ML20092J255

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Comment Supporting Draft RG DG-1043, Nuclear Power Plant Simulation Facilities for Use in Operator License Exams
ML20092J255
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/15/1995
From: Carier P
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR36833, RTR-REGGD-01.149, RTR-REGGD-1.149, TASK-*****, TASK-RE 60FR36833-00006, 60FR36833-6, NUDOCS 9509220037
Download: ML20092J255 (2)


Text

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Tennessee Vaney Authordy,1101 Market Svent. Chananooga. T A02d . c l{,

St*' 151995 Chief, Rules Review and Directives Branch Division of Freedom of Information and Publications Se vices Office of Administration, Mall Stop T-6D-59 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Sir:

NUCLEAR REGUI.ATORY COMMISSION (NRC)- REQUEST FOR COMMENT ON DRAFT REGULATORY GUIDE DG-1043, NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE IN OPERATOR LICENSE EXAMINATIONS (REVISION 2 TO REGULATORY GUIDE 1.149)

The Tennessee Valley Authority (TVA) has reviewed the subject draft Regulatory Guide (RG) which was noticed in the Federal Reoister (60FR36833-36834) and is please to provide the following comments.

The RG defines an " acceptable" method of meeting the requirements of 10 CFR 55.45.

Although not a rule in itself, the RG has at least the economic force of a rule in that a substantial burden is placed on the licensee to obtain approval of an attemate method. The 10 CFR 55.45 rule specifically deals with operator exams. By including references to training in this RG, it implies a regulatory pos!!!on on training which was not evaluated in the value/ impact analysis conducted for the previous revision and is therefore inappropriate.

1. RG section 1.4:

The words " training and" should be deleted from the last sentence. RG section 1.2 makes clear the Intention of the RG to endorse ANS 3.5-1993 as it applies to testing, not training.

Although the extension to training makes good common sense, a regulatory position should not be established by implication.

2. RG section 1.6:

The words " training and" should be deleted from the first and second sentences.

TVA appreciates this opportunity to comment.

Sincerely, m

Patrick P. ier Manager Corporate Licensing cc: See page 2 9509220037 950915 PDR REGGD 01,149 C PDR l i

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Nuclear Regulatory Commission Page 2 l l

6tr 151995 . l cc: Mr. Jim Davis -

Nuclear Energy institute 17761 Street, NW Suite 400 Washington, DC 20006-3708 l

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