ML20090J841

Comment Supporting Proposed Rules 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel

ML20090J841
Person / Time
Site:	Kewaunee
Issue date:	03/10/1992
From:	Schrock C WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-92-026, CON-NRC-92-26, FRN-57FR537, FRN-58FR21904, RULE-PR-50, RULE-PR-52 57FR537-00026, 57FR537-26, AD80-2-047, AD80-2-40, AD80-2-45, AD80-2-47, NUDOCS 9203180066
Download: ML20090J841 (1)

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March 10,1992 Secretary of the Commission Attention Docketing and Service Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlenien:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Commenfs on th.cBopmei_Trainine t Fe i e

Reference:

57FR537 Publication of the Proposed Training Rule This provides WPSC's comments on the above referenced Proposed Rule, in general, WPSC is in agreenient with the proposed rule, especially in that, it recognizes the industry's effort to improve training though the use of performance based trainmg programs and it endorses a systems apprcach to training (S AT).

While WPSC agrees with the proposed rule, we suggest an additional step be taken to review 10 CFR 55 to ensure that it complements this rule in its entirety. It is our opinion that certain prescriptive features of 10 CFR 55 may be eliminated by embracing the SAT process, thus improving the quality of training provided under 10 CFR 55.

In conclusion, we agree that the proposed rule is consistent with existing industry practice for personnel training and should be pre nulgated. We suggest 10 CFR 55 be reviewed in light of this rule.

Sincerely, OA I C. A. Schrock Manager-Nuclear Eneineering djm cc - Mr. Patrick Castleman. US NRC US NRC - Region til Documeat Control Desk, US NRC TR AINING.COM 9203180066 920310 PDR PR  %

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