousuy programs have been (3) incorporate mstrucuonal requirements; denloped consistent mth this '

requ2rements to proude quahfied (2) Tramteg is esalvated and revised approach. From the NRC's morutonna of persortnel who can safely opuste th in terms of the lob performance mdustry tramms programs strice the facihty tn su mooes of operation; requirements and observed results on 19&S pokey statement went mto effect, (4) Penodacauy review. evaluate and the tobi the NRC has concluded that these tense tM traming program: and (3) Trames success m tra nmg can propams have been generally effectae ($1 Ms.ntam and keep ateilable for predict satafectory on.thegoo m ensunts that persormel het e NRC mspection sufficient records to perfortnance: and quahficat one com.mensurate with the Serify the adequacy of the tramirs (4) Training and assecia'ed creers- s h,4.d-performance requirements of their sobs, prepa* can be read.tly sus 40 becaue they Anhoop es written response would :nsois e clearly dehntated process s'ers #k l UlsCWaioo be reuret bcensees wowid be and doc.1nentation. l De safety of nuclear power plant npecwd ts *n'ew 'uit hcense and The $AT process contams Ase ma:ct cperations and the assurance of general othn merou for consauncy we elements and is miended to teq;;.re a pubhc hesith and safety depend on 2' n'* M tramms systett that wid ensure The Cen*rassion has also developed successful performance on the lob b) persormel performes at adequate performance lesets. The systematic confm ammenenu to 10 m pans tramed mdmduals. The elements are-datermmauen of quahfications and the 50 and $2 to accompany the proposed (1) Anal) sis of sob puformance prevaion of effectas truusi tramms and rsa T*o chanees, to pans 50 and $", requirements and tratams needs:

periodac rettatnms will erthance would update mformauen collect 1on 9) Denvat on oflearrung obiecuses:

conf;dence that workers can perfor'ri et adecuate performance leseis. [{. fa P"" IE 's more substantive and has a

(3) Design and tmptementauen of the trammg programs:

Quahficauens m the content of that rWe means that nuclear power plant bun descioped to ensure that N pTre gMum g ,

persormel have completed the trattung apphcants fat a combmed beense t

The SAT procen also provides a gregram.

y taeetma er thepana

[C("$',D("j thereof, as evidenced tob performance

, 'nu"a'na am a sequental method of generstmg the t)pe ttain rd a mth tbe of documentauon needed for tramma re uinments. and are pertrutted to p]n rev ew. Use of SAT mil obviate the in ependendy perform specac ,,q ,

need for addiuonal documentauon for muviues. The Commision has taken an proposed rule is not intended to NRC review

.proach in tius proposed rule that preclude vender tratrung programs developed in contvncuen wsth na SAT process is e genene process.

l would specify the procan to be and its ap licauon ta notlinuted to a l implemented by applicanta and standstduauen of design. , , , ,

beenun by which lob performance Discusalon of Proposed Rule licenses personnel.Trainmg pros ama cntens and assocasted personnel A new secuen. I 50120, would be band on tob pe isrmance requirements tratrung would be danved. This have been successfuUy used by the added to 10 CI'R part 50, entitled approach provides for Doubibty and "Trauung and quahticauon of nuclear mihtary for evn 20 years, and by the site sper.tftc adaptatione in the tramms power plant pmonnel.- nuclear mdustry for much of the past programa. No additional cost is ne proposed rule would utablish the decade, l'urthermore, the Commission snucipated with this app cach for requirements for and the essental has recognaed the appropnateness of hcertsees mth secteditet programa elements of the process to be used by usms thae approach to tratrung in its because the proposed rule is beueved to requirementa for operstor licensms applicants and Licanuee to l be consistent mth existing industry presenbed in i SS.31te)(4). and for (1) Detertama tramma and pracnce for perssanel traming. qualocauon requirementa for all operator requahtication presenbed in l Approaches to tha rulemakang other appropnate peonnah (2) develop I15.59(c).

