ML20045H875

Comment on Proposed Rule 10CFR55 Re Exam Procedures for Operator Licensing.Supports Rule

ML20045H875
Person / Time
Site:	Indian Point
Issue date:	07/19/1993
From:	Bram CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Chilk S NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-58FR29366, FRN-59FR5934, RULE-PR-55 58FR29366-00017, 58FR29366-17, AE39-2-063, AE39-2-63, NUDOCS 9307220052
Download: ML20045H875 (3)

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Indian Point Staten July 19, 1993 Broadway & BleanJey Avenue g a f, ,C ', 4 Buchanan. NY 10511 Re Indian Point Unit No. 2 Tetophone (014) 737 8116 Docket No. 50-247 Mr. Samuel J. Chilk Secretary /'[' ;

US Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTICN: Docketing and Service Branch

SUBJECT:

Notice of Proposed Rulemaking - Operators' Licenses: 10 CFR Part 55, 58 FR 29366 (May 20, 1993)

Consolidated Edison Co. of New York Inc. . as owner and operator of Indian Point Unit No. 2, welcomes this opportunity to provide comments on the proposed amendments to 10 CFR Part 55, operators' Licenses. The proposed rule change would delete the requirement that the NRC administer a comprehensive requalification written examination and an operating test for each licensed operator during the term of the operator's 6-year license as a prerequisite for license renewal.

Consolidated Edison fully supports the Commission's proposal to terminate the NRC administered examination as a condition for license renewal under 10 CFR Part 55 Although the NRC's involvement has had a positive impact on the content and conduct of license requalification, utilities have proven their ability to develop and administer requalification exams that meet the requirements of 10 CFR 55.59 (A) (2) (i&ii).

We also agree that the preposed rule change will serve dual purposes: reducing the regulatory burden on licensees and improving operational safety at nuclear facilities. For example, increased operating crew continuity, afforded by this rule change, will improve operational safety. In the past, to accommodate the NRC administered requalification exam, operating crews were reconfigured by putting together individuals whose six years were about to end. This practice, performed only to facilitate the conduct of requalification exams, was not in the best interest of crew ,

coordination and teamwork.

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One issue of concern with the proposed rule change is the requirement that licensees submit exama to the NRC 30 days prior to their administration. This new requirement would result in an additional administrative burden on the utilities, both in developing the exame within the required lead time as well as sending multiple weeka worth of exams to the NRC. Furthermore, this approach raises the following questions o

Does the NRC retain approval authority over utility examinations't o Can the NRC change utility examinations?

o Can the utility change examinations after submittal?

In addition, an NRC staff audit of the examinations will require ref erence material consisting of as nany as 30 to 40 notebooks of lesson plans, procedures, Technical specifications, etc. Utilities would have to provide the NRC staff with updates of this material for each exam. This would place a large burden on the utilities, as well as the NRC staff, and therefore seems inconsistent with the intent of the proposed rule change.

Alternatives to this approach would ben o Utilities submit their completed exam banks to the NRC overy two years. This would allow the NRC to evaluate the exam banks for adequacy.

o Utilities submit one exam to the NRC for review at the end of each requalification program as a sample. The sample would demonstrate the depth and breadth that all requalification exams exhibit.

This approach is no different than the present, where the NRC is involved only in reviewing the  !

exam they administer. Presently, this is only l required every two years.  !

o Utilities submit exams to the NRC af ter they have been administered. This would provide the NRC with )

the opportunity to audit the material fer i conformance to 10 CFR 55.59 (a) (2) (iLii). f l

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Any of these approaches would maintain the existing high quality of operator training programs while significantly reducing the burden on the utilities and the NRC staff. In conjunction with the URC's onsite inspections, they would accomplish the important items targeted by the rule change.

However, the procedural requirements set forth in the proposed notice of rulemaking would substantially burden licensees and remove many of the efficiencies which form the primary incentive for the rule change, without providing commensurate further assurance that requalification exams are '

being administered appropriately.

Very truly yours, cc: Document Control Desk US Nuclear Regulatory Commission Nbil Station Pl-137 Washington, DC 20555 Mr. Thomas T. Martin Regional Administrator - Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Francis J. Williams, Jr., Project Manager Project Directorate I-l Division of Reactor Projects I/II US Nuclear Regulatory Commission Mail stop 14B-2 Washington, DC 20555 Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511

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