ML20212M720
| ML20212M720 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1987 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20212M636 | List: |
| References | |
| FRN-49FR46428, RULE-PR-50, RULE-PR-55 AA88-2-3, NUDOCS 8703120152 | |
| Download: ML20212M720 (50) | |
Text
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l RESOLUTION OF PUBLIC COMMENTS ON PROPOSED RULE CHANGES TO 10 CFR'55 F703120152 870310 i
I.
LIST OF C0WiENTERS Letter Number Commenter 1
R. N. Meyer, Professional Reactor Operator Society 2
D. E. LaBarge, Professional Reactor Operator Society, Region I Office 3
N. S. Elliot, Babcock & Wilcox 4
L. S. Goodman, Lacrosse, WI 5
N. S. Elliot, American Nuclear Society 6
L. Roberts, Indian Point, NY 7
D. E. Howard, Toledo, OH 8
G. J. Vargo, Jr., Fulton, NY
'.9 R. Higgins, Region III 10 D. A. Dvorak, Oakdale, CT 11 R. C. Dawney, Hartsville, SC 12 E. J. Fuerst, Chicago, IL 13 J. T. Beckham, Jr., Georgia Power 14
- 0. R. Lee, Public Service Company of Colorado 15 M. D. Schultz, Northeast Utilities 16 M. Navarro, Avila Beach, CA 17 R. C. Kraemer, Northeast Utilities 18 J. N. Marquis, Lcs Altos, CA 19 R. J. Mette, Vista, CA 20 A. E. Bolon, University of Missouri-Rolla 21 R. E. Landrum, Antioch, IL 22 M. A. Perry, Big Lake, MN 23 G. L. Koester, Kansas Gas and Electric Company 24 D. J. Johnson, Russellville, AR 25 C. Barton, University of Missouri-Rolla 26 L. L. Weckbaugh, Dunkirk, MD 27 B. D. Kenyon, Pennsylvania Power & Light Company 28 J. T. Enos, Arkansas Power & Light Company 29 M. Straka, University of Missouri-Rolla 30 E. Chatfield, Yankee Atomic Electric Company 31 T. C. Houghton, KMC, Inc.
32 H. B. Tucker, Duke Power Company 33 W. L. Stewart, Virginia Power 34 G. W. Beale, Wildwood, IL 35
- 0. W. Dixon, Jr., South Carolina Electric & Gas Company 36 W. H. Jens, Detroit Edison 37 R. W. Deutsch, General Physics Corporation 38 D. E. Geltz, Texas Engineering Experiment Station 39 M.0 Medford, Southern California Edison Company 40 W. L. Whittemore, GA Technologies, Inc.
41 J. W. Williams, Jr., Atomic Industrial Forum, Inc.
42 R. E. Helfrich, Yankee Atomic Electric Company 43 J. R. Thorpe, GPU Nuclear Corporation 44 G. R. Westafer, Florida Power Corporation 45 R. L. Andrews, Omaha Public Power District 1
l Letter Number-Commenter 46 D. Musolf, Northern States. Power Company 47 C. W. Fay, Wisconsin Electric Power Corporation 48 P. M. Richardson, Public Service of New Hampshire 49 J. A. Tiernan, Baltimore Gas and Electric 50 L. Spalding, Address Unknown 51 J. W. Williams, Jr., Atomic Industrial Forum, Inc.
52 J. D. Shiffer, Pacific Gas and Electric Company -
53 T. G. Skaskal, Cleveland, WI 54 J. Baker, Benton City, WA-55 J. H. Schilling, Bay City, WI 56 N. W. Reynolds, Bishop, Lieberman, Cook, Purcell & Reynolds 57 J. J. Carey, Duquesne Light 58 J. Doering, Jr., Philadelphia, PA 59 J. R. Hill, St. Leonard, MD 60 B. D. Hiestand, St. Leonard, MD 61 J. H. Miller, Jr., Nuclear Utilities Management and Human Resources Committee 62 L. F. Dale, Mississippi Power & Light Company 63 J. B. Hudson, Cary, NC 64 C. M. Gray, Mishicot, WI 65 R. L. Wenderlich, Dunkirk, MD 66 W. D. Harrington, Boston Edison Company 67 G. Alexander, Commonwealth Edison 68 J. Friedrichs, International Brotherhood of Electrical Workers 69 B. D. Withers, Portland General Electric Company 70 M. A. Kay, Reed College 71 W. A. Nichols, Indiana & Michigan Electric Company 72 A. E. Scherer, Combustion Engineering, Inc.
73 W. G. Smith, Indiana & Michigan Electric Company 74 J. Peterson, Professional Reactor Operator Society 75 T. C. Houghton, KMC, Inc.
76 R. W. Kober, Rochester Gas and Electric Corporation 77 B. G. Hooten, Niagara Mohawk Power Corporation 78 E. P. Rahe, Jr., Westinghouse Electric Corporation 79 H. J. Cato, Custom Training Programs 80 D. C. Hintz, Wisconsin Public Service Corporation 81 W. G. Counsil and W. F. Fee, Northeast Utilities 82 S. R. Zimmerman, Carolina Power & Light Company 83 A. F. DiMeglio, Rhode Island Atomic Energy Commission 84 J. M. Yoe, Lusby, MD 85 G. C. Sorensen, Washington Public Power Supply System 86 J. C. McKibben and D. M. Alger, University of Missouri 87 J. W. Hufham, Tennessee Valley Authority 88 L. Clark, Jr., Massachusetts Institute of Technology 89 W. J. Richards, American Nuclear Society 90 G. D. Whittier, Maine Yankee Atomic Power Company 91 R. L. Mitt 1, Public Service Electric and Gas Company 92 D. L. Hubbard, Granbury, TX 93 W. G. Ruzicka, Union Carbide Corporation 94 M. Navarro, Avila Beach, CA i
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Letter Number Commenter 95 L. L. Weckbaugh, Dunkirk, MD 96 L. L. Weckbaugh, Dunkirk, MD 97 B. R. Clements, Texas Utilities Generating Company 98 L. L. Weckbaugh, Dunkirk, MD 99 R. J. Kennedy, Northeast Utilities 100
- 0. W. Dixon, Jr., South Carolina Electric & Gas Company 101 W. L. Whittemore, GA Technologies, Inc.
102 W. L. Whittemore, GA Technologies, Inc.
103 R. L. Andrews, Omaha Public Power District 104 R. L. Andrews, Omaha Public Power District 105 J. A. Tiernan, Baltimore Gas and Electric 106 J. A. Tiernan, Baltimore Gas and Electric 107 J. D. Shiffer, Pacific Gas and Electric Company.
108 L. A. Spalding, Address Unknown 109 C. W. Fay, Wisconsin Electric Power Company 110 C. W. Fay, Wisconsin Electric Power Company 111 B. D. Hiestand, St.' Leonard, MD 112 J. R. Hill, St. Leonard, MD 113 L. L. Weckbaugh, Dunkirk, MD 114 D. Musolf, Northern States Power Company 115 R. L. Andrews, Omaha Public Power Company 116 J. R. Hill, St. Leonard, MD 117 G. Alexander, Commonwealth Edison 118 R. L. Wenderlich, Dunkirk, MD 119 H. B. Tucker, Duke Power Company-120 M. R. Edelman, Cleveland Electric Illuminating Company 121 R. L. Jones, Perry, OH 122 B. R. Clements, Texas Utilities Generating Company 123 J. A. Tiernan, Baltimore Gas and Electric 124 R. P. Crouse, Toledo Edison 125 G. R. Westafer, Florida Power Corporation 126 B. D. Kenyon, Pennsylvania Power & Light Company 127 W. L. Stewart, Virginia Power 128 J. M. Yoe, Lusby, MD 129 J. M. Yoe, Lusby, MD 130 W. J. Richards, American Nuclear Society 131 G. C. Sorenson, Washington Public Power Supply System 132 R.L. Mittl, Public Service Electric and Gas Company i
133 C. W. Fay, Wisconsin Electric Power Company i
134 M. O. Medford, Southern California Edison Company l
135 W. D. Harrington, Boston Edison Company Comments are referred to by two numbers.
The first number corresponds to the letter number and the second refers to the comment number within the letter.
For example, comment 2-1 refers to the first comment in letter number 2.
In Section II of this report, comments are grouped in general categories followed by the resolution to that series of comments.
An index of specific comments can be found in Section III.
3
II.
RESOLUTION OF PUBLIC COMMENTS TO 10 CFR 55, "0PERATORS' LICENSES" A.
' General 1.
Comments 2-1, 8-1, 24-1, 32-1, 33-1, 48-1, 52-1,.53-1, 64-1, and 92-1 pro-vide general support for the proposed rule.
Resolution:
The comments have been noted.
2.
Comment 85-3 indicates that 10 CFR 55 relates not only to issuance of licenses, but to conditions required to maintain those licenses, including requalification, and recommends that S 55.1 be modified to indicate the full purpose of 10 CFR 55.
Resolution:
Agree.
S 55.1 has been modified to indicate the full pur-pose of 10 CFR 55.
3.
Many comments suggested changes or additions to 10 CFR 55.4, " Definitions."
Comments (a) through (s) refer to " simulation facilities."
Comment 43-7 requests that the regulations more clearly indicate a.
under what conditions a plant can be used as a " simulation facility" and, if it is used as such, how it will be used in administering the operating test.
b.
Comments 5-9a, 19-42, 22-1, 30-10, 31-16, 31-17, 39-42, 45-16, 45-17, 46-16, 46-17, 56-6, 62-16, 62-17, and 74-5 object to the inclusion of the plant in the definition of a " simulation facility" because the plant cannot safely perform the functions that a simulator can.
Comment 76-16 indicates that the proposed changes do not identify c.
the conditions for, or limitation oa, the use of the plant for operating tests and operator +. raining, and requests that such guidelines be provided.
d.
Comment 4-1 indicates a concern with using the plant to initiate transients, but indicates that if the plant was chosen as the simulation facility the application should not need to include much of the details specified in S 55.45(b).
Resolution:
NRC neither encourages nor permits the initiation of transients on the plant as training evolutions. The designation of l
the plant as a simulation device was envisioned as a possible approach that a facility licensee might propose to use in conjunction with l
another simulation device, or devices, in lieu of a plant-referenced simulator.
This approach might be especially suitable for older plants without plant-referenced simulators Where manipulations of the plant (to the extent consistent with plant conditions) might be used to demonstrate familiarity with the plant for which the candidate would be licensed.
e.
Comments 19-7, 32-8, 36-26, 39-7, 47-12, 52-18, and 76-16 note that the definitions of a " simulation facility" in ANS 3.5 and S 55.4 are not consistent in that ANS 3.5 does not include the plant as a simulation l
4 1
=
facility.. These comments also indicate that there are several reasons-why a plant'could not meet the requirements of ANS 3.5.
Resolution:
Disagree.
ANS 3.5 (1985) does not define " simulation facility." It does define " reference plant" in a manner similar to the definition in:10 CFR 55.4 of " plant referenced simulator." It
-is agreed that the plant itself cannot meet the requirements of-ANS 3.5.
f.
Comment 53-6 indicates that the process was not reasonable because non plant-referenced simulators are disallowed.
g.
Comments 30-18 and 34-3 indicate that S 55.45(b)(2) and (3) erroneously assume that a. plant-referenced simulator is the only tool available for testing skills and abilities.
The commenters indicate that other acceptable methods: include: (1) non plant-specific simulators-and plant walk-throughs,-
(2) apprentice programs where an operator would be required to be on watch L
with another licensee for a period of time, or (3) observation of the candidate performing the job by a qualified individual.
i:
h.
Comment 53-7 indicates that similar non plant-referenced simulators should be acceptable for initial qualification examinations.
i Resolution:
The NRC is not stating that non plant-referenced simula-tors.are unacceptable for initial qualification examinations.
How-i' ever, for situations where a simulation device is proposed.that-is not referenced'to the facility's plant and unit, the NRC is requiring Uie' facility licensee to:
(1) document the analysis that was done to support the determination that the simulato. proposed is an appro-priate simulation device for administering an operating test for the facility's reference plant; and (2) submit the application for NRC t
approval.
i.
Comment 64-3 indicates that a plant-referenced simulator is not i
required for accurate examinations, but rather that accurate examinations are a function of the examiner.
Resolution:
The NRC has not proposed that plant referenced simula-l-
tors be required for examinations.
It is NRC's position that the quality of examinations is a function of both the examiner and the simulation facility.
j.
Comments 19-20, 31-16, 39-20, 45-16, 46-16, 52-2, and 62-16 indicate that the term " referenced plant" should refer only to the specific nuclear power plant from which a simulator's configuration is derived and not to the specific unit, because exact replication of a multiunit plant of the same vendor and vintage is unnecessary and because a simulator will never s
be an exact replica of an individual unit because of the nature of plant modifications.
Resolution:
Disagree.
Although the word " unit" has been deleted from the definition of " reference plant" for purposes of clarification (since the term " nuclear power plant," used in the definition, refers to a plant with a specific docket number), the intent remains the same.
Not every multiunit plant has each unit of the same vendor and/or 5
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' vintage.
Specific guidance-is provided in RG 1.149 for those utilities
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.who want:to propose one simulation facility for use at more than one.
unit of a plant.
For those situations ~in which a multiunit plant is composed of units from the same vendor and vintage, it is reasonable to' assume that only one plant-referenced simulator will be needed.
Y-k.
Comment 42-6 suggests that the definition of a simulation facility ~
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be expanded to include:
(1) a plant-referenced simulator operated by the-
. facility licensee, (2) a vendor's simulator, or (3) other faithful simula-tion devices.
Resolution:
Disagree.
The existing definition in 10 CFR 55.4 is-already broader than the definition suggested here.
In S 55.4~,'a e
" plant-referenced simulator" need not be " operated by the facility o
' licensee" and "another-simulation device" can include both "a ven-dor's simulator" and "other faithful simulation devices" as well as others not' encompassed in this proposed definition.