! than that proposed, which establishes correspondms personnel trainmg De rule would provide for the requitetnenta consistent with the programa to ensure that qualded tratrung and qualificauon of the Proscame sheady largely devebped and personnel are aveLisbte to operate and followmg nuclear power plant implemented by the industry, were not mamtain the focality in a safe manner: personneh evaluated M deta11.Dere is tse eetdance and (3) implement and matatnin these (1) Non-licensed operator, that any other approach wodd provide programs effectively on a conunuing (2) Shttt supervisor or equivalent.

greeter protection of the public's health bute. . (3) Shift technical advteor.

and safety than the sitsrepectftc trsining paragraph (a). " Applicability," (4) Instrument and control techrucien.

programa called for in the proposed rule. ladicates that the proposed rtue would (5) Electncal instater ance personnel.

At the same time, other approaches apply to each applicant for and each (6) Mechanical maintenance would involve greater costa to the holder of an operstmg licenu for a personnel.

industry and the NRC. nucleat power plant. (7) Radiolog. cal protection technician.

Susamary of Proposed Rule paragraph (b). " Requirements."

require that each applicant and licensee would (8) Chemistry technican, hg (9]On site tWwt staff and Each applicant for and each holder of establish. implement, and maintain a manaam.1.icensed operators, such as e3 an operstma license for a nuclear power program for training nuclear power plant control room operatore and senior ant would be requtred to.-- personnel which acidrosses all modes of control room operetors are not covmd (1) Establish a training program for opersuon and la denved from a systema by this rule.ney mil conunue to be certam nuclear power plant personnel approach to traming (SAT). De SAT covmd by to CF11 part 55 for bo'h

.y .

Federn! Regislog' / Vel

• 37. Mi W1% eda /. fairuary f.' trW / Pr6esed Wde'e' -

m truttal and requalinc4uon tramms. evaluate and rottu, ee e pproprista. As noted above. the NRC has the Decauw some struor control room esistmg technical speoAcanone (e 3 ability to vertfy comphance wtth tha operetore may also be shift supervisora, perhaps delsurg Standard Technical regulanon throcsh the mapecuon ordy those espects of treimas related to Spectficaton Secuon 6.4--Tratrung) prograin and wul do so as apprennete.

their shift supervtaar function would be and/or previous commutments.11us La thett tnspecuans the NRC staff mil i covered by the ptoposed rula. approach ml) ensure a common use inspecton Procedure 415m 1 The ruje would require that trsJrdng urwritandmg of tramma connutments programs be penodicauy evehiated and 7te mms and Quahficauon i (beteen spoucants and beensees and revised as appropnete and also be Effectiveness." which references the e

the NSC suff) when future mapecuens gwdence m Nt/ RIG-1:.W "Trairtma peno&cady renewed by taansgement are conducted-for effectiveness Cornnt mdustry Renew Cntens and Procedures " Dased

, entena in this re3std myohe the /mpoet of W Au/e on Eustas Industry on NRC marecuena conducted to case.

tvaluation by rosnagement ofindividual Trommgprogremt the Comitussion behoves that the tramms propoms on a contmums or The rule. if adopted. would supersede entens and procedures a NL'RIC-t:;3 penodac basis to identJy propem the Pohey Statement ont Treitung and krowde ,gcienuy clear twdance to

' eUow appbcants and beensees to strengths, weakriesses. and Quahf. canon of Nuc. lear Power Plant I tmplement eMuun mma prearams a effectn eness. nese evalustot1 AIL Personnel. De Cornmission behenes termsHY coweted wet e three to sts that the rule would not result m any compbance mW the rh nardent ;a drwea.sabn'tt renod foilewg.gmeieuen of change to accredited trstrung propams. Commassor does not behese it .s lg5 e, tramme eregIgms ne surn of these Inspecuons by the NRC have found the nnustry to neue a retwaiory rede 's e,aiu,i,onsr,,uiis , ,co,npt,sen,ive ,,op,,, to be gener.uy .cceptabie. Provide eddeuenal g= dance for

!I De Comm seion concluces that those cornplyng with the rule.

