RC-97-0219, Comment Opposing Proposed Rule 10CFR55 Re Initial Operator Exam Requirements: Difference between revisions

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Op U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Rulemakings and Adjudications Staff n.
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==Subject:==
==Subject:==
VIRGIL C. SUMMER NUCLEAR STATION                                                                       b1 bS DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 PROPOSED RULE ON INITIAL OPERATOR EXAM REQUIREMENTS COMMENT South Carolina Electric and Gas (SCE&G) offers the following comments to the proposed changes to 10CFR55.
VIRGIL C. SUMMER NUCLEAR STATION b1 bS DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 PROPOSED RULE ON INITIAL OPERATOR EXAM REQUIREMENTS COMMENT South Carolina Electric and Gas (SCE&G) offers the following comments to the proposed changes to 10CFR55.
SCE&G does not agree with the proposed rule in its present forrn. SCE&G supports the comments as provided by NEl in response to the Federal Register Notice concerning proposed rulemaking on initiallicensed operations examination requirements (62 Federal Register 42426 of August 7,1997). In addition to the comments made by NEl, SCE&G believes that critical tasks should not be used during Integrated Plant Operation evaluations, as required by ES-301, D.4.d. Critical tasks, defined in Appendix D, place an unnecessary development burden on utilities. The competencies outlined in ES-303 are sufficient to conduct an accurate evaluation of a candidate's ability to safely operate the plant's systems under dynamic, integrated conditions.
SCE&G does not agree with the proposed rule in its present forrn. SCE&G supports the comments as provided by NEl in response to the Federal Register Notice concerning proposed rulemaking on initiallicensed operations examination requirements (62 Federal Register 42426 of August 7,1997). In addition to the comments made by NEl, SCE&G believes that critical tasks should not be used during Integrated Plant Operation evaluations, as required by ES-301, D.4.d. Critical tasks, defined in Appendix D, place an unnecessary development burden on utilities. The competencies outlined in ES-303 are sufficient to conduct an accurate evaluation of a candidate's ability to safely operate the plant's systems under dynamic, integrated conditions.
The administra+ive requirements that have been added during and after the pilot program have increased the examination preparation effort significantly. Not only is this a large burden on the training staffs, the requirements cf the process very much limits the versatility of the training staffs. An example of this is the requirement that the personnelinvolved in developing the exam can have limited previous involvement with the class, and once a member of the training staff acquires knowledge of the exam, he can no longer have any training                                                                     3 involvement with the class. This may prevent instructors that are subject matter experts from working with students due to their potential involvement in the exam a year later. The complexities associated with NUREG 1021, by definition, limits the utility staff expertise to a f ew individuals, thereby minimizing their full utilization in the operator training programs. This situation is also a problem for 9711060226 971024 PDR PR 55 62FR42426                   PDR O C G P %_     .
The administra+ive requirements that have been added during and after the pilot program have increased the examination preparation effort significantly. Not only is this a large burden on the training staffs, the requirements cf the process very much limits the versatility of the training staffs. An example of this is the requirement that the personnelinvolved in developing the exam can have limited previous involvement with the class, and once a member of the training staff 3
b               !      l       I.
acquires knowledge of the exam, he can no longer have any training involvement with the class. This may prevent instructors that are subject matter experts from working with students due to their potential involvement in the exam a year later. The complexities associated with NUREG 1021, by definition, limits the utility staff expertise to a f ew individuals, thereby minimizing their full utilization in the operator training programs. This situation is also a problem for 9711060226 971024 PDR PR 55 62FR42426 PDR O C G P %_
b l
I.


i SCE&G Comments on initial Operator Exam Proposed Rule Page 2 of 2 training supervision and management who are responsible for accomplishing both tasks of training the candidates and preparing the exams.
i SCE&G Comments on initial Operator Exam Proposed Rule Page 2 of 2 training supervision and management who are responsible for accomplishing both tasks of training the candidates and preparing the exams.
With the revised criteria contained in Rovision 8 to NUREG 1021, future contrauor prepared examinations will involve more effort, resulting in higher fees and does not nececsarily ensure a better exam. Exams developed by the NRC are not subject to the safns resVictions that utilities are. This may lead to the development of an exam that meets the requirements of NUREG 1021 but is not a representative sampling of the candidates real knowledge. For example, a         .
With the revised criteria contained in Rovision 8 to NUREG 1021, future contrauor prepared examinations will involve more effort, resulting in higher fees and does not nececsarily ensure a better exam. Exams developed by the NRC are not subject to the safns resVictions that utilities are. This may lead to the development of an exam that meets the requirements of NUREG 1021 but is not a representative sampling of the candidates real knowledge. For example, a utility can not have more that 25% of the questions on the exam that were used in the training program that was built and evaluated using a systems approach to training, where the NRC is not limited to this requirement because they have no knowledge of what was taught.
utility can not have more that 25% of the questions on the exam that were used in the training program that was built and evaluated using a systems approach to training, where the NRC is not limited to this requirement because they have no knowledge of what was taught.
SCE&G suggests that a better " partnering" approach between the NRC and the utilities should be developed to improve the examination process.
SCE&G suggests that a better " partnering" approach between the NRC and the utilities should be developed to improve the examination process.                 )
)
We appreciate the opportunity to comment on this proposed rule. If you havo any questions, please call Mr. Terry Matlosz of my staff at (803) 931- 5100.
We appreciate the opportunity to comment on this proposed rule. If you havo any questions, please call Mr. Terry Matlosz of my staff at (803) 931-5100.
V ry tr             yours, cac
V ry tr
: yours,
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c: J. L. Skolds W. F. Conway R. R. Mahan R. J. White A.R. Johnson NSRC RTS (PR 970004)
cac c: J. L. Skolds W. F. Conway R. R. Mahan R. J. White A.R. Johnson NSRC RTS (PR 970004)
File (811.02, Folder 55.006)
File (811.02, Folder 55.006)
DMS
DMS
                                                                                                                        ,}}
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Latest revision as of 09:42, 10 December 2024