1.
Comment 78-2 requests that the proposed rule be revised to more clearly state that plant-referenced simulators are not required for train-ing or licensing examinations.
Resolution:
Disagree.-
The definition of " simulation facility" in 10 CFR 55.4 clearly states that plant-referenced simulators are not the only devices that meet the definition.
m.
Comment 78-4 indicates that the proposed rule fails to address simu-2 lators that may-be owned or operated by a non-licensee.
The commenter recommends that the regulation be revised to permit a vendor to obtain generic approval for a simulator which then could be used for training and licensing for plants referenced in such generic approval.
The ccmmenter notes that this approach is similar to the generic approval currently authorized for quality assurance plans under 10 CFR 50.
Resolution:
Disagree.
Generic approval of simulators is considered inappropPate for the Commission's intent of ensuring that more l
uniform examinations are conducted at all facilities.
L n.
Comments 31-13, 31-17, 45-13, 45-17, 46-13, 46-17, 62-13, 62-17, and i
69-27 recommend that the definition of a " simulation facility" be modified to indicate that a vendor or utility simulator is an acceptable device for training / examining personnel from other utilities if there is enough similarity to allow the learning objectives of the training program to be accomplished and the NRC examiner to make a fair and informed decision on the candidates' abilities.
Resolution:
The definition of " simulation facility" expressly pro-vides for simulators other than plant-referenced devices by use of the term "another simulation device." Because of the diversity of design and proposed application of vendor or utility simulators when l
used for training / examining personnel from other utilities, it is not possible to address all cases with a specific definition.
- Thus, the term "another simulation device" has been included to provide for this possibility.
6
o.
Comment 6-2 indicates that the use of plant-referenced simulation facilities is a great improvement and that generic simulators can serve essentially the same purpose from a major evolution standpoint.
Resolution:
Noted.
p.
Comments 13-21, 27-6, 36-8,-78-16, and 91-15 indicate that the defini-tion of a " simulation facility" was satisfactorily clear, comprehensive, and distinctive.
Resolution:
Noted.
q.
Comment 5-10 recommends that under the definition of a " simulation facility" the term " plant referenced simulator" be replaced by the term
" full-scope simulator" because the term full-scope simulator uniquely identifies the only type of training device that is subject to the provi-sions of ANS 3.5.
Resolution:
The term " plant-referenced simulator" is directly linked to the intent of the proposed regulations and is tied to terminology used in ANSI /ANS 3.5 and, therefore, is retained.
r.
Comment 67-28 states that the requirements in S 55.45 should be satis-fied without providing test data for simulators that are vendor owned and operated.
Resolution:
See paragraph II.A.3.h,'above, s.
Comment 30-6 indicates that the need for a plant-referenced simulator to allow proper examinations of operators is questionable.
The commenter requests that an additional section be added to S 55.45 on non plant-referenced simulators, rather than leaving it up to utilities to justify them.
The commenter further indicated that RG 1.149 should be applicable only to plant-referenced simulators.
Resolution:
See paragraphs II.A.3.h and n above.
t.
Comments 31-15, 45-15, 46-15, 52-3, 62-15, 71-3, and 73-3 suggest an alternative definition of a senior operator in S 55.4:
"a senior operator means any individual licensed under this part to manipulate the controls of a facility and to direct the licensed activities of licensed operators."
Resolution:
Agree.
Definition has been changed in final rule.
u.
Comments 14-13, 19-19, 32-22, 35-20, 35-21, 39-19, and 69-4 suggest that the following terms should be defined in S 55.4:
exemption, waiver, actively and extensively, satisfactory performance, and evidene s Comments 21-10, 35-7, and 67-27 recommend that the terms " team-dependent" and " time critical" used in S 55.45 be defined in S 55.4.
7
Resolution:
These terms are used in their everyday sense and further definition is not necessary.
Moreover, the revision to S 55.45(a)(13).
deletes these terms from the final rule.
Comment 9-1 questions whether the definition of " manipulate a control" in S 55.4 included radioactive waste operators, auxiliary operators, turbine building operators, plant chemists, and health physics technicians?
Resolution: No, " manipulate a control" applies to the definition of
" control" in S 55.4, which is not intended to include the above per-sonnel.
4.
Comments 19-19, 39-19, and 74-6 ask for clarification between S 55.11,
" Specific Exemptions," and S 55.47, " Waivers of Examination and Test Requirements," and for amplification of 9 55.71.
Resolution: S 55.11 is much broader in coverage and allows exemptions at the Commission's initiative.
S 55.47 is limited to examination and test requirements waivers requested on the application.
S 55.71 does not require amplification.
5.
Comments 19-19, 39-19, and 74-6 asked for clarification of S 55.13.
Resolution: Wording changes made to S 55.13(b) to clarify that exemp-tion for a trainee at a facility is only while participating in an NRC-approved training program.
6.
Comments 30-11 and 36-10 suggest adding these words to the end of S 55.6
..., facility license or license."
Resolution:
Disagree.
Paragraph 55.6 deals with Commission interpretations.
B.
Medical Requirements - Subpart C i
i Most comments support the revisions to the medical requirements.
1.
Comment 14-2 agrees with the intent of 9 55.23 which is to require medical reports only when there is a medical problem.
For the usual case, a brief certification by the utility in Form NRC-396 will be sufficient.
l I
Resolution: Comment noted.
2.
Comments 9-3, 9-6, and 105-2 question the relationship of the medical re-quirements to drug and alcohol problems and programs.
Resolution:
Drug use and alcohol dependence are covered by a sepa-rate Policy Statement on Fitness for Outy of Nuclear Power Plant Personnel (51 FR 27921) published August 4, 1986 by the Commission.
3.
Comments 13-4, 19-25, 23-4, 26-7, 28-10, 28-11, 31-19, 39-25, 43-9, 45-19, 46-19, 47-4, 49-6, 52-8, 59-6, 60-6, 62-19, 65-6, 67-4, 67-25, 71-5, 73-5, 76-1, 84-5, 84-6, 85-7, 96-1, and 105-1 suggest that facility licensees should not be required to obtain NRC approval before reinstating a 8
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temporarily incapacitated operator, but rather notification of the NRC should be required.
This would impose an unnecessary burden on facility licensees by requiring personnel to immediately cease performance of licensed duties for easily correctable physical conditions while the NRC reviews the medical certification.
Resolution:
Agree.
S 55.25 has been revised to not require notifi-cation of the NRC when a temporarily incapacitated operator is rein-stated.
4.
Comment 52-7 recommends that S 55.33(a)(i)(ii) be revised to indicate that "when the certification requests a conditional license based on medical evidence, the medical evidence shall be available for review upon request by the Commission."
Resolution:
Disagree.
Implementing this recommendation would put the NRC in the position of acting on a facility licensee's request for a conditional license without having the necessary medical infor-mation by which to judge the appropriateness of the request.
5.
Comment 74-7 noted that the " licensed medical practitioners" are generally not knowledgeable of what medical / health conditions are needed to preclude
" operational errors, endanger public health and safety." Thisjudgmentis best made by the facility licensee, using the medical examiner's findings as a basis.
Resolution:
Disagree.
ANSI /ANS 3.4-1983 requires the facility to provide the physician with a description of the operator's duties.
6.
Comments 28.9, 31-18, 45-18, 46-18, 62-18, 87-3, 87-4, and 91-3 indicate that a large number of licenses are conditioned to require the licensee to wear corrective lenses while performing licensed duties.
The commenter recommends that S 55.23(b) be revised so that detailed medical evidence need not be submitted for this common condition.
Comment 52-5 suggests that S 55.23 be revised to state that "once Form NRC-396 is completed by a qualified medical examiner, an authorized repre-sentative of the facility licensee will sign the form certifying the fit-ness of the applicant."
Resolution:
Agree.
These revisions have been made to Form NRC 396.
7.
Comment 21-3 suggests that criteria should be stated by which " defective i
hearing or vision" may be judged. The commenter further suggests that limits of criteria should be provided with respect to "any other physical i
or mental condition that might cause impaired judgment or motor coordination."
Resolution:
ANSI /ANS 3.4-1983 is considered to provide adequate cri-teria for implementation.
8.
Comments 29-1, 40-1, 40-5, 83-1, 86-1, 88-1, 89-1, and 130-2 urge maintain-ing the status quo for research, test and training reactors.
l l
Resolution: Agree.
The intention for research, test and training reactors was to maintain the status quo.
The_ rule has been revised to be clearer in this regard.
9.
Comment.52-6 requests that revised Form NRC-396 be sent out for comment before the rule is issued.
Comment 86-5 requests a list of specific items to be used to report " medical qualification data."
Resolution:
Form NRC-396 was sent for review under Office of-Management and Budget regulations and reflects the final rule requirements.
10.
Comments 14-1, 36-11, 48-3, and 85-6 recommend the frequency of medical examinations be tied to license renewal (once every 5 years) rather than the S 55.21 requirement of once every 2 years.
Resolution:
The frequency of medical examinations and license renewal has been coordinated by requiring license renewal every 6 years and retaining a biennial medical examination requirement.
C.
Applications - Subpart D 1.
Comments 19-27, 19-30, 39-27, 39-30, and 85-8 suggest that in S 55.31(a) the phrase "and the. facility licensee's need for an operator, senior oper-ator, or a special operator to perform assigned duties" and S 55.33(a)(3) be deleted in total because the facility licensee will not submit an appli-cation unless there is a "need," and further because there is not a defini-tion or standard that defines "need."
Comments 8-3, 14-15, 24-2, 31-38, and 31-39 expressed concern with the continuing "need" provision of S 55.57(b)(3) for license renewal for similar reasons.
Resolution: Noted.
The facility licensee's definition /interpre-tation of "need" will be accepted by the NRC.
The requirement is intended to simply have the facility licensee's management inter-nally review the need for the license before the application is made. The requirements remain the same.
2.
Comments 19-27, 39-27, and 67-5 suggest that in S 55.31(a) details should not be necessary for submittal because program requirements are already defined, particularly for INP0-accredited training programs.
Resolution:
If an applicant has successfully completed an INPO-accredited program, S 55.31(a) information can be replaced with a certification by the facility (on Form NRC-398) that the candidate has successfully completed the INPO-accredited program that uses a simulation facility acceptable to the Commission.
3.
Comments 19-27 and 39-27 suggest that in S 55.31(a)(4) the phrase "the startup and shutdown experience received" be replaced with "the startup and shutdown experience received on a plant referenced simulator or on an actual reactor." The commenters indicate that a plant-referenced simula-tor is equivalent to or better than an actual reactor because it allows demonstration, practice, and the insertion of malfunctions.
10
Resolution:
Disagree.
Current' requirements will continue.
4.~
. Comments 21-4 and 21-6 indicate that the phrase " learned to operate" in S 55.31(a)(4) is a poor choice without providing criteria and further sug-gested that the applicant also should sign the statement to share the responsibility for its truth.
Resolution:
This paragraph has been revised to require the facility licensee to certify that the candidate has successfully completed the facility's requirements.to be licensed as a RO or SRO.
There-fore, an applicant's signature would not be necessary.
5.
Comment 46-71 suggests that in S 55.31(b) it be made clear that only information related to the medical or general health of'the' applicant /
licensee may be, requested.
Resolutionf This paragraph is intended to address any information that may be relevant to granting or denying the application or whether to revoke, modify, or suspend the license and, therefore, will remain as is.
6.
Comment 66-2 indicates that the directions provided on Form NRC-398 are minimal and unclear and that the detailed 'information on the content of the Form NRC-398 either be retained in S 55.31 or that Form NRC-398 be modified to clarify the directions for completing the form.
Resolution:
Directions for. completion of Form NRC-398 have been revised.
7.
Comment 21-5 requests that in S 55.33(a)(1)(i) criteria be provided for what would " constitute sufficient cause for denial."
Resolution:
Disagree.
The criterion is clear in ANSI /ANS 3.4-1983.
Moreover, this paragraph has'been deleted.
8.
Comment 9-7 suggests that the following phrase be added to the end of 8 55.33(a)(1)(ii) "... while performing assigned operator job duties during emergency situations requiring the use of respirators."
Resolution:
The subject section has been deleted.
D.
Written Examinations and Operatin0 Tests 1.
Comments 2-2, 13-5, 13-6, 14-4, 14-5, 14-6, 22-4, 23-5, 26-1, 26-2, 28-12, 28-14, 30-15, 30-16, 31-3, 31-6, 31-21, 31-22, 31-25, 32-11, 33-3, 35-3, 35-4, 36-15, 36-17, 37-3, 37-6, 37-7, 37-11, 42-1, 42-2, 45-3, 45-6, 45-21, 45-22, 45-25, 46-21, 46-3, 46-6, 46-22, 46-25, 47-5, 49-1, 49-2, 52-11, 52-12, 52-14, 52-16, 59-1, 59-2, 60-1, 60-2, 62-3, 62-6, 62-21, 62-22, 62-25, 65-1, 65-2, 66-1, 66-25, 67-1, 67-8, 71-7, 71-8, 71-10, 71-11, 73-7, 73-8, 73-10, 73-11, 74-9, 74-13, 76-2, 77-2, 80-2, 84-1, 85-9, 87-5, 87-8, 90-4, and 91-1 indicate that the principal means of determining knowledge, skills, and abilities for operator licensing examinations should be the learning objectives derived from a systematic analysis of 11
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the jobs, but that these objectives are " buried" in a long list of infor-mation to be used in the development of an examination.
These commenters recommend that-these learning objectives form the basis and scope of examinations and that the other sources of information will only be used '
until the objectives are available.
2.
Comments _ 19-31, 19-33, 19-35, 35-1, 35-2, 39-31, 39-33, and 39-35 object to the inclusion in 9 55.41(a) of." operating manuals" and "other materials requested from the facility licensee" because of a concern that. irrelevant-
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or trivial questions would thus be included on the examination.
3.