, renew e

P tod:e overall tremma etelustions creersms are bema of trairung thf. done propams accredated and Vender 4evelopedPrerrom v m et four-vear mdustry tmplemented ronsistent Mth the i accreditation cycle no Cornmassion mdustry propam obiecuves and enterta la to CT11 part $1 the Cotrtmassion

' espects the abo 6e practices to contmue would be a compbance mth the aruculated the goal of selety througn in sortfomtance mth than ru!e. recturement of tha regujeuor6 nis staniardizauon of design. De Determmauon el sob performance conclusion is based both on mapections requtrements and tramms needs is pa t Commission believes inet the benefits of by the staff which have found the standardisabon could myolve the of analysis in the SAT process r.nd is propams to be genersUy acceptabib. standardtsanon of some types of teflected in qualtfication requaements.

and the staf!'s teview of documents trairung anocts'ed mth the to CFR part it will be the responsibdity of the facility appucant or licenses to ensure that all wiuch provide the mdustry propram 52 design ceruficabon. Denfore, objecuves and cntena. An appucant or nothing in the proposed rule is intended the cope f a prop : I came c sid als ccmp y eth the to preclude standard tretrug programs e

han quahficanons cominensurate mth EgY,28 geEPmpmd nde bems dt.voloped orimplemented by a lob performance requirements for thou vendot. For example. the inical tratruns tasks for which they are assigned. Ituttal An sustms Memorandum of for instrenent and control techruciana and contmums tratama, as appropnete.

is espected to be provided to job

,"*[ M' C "

ba f C related to a parucular standard design aney be conducted by a vendor. As a meumbents in posiuons covered by the an[

proposed rule. I^ modiacaum or updatu

to me result. there could be a pool of Each apphcant and licensee would be m d n ] oul warrant technicians trained by the vendw on the

" " ' certified deetga avedoble for hire at a required to mamtam and keep available for NRC review and inspecuon the wed nu us nuclear power plant site, na pereormel to momtor the industry accreditsuon bowour, would need to completo site, matenals used to estabitsh and specific training related to the implement required training programa procm by -

for the affected persormel Current (a) Nouunsung individuals who ans administrouve and operating plulosophy industry crttone in this regard involte not on the NRC staff to urve as of the site as well as any other specific members of the NauocalNuclear requirements of the licenses.

upp rt m gemen infor t Accredittrig Board mth full voting Rus. the requirements for personnel and to pronde requtrod histortcal data, rtvilegee: training programa preecnbed by l 501:0

. In general. these tacinde rooords of (b) Hanns an NRC staff member do not prevent a vendor from tretrung

' propam developeneet, evalaation, and attend and observe selected National personnel or free dmlopmg a tratrung revision related to the existing training Nuclear Accrediting Board meetings proceu. However,it is important to note propam. ne NRC laepection of trainmg wtth the INp0 staff and/or the unitry that vendor traming programs en not propame has found that sufficient rePruentauves: governed by the proposed rule end that records are being retained for penode (c) Having NRC employees observe the licensee is ulumately responsible for that are adequate for regulatcay INPO acasditation team site vtstta; ensunns that personnel are quahfied.

purposes.De Communston believes that (d Revtewtng any modificauona in no addauonal guidance for the p)rogram oblecuves and critetta as recordkeepmg te necessary. currenuy desenbod in the National i ce, w wasc tsas ear bmm f,pi No wntten responu is required by the Academy for Nuclear Training proposed rule. However epplicante and document "ne Objecoves and Criteria

$ $ $ d, N $, N G "'

snea.sona c e,. i.e em. Inie use beensees would be expect 31 to compare for Accreditauon of Training ta the Namenal Toshasses taswesena semca. saas Pm their current trainmg commitments ard Nuclear power In6stry"(ACAD 31 e j

i licenstng bases with the requirements of 013): and, Qa.

in. Nac P.66s o anesp, the proposed nde.1.lcansees should use es ases6 stat t. sem (e) Vanfytng hceme programs w w.3,.w i m e.te. c .p.24 %

the results of that companson to through the NRC laspeccon procesa. Washasise6 DC.