Comment Opposing Proposed Rule 10CFR55 Re Initial Operator Exam Requirements
ML20198N975
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 10/24/1997
From: Gabe Taylor
SOUTH CAROLINA ELECTRIC & GAS CO.
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR42426, FRN-64FR19868, RULE-PR-55 62FR42426-00011, 62FR42426-11, AF62-2-035, AF62-2-35, RC-97-0219, RC-97-219, NUDOCS 9711060226
Download: ML20198N975 (2)
v • d • e


Text

- -._

uth Carolina Doctric & Gas Company G

J.T or

/I 5

a.nunive..se mes numar operaena am us-4x4 DOCKETED USNRC gM na.,.m W OCT 30 P4 :19 October 24, 1997 OFP(

.M

'Rc,9Zf219 RUI t ~.

.s Secretary ADJUX M -

Op U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Rulemakings and Adjudications Staff n.

7. j, g, [ [j h 8 Deat Sir,

Subject:

VIRGIL C. SUMMER NUCLEAR STATION b1 bS DOCKET NO. 50/395 OPERATING LICENSE NO. NPF-12 PROPOSED RULE ON INITIAL OPERATOR EXAM REQUIREMENTS COMMENT South Carolina Electric and Gas (SCE&G) offers the following comments to the proposed changes to 10CFR55.

SCE&G does not agree with the proposed rule in its present forrn. SCE&G supports the comments as provided by NEl in response to the Federal Register Notice concerning proposed rulemaking on initiallicensed operations examination requirements (62 Federal Register 42426 of August 7,1997). In addition to the comments made by NEl, SCE&G believes that critical tasks should not be used during Integrated Plant Operation evaluations, as required by ES-301, D.4.d. Critical tasks, defined in Appendix D, place an unnecessary development burden on utilities. The competencies outlined in ES-303 are sufficient to conduct an accurate evaluation of a candidate's ability to safely operate the plant's systems under dynamic, integrated conditions.

The administra+ive requirements that have been added during and after the pilot program have increased the examination preparation effort significantly. Not only is this a large burden on the training staffs, the requirements cf the process very much limits the versatility of the training staffs. An example of this is the requirement that the personnelinvolved in developing the exam can have limited previous involvement with the class, and once a member of the training staff 3

acquires knowledge of the exam, he can no longer have any training involvement with the class. This may prevent instructors that are subject matter experts from working with students due to their potential involvement in the exam a year later. The complexities associated with NUREG 1021, by definition, limits the utility staff expertise to a f ew individuals, thereby minimizing their full utilization in the operator training programs. This situation is also a problem for 9711060226 971024 PDR PR 55 62FR42426 PDR O C G P %_

b l

I.

i SCE&G Comments on initial Operator Exam Proposed Rule Page 2 of 2 training supervision and management who are responsible for accomplishing both tasks of training the candidates and preparing the exams.

With the revised criteria contained in Rovision 8 to NUREG 1021, future contrauor prepared examinations will involve more effort, resulting in higher fees and does not nececsarily ensure a better exam. Exams developed by the NRC are not subject to the safns resVictions that utilities are. This may lead to the development of an exam that meets the requirements of NUREG 1021 but is not a representative sampling of the candidates real knowledge. For example, a utility can not have more that 25% of the questions on the exam that were used in the training program that was built and evaluated using a systems approach to training, where the NRC is not limited to this requirement because they have no knowledge of what was taught.

SCE&G suggests that a better " partnering" approach between the NRC and the utilities should be developed to improve the examination process.

)

We appreciate the opportunity to comment on this proposed rule. If you havo any questions, please call Mr. Terry Matlosz of my staff at (803) 931-5100.

V ry tr

yours,

(

cac c: J. L. Skolds W. F. Conway R. R. Mahan R. J. White A.R. Johnson NSRC RTS (PR 970004)

File (811.02, Folder 55.006)

DMS

,

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