NRC-92-0035, Comment Opposing Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel

Comment Opposing Proposed Rule 10CFR50 & 52 Re Training & Qualification of Nuclear Power Plant Personnel

ML20090F961
Person / Time
Site:	Fermi
Issue date:	03/09/1992
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
CON-NRC-92-0035, CON-NRC-92-35, FRN-57FR537, FRN-58FR21904, RULE-PR-50, RULE-PR-52 57FR537-00019, 57FR537-19, AD80-2-040, AD80-2-40, AD80-34, AD80-40, NUDOCS 9203120005
Download: ML20090F961 (2)

Text

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""* NEO-92-0035 Secretary. V. S. Nuclear Eegulatory Occ= lesion Washingt on. L. C. 20555 Attn Docketing and Service Branch Refe rence s : 1) Fermi 2 NPC Locket No. 5&-341 NRC License No. NFT-43

2) Federal Register. Vol. 57. No. 4. Page 537 RIN 31bO-ADSO. dated January 7.1991

Subject:

Coensnts on Proposed Rule on Trairdng and Qualification

f Nelear power Plant Personnel (57 TR 537)

The purpose of this letter is to provido Detroit Rdison's corments on Detroit Edison the subjact proposed rule described in Ref erence 2.

apprecistes the cpportunity to participate in such an important rulensking. 'We also recognize end appreciste the NRC's ef fe,rt to write a rule that is much less prescriptive than the es tiler draf ts.

Detroit Edison believes that the industry hs.s established higt.ly successful performance-based training programs that have contributed to safe and ef ficient operation of our nation's nuclear power plants and that stand as the model for other nations with nuclear power facilities. Therefore, it is unfortunate that a ruit is beir.g required by the courts considering the acknowledgt d affectiveness of current training programo and the f act that neither public heal th and safety nor the public interest require the adoption of s:uch a rule.

It has been repeatedly eencluded that the industry's training and accreditation programs are cifective for ensuring that pereonnel have qualifications co.mensurate with the perfermance requirements of their jobs.

Therefore. retroit Edison's position ic that a training rule is not needed although it is realized that court decisions enndate that the NFC develop such a rule. The highly suceossful training and accreditation programs presently in place and the continuing emphasis on t raining through tae National Acadsay for Nuclear Training are evidence et the eczemitment the industry has made to improve training and overall plant perf ormance.

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SLeretary March 9.1942 NPC-92-003b l Page 2 l l

If there is going to t4 a training rule. it should be ensured that the rule and its future interpretations does not ccidlict with the  ;

cristing industry prograr.s or inpose any ariditional burdens on the industry since no a$ditional actions are needed bvyond current industry pregrams proven to be of fective to protvet the health and safety-of the public. Therefore. the statsment of consideration issued with the final tule shonid state the requiraciit ' ' sainstaining an INP0 accredited training program .

Additions 11. 7 Detroit Edison has reviewed and strongly supports the

)PJ. ARC cccmento on the preposed training rule.

If you have any questions, please contet Mr. Girija S. $bukta at (313) $06-4270.

Since rely.

cc T. G. Celburn A. B. Davis R. *d. DeFayette S. Stasek R. Whitesel (hW. ARC) l l

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TOTA P,03

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