Comments 52-10, 52-13, and 52-15 indicate that in S 55.41(a), S 55.43(a),
and S 55.45(a), the words " operating manuals" implied technical manuals-which generally exceed the knowledge requirements of an operator.
Resolution:
The examination sources listed in the proposed regula-tions for licensing examinations have been reviewed.
Each item was-found to be a necessary reference for examiners in developing content-valid examinations for a specific facility.
However,"learningobjec-I tives" have been moved to indicate their importance as the major In addition, the wording has been changed to clarify what 4
source.
is meant by " operating manual." The new wording is " system descrip-tion manuals and operating procedures."
4.
Comments 6-3, 6-4, 7-6, 13-3, 19-2, 39-2, 46-76, 53-2, 64-4, and 74-1 ques-tion the context basis of the examination and operating test and noted that trivial or irrelevant content is tested.
5.
Comment 50-1 indicates that the required knowledge for R0 and SRO examina-tions should be more specific.
The comenter recomends that the NRC issue a document that specifica11y' delineates what an RO or SRO is respon-sible for on NRC examinations and that the document be complete, condensed, accurate, and up-to-date and should be contained in no more than two or j
three volumes.
l Resolution:
The NRC has conducted an extensive review of the content bases for examinations.
For PWRs the results of this review have been published in NUREG-1122.
For BWRs the results have been pub-lished in NUREG-1123.
Based on subject-matter expert input, only important content will be tested.
6.
Coment 16-1 indicates that the Comission is being premature in proposing I
l to promulgate regulations that would draw license examination questions l
from a systematic analysis that neither the NRC nor the general public has yet seen.
Resolution: Job-task analysis is an accepted methodology for deriv-ing licensing examination content.
Job-task analyses are part of the i
performance-based training programs being implemented by facility licensees as part of the INP0-accreditation program.
Promulgating j
regulations provide assurances to facility licensees that licensin examinations and operator training programs will be on a more con g sistent basis.
I 12
E 1
l 7.
Comment 2-7 indicates that there were some differences between the list of testable subjects in the present S 55.21 and S 55.22 and the proposed S 55.41 and S 55.43 and that these differences were not pointed out in the description of the changes in the Federal Register.
The commenter further indicated that, for the most part, the proposed changes clarify the require-ments except for the addition of " administrative procedures" which the commenter indicated should not be incorporated in the examination.
Resolution:
Noted.
These changes are as detailed in the following list.
Brackets indicate additions to present categories.
Subpart E - Written Examinations and Operating Tests S 55.41 Written examination: Operators.
(a) Content.
The written examination for an operator will contain a representative selection of questions on the knowl-edge, skills, and abilities needed to perform licensed oper-ator job duties.
The knowledge, skills, and abilities will be identified in part from information in the Final Safety Analysis Report, [ system description manuals and operating procedures], facility license and license amendments, Licen-see Event Reports, the learning objectives derived from a systematic analysis performed by each facility licensee and contained in its training program, and other materials requested from the facility licensee by the Commission.
(b) The written examination for an operator for a facility will include a representative sample from among the following 14 items, to the extent applicable to the facility, --
(1) Fundamentals of reactor theory, including fission pro-cess, neutron multiplication, source effects, control rod effects, criticality indications, [ reactivity coefficients, and poison effects.]
(2) General design features of the core, including core structure, fuel elements, control rods, core instru-mentation, and coolant flow.
(3) Mechanical components and design features of the reactor primary system.
(4) [ Secondary coolant and] auxiliary systems that affect the facility.
(5) [ Facility) operating characteristics [during steady-state and transient conditions, including coolant chemistry,] causes and effects of temperature, pressure and reactivity changes, effects of load changes, and operating limitations and reasons for these operating characteristics.
13
(6) Design, components, and functions of [ reactivity control mechanisms] and instrumentation.
(7) -[ Design], components, and functions of control and safety systems, including instrumentation, signals, interlocks,
[ failure modes,] and automatic and manual features.
(8) Components, capacity, and functions of emergency systems.
(9) Shielding, isolation, and containment design features, including access limitations.
(10) [ Administrative, normal, abnormal) and emergency operating procedures for the facility.
(11) Purpo:,e and operation of radiation monitoring systems, including alarms and survey equipment.
(12) Radiological safety principles and procedures.
[(13) Procedures and equipment available for handling and disposal of radioactive materials and effluents.]
[(14) Principles of heat transfer thermodynamics and fluid mechanics.]
S 55.43 Written examination:
Senior operators.
(a) Content. The written examination for a senior operator will contain a representative selection of questions on the knowledge, skills, and abilities needed to perform licensed senior operator job duties.
The knowledge, skills, and abili-ties will be identified in part from information in the Final Safety Analysis Report, [ system description manuals and operat-ing procedures], facility license and license amendments, Licensee Event Reports, the learning objectives derived from a systematic analysis performed by each facility licensee and contained in its training program, and other materials re-quested from the facility licensee by the Commission.
(b) The written examination for a senior operator for a faci-lity will include a representative sample from among the following 7 items and on the 14 items specified in S 55.41, to the extent applicable to the facility, --
(1) Conditions and limitations in the facility license.
(2) [ Facility] operating limitations in the technical spe-cifications [and their bases].
(3) Facility licensee procedures required to obtain authority foi design and operating changes in the facility.
14
(4) Radiation hazards that may arise during [ normal and abnormal situations] including maintenance activities and various contamination conditions.
[(5) Assessment of facility conditions and selection of ap-propriate procedures during normal, abnormal and emer-gency situations.]
(6) Procedures and limitations involved in initial core loading, alterations in core configuration, control rod programming, and determination of various internal and external effects on core reactivity.
(7) Fuel handling facilities and procedures.
6 55.45 Operating tests.
(a) Content. The operating tests administered to applicants for operator and senior operator licenses in accordance with paragraph (b)(1) of this section are generally similar in scope. The content will be identified, in part, from infor-mation in the Final Safety Analysis Report, [ system descrip-tion manuals and operating procedures,] facility license and license amendments, Licensee Event Reports, learning objec-tives derived from a systematic analysis performed by each facility licensee and contained in its training program, and other materials requested from the facility licensee by the Commission.
The operating test, to the extent applicable, requires the applicant to demonstrate an understanding of and the ability to perform the actions necessary to accom-plish a representative sample from among the following 13 items:
(1) Perform pre-start-up procedures for the facility, including [ operation of those controls] associated with plant equipment that could affect reactivity.
(2) Manipulate the console controls as required to operate the facility [between] shutdown and desig-nated power levels.
(3) Identify annunciators and condition-indicating signals and perform appropriate remedial action where appropriate.
(4) Identify the instrumentation systems and the signi-ficance of [ facility] instrument readings.
(5) [0bserve and safely control] the operating behavior characteristics of the facility.
(6) Perform control manipulations required to obtain desired operating results during normal, abnormal, and emergency situations.
15
9.
Many comments suggest changes to S 55.41, S 55.43, and S 55.45 regarding the content of written examinations and operating tests.
Specifically, the following comments were reviewed:
9-9, 9-10, 9-11, 9-12, 9-14, 14-9, 14-10, 14-11, 19-36, 19-37, 19-38, 19-39, 23-6, 32-4, 32-12, 32-13, 32-14, 32-15, 35-5, 39-36, 39-37, 39-38, 39-39, 46-73, 46-74, 46-75, 46-77, 46-78, 47-6, 47-7, 47-8, 47-9, 48-5, 48-6, 69-6, 69-7, 69-8, 69-9, 71-12, 71-13, 71-14, 73-12, 73-13, 73-14, 74-10, 74-11, 74-12, 82-1, 82-3, 85-11, 85-12, 85-13, 85-14, 87-6, and 92-2.
Resolution:
These comments were reviewed by subject matter experts and changes were made to the regulation to clarify or improve the content categories.
The modifications are reflected in S 55.41, S 55.43, and S 55.45(a).
10.
Many comments were received about categories S 55.45(a)(12) and S 55.45(a)(13).
a.
Comments 13-7, 19-41, 23-8, 28-16, 30-17, 31-26, 32-17, 39-41, 43-6, 45-26, 46-26, 46-80, 47-10, 52-17, 62-26, 69-10, 71-15, 73-15 74-14, 76-3, 81-1, 85-15, and 87-9 indicate that S 55.45(a)(12) is too subjective and should be deleted or combined with (13) as follows:
" Demonstrate the knowledge and ability to function as a member of the control room team by assuming the responsibilities of the assigned position for the safe oper-ation of the facility and performing operating evolutions in a manner consistent with station procedures and requirements."
b.
Comments 19-41, 30-17, 39-41, 47-11, 69-11, 71'-16, 73-16, 74-15, 77-3, 84-2, and 85-16 indicate that the requirements of S 55.45(u)(13) to " Demon-strate team dependent and time-critical behaviors associated with safe operations of the facility" are not objectively measurable. The commenters recommend deleting the requirement or changing the sentence to read "Indi-viduals function within the team so that procedural and license limitations are maintained."
c.
Comments 14-8, 42-4, 42-5, and 48-8 question whether " team-dependent and time-critical behaviors" can be reliably measured through individual examinations.
The commenters suggest that team performance might be l
better measured through requalification examinations.
d.
Comments 14-7, 19-1, 19-40, 28-15, 32-16, 33-4, 35-6, 36-1, 36-18, 36-19, 37-12, 39-1, 39-40, 47-10, 48-7, and 91-2 question whether in S 55.45(a)(12) " willingness and ability to assume responsibility" can be measured. Commenters indicate that, unless objective and measurable standards were provided, this was best determined by the facility licensee through selection and training programs.
Resolution:
Agree that the wording changes are necessary to clarify the intent of these categories.
However, as reworded these content areas can be measured.
Time-critical includes timely adherence to technical specifications and limiting conditions for operation.
Team-dependent includes communications and other interactive behaviors.
The rule has been reworded as follows:
l l
l 17 i
(12) Demonstrate the knowledge and ability to assume the respon-
~
sibilities, as appropriate to the assigned position, asso-ciated with the safe operation of the facility.
(13) Demonstrate the applicant's ability to function within the control room team, as appropriate to the assigned position, so that procedural and license limitations are maintained.
11.
Comments 23-6, 32-12, 46-74, and 46-77 suggest that the phrase "to the extent applicable to the facility" in S 55.41(b) and S 55.43(b) be changed to "to the extent applicable to the operator's job at the facility."
Resolution: Noted.
The word " facility" will remain because the operator's job is related to the facility " hardware" and license.
12.
Comments 30-5, 43-5, 54-1, and 92-2 suggest that with the increased emphasis on the operating test that is provided through the availability of plant-referenced simulators this is an ideal time to modify the written examination process.
Commenters suggest that the learning objectives be evaluated by review to determine whether they are best evaluated through the operating test or written examination.
Their expectation is that this would result in less reliance on the written test, which would do away with the situation where one set of skills is required to safely operate a nuclear power plant and a very different (and inappropriate) set of skills to obtain a license.
Comment 48-4 suggests that more emphasis should be placed or operating tests.
Resolution:
Noted.
This issue is being addressed through an ongoing examination development project, which will be implemented through appropriate revisions to Examiner Standards.
13.
Comments 19-32, 31-23, 36-16, 39-32, 45-23, 46-23, 62-23, 71-9, 73-9, and 85-10 take exception to the words " design" and " design features" in S 55.41(b) and suggested that the words " operational limitations" would be more appropriate because they are within the operator's ability to con-trol and deal with and design features are not.
14.
Comments 21-8 and 21-9 indicate that S 55.45(a)(9) requires an operator to " demonstrate or describe the use of portable survey equipment" and S 55.45(a)(10) requires similar ability with respect to ALARA procedures, yet these are not tasks that an operator must perform.
Therefore, the commenter recommends that the items be deleted.
Comment 49-1 indicates that radiological safety should not be part of the operators' examination.
Resolution:
NRC sets minimum requirements for licensed R0s and SR0s.
These requirements are reflected in S 55.41, S 55.43, and S 55.45.
R0s and SR0s are held responsible for the performance of these tasks even if they are delegated to others.
Similarly, while the design features are outside the direct control of an R0, it is essential that the R0 has an appreciable understanding of design features so that (s)he knows how and what is affected by what (s)he can control.
15.
Several comments address issues about the examination or operating test that are more appropriately addressed in NUREG-1021, " Operator Licensing 18
Examiner Standards." These included comments 23-7, 32-18, and 43-5, which suggest that sections be added to S 55.41 and S 55.43 to provide for utility review of licensing examinations.
Comment 67-15 also is concerned with utility review of examinations.
a.
Comment 40-3 and 85-11 recommend that S 55.41(b) contain a list worded similar to lines of the written examination categories with additional details on the content as is deemed appropriate for each category.
b.
Coment 11-2 requests more multiple-choice questions.
Comment 14-10 recommends that S 55.41(b)(10) be more specific.
Comments 21-11 and 26-3 express concern with the conduct of operating tests.
Resolution: These issues are administrative and covered in NUREG-1021.
16.
Several comments suggest waiver to examinations.
Coment 67-14 recommends consideration of the check operator concept a.
discussed in NUREG/CR-1750 as a basis for waivers and to relieve the exami-nation burden on the NRC.
b.
Comments 71-17 and 73-17 recommend changes in S 55.47 to specifically describe criteria and procedures for waivers of examinations based on oper-ating experience at a comparable facility.
Comment 74-16 recommends that operating experience be defined as 5 years actual operating experience, c.
Coments 28-13, 47-15, 67-14, 71-17, and 73-17 recommend that the Commission adopt in S 55.47 the latitude for waiver of written and/or oper-ating tests for operator candidates who have completed an INP0-accredited training program and/or requalification programs.
d.
Comment 52-25 recommends that S 55.47(1) be revised to incorporate "an extensive amount of instruction regarding operating at a comparable facil-ity" as a criterion for waivers.
