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Central Files Richard l!. Starostocki, Director TSzymanski HEMORANDUf1 FOR:
Division of Project & Resident Programs, RI BB.oger C IBeckham\
John A. Olshinski, Director Division of Engineering & Operational Programs, RII s R. Lee Spessard, Director Division of Engineering, RIII Richard P. Denise, Director Division of Resident Reactor Project and Engineering Programs, RIV Thomas 11. Bishop, Director Division of Reactor Safety and Projects, RV FR0!!: Hugh L. Thompson, Jr. , Director Division of Human Factors Safety Office of Nuclear Reactor Regulation
SUBJECT:
CLARIFICATION TO THE ADMINISTRATION OF OPERATING TESTS PRIOR TO INITIAL CRITICALITY (10 CFR 55.25(b) MEMORANDUM DATED 4/16/84)
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In ny memorandum to you dated ApriN6,- 1984, I stated that for candidates who are eligible to be licensed based on the completion of a cold license training program (e.g., cold license candidates and instant SR0's) an exemotion to the requirements of $55.25(b) must be nade pending Comission action on revising the rule. At that time, we were taking a very strict line on granting licenses pending more detailed review of existing requirenents and staff oractice. At our discussions with the Division of Licensing and the Office of the Executive Leaal Director, we have determined that the regulatory requirement of 155.25(b) is not tied through the regulations to -
instant SRO's. Therefore, the exemption to requirenents of $55.25(b) is Wot needed. However, in T!!! Action Plan Iten I. A.2.1, as clarified in NUREG-0737, " Clarification of the Tit! Action Plan," SRO's to be licensed at operating plants without first having been licensed as a Reactor Operr. tor must complete a training progran comparable to a cold license training program.
For applicants for operator or senior operator licenses prior to facility initial criticality, the requirements of 10 CFR 555.25(b) apoly. In accordance with ny April 16, 1984, memrandum, an exemption may be granted by you if all provisions of the cold license training program have been completed. If any portions have not been completed, the applicant must request a waiver of that portion and provide justification for the reouest..
(see Generic Letter S4-10 issued April 26,1984). All waivers for ki I incompleted po_rtions of the cold license training _p,rocram_bv m candidates for j licenses prior to initial criticality should be directed to 0LS headquarters 4 I
"4 .. .for. rwiew and. approval . - .
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Addressees ,
For applicants for instant senior operator licenses at operating reactors, 4 the provisions of the cold license training program described in the facility FSAR should be met. However, you may grant waivers from the FSAR's cold license training requirements for applicants who, through a combination of .
experience and training, have completed a program comparable to the cold license training program. You should document the waivers you have granted 'l as per my March 7,1984, memorandum on, " Operator Licensing Waiver
- Requirements".
If you have any questions concerning this matter, please contact Don Beckham, Chief, Operating Licensing Branch at FTS 492-4868.
pl m qi k ugh L. Thompson, Jr., Director ivision of Human Factors Safety Office of Nuclear Reactor Regulation ec: H. Denton T. Murley, RI J. O'Reilly, RII J. Keppler, RIII J. Collins, RIV J. Martin, RV -
G. Cunningham, ELD ~
H. Plaine, OGC h.-
DW/ CLARIFICATION /TED1
- see previous concurrence Oh/
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