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* P O W E A & Li G H T! p,42 ces Nes S: assto sox SDC8 * NEW CALEANS LCutSIANA 70174 * (504) 356-234:

M! COLE SOUTHUTiuT<ES SYSTEY

Januarv 28, 1981

W3P81-01433-A34

Secretarv of the Commission 'ci : , A~

' /\U.S. Nuclear Regulatory Commission -

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Washington, D.C. 20555

Subject: Proposed Revision 2, Reg. Guide 1.8; ( pg. _ B |" Personnel Oualification and Training" 'I -l-

dated Decemb'er 19, 1980 4 ,19g -

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[Gentlemen: N

.$liis \The purpose of this letter is to provide con.ents on pro _ l' d ision 2,.

to Regulatory Guide 1.8. LP&L offers co :.ents of both general and

specific aatures as follows:

I. General Comments

' A. A quick review of Sectio 1 B entitled " Discussion" and a glanceat the list of references on Pages 22 and 23 is indicative of

the difficulty a utility faces in making a simple determinationof the actual requirements. The m:.Tiad of documents andentities involved in development of these documents couldeasily lead to the conclusion that no single entity reallyknows what the requirements actually are. While we believethe industry is capable of struggling through the regulations,

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it sure would be nice if a sin;;1e document, or even two oriNthree, could be written to incorporate all the requirements, g

without again changing them. Once such a compilation is made,the myriad of underlying documents could and should be Scancelled.

Pg CB. In some respects, it appears that the entities involved in ! 04

U87 gmaking determinations as to the actual regulatory requiremen rare attempting to outdo one another in adding their own new q 3r

Nrequirements. The following questions should be asked:/. ,' sg /#''Iv

1. Doe:, an additional recuirement actually add to the safety --

of nuclear plant operations, or could the additionalcomplexities lead to degradation of nuclear plant safety?

2. Is the industry capable of acconmodating the regulations .

without dilution of expertise in other important areas?e.g. Hardware design review, human factors engineering, ,ymanagement. \\

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II. Specific Comments

- In offering specific comments, it is not intended that commentsbe made on each and every referenced document used in developmentof the proposed draft.

A. Page 6, Section 2.2.2a - While we can understand how time

limits for examinations would seem beneficial from thepoint of view of testing an applicant's ability to work

- under stress, we do not believe that the operator writtenexaminations are or should be used for this purpose.Psychological screening and other methods, includingthe plant operational test (oral examination, plantwalk through) are more suitable for this purpose. Thepurpose of the written examination is tc' test the applicant'stechnical knowledge, and we do not believe the added stress -

of restrictive time limits is appropriate for this purpose.

B. Page 6, Sections 2.2.2c & 2.2.2d - These sections eitherindicate or imply that the NRC will actually administerintermediate certifications or examinations for thevarious steps in the operator. training program. Wedoubt whether the NRC will have the capability to carry outthe actual administration for all the various types anddesigns of nuclear power plants. The individual nuclearpower plant training programs, on the other hand, arecustomized and will be available to carry out thesefunctions in a plant-specific manner. This comment alsoapplies to requalification programs. NRC audit of theseplant-specific programs is welcome and, in our opinion,provides a better opportunity for program improvement.

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C. Page 12, Section 1.3 " Equivalency" should be allowed inthe definition of " College Level Education". We recognize(Section 1.4c) that college level training in certain areasis appropriate. On the other hand, significant practicalexperience in the listed areas is certainly of value inachieving the objectives desired. A case-by-case evaluationand justification of equivalency would be an appropriaterequirement..

This section requires that courses be conducted by anaccredited college or university. This requirement maylimit a utility's ability to meet the college educationrequirements by limiting thg location of the course tothe college or university campus. The regulatory guideshould allow a utility to meet this objective by hiring aqualified professor or training consultant to conductcustomized courses on site.

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D. Page 12, Section 1.4.a - There should be some differentiationbetween the exp3rience requirements for Senior Reactor

1 Operators and the experience requirements for Shif t Supervisors.While it may be appropriate to require a full year of experiencefor the Shift Supervisor, we believe that six months of

experience for a non-supervising Senior Reactor Operatorshould be adequate.

The proposed regulatory guide does not address Senior Reactor,

Operator licenses limited to fuel handling. It should do so,and the experience requirements should be significantly less ,

than the six months or one year.

E. Page 13, Section 1.4.d - We assume that the three month training [requirement of this paragraph can be concurrent with theexperience requirements of Section 1.4.a.

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F. Page 14, Section 2.1 - The restrictions on exceptions, based~

on a case-by-case evaluation of an individual's qualifications,should allow for replacement of the particular personnel listedin this section for short periods of time to accommodatevacations, illnesses, etc. Certainly a one month maximumlimitation would be appropriate.

G. Page 15, Section 2.3.1 and Page 20-21, Section D - Thesesections require that shif t supervisors achieve a Bachelorof Science degree by January 1, 1986. We have several commentson this requirement as follows:

1. The additional training for SRO's and the experiencerequirements for SRO's and supervisors provide the .operating shift with the adequate technical, experiential,and supervisory capabilities to carry out its safety functions.

2. For what it's worth, this utility firmly believes thatthe overall effect of requiring a degreed shift supervisorwill be negative for the simple reason that it will resultin instability in the Operation's team as a result of ahigh turnover race. As a rule, engineers do not want tobe assigned to shift work.

3. A utility currently training for cold licenses will have !

great difficulty in achieving Bachelor of Science degreesfor-shift supervisors by January 1, 1986, without eitherfilling the slots with graduate engineers now or withoutsignificantly over-staffing. The combined work load ofplant organizational development, cold license training,startup preparation and testing, plant debugging andmaintenance following initial operation and other dutiesseverely limits a utility's ability to make peopleavailable for a college education.

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H. Page 17, Section 2.6 - The word " systems" should be expanded: to read " systems important to safety".

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I. Page 17, Section 2.7 - We question the continued need fork Shift Technical Advisors (STA) within ten minutes of the

control room. We believe that this requirement wascorrectly imposed on utilities as a short-term device toupgrade plant safety following the TMI incident. Webelieve that the many other improvements resulting fromthe TMI analyses now reduce the need for an immediately-available SIA. Examples of such improvements are the

- safety parameter display system (SPDS), the control roomreview, the reactor vessel vent and level instrumentation,the safety system status panel (Regulatory Guide 1.47),the margin-to-saturation instrumentation, and the emphasison special training, etc. These improvements should, atthe very least, ease the respcase requirement for SIA's.If the STA concept is retained, response to the controlroom within one hour of notification should be adequate.

J. Page 19, Section 3.1 - This paragraph states that a" position task' analysis should be conducted for alloperations personnel....". The word " operations impliesthat this applies only to those personnel in shiftoperating positions. If it is intended that this include -

all personnel on the plant staff, then we would takeexception to this section. We feel that position taskanalyses should be required only for on-shift personneland other key personnel who manage tasks directly associatedwith nuclear safety.

LP&L appreciates the opportunity to provide meaningful comment on theproposed Regulatory Guide. We have consumed significant management timein doing so. We continue to place nuclear safety in a very high corporatepriority, and our comments should be regarded as a positive attempt toimprove safety. We are confident that the NRC will so regard them in thefinalization of the proposed Regulatory Guide.

Yours very truly,

D. L. AswellVice President-Power Production

DLA: DBL:ver

cc: Institute of Nuclear P9wer OperationsAtomic Industrial ForumEEI Nuclear Operations Committee

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Mr. G. D. McLendonDr. D. C. Gibbs

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