ML19323G581
| ML19323G581 | |
| Person / Time | |
|---|---|
| Issue date: | 04/07/1980 |
| From: | Benedict R Office of Nuclear Reactor Regulation |
| To: | Joel Wiebe NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| NUDOCS 8006040465 | |
| Download: ML19323G581 (2) | |
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.APR.07 W Central File LWR #2 File RABenedict RLBaer JLee MEMORANDUM FOR:
J. S. Wiebe, Office of Standards Development Or%najggnep,,,g THRU:
Robert L. ~Baer, Chief, Light Water Reactors Branch No. 2 DPM FROM:
R. A. Benedict, Project Manager, Light Water Reactors Branch No. 2, DFM
SUBJECT:
PROPOSED RULEMAKING,10 CFR 55, OPERATORS LICENSES (RS-019-1)
The March 21, 1980 memorandum from W. M. Morrison requested coments on the proposed rule.
Enclosed am my coments, both editorial and substantive, regarding the Rule and the Value/ Impact Statement.
c Mr. Morrison's memorandun also asked whether or not the SRO and RO experience 1
and training should be specified in the regulation.
I suggest that it be spelled out in a Regulatory Guide rather than in a Regulation because of the difficulty in changing regulations to keep up with changes.in requirements.
O. rigtna,l Slgne,d by,
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R. A. Benedict Light Water Reactors Branch No. 2 Division of Project Management
Enclosure:
Coments l
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P. F. Collins
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J. C. Stone W. M. Morrison D. B. Vassallo L. P. - Crocker S. A. Varga f.
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ENCLOSURE 07 M Proposed Rule (Enclosure A):
Page 6, Item 4(d)
The first word in the fourth line should be " simulator's".
Page 7, Item 5 In the third line, apostrophize " applicants".
Page 7, Item (b)(3)
For clarity, make this itea read " Reactivity and the effects of poisons".
Page 10, Item (d)(1)
Add " flow" to the list.
Page 10, Item (d)(4)
" Reason" should be plural.
Page 10, Item (f)(1)
Add the word "and" at the end of the second line (following " interlocks,").
Page 13, Item (c)(1)
In the first line, change "which" to "that".
This coninent also applies elsewhere.
Page 13, Item (d).(2)
Add " flow" to the list.
Page 13, Item (e)(1)
Correct the spelling of " involved".
Page 13, Add an Item (g) " Emergency procedures, including onsite and offsite notifications".
Page 14, Item 8 It might not be too unreasonable to have the appli-cant trained on a reactor manufactured by the same reactor vendor as the one on which he is seeking a license. Thi coment also applies to Item 15 on page 18.
Page 19, Third Line Apostrophize " simulators".
Value/ Impact Statement (Enclosure D):
On page 3, Item 3 says that there will be less down-time and more efficient utilization of the facility. This is an obvious advantage to the industry.
However, Item 4 seems to forget that these favorable industry factors would pass through to the consuming public, thus reducing rates for the service.
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