Resolution: As the agency responsible for public health and safety, the NRC cannot, as a practice, waive independent assessment of I
operators and senior operators. Waivers are based on previously pas-sing all or part of a licensing examination.
Details regarding waivers are addressed in NUREG-1021.
17.
Many comments support the addition of S 55.49, " Integrity of Examinations and Tests." Comments 13-9, 19-45, 23-12, 27-7, 31-33, 39-45, 43-8, 45-33, 46-33, 47-16, 62-33, 77-6, 80-4, and 81-4 felt that the penalties in S 55.71(a) were excessive.
Commenters indicate that, as stated, uninten-tionally contributing to the compromise of an examination is a crime.
Comment 35-11 questions whether S 55.49 would be interpreted to mean that discussing the examination after it was administered would be considered a crime. This comment and comments 66-4, 74-17, 76-8, and 85-29 also re-quest that the limits of examination integrity and activities prohibited be more accurately defined in S 55.49, because activities such as practice examinations might be interpreted as cheating.
Also, the role of facility 19
licensees in enforcement should be identified.
Comment 28-19 indicates that S 55.49 is unnecessary.
Resolution:
In regard to S 55.71, the specific language used is "will-
. fully violates." In regard to examination review, the statement of considerations of the final rule makes clear that an examination could be discussed after it was administered and that practice examinations will be allowed.
More specificity about prohibited activities is un-necessary. NRC always has prosecutorial discretion not to take en-forcement actions in unclear cases or to take enforcement action against both facility licensees and operator licensees where both violated the regulations.
E.
Simulation Facilities 1.
Many comments express concern with the burdensome administrative procedure required for facility licensee initial and subsequent application for approval of simulation facilities, a.
Comments 19-44, 31-4, 31-9, 39-44, 45-4, 45-9, 46-4, 46-9, 62-4, and 62-9 suggest that the NRC should minimize the administrative burden on utilities to justify their use of simulation facilities.
Specifically, (1) for utilities with plant referenced simulators a commitment to industry standards is recommended, (2) utilitie, that use simulators referenced to plants other than their own should simply be required to justify how the learning objectives can be achieved with the simulator, and (3)' older plants seeking to use some other simulation device for the operating test should justify how learning objectives will be achieved.
One commenter suggests that specific mention of the possibility of exceptions for older plants should be stated in the rule.
b.
Comments 5-1, 5-11, 13-8, 23-11, 26-4, 27-1, 27-2, 28-1, 28-2, 28-17, 31-7, 31-8, 31-28, 32-2, 32-19, 33-5, 37-1, 37-4, 41-4, 45-7, 45-8, 45-28, 46-7, 46-8, 46-28, 47-14, 49-3, 49-4, 51-4, 52-21, 56-2, 59-3, 59-4, 60-3, 60-4, 61-1, 52-7, 62-8, 62-28, 65-3, 65-4, 69-2, 69-22, 69-23, 77-1, 77-4, 78-12, 78-3, 78-11, 82-5, 84-3, 84-4, 85-17, 85-21, 85-25, 90-1, 91-10, and 99-11 indicate that the requirements for testing, documentation, and certi-fication of simulators in the proposed changes to S 55.45 are unnecessarily restrictive and burdensome and are more extensive than what is required for the plants themselves.
The commenters recommend instead that the regu-lations and regulatory guides should require: (1) a utility's certification that its simulator meets the industry standard (ANSI /ANS 3.5), (2) the development of a procedure for keeping the simulator up to date with the
~
plant, and (3) the availability of test results at the utility, or (4) some other efficient process.
c.
Comments 37-14, 43-7, 81-3, and 85-22 indicate that the information,'
to be submitted to the NRC regarding simulation facilities, consists of extensive computer printouts and supplementary information.
- Further, collection and transmittal of the information is expected to be very costly, and the information is available for review by the NRC at any I
time, on-site.
The commenters expect that analysis of the information will require special expertise and extensive manpower by the NRC.
For l
these reasons, the commenters recommend that submittal of the data to the 20
NRC should not be a requirement, but rather the information should be available for on-site inspection.
d.
Comment 5-4 provides a markup of 6 55.45, which relies on licensee certification of the simulation facility, subject to NRC review / approval of the certification. This commenter and comment 37-15 suggest that the following are the advantages of this approach:
1.
Liability and responsibility remain with the facility licensee as the certifier subject to ultimate approval of the NRC.
2.
All information will be available for NRC audit.
3.
Data transmittal to the NRC, and NRC staff review time will be reduced.
4.
More reliable, realistic and effective operability testing.
5.
More time available for training.
e.
Comment 7-2 recommends certification by the facility licensee as is allowed in S 55.47(b) for candidates for licensing examinations, f.
Comments 5-6, 13-17, 35-9, and 87-13 recommend that certification and application should consist of:
1.
Description of the simulation facility.
2.
Description of annual performance test (comment 5-6 provides a recommended test).
3.
Statement that performance testing was conducted with a summary of the results of the testing and/or corrective action plans.
4.
Schedule for the next performance test.
5.
Schedule for the next annual submittal of certification by licensee.
6.
Statement that detailed documentation is available for audit.
g.
Comments 5-3, 67-10, 76-6, 87-3, and 87-12 indicate that certifica-tion of the simulation facility by the licensee provides the same credi-bility as the method in the proposed S 55.45 with much less administrative burden on the licensee and the NRC staff.
The commenters also indicate that licensee certification is consistent with the methods used by the NRC for medical examination records and operator license applications (S 55.23 and S 55.31).
Resolution: The major substance of these comments has been incorpo-rated into the final rule.
For facility licensees which use a simu-lation facility that is a plant-referenced simulator in accordance with the definition in 10 CFR 55.4 and meets the requirements of ANS 3.5-1985, as modified by RG 1.149, certification to the NRC by the facility licensee will be permissible.
For other simulation facilities, NRC approval of the simulation facility based on the facility licensee's application will be required.
For all simulation facilities, detailed documentation of performance testing may be maintained by the facility licensee for N'lC review, and need not be transmitted to NRC.
21
2.
Coments 5-11 and 87-11 recommend that the title of 9 55.45(b)(3) be changed to " Initial Licensee Certification of Simulation Facilities" because their opinion is that simulation facility certification responsi-bility should be with the facility licensee not the NRC.
Comment 5-11 provides proposed change pages to S 55.45(b) to reflect this certification approach.
Resolution:
$$55.45(b) has been rewritten, and the titles of the paragraphs have been modified.
3.
Comment 56-7 ind :ates that S 55.45 is overly complex in its structure and recommends dividing it into two sections:
$ 55.45, " Operating Tests-Content," and S 55.46, " Operating Tests-Implementation."
Resolution:
Noted.
10 CFR 55.45 has been simplified as discussed in paragraph E.1.g above.
The structure of S d5.45 has been somewhat modified.
4.
Comment 13-18 indicates that an annual report that documents changes to the simulation facility, changes to the reference plant that would affect the simulation facility, and the results of tests conducted to ensure the performance capability of the simu!ator with respect to these changes should be sufficient to maintain an approved simulation facility.
Resolution:
Noted.
The requirement for an annual report has been eliminated.
5.
Comment 30-7 indicates that the application should only state that the simulation facility is sufficient to meet the utility's training and testing needs.
Resolution:
Noted.
This level of detail would not permit the Com-mission to have assurance that the simulation facility is appropriate for the partial conduct of operating tests.
6.
Several comments indicate reapproval of a simulator facility is not necessary.
a.
Comment 32-4 indicates a perception that S 55.45(b)(3)(v)(c)(1) and (c)(2) taken together with S 55.45(b)(3)(vii)(c) would require repetitive submittals of the same test results.
l b.
Comments 26-6, 31-30, 45-30, 46-30, 49-5, 59-5, 60-5, 62-30, 65-5, and 84-4 suggest that the portion of S 55.45(b)(3) on application renewals be changed to read "... documentation of all performance tests conducted since the last annual report."
c.
Comment 76-7 recommends that the S 55.45(b)(vii) requirement for re-application for simulator approval should be abandoned because it provides no additional safeguards and is an administrative burden.
The commenter indicates that this position is supported in NUREG-0885 (issue 3).
d.
Comments 37-16, 52-23, 52-24, and 85-27 indicate that approval of a simulation facility on a 4 year basis is an unnecessary administrative 22
requirement.
The commenters recommend that the continued adequacy of simu-lators should be based on their use in training and operator examinations and through a review of the configuration management system; further ap-plications should be required only if a facility licensee changes simula-tion facilities.
Resolution:
Substantially agree.
The regulation has been changed to delete the requirement for facility licensees to reapply for approval of a simulation facility every 4 years.
7.
Comments 56-1 and 85-26 note the following concerns with the process:
a.
The submittal of a plan in S 55.45(b)(2) is redundant with the application for approval.
Also, future facility licensees would apparently not be required to submit this plan.
b.
The annual report essentially is a renewal application and should be eliminated or replaced with a requirement to submit information on significant changes as they occur.
c.
The standard to be used by the NRC in approving simulation facili-ties is too vague.
Resolution:
(a) Disagree.
The plan in S 55.45(b)(2) (now S 55.45(b)(2)(1) and (b)(3)(i) for facility applicants) requires the utility to submit a plan, in accordance with which it will develop a simulation facility and apply for approval of that simulation facility.
The actual application for simulation facility approval, in S 55.45(b)(4)(1) is not part of the plan.
Future facility licensees have been addressed in the final rule.
(b) See resolution at paragraph E.6 above.
(c) See Enclosure C, resolution at paragraph III.B.4.c.
8.
Many comments address the burden of undertaking periodic performance tests, and several divergent recommendations were made about the performance test cycle.
l a.
Comment 30-6 indicates that the requirements of 9 55.45(b) would necessitate the creation of an entire department to test the simulation i
facility and that very little time would remain for actually using the simulator.
b.
Comments 32-4, 41-5, 51-5, and 32-4 recommend that S 55.45(b)(3)(i)(c) not require a detailed schedule for performance tests each year, but rather a list with a commitment to conduct 25% i 5% of the tests each year with 100% in 4 years, or some other less prescriptive approach.
c.
Comments 18a-1, 31-29, 45-29, 46-29, and 62-29 indicate that a re-quirement for 25% of all performance tests to be performed each year is excessive. One commenter indicates that it makes little sense to perform more tests on the simulator than on the plant itself.
23
~ d.
Coment 3-1 recommends that performance tests for simulators be con-ducted each year to demonstrate the acceptability of the. simulator perfor-mance.
The commenter estimates that such a_ test could be completed in 1-
- to'2 days.
e.
Coments 36-21, 72-2, and 72-9 recommend deleting 9-55.45(b)(3) in its entirety because these issues are unfit for the rigor of regulation.
The commenter further indicates that the proposed rules are unrealistic-and very costly in simulator time required to accomplish such requirements and unnecessary.
f.
Coments 82-2 and:85-23 indicate that a complete simulator perform--
ance test package requires about-40 shift weeks to complete and feel.that a requirement to perform 25% of these each year is excessive. The.
commenters recommend instead that the portions of the simulator affected by modification be tested, as required.
The comenters point out that software needs to be reverified only when it is altered.
g.
Coments 28-3 and 56-3 recommend that all of 9 55.45(b) except (b)(1) and (b)(3)(c)(iii) be deleted and that RG 1.149 endorse performance testing and documentation guidelines found in Section 5.4 and Appendices of ANS 3.5.
h.
Coments 28-4 and 56-4 indicate that endorsing Section 5.4 of ANS 3.5 is sufficient and that requiring annual testing is an unnecessary admin-istrative requirement.
i.
Comments 30-8 and 91-13 indicate that performance testing should only be required when changes are made to the simulation software; then only to the extent necessary to ensure that the changes have been properly made.
j.
Comments 41-5 and 51-5 recommend that complete performance testing be required once every 4 years, rather than 25% per year, to provide flexibility in sche.Juling.
Resolution: The Comission believes that certain performance tests relating to abnormal and emergency events should be performed on a regular basis. The Commission has endorsed in RG 1.149, the appli-cable paragraphs and Appendices in ANSI /ANS-3.5, 1985. The Commission i
has specified that these performance tests be performed over a 4 year cycle, approximately 25% per year, to achieve a balance between the workload of NRC's simulator reviewers, the burden of undertaking such testing by the facility licensee, and providing assurance that a simu-t lation facility remains acceptable over time.
[-
9.
Coment 87-12 recommends changes to S 55.45 to emphasize that the perfor-l mance test is a one-time event.
Resolution: The comenter misinterpreted S 55.45.
The performance test is not a one-time event.
- 10. The Commission had requested specific public coment on the nature of per-l formance tests needed to adequately assess simulation facility adequacy I
24 i
i
,--~ __,_._
b
.c and on the~ method by which such performance. tests should be selected and scheduled. 'Several comments address these issues.
Comment 91-12 recommends that license examiners verify simul [ tor 2
a.
. performance as part of operator examinations rather than require pe'rform--
ance. testing.
b.
Comment:78-13 suggests that assurance of adequate ' simulator perform-r ance.is best provided by. observation during annual training and by cogari-son of simulator performance to actual plant perforrance.
Resolution: Agree in part. Although observation by experienced pe'r'-
sonnel is-a' valuable part of simulator performance assurance, it cannot substitute for an objective, quantifiable performance test.
The level of fidelity and time scale for performance measurement specifiec in ANS 3.5 is not amenable to human observation.
It is -
agreed that comparison of simulator performance to actual plant performance is an excellent way to assure simulator adequacy.
Comment 35-10 provides a' suggested performance testing program for a c.
. simulation facility.
4 Resolution: Noted.
d.
Comment 53-8 recommends no performance testing because " testing is not an acceptable measure of performance assurance."
Resolution: Noted.
e.
Comments 27-4, 31-11, 36-6, 45-11, 46 11, 53-9, 62-11, and 69-25 in-dicate that no performance testing should be required.
Resolution:
Noted.
See paragraph II.E.8 above, f.
Comment 13-19 indicates that the selection be left to the facility licensee to indicate in the initial application.
Resolution: Agree.
That is the intent of the regulation, n
g.
Comment 32-5 indicates that the RG 1.149 statement, "every malfunc-tion condition that can be introduced into the simulator by the simulator operator should be tested if such malfunctions may be used in the conduct of operating tests," unfairly penalizes utilities that procure and main-tain state-of-the-art simulators that have the capability to simulate more malfunctions.
Resolution: Noted.
The Commission recognizes that a requirement to perform additional performance tests imposes an additional burden.
The capability of a simulator to perform additional malfunctions is of little value, however, unless it can be demonstrated that those mal-functions are faithfully simulated. Worse, the simulator exercise of a low fidelity malfunction may have adverse effects on operator per-formance in the plant.
The Regulatory Guide has been changed to endorse the list of malfunctions specified in ANS 3.5.
a 25
i o
s
}
f y
5' q
- ~
h.
~ Comment 78-14 recommends that the selection, scheduling, and perfor-i mance of simulater performance tests be at the. discretion of the facility Nicensee and thAt..NRC should limit its participation to' auditing facility records.'
i b
i Comment 32-6 recommends that performance testing be tied to the J
manipulations specified in 5 55.59(c) and suggests' specifics with respect.
to the frequency of testing for.each manipulation.
Resolution:
Noted.
The Regulatory Guide has been changed to endorse the list of malfunctions'specified in ANS 3.5.
c s#
~
ii 11.
Several comments suggest adoption of a configuration management system in lieu of performance testing.
3 s
a.
Comments 27-3, 31-10, 37-15, 45-10, 46-10, 62-10, 69-24, and 76-5
[ ", ' ~
\\'
recommend that rather than performance testing, a configuration management
' l#
system be required.
Coment' 36-5 provides the same recommendation supple-w Jv 4,
mentedwithgeriodicauditsbytheNRC:
b I
g i
b.
Commerts :i-2, 5-7, and 87-7 indicate that simulator fidelity can be-l more effectively achieved by a comb % ration of simulator configuration con-trol and periodic performance testing (Appendix B of proposed revision to ANS3.5L3 One,::ommenter provides a proposed simulator configuration con-tro)progr4eandaperiodicperformarcetestingprogram.asenclosuresto I
thercomments.
The comenter indicates =that these two program.s would pro-
[
vid4 a' reduced burden on the facility licensee and an. increased assurance y
of *performar,ce capability compared to proposed NRC requirements.
1 l
,t.
Comment 5;.-22 recomends that an in-depth study be undertaken of i
the essential ' components of an effective configuration management system F
before estabTishing such a requirement.
h' 1-Resolution:
Noted. While the Commission recognizes the benefits of m
an effective configuration management system, its responsibility is to ensure that simulation facilitier, are appropriate for the partial conduct of operating tests, and not to dictate the manner in which a i'
utility develops the capability to provide that assurance.
12.
Several comments address the NRC approach to review and approval of simulation facilities.
1 a.
Comment 77-5 suggests that the majority of changes to the simulator i
will follow Commission-approved plant changes and that it is redundant to require approval of these same changes for the simulator.
Resolution: Disagree.
Withcut requiring that changes be made to a simulation facility, there is no assurance that any plant changes i
will be incorporated 'into that simulation facility.
t.
b.
Comments 19-5, 19-6, 39-5, 39-6, and 80-3 indicate a need to develop i
safety-related criteria for each type of simulation facility, particularly non plant-referenced simulators.
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Comment 85-24 indicates that S 55.45(b)(3)(iii) provides no guidance c.
as to " appropriate use," so that there is no assurance of approval.
d.
Comment 67-13 questions if a plant-referenced simulator is not used, what data should be submitted in response to S 55.45 (b)(3)(vii) since ANS 3.5 performance data is based on a plant-referenced simulator.
The commenter further indicates that that level of data is not necessary for a non plant-referenced simulator.
e.
Comment 85-18 indicates that S 55.45(b)(2) is unrealistic in that it permits only full compliance or some unspecified " acceptable alternative method for complying" without providing any guidance or objectives upon which to measure acceptability.
The commenter further indicates that I
blind reference to ANS 3.5 is inappropriate because many portions of that standard are not required to permit a simulator to be effectively used as a training and examination tool.
Resolution:
It is the Commission's intent that a plant-referenced simulator that meets the requirements of ANS 3.5 as modified by Regu-latory Guide 1.149 may be used in the conduct of operating tests based on a certification submitted by the facility licensee.
Detailed guid-ance, including approval criteria, will be developed by the Commission and made available to all facility licensees before the time when simulation facility audits will be conducted.
Such guidance will not impose any new requirements.
Equivalent guidance will be developed for simulation facilities other than plant referenced simulators.
It should be noted that ANS 3.5 is an industry consensus standard endorsed by NRC with certain exceptions.
Endorsement of this standard is more efficient and less burdensome than NRC development of its own independ-ent guidance.
13.
A number of comments criticize the time schedules established in S 55.45 as being e=asonably short.
a.
Comments 5-5, 13-16, 19-4, 19-43, 23-9, 31-27, 35-8, 36-3, 36-20, 39-4, 39-43, 41-3, 43-7, 45-27, 46-27, 47-13, 51-3, 52-19, 52-20, 62-27, 67-9, 67-11, 78-11, 81-2, 85-19, 85-20, and 87-10 indicate that the time require-ments in S 55.45(b) were unrealistically short.
The 120-day requirement for plan submittal was not felt to provide sufficient time for investigating options, estimating costs, and validating the ability to meet the plan.
A period of 1 year is recommended.
The 3 year date for having an approved simulation facility operational also was judged to be an unreasonable time in which to prepare a specification, procure and fabricate a simulator, and conduct acceptance testing; recommendations for a reasonable time ranged from 4 to 6 years.
Resolution: Agree.
The 120-day requirement for plan submittal has been changed to 1 year and the 3 year date for an acceptable simula-tion facility has been changed to 4 years.
14.
Several comments express concern with the harshness of the penalty to be invoked in the event of the unavailability of a simulation facility for the conduct of examinations.
27
4 Comment 67-12 indicates that the regulations should provide for an a.
appeal process for simulation facilities that are not acceptable to the NRC.
Resolution:
It is the Commission's intent that approval of simula-tion facilities will be addressed, if needed, on a case-by-case basis.
The preamble to the final rule will address this issue.
b.
Comments 23-10, 31-31, 31-44, 32-20, 45-31, 45-44, 46-31, 46-44, 46-81, 62-31, 62-44, and 85-20 take exception to a portion of 9 55.45(b)(3)(x),
which states:
"If the facility licensee subsequently fails to obtain approval for its simulation facility, or if the Commission withdraws its approval in accordance with [1] (b)(3)(xii) of this section, the Commission will cease to conduct operating tests for that facility licensee's reference plant." The commenters indicate that this would result in the facility ceasing operations because of technical specifications and felt that this accorded this provision an importance that has not been justified.
Several of the commenters outlined proposed provisions for allowing a licensee to use another simulation facility and further recommended that the regulations provide for alternatives for the operating test in the event of loss of the simulator (e.g., fire, flood, etc.).
Resolution:
It is the Commission's intent that every facility licensee have available a simulation facility that meets the Commission's regu-lations, and that, once available, the simulation facility be main-tained and upgraded as needed to maintain its acceptability.
The Commission recognizes that unique circumstances may occur from time-to-time on a plant-specific basis that may result in a simulation facility becoming temporarily unacceptable for the conduct of operat-ing tests.
It is the Commission's intent to address such situations on a case-by-case basis.
15.
A number of comments suggest that simulation facility reviews be per-formed by licensing examiners, a.
Comments 26-5, 31-4, 45-4, 46-4, 49-3, 59-3, 60-3, 62-4, 65-3, 84-3, 95-4, 98-4,111-4.112-4,118-4, and 128-4 indicate that any simulator audits or reviews performed by the NRC should be conducted by NRC licensing examiners because they are the individuals who will conduct operating tests using these simulators.
Resolution: Noted.
The review or audit of a sophisticated simulator requires expertise in several disciplines.
A study is presently being conducted for the NRC, one purpose of which is to define the expertise needed by members of a simulation facility evaluation team.
1 It is likely that the discipline of licensing examiner will be rec-l ommended for inclusion in such a team.
l 16.
Several miscellaneous comments to S 55.45 were submitted.
a.
Comment 5-6 indicates that footnotes in S 55.45(b)(3)(i)(B),
S 55.45(b)(3)(iii), and S 55.45(b)(3)(ix) referring to RG 1.149 violate the traditional hierarchy of regulatory documents.
i l
l l
28 l
Resolution:
These footnotes were included in the Federal Register notice for the information of the reviewers.
They will not be included in the final rulemaking/ regulations.
b.
Conment 9-13 indicates a typographical error in 9 55.45(a) in that "and understanding" should read "an understanding."
Resolution:
Corrected.
c.
Comment 2-8 recommends that S 55.45(b) be included in a new part of 10 CFR (not in Part 55) because Part 55 is entitled " Operator Licenses" and S 55.45(b) is simulator information/ requirements.
Resolution:
S 55.45(b) deals with characteristics of a simulation facility that will be required for administering the operating test portion of R0 and SR0 licensing examinations.
For that reason it will remain in Part 55 of 10 CFR.
d.
Comments 21-12 and 21-16 recommend that the NRC issue a policy state-ment requiring operating tests to be administered on a " simulation facil-ity" rather than implementing regulations.
The commenter indicates that this approach would mean there would be no requirements for reports, thus minimizing paperwork.
Resolution:
Disagree.
A policy statement cannot include requirements.
The rule has been. rewritten to minimize the reporting requirements.
e.
Comments 19-9 and 39-9 indicate an opinion that, with respect to simulators, S 55.45 and RG 1.149 are attempting to regulate well beyond the criteria necessary to ensure safe operations or evaluation.
Resolution:
Disagree.
f.
Comments 21-11, 26-3, and 84-2 express concern that an individual might fail an operating test because of the individuals with whom he/she is assigned, and recommend that an appliccnt be judged solely on his/her own abilities.
Resolution:
Agree. This is addressed in Examiner Standards.
g.
Comment 37-13 indicates that S 55.45(b)(3) shows inadequate under-standing of current industry practices and standards for simulators and the administrative and technical burdens associated with the proposed rule.
Resolution:
Noted.
h.
Comment 36-17 suggested specific wording in S 55.45 with respect to operating tests for special operators.
Resolution:
Reference to special senior operators has been deleted in 5 55.45.
29
i.
Although Comment 7-3 was provided in response to the subject ques-tion, the commenter's primary point is that knowledge of Technical Specifications should not be compulsory for an R0.
Resolution: Noted.
Commenter misunderstood this question regarding simulators.
j.
Comment 7-4 recommends a random selection (the commenter, although responding to the question, apparently misinterpreted the question as applying to operator requalification rather than simulator performance testing).
Resolution: Noted.
k.
Comments 74-3 and 85-28 caution the NRC to ensure that any regulations with respect to simulators do not discourage improvements as advances in simulation technology are made.
Resolution: The regulations and regulatory guidance proposed have been written specifically to encourage improvements and advances in simulation technology.
This belief served as one impetus for the term "another simulation device" as used in 10 CFR 55.4.
- Further, the discussion section of RG 1.149 refers to " rapidly changing tech-nology in the simulation industry" and suggests that this might lead a facility licensee to seek alternative ways to meet the requirements of 10 CFR 55.
1.
Comment 76-4 expresses concern that the NRC's simulation facility requirements provide flexibility for simulators already in existence or under construction.
The commenter indicates that as the rule was issued for comment, for a simulator that was partially completed the utility would be required, in effect, to halt construction pending NRC approval of the plan by which the facility was being developed.
Resolution: The Commission has provided flexibility for simulation facilities in existence or under construction by allowing 1 year from the effective date of the rule for a plan to be submitted for simulation facility development and use and 4 years for actual availability of a simulation facility.
Further, all simulators known to be under development or planned, are believed to have been designed to ANS 3.5 standards, and thus should require only a certi-fication from the facility licensee to this effect.
F.
Licenses - Subpart F 1.
Many commenters question the issuance of special senior operator licenses.
a.
Comments 21-7, 28-6, 30-10, 31-2, 31-5, 33-6, 37-2, 42-7, 45-2, 45-5, 46-2, 46-5, 62-2, 62-5, 74-2, and 91-4 question the statutory authority of the Commission to issue special senior operator licenses.
b.
Comments 19-16, 19-17, 19-18, 19-21, 19-23, 19-24, 19-29, 19-34, 21-16, 23-2, 28-7, 28-13, 31-2, 31-34, 39-16, 39-17, 39-18, 39-21, 39-23, 39-24, 39-29, 39-34, 43-4, 45-2, 45-34, 46-2, 46-34, 47-3, 52-4, 61-2, 62-2, 62-34, 30
69-1, 72-1, 78-8, and 90-2 indicate that the present NRC requirements in NUREG-0737 concerning certification of instructors, are sufficient and that licensing of these instructors-is unnecessary.
c.
Comments 31-2, 31-24, 33-6, 37-2, 41-2, 43-1, 45-2, 45-24, 46-2, 46-24, 51-2, 62-2, 62-24, 72-1, 72-6, and 90-2 indicate that the special senior operator license should not be implemented because INPO accreditation of the facility training programs includes instructor training and qualification procedures.
The commentors also indicate that the special senior operator license for instructors was inconsistent with the NRC's Policy Statement on Training and Qualifications.
Comment 61-4 indicates that the regulations should be consistent with the Policy Statement on Training and Qualification.
d.
Comments 28-8, 31-14, 32-9, 37-5, 45-14, 46-14, 47-3, 52-1, 62-14, 67-3, 71-2, 73-2, and 74-4 suggest that the definition of special senior operator be modified to delete instructors.
