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APR 161984 MEMORANDUM FOR:
Richard W. Starostecki, Director Division of Project & Resident Programs, RI John A. Olshinski, Director Division of Engineering & Operational Programs, RII R. Lee Spessard, Director Division of Engineering, RIII Richard P. Denise, Director Division of Resident Reactor Project h
and Engineering Programs, RIV 7
Thomas W. Bishop, Director
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Division of Reactor Safety and Projects, RV
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- .2 FROM:
Hugh L. Thompson, Jr., Director E
Division of Human Factors Safety Office of Nuclear Reactor Regulation J
SU3 JECT:
ADMINISTRATION OF OPERATING TESTS PRIOR TO INITIAL CRITICALITY (10 CFR 55.25)
In my April 11, 1984 memorandum to you, I informed you of the question concerning the existing staff practice of allowing an approved cold license training program to meet the requirement for extensive actual operating experience at a comparable facility.
On April 13, 1984, the Comissioners considered the matter..They detennined that additional action was required to clarify the Comission position that completion of NRC approved training programs could be substituted for experience requirements. They directed the Office of the General Counsel to initiate a rulemaking to make 10 CFR 555.25(b) fully consistent with current staff practice. They also affirmed that licenses in effect will remain valid.
For future licensing actions pending Comission action on the revised rule, the Comission authorized the staff to grant exemptions to the requirements of $55.25(b) for those individuals who have completed an approved cold license training program for their facility. The program must have included:
(a) nuclear fundamentals, including ten reactivity manipulations at a nuclear reactor, (b) observation training on shift at a comparable operating reactor, (c) training on a simulator and (d) training on actual system design of the candidate's plant.
For candidates who are eligible to be licensed based on the completion of a training program (e.g., cold license candidates and instant SR0's at operating plants) an exemption must be granted, y2
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You are authorized to grant exemptions to eligible individuals. The individual exemptions shall be documented by including the following statement on the license letter or in a cover letter included with the license:
Based upon your successful completion of the NRC approved cold license training program for jidentify) facility which included: (1) nuclear fundamentals, including ten reactivity manipulations at a nuclear i
reactor;(ii)observationtrainingonshiftatacomparableoperating reactor; (iii) training on a simulator; and (iv) training on actual i
system design of the candidate's plant, the Connission has concluded that pursuant to the provisions of Title 10 C.F.R. 55.7 an exemption from the requirements of Title 10 C.F.R. 55.25(b) that "[T]he applicant i
has had extensive actual operating experience at a comparable reactor" is appropriate and that such an exemption is hereby granted. The Comission further concludes that the granting of this exemption is 1
authorized by law and will not endanger life or property and is otherwise in the public interest.
' This applies to all licenses issued after April 12, 1984, for which eligibility was based on substitution of a cold license training course for actual experience.
Exemptions for individuals who completed cold license training programs that did not include all of the element identified shall be evaluated on a case-by-case basis in consultation with NRC Headquarters.
If you have any questions concerning this matter, please contact Don Beckham, Chief, Operator Licensing Branch or Ed Christenbury, Office of the Executive Legal Director.
ugh
. Thompson, Jr Dire r
Div' on of Human F tors fety Office of Nuclear Reactor Regulation cc:
W. Dircks H. Denton T. Murley, RI J. O'Reilly, RII J. Keppler, RIII J. Collins, RIV J. Martin, RV G. Cunningham, ELD H. Plaine, OGC l
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