Resolution:
Although the Commission has the authority under Sec-tion 107 of the Atomic Energy Act to issue special senior operator licenses, special senior operator licenses have been deleted from the final rule.
This action is in recognition of the industry commitment to INPO accreditation of training programs, which includes instructor training, qualification and evaluation, and is in keeping with the intent of the " Commission Policy Statement on Training and Qualifica-tions of Nuclear Power Plant Personnel," dated March 20, 1985.
Indus-try efforts in implementing instructor training, qualification and evaluation programs will be monitored as directed by the Policy Statement.
Until a program is accredited, current requrements will continue for instructor certification.
Moreover, senior operator licenses limited to fuel handling will continue to be issued as they are currently.
However, since INP0 accreditation includes instructor evaluation, current NRC instructor certification will not continue.
2.
Many comenters make specific suggestions regarding the issuance of special senior operator licenses.
These comments ranged from the duration of the license, the qualifications of holders of the license, to the content of the requalification program for special senior operators.
Comments 1-1 and 64-2 recommend that the issuance of senior operator a.
licenses be limited to people who imediately supervise reactor operations and that licensing others who do not operate on a daily basis is counter-productive. Coment 9-2 questions whether the special SR0 license for instructors would be differentiated from that of a fuel handler.
b.
Coments 22-3, 22-5, 26-13, 32-24, 35-12, 37-9, 42-3, 59-12, 60-12, 65-12, 72-5, 72-8, 72-10, 78-7, and 84-11 suggest that sections in 10 CFR 55 include a specific listing of what medical, written examinations, operating tests and requalification programs would be required for fuel handlers and instructors. Specific language changes are recommended by comments 13-10, 19-15, 19-27, 19-46, 19-49, 19-50, 20-2, 28-2, 28-20, 30-19, 36-13, 36-17, 37-8, 39-15, 39-27, 39-46, 39-49, 39-50, 46-79, 46-82, 46-84, 46-85, 52-25, 67-5, 67-17, and 76-9.
31
c.
Comments 19-26, 22-2, 30-12, 31-20, 36-12, 36-14,.39-26, 45-20, 46-20, 52-9, 62-20, 72-4, 74-8 suggest that the medical requirements of 10 CFR 55 be. deleted for special SRO instructors.
d.
Comments 13-2,19-22,,30-3,30-4,;31-32,35-13,35-14,39-22,45-32, 46-32, 52-26, 62-32, 78-9, and 81-5 question the relationship of special senior licenses to current senior operators or instructors.
Comments 2-3,
_9-15, 19-15, 31-34, 34-2, 39-15, 45-34, 46-34, 62-34, 72-7, 72-11, 72-13,'
72-14, 72-15 and 78-8 discuss problems with the proposed special senior operator requirements.
Comments 14-12, 27-8, 30-2,-31-5, 32-10, 36-9, 37-1, 41-2, 42-8, 45-5 46-5, 47-2, 48-2, 51-2, 62-5, 69-3, 71-1, 71-4, 72-1, 72-3, 73-1, 73-4, 78-5, 78-6, 79-1, 85-4, 87-1, 87-2, and 131-4 also dis-cuss implementation problems for special licenses.
e.
Comments 46-93 and 46-95 recommend dropping the words "special senior operator" from 10 CFR 50.74.
4 Resolution: These comments are noted.
Since the Commission is delet-ing the implementation of the special senior operator license from the final rule, no further resolution is necessary.
3.
Several commenters support the issuance of special senior operator licenses.
Comments 8-7, 16-3, 17-2, 22-6, 26-8, 49-7, 59-7, 60-7, 65-7, 82-6, 84-6, and 84-7 support additional staff licenses.
Comment 34-1 supports requiring requalification examinations for instructors.
Resolution: These' comments are noted.
l 4.
Comment 35-15 requests a definition of " actively performing the duties of,"
as used in S 55.53(e).
i Resolution: " Actively performing the functions of an operator or senior operator" has been defined in S 55.4, " Definitions," to mean an individual who takes responsibility for and carries out a position on the shift crew that requires the subject license as defined in the facility's Technical Specifications.
At a minimum, this will consist of seven 8-hour shifts or five 12-hour shifts per calendar quarter.
5.
Comment 47-17 suggests the substitution of satisfactory participation in an approved requalification program in lieu of reexaminations or other demonstrations of competence, outlined in S 55.53(e).
6.
Comments 8-5, 13-11, 13-32, 23-13, 31-35, 35-16, 41-6, 45-35, 46-35, 51-6, 62-35, 77-7, 81-6, and 85-30 state that a utility should not have to wait for NRC concurrence before returning an operator to licensed duties.
This L
limits the flexibility of the facility licensee.
The determination of satisfactory knowledge should be in accordance with approved administrative and training procedures and in the purview of the license.
Resolution:
It is not intended that NRC concurrence be required before returning each operator to licensed duties.
Rather, the licensee will be required to complete a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of shift functions under the direction of the operator or senior operator in the position to which that individual will be assigned.
32
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7.
Comments 8-3, 8-4, 24-2, 28-21, 28-29, 30-20, 30-22, 31-36, 31-39, 33-7, 37-17, 43-10, 45-36, 45-39, 46-36, 46-39, 52-27, 62-36, 62-39, 69-15, 71-19, 73-19, 74-18, 82-7, and 91-6, strongly disagree with the intent of S 55.53(f) and S 50-74 in that the issue of certifying need and utilization of licensed personnel in positions within the facility should be a facility's management prerogative.
Resolution:
Disagree.
S 55.53(f) does not contradict management's prerogative to use staff within license conditions.
8.
Comments 71-18 and 73-18 recommend rewriting the first sentence of S 55.53(f) [now S 55.53(g)] to state:
"The facility licensee shall notify the Commission within 30 days of the following."
Resolution:
Noted.
The facility's responsibility is covered in 5 50.74.
9.
Comment 72-12 indicates _that the requirement for "the facility licensee" to " notify the Commission within 30 days," etc., is a burden on the -
licensees and serves no apparent purpose.
Resolution:
This documentation is needed by the NRC as data to support the facility's fulfillment of S 50.54(m) requirements with respect to licensed operator / senior operating staffing levels.
10.
Comment 80-6 recommends removal of the words "for a period of four months or longer" from 9 55.53(e).
Resolution:
Agree.
This phrase has been deleted.
11.
Comments 13-12, 16-4, 19-47, 31-37, 35-17, 37-18, 39-47, 41-7, 45-37, 46-37, 47-18, 51-7, 62-37, and 74-19 suggest S 55.53(f)(4) be deleted as ambiguous or further defined.
If meaningful legislation in regard to crime reporting is a concern, then the crime list should be definitive and provided for public comment.
Resolution:
Agree.
S 55.53(f)(4) has been rewritten as S 55.53(g).
Xs to criminal behavior, NRC is interested in any and all convictions of a licensee for felony.
The NRC considers that there may be a rela-tionship between criminal convictions and job performance.
12.
Comments 6-1, 82-8, 87-14, and 91-7 commend the extension of U.a license renewal interval to 5 years as a step in reducing the paperwork burden on the facility and the Commission.
Comments 26-9, 26-10, 49-8, 49-9, 53-4, 59-8, 59-9, 60-8, 60-9, 65-8, 65-9, 84-7, and 84-8 indicate that the proposed S 55.55 that changes the license renewal period to 5 years is a marked improvement, but question why licenses need to be renewed at all. The commenters indicate that renewal is purely an administrative requirement that did not help determine the continued suitability of an operator for licensed activities.
Resolution:
Noted.
This renewal information is necessary for NRC documentation of licensed reactor operators / senior reactor operators.
33
13.
Comments 14-3, 19-48, 23-3, 32-21, 35-19, 36-22, 39-48, 47-19, 54-2, 67-16, 74-20, 76-10, and 80-7 indicate that the license expiration period (every 5 years) and the medical examination requirement (every 2 years) should be made to coincide.
The commenters recommend that the license expiration be every 6 years or that the previous medical examination be accepted with the license renewal application.
Resolution:
Agree.
The license expiration has been changed to 6 years.
14.
Comment 46-83 recommends that S 55.55(b) be revised to also allow filing an application by telecopy or electronic medium to expand the methods to be state-of-the-art.
Resolution:
Documentation of the filing, including the date, is needed.
NRC is investigating the possibility of alternative communi-cations in this context and for other filings as well.
Regulations for such alternatives will be promulgated separately as appropriate.
15.
Comment 74-21 indicates that in S 55.57(b)(1) " medical condition and general health" need clarification.
Resolution:
The term is considered clear enough for the regulation.
Further clarification is provided in ANSI /ANS 3.4-1983.
-G.
Requalification 1.
Many comments were received regarding the relationship of the requalifica-tion program requirements and INPO accreditation of performance-based training programs.
a.
Comments 19-14, 19'51, 19-52, 19-53, 19-54, 28-2, 28-22, 28-23, 31-40, 32-23, 33-8, 36-23, 36-24, 37-19, 39-14, 39-51, 39-52, 39-53, 39-54, 45-40, 46-40, 47-20, 47-21, 47-22, 47-23, 62-40, 71-20, 71-21, 71-22, 73-20, 73-21, 73-22, 80-8, 80-9, 80-10, 80-11, 81-7, and 82-9 indicate that S 55.57(b)(2)(ii) and (iii) should not require NRC approval of the requali-fication program because S 55.59 defines the requirements for the program, and these programs will be accredited by INP0.
Commenters indicate that NRC always can audit the program if concerns arise. Some commenters indi-cate that NRC approval of requalification programs was inconsistent with the Policy Statement dated March 20, 1985.
b.
Comment 52-28 recommends that S 55.57(b)(2)(iii) either define the t
content of an operating test as it applies to S 55.59 or delete the requirement.
Comment 91-8 indicates that the use of learning cbjectives developed c.
from a task analysis should be permitted for requalification examinations once the utility has performed the analysis.
d.
Comment 21-13 recommends that in S 55.59(c) the remainder of the sec-tion after " systems approach to training" be deleted because the program will now be developed from the systems approach to training.
34
Coment 23-15 requests clarification on which of the "following re-e.
quirements";are met by using a systems approach to training (the remainder of 8 55.59(c) or just the content of lectures or on-the-job training).
f.
Comments 31-41, 45-41, 46-41, 48-9, and 62-41 request that S 55.59(a)(2) be expanded to indicate that the requalification' examination will be based upon the facility's performance-based requalification program and recent operating events of significance.
g.
Comment 85-31 provides a proposed replacement for S 55.59 to facilitate implementation of systematic approaches to training.
p Resolution:
NRC approval of requalification programs will remain as a requirement, in keeping with the NRC's mission to protect the public health and safety. A list of content areas will be added to S 55.59 E
to clarify the issue of examination and operating test requirement.
4 Appendix A is intended to be replaced by a systems approach to train-ing, if implemented at the facility.
In its Final Policy Statement on Training and Qualification of Nuclear Power Plant Personnel, the -
Comission endorsed industry-accredited programs as performance based.
1 2.
Many coments suggest specific changes to S 55.59(c), "Requalification Program Requirements." These comments relate to the program requirements specified for a program if it is not developed using a systematic approach to training. Comments in this category include:
9-18, 9-19, 9-20, 9-21, 9-22, 9-23, 13-15, 14-15, 19-56, 19-57, 19-58, 21-14, 26-11, 26-12, 28-24, 28-25, 30-21, 31-42, 31-43, 31-44, 32-25, 33-9, 33-10, 36-25, 39-56, 39-57, 39-58, 45-42, 45-43, 45-44, 46-42, 46-43, 46-44, 46-87, 46-90, 49-10, 59-10, s
59-11, 60-10, 60-11, 62-42, 62-43, 62-44, 65-10, 65-11, 67-19, 69-13, 69-14, 76-11, 82-10, 82-11, 84-9, 84-10, 85-31, and 100-1.
Resolution:
A list of content areas for the comprehensive written requalification examination and operating test has been added to S 55.59.
S 55.59(c) will remain with an "or" to provide an interim measure from the current Appendix A (detailed verbatim as S 55.59(c))
until each facility implements a systems approach to training. More-over, if a facility does not implement a systems approach to training and for test and research reactors, current requirements will continue.
3.
Comments 9-17, 13-13, 14-13, 31-38, 41-8, 43-11, 45-38, 46-38, 51-8, 62-38, 77-8, and 91-9 request a definition in S 55.59 of " actively and extensively engaged" and indicate that this term did not apply to managers, engineers, and instructors.
Resolution:
" Actively and extensively engaged" has been deleted from the final rule.
Therefore, active participation in the facility's requalification program, including attending all requalification training and satisfactorily completing requalification examinations, constitute the basic requirement to maintain a license.
- However, before assuming licensed duties, the conditions of a license in S 55.53(e) must be met.
4.
Comments 2-4, 2-5, and 2-6 request that in S 55.59 the word " annual" be deleted from the requalification program and requalification examination 35
so that flexibility would be provided to cover material that is beneficial but that does not fit within an annual cycle because of other required topics.
The comenters note that S 55.59(c)(1) discusses a 2 year re ification program cycle and 'ecommend that all~ references to " annual" qual-be deleted and that the 2 yet-cycle serve as the basis for this requalifica-tion requirement.
Comments 19-55, 39-55, 47-24, 69-12, 71-23,.and 73-23 t
recomend that the 2 year cycle be dropped in-favor of a continuous sched-ule. The comenters indicated that 2 years was based on license renewal schedules, which are proposed to be. extended to 5 years.
Resolution:. Agree.
More flexibility is necessary. Thel frequency of.
the requalification. written examination has been changed.to a maximum -
of every.2 years, and to every year for the operating test.
The re.
qualification program must be conducted for a continuous period not to exceed 24 months.
The specific cycle will be approved for each facility by the NRC.
5.
Coment 40-4 questions whether it is the -intent of S 55.59 to impose tighter requalification program requirements for research, test, and training reactors. The commenter provides as an example, the wording of 9 55.59(a)(1),
l which would appear to render invalid the biennial written requalifications -
examinations that are currently utilized by these factors.
Resolution:
It is intended that S 55.59(C)(7) be interpreted that-current requalification requirements for research, test and training.
reactors be continued.
6.
Coment 67-18 indicates that in S 55.57(b)(2)(iii) the requirement for-passing annual examinations is redundant because S 55.57(b)(2)(ii) already 4
requires the candidate to successfully complete the annual requalificationL program.
7.
Coment 52-29 recommends that in S 55.59(a)(2) the words "a licensin'g or"
-be inserted in front of "requalification examination" to allow credit in-
.the requalification program for passing a full licensing examination during the year preceding the requalification examination. Comment 52-30 su
.that the requalification examination be less comprehensive in scope. ggests Resolution:
Disagree.
Licensing and requalification programs and examinations are not intended to be equivalent.
The requalification examination and operating test should be comprehensiva examinations to evaluate an individual's maintenance of proficiency in all areas of license responsibility.
8.
Coment 14-14 questions why documentation of a licensed operator's requal-t ification be retained until the operator's license is renewed.
The commenter recomends that the records be required to be maintained for 4 years.
Resolution: As a policy matter, records are generally maintained until they are supplied. NRC considers this a valid reason for the requirement.
An additional reason is that this requirement supports enforcement action needs.
36 l
(
I 9.
Coments 53-5 and 55-2 recommend deleting the requirement for passing an annual'requalification examination.
Comment 53-5 notes that other pro-fessions (engineers,_ doctors,. pilots, lawyers, etc.) are not required to retake academic requalification examinations periodically.
Resolution:
Disagree. Although-it is inappropriate to compare dis-similar professions, t'e professions above do have reexamination /
recertification requirements which, in some cases (e.g., pilots),
require reexamination and in others require participation.in continu-ing training programs.
10.
Comments 68-1 and 68-2 indicate that further auditing of operator training-programs and the administration of requalification examinations by the NRC-was creating undue pressure' on licensed personnel and asks the NRC to re--
consider implementation of this requirement.
Coment 80-10 indicates that administration of requalification examinations by the NRC is unnecessary.
Comment 13-14 indicates that NRC examinations should be in lieu of facility examinations.
I Comments 32-3 and 87-15 indicate that for INP0-accredited programs, NRC-administered requalification examinations, if administered at all, should be only an operating test.
Resolution: The NRC has always had the option of administering requalification examinations, this change only clarifies the point.
While NRC administration of requalifica. tion examinations may place additional stress on some licensees, it is not agreed that the stress is undue. NRC-administered examinations have, on several occasions, identified serious weaknesses that had not been identified by facil-t ity licensee requalification examinations.
Moreover, NRC-administered requalification examination are in lieu of facility examinations.
The Commission believes that an NRC administered examination for license renewal provides assurance that an operator or senior opera-tor can operate the controls in a safe and competent manner and that a senior operator can direct the activities of other licensed oper-ators in a safe and competent manner.
The Commission also believes that NRC administered examinations provide assurance that facility licensee administered requalification programs are successfully main-taining the proficiency and knowledge of licensed personnel.
To this end, the rule requires in $55.57 that each applicant for renewal of a license pass an NRC administered comprehensive requalification written examination and operating test at least once during each six year license.
The NRC will administer requalification written examinations and operating tests on a random basis so that no opera-tor will go longer than six years without being examined by the NRC once a six year license is issued.
f' Comments 46-88 and 85-32 recommend that in S 55.59(c)(3)(iii) the word "significant" be added because each year many procedures and design changes occur that have little impact on the operator, also the operator should use the procedures even if he knows them.
l.
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Resolution:
Disagree.
It is the operator's responsibility-to be aware of all_ procedure and design changes and what effect, if any, they have on safe plant operation.
i 1
H.
Other Coments 1.
Coment 46-91 reccmmends that in S 55.61(b)(1) the words " willful or intentional material false statement" be used because applications are completed based on recall of information and it is unwarranted and violated due process unless there is a willful intention to deceive.
Resolution:
It is not a violation of "due process" to suspend, modi-fy, or revoke a license if the regulator determines that the " false statement" was material to the grant of the license, whether or not there was any " intent" to mislead.
2.
Comment 80-1 indicates that Section 306 of the Waste Policy Act provides the NRC to promulgate either regulations or guidance and that the NRC should not assume that regul'.tions are mandated by the Act.
Resolution:
Noted. Guidance has been used by the NRC, where consid-ered appropriate, to meet the requirements of -Section 306 of the Nuclear Waste Policy Act of 1982, Pub. L.97-425, including the Com-mission Policy Statement on Training and Qualification of Nuclear Power Plant Personnel.
3.
Comment 47-1 indicates the opinio'n that issues relating to qualification and training, medical evaluations and use of simulators in training are best left to industry programs such as the agreements between NRC and NUMARC or to the facility licensee.
Resolution:
Agreeinpart.
However, these regulations are within the Commission s statutory authority and stated mission.
4.
Coments 20-1, 21-17 and 25-1 indicates that insufficient time was provided for meaningful review and preparation of comments.
Resolution:
The Public Comment period was longer than most proposed rules. Moreover, comments received after the end date of the public comment period were included in the Commission's analysis of public coments.
5.
Comments 19-12, 30-1, 31-1, 39-12, 45-1, 46-1, 62-1, 63-1 and 85-2 indicate that Part 55 should clearly state in the preamble that these new regula-tions incorporate and supersede documents such as NUREG-0737, NUREG-0060, and SER's.
Resolution:
Agree.
A statement has been added to the preamble that these rules supersede all current regulations for operator licenses.
6.
Comments 19-13 and 39-13 request the opportunity to comment on the pro-posed regulations and regulatory guides again after initial comments are incorporated.
38
Resolution:
The'only significant changes to the proposed regulations and regulatory guides that resulted from public comments were changes to reduce some requirements from those initially proposed.
Therefore, there is no need for an additional public review.
7.
Comments 9-4, 9-5, 9-8, 9-13, 9-16, 19-59, 30-13, 36-1, 37-10, 39-59, 42-7, 46-71, 46-72, 47-5, and 52-6 suggest changes dealing with misspellings in the Federal Register notice, editing, or format.
Resolution:
These comments were reviewed by an NRC technical editor arid incorporated as appropriate.
8.
Comments 1-1, 7-5, 18-1, 18a-2, 19-28, 36-2, 39-28, 55-1, 69-5, 71-6, 73-6, 78-10, 85-1, 94-2, and 107-13 suggest additions that are not appropriate for regulations.
Comments 7-5, 16-2, 18-1, 46-86, 55-1, and 64-2 do not pertain to the proposed regulations.
Resolution:
Noted.
I.
Conforming Amendment - 10 CFR 50.74 1.
Comments 2-9,14-16, 35-18 and 46-92 question whether licensee in S 50.74 referred to facility licensee or the licensed individual.
Some commenters recommend using facility when referring to the facility licensee and licenses when referring to operators.
Resolution:
The definitions for Part 50 are found in S 50.2.
The terms " facility licensee" and " licensee" are also defined in S 55.4.
2.
Comments 14-17, 21-1, 32-26 and 85-33 question whether the reporting re-quirements for notification of reassignment are on the basis of how the li-cense is used (i.e., R0, SRO, Shift Foreman, training, etc.) or on whether the license is necessary for the position; when the individual receives a promotion to management or when the individual is reassigned by the facility.
Resolution: The part of S 50.74 referenced refers to 55.33(a)(3).
In this part it is indicated that the facility licensee must certify a need for a licensed operator or senior operator.
If the reassignment affects this need, then the NRC should be notified.
3.
Comments 13-1, 14-18, 14-19, 19-60, 21-2, 23-1, 23-14, 39-60, 41-1, 43-3, l
51-1, 69-2, 67-2, 69-15, 71-24, 73-24, and 77-9 request definition of the terms "other conditions" and " crime" in S 50.74, as they are too vague as written. Further some commenters indicate that conviction of minor traf-fic violations should not require reports to the NRC.
Resolution: Agree.
S 50.74(d) has been deleted and S 55.53(g) has been reworded.
4.
Comment 46-94 requests clarification of whether the termination in S 50.74 is for cause or for any reason.
l Resolution:
" Termination" means for any reason.
This provision is i
for recordkeeping purposes.
39
- f 5.
Comment 66-3 requests.that 50.74 be changed to read "within-30 days of becoming aware of the conditions..."
Resolution: Noted.
This is the intent of the provisions ~.
3 J
k I
i e
l il' i
f 40
INDEX OF SPECIFIC COMMENTS Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Cn!!mnt 11 111 C II:
Coment M
Ct 11:
1-1 F2a. G13. H8 5-9j 821 2-1 A1 5-9k 36c 2-2 D1 5-10 A3q 2-3 F2d 5-11 Elb E2 2-4 S4 5-12 Resolved By 2-5 64 Resolution of Connents 2-6 64 5-9a 5-9c 5-9h and 5-9k 2-7 D7 6-1 F12 2-8 E16e 6-2 A3o 2-9 11 6-3 D4 C12 3-1 E9d 6-4 D4 C22. C23 4-1 A3d 7-1 89s 4-2 C28b 7-2 Ele 4-3 C1 7-3 E161 4-4 C1 7-4 Elfj 5-1 Elb 7-5 M8 5-2 E11b 7-6 D4 5-3 E19 8-1 A1 g
5-4 Eld 8-2 C28b 5-5 E13a 8-3 F7 56 Elf. E16a 8-4 F7 6-7 E11b 8-5 F6 5-8 82f 8-6 C20d 5-9 88e 8-7 F3 5-9a A3b 84c 9-1 A3w 5-9b 82b 9-2 F2a 5-9c B2a 9-3 82 5-9d 89c S-4 M7 5-9e 89a 9-5 H7 5-9f 82h 96 82 5-99 821 9-7 CS 5-9h 82e 9-8 H7 5-91 82:
9-9 D9
s Resolved By Resolved By Resolved 8y Reso1xed 9y Inclosure Enclosure Enclosure Enclosure Coment Rr II:
$1.11;,
Cofurtent Ie IIr Cr IIf
.~
9-10 D9 13-16 E13a 9-11 D9 13-17 Elf 9-12 09 13-18 E4 9-13 E16b H7 13 19 E10f 9-14 09 13 20 54b 9-15 F2d 13 21 A3p 9-16 H7 13-22 C3 9-17 G3 13-23 C11 9-18 G2 13 24 C20a 9-19 G2 13-25 C12 9-20 62 13-26 C14 9-21 82 13-27 C19 9-22 G2 13 28 C22 9-23 G2 13-29 C25 10-1 C12 13-30 C26 11-1 C27 13-31 C28c 11-2 015b 13-32 F6 12-1 CIS 13-33 51g 13-1 13 13-34 82m 13-2 F2d 13-35 B2e 13-3 D4 13-36 82k 13-4 33 13-37 86a 13 5 01 14-1 810 13-6 D1 14-2 51 13-7 Dion 14-3 F13 13-8 Elb 14-4 D1 13-9 D17 14-5 D1 13-10 F2b 14-6 01 13-11 F6 14-7 D10d 13-12 F11 14-8 D10c 13-13 G3 14-9 09 13-14 G10 14-10 D9, D15b 13-15 G2 14-11 09
e e
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Coment M
C II:
Coment M
Cr 11;
~
14-12 F2d 19-16 F1b 14-13 A3u, G3 19-17 F1b 14-14 G8 19-18 F1b 14-15 G2 19-19 A3u, A4, A5 14-16 11 19-20 A3j 14-17 12 19-21 F1b 14-18 13 19-22 F2d 14-19 13 19-23 F1b 15-1 C12 19-24 F1b 16-1 D6 19-25 53 16 2 H8 19-26 F2c 16-3 F3 19-27 C1, C2, C3, F2b 16-4 Fil 19-28 HC 17-1 C12 19-29 F1b 17-2 F3 19-30 C1 18-1 H8 19-31 02 16A-1 E8e 19-32 013 18A-2 G13. H8 19-33 D2 19-1 010d 19-34 F1b 19-2 04 83c 19 35 D2 19 3 Ble, 83e 19-36 09 19-4 E13a 19-37 09 l
19-5 E12b 19-38 09 19 6 E12b 19-39 09 19-7 A3e 19-40 010d 19-8 88f 19-41 D10a, D10b 19-9 E16e 19-42 A3h 19-10 Bla 19-43 E13a
~
19-11 87e 19-44 Ela 19-12 H5 19 45 D17 19-13 H6 19-46 F2h 19-14 Gla 19 47 F11 19-15 F2b F2d 19-48 F13
i Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment 11_11;,
C: 1I:
Consent 3,,,,111,
$A,,,11
.~
19-49 F2h 22-2 F2c 19-50 F2b 22-3 F2b 19-51 Gla 22-4 D1 19-52 Gla 22-5 F2b 19-53 Gla 22-6 F3 19-54 Gla 23-1 13 19-55
$4 23-2 F1b 19-56 G2' 23-3 F13 19-57 82 23-4 B3 19-58 G2 23-5 01 19-59 M7 23-6 011 19-60 13 23-7 015 20-1 H4, 14 23-8 010a 20-2 F2b B3c 23-9
- 09. E13a 20-3 A2, 83e 23-10 E14b 21-1 12 23-11 Elb 21-2 13 23-12 D17 21-3, B7 23-13 F6 21-4 C4 23-14 13 21-5 C7 B9m 23-15 Gle 21-6 C4 24-1 A1 21-7 Fla 24-2 F7 21-B D14 25-1 H4 21-9 D14 25-2 A2 21-10 A3v 26-1 01 21-11 E16f, D15b 26-2 D1 21-12 E16d 26-3 E16f, 015b 21-13 G1d 26-4 Elb 21-14 G2 26-5 E15a 21-15 88b 26-6 E6b 21-16 E16d F1b 26-7 33 21-17 H4 26-8 F3 22-1 A3b 26 9 F12
i O
Resolved By Resolved By Resolved By Resolved 8y Enclosure Enclosure Enclosure Enclosure ggman,t er II:
cr II:
Comnent M
$1111 26-10 F12 28-22 Gla 26-11 42 28-23 Gla 26-12 42 28-24 42 26-13 F2b 28-25 62 27-1 Elb 28-26 51f 27-2 Elb 28-21 89d 27-3 Ella 28-28 89g 27-4 E10e 28-29 F7 27-5 89m 28-30 C12 27-6 A3p 28-31 C19 27-7 D17 28-32 C28b 27 8 F2d 29-1 88 28-1 Elb 30-1 H5 28-2 Elb, F2b Gla 30-2
- F2d 28-3 E8g 30-3 F2d 28-4 E8h 30-4 F2d 28-5 83a 30-5 012 28-6 Fla 30-6 A3s, Esa B1b 28-7 F1b 30-7 E5 28-8 F1d 30-8 E81 28 9 36 30-9 Bld 28-10 83 30-10 A3b, Fla 28-11 33 30-11 A6 28-12 D1 30-12 F2e 28-13 F1b 30-13 H7 28-14 D1 30-14 08 28-15 010d 30-15 D1 28-16 D10a 30-16 D1 28-17 Elb 30-17 010a, 0106 28-18 D16c 30-18 A3g 28-19 D17 30-19 F2h 28 20 F2h 30-20 F7 28-21 F7 30-21 G2
Resolved By flesolved By Resolved 8y Resol.ved By Enclosure Enclosure Enclosure Enclosure EEEtal M
$1.111 comment m
n 30-22 F7 31-33 D17 31-1 H5 31-34 F1b, F2d 31-2' Fla,F1b,Flc 31-35 F6 31-3 D1 31-36 F7 31-4 Ela, E15a 31-37 Fil 31-5 Fla,'F2d 31-38 53 31-6 D1 31-39 F7 31-7 Elb 31-40 Gla 31-8 Elb 31-41 61f 31-9 Ela 31-42 82 31-10 Ella 31-43 42 31-11 00e 31-44 E14b, G2 31-12 83d 31-45 C4 31-13 A3n 31-46 C8 31-14 F1d 31-47 C1, C2 31-15 A3t 31-48 C11 31-16 A3b,A3j 31-49 C20a 31-17 A3b, A3n 31-50 C12 31-18 86 31-51 C19 31-19 83 31-52 C20s, C20e 31-20 F2e 31-53 C22 31-21 D1 31-54 C23 31-22 D1 31-55 C24 31-23 D13 31-56 C26 31-24 Flc 31-57 C28b 31-25 D1 31-58 A15 31-26 010s 31-59 A5 31-27 113a 31-60 82c,88c 89s 31-28 Elb 31-61 89n 31-29 E8e 31-62 88f 31-30 E6b 31-63 88d 31-31 E14b 31-64 88d 31-32 F2d 31-65 890
-Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment 8: II:
C: II:
Comment 8: II:
C:
'2 f :
31-66 B5b 32-29 A4b 31-67 B6a 32-30 Bla 31-68 89k 32-31 87c 31-69 B9f 32-32 88f 31-70 85c, B9e 32-33 891 32-1 Al 32-34 B6a 32-2 Elb 32-35 881 32-3 G10 33-1 Al 32-4 D9, E6a, E8b 33-2 C1 32-5 E10g 33-3 D1 32-6 E101 33-4 D10d 32-7 B4a 33-5 Elb 32-8 A3e 33-6 Fla, Flc 32-9 F1d 33-7 F7 32-10 F2d 33-8 Gla 32-11 D1 33-9 62 32-12 D9, D11 33-10 G2 32-13 D9 34-1 F3 32-14 D9 34-2 F2d 32-15 D9 34-3 A3g 32-16 D10d 35-1 D2 32-17 D10a 35-2 D2 32-1B D15 35-3 D1 32-19 Elb 35-4 D1 32-20 E14b B7c 35-5 D9 32-21 F13 35-6 D10d 32-22 A3u 35-7 A3v 32-23 Gla 35-8 E13a 32-24 F2b 35-9 Elf 32-25 G2 35-10 E10c 32-26 12 35-11 D17 32-27 A9 35-12 F2b 32-28 A10 35-13 F2d
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Coment B: II:
C1_11 Coment B: II:
C: II:
~
35-14 F2d 36-26 A3e 35-15 F4 37-1 Elb, F2d 35-16 F6 37-2 Fla, Flc 35-17 F11 37-3 D1 35-18 11 37-4 Elb 35-19 F13 37-5 F1d 35-20 A3u 37-6 D1 35-21 A3u 37-7 D1 36-1 D10d, H7 37-8 F2b 30-2 H8 37-9 F2b 36-3 E13a 37-10 H7 36-4 82j 37-11 D1 36-5 Ella
~37-12 D10d 36-6 E10e 37-13 E16g 36-7 B3a 37-14 Elc 36-8 A3p 37-15 Ella 36-9 F2d 37-16 E6d 36-10 A6 37-17 F7 36-11 810 27-18 F11 36-12 F2c 37-19 Gla 36-13 F2b 38-1 A2 36-14 F2c 38-2 A4c 36-15 D1 38-3 A2 36-16 B13 39-1 D10d 36-17 D1, E16h, F2b, 39-2 D4 B3c 36-18 D10d 39-3 Ble, 83e 36-19 010d 39-4 E13a 36-20 E13a 39-5 E12b 36-21 E8e 39-6 E12b 36-22 F13 39-7 A3e 36-23 Gla 39-8 88f 36-24 81a 39-9 E16e 36-25 82 39-10 Bla
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B: II:
C: II:
Comment B: II:
C: II:
39-11 B7e 39-44 Ela 39-12 H5 39-45 D17 39-13 H6 39-46 F2b 39-14 Gla 39-47 F11 39-15 F2b, F2d 39-48 F13 39-16 F1b 39-49 F2b 39-17 F1b 39-50 F2b 39-18 F1b 39-51 Gla 35-19 A3u, A4, A5 39-52 Gla 39-20 A3j 39-53 Gla 39-21 F1b 39-54 Gla 39-22 F2d 39-55 G4 39-23 F1b 39-56 G2 39-24 F1b 39-57 G2 39-25 B3 39-58 G2 39-26 F2c 39-59 H7 39-27 C1, C2, C3, F2b 39-60 13 39-28 H8 40-1 88 39-29 F1b 40-2 A2 l
39-30 C1 40-3 015a 39-31 D2 40-4 G5 39-32 013 40-5 B8 39-33 D2 41-1 13 39-34 F1b 41-2 Flc, F2d 39-35 D2 41-3 E13a 39-36 D9 41-4 Elb 39-37 09 41-5 E8b, E8j 39-38 D9 41-6 F6 39-39 D9 41-7 F11 39-40 D10d 41-8 G3 l
39-41 D10a, D10b 42-1 D1 39-42 A3b 42-2 D1 39-43 E13a 42-3 F2b
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B: II:
C: II:
Comment B: II:
C: II:
42-4 D10c 45-16 A3b,A3j 42-5 D10c 45-17 A3b A3n 42-6 A3k 45-18 B6 42-7 Fla, H7 45-19 83 42-8 F2d 45-20 F2c 43-1 Flc 45-21 D1 43-2 C1, C20a 45-22 D1 43-3 13 45-23 D13 43-4 F1b 45-24 Flc 43-5 D15 45-25 D1 43 D10a 45-26 D10a 43-7 A3a, Elc, E13a 45-27 E13a 43-8 D17 45-28 Elb 43-9 B3 45-29 EBc 43-10 F7 45-30 E6b 43-11 G3 45-31 E14b 44 Endorsed letter #31 45-32 F2d w/o additional comments 45-33 D17 45-1 H5 45-34 F1b, F2d 45-2 Fla, F1b, Flc 45-35 F6 45-3 D1 45-36 F7 45-4 Ela, E15a 45-37 Fil 45-5 Fla, F2d 45-38 G3 45-6 D1 45-39 F7 45-7 Elb 45-40 Gla 45-8 Elb 45-41 G1f 45-9 Ela 45-42 G2 45-10 Ella 45-43 G2 45-11 E10e 45-44 E14b, G2 45-12 B3d 45-45 C4 45-13 A3n 45-46 C8 45-14 F1d 45-47 C1, C2
{
45-15 A3t 45-48 C11
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Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure-Enclosure Comment B: II:
C: II:
Comment B: II:
C: II:
45-49 C20a 46-12 83d 45-50 C12 46-13 A3n 45-51 C19 46-14 F1d 45-52 C20a, C20c 46-15 A3t 45-53 C22 46-16 A3b,A3j 45-54 C23 46-17 A3b, A3n 45-55 C24 46-18 B6 45-56 C26 46-19 B3 45-57 C28b 46-20 F2c 45-58 A15 46-21 D1 45-59 A5 46-22
'D1 45-60 B2c, B8c, 89 46-23s D13 45-61 B9n 46-24 Flc 45-62 88f 46-25 D1 45-63 B8d 46-26 D10a 45-64 88d 46-27 E13a 45-65 B90 46-28 Elb 45-66 85b 46-29 E8e 45-67 B6a 46-30 E6b 45-68 B9k 46-31 E14b l
45-69 B9f 46-32 F2d i
45-70 BSc. B9e 46-33 D17 46-1 H5 46-34 F1b, F2d 46-2 Fla, F1b, Flc 46-35 F6 46-3 D1 46-36 F7 46-4 Ela, E15a 46-37 Fil 46-5 Fla, F2d 46-38 G3 46-6 D1 46-39 F7 46-7 Elb 46-40 Gla 46-8 Elb 46-41 G1f 46-9 Ela 46-42 G2 46-10 Ella 46-43 G2 l
46-11 E10e 46-44 E14b, G2 l... --
4 Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B: II:
C: II:
Comment B: II:
C: II:
46-45 C4 46-78 D9 46-46 C8 46-79 F2b 46-47 C1, C2 46-80 010a 46-48 C11 46-81 E14b 46-49 C20a 46-82 F2b 46-50 C12 46-83 F14 46-51 C19 46-84 F2b 46-52 C20a, C20c 46-85 F2b 46-53 C22 46-86 H8 46-54 C23 46-87 62 46-55 C24 46-88 G11 46-56 C26 46-89 89r 46-57 C28b 46-90 G2 46-58 A15 46-91 H11 46-59 A5 46-92 Il 46-60 82c, B8c, B9s 46-93 46-61 B9n 46-94 I4 46-62 B8f 46-95 l
46-63 B8d 46-96 B5a 46-64 B8d 46-96a 86a, B6b, B6d 46-65 890 47-1 H3 46-66 B5b 47-2 F2d 46-67 B6a 47-3 F1b, F1d 46-68 89k 47-4 83 46-69 89f 47-5 D1, H7 46-70 85c, B9e 47-6 D9
(
46-71 C5, H7 47-7 D9 46-72 H7 47-8 09 46-73 D9 47-9 D9 46-74 09 47-10 D10a, D10d 46-75 09 47-11 D10b 46-76 D4 47-12 A3e 46-77.
D9, D11 47-13 E13a
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Cossents B: II:
C: II:
Coment B: II:
C: II:
47-14 Elb 51-3 E13a 47-15 D16c 51-4 Elb 51-5 E8b,E8j 47-16 D17 47-17 F5 51-6 F6 47-18 Fil 51-7 Fil 47-19 F13 51-8 G3 47-20 Gla 51-9 C20a 47-21 Gla 51-10 C12 47-22 Gla 51-11 C19 47-23 Gla 51-12 C28b 4
47-24 64 51-13 B2m 48-1 A1 51-14 89g 48-2 F2d 51-15 B2m 48-3 B10 52-1 A1, F1d 48-4 D12 52-2 A3j 48-5 D9 52-3 A3t 48-6 D9 52-4 F1b 48-7 D10d 52-5 86.1 48-8 D10c 52-6 89, H7 48-9 81f 52-7 B4 49-1 D1, D14 52-8 83 49-2 D1 52-9 F2c 49-3 Elb, E15a 52-10 D3 i
l 49-4 Elb 52-11 D1 49-5 E6b 52-12 D1 49-6 83 52-13 D3 49-7 F3 52-14 D1 49-8 F12 52-15 D3 49-9 F12 52-16 D1 49-10 62 52-17 D10a 50-1 D5 52-18 A3e 51-1 13 52-19 E13a 51-2 Flc, F2d 52-20 E13a
t Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Coquent 8: II:
C: II:
Comment B: II:
C: II:
52-21 Elb
.59-2 D1 52-22 Elle 59-3 Elb, E15a 52-23 E6d 59-4 Elb 52-24 E6d 59-5 E6b 52-25 D16d. F2b 59-6 83 52-26
.F2d 59-7 F3 52-27 F7 59-8 F12 52-28 Gib 59-9 F12 52-29 G7 59-10 G2 52-30 87 59-11 G2 53-1 A1 59-12
'F2b 53-2 D4 60-1 D1 53-3 B8a 60-2 D1 53-4 F12 60-3 Elb, E15a 53-5 69 60-4.
Elb 53-6 A3f 60-5 E6b 53-7 A3h 60-6 83 53-8 E10d 60-7 F3 53-9 E10e 60-8 F12 54-1 D12 60-9 F12 54-2 F13 60-10 G2 55-1 H8 60-11 G2 55-2 69 60-12 F2h 56-1 E7 61-1 Elb 56-2 Elb 61-2 F1b 56-3 E8g 61-3 C12 56-4 E8h 61-4 C20b 56-5 B4c 62-1 H5 56-6 A3b 62-2 Fla, F1b, Flc 56-7 E3 62-3 D1 l
57-1 B3a 62-4 Ela, E15a 58-1 B7a 62-5 Fla, F2d j
59-1 D1 62-6 D1 62-7 Elb
d' Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Coment 5.1 ]h C: II:
EgggDt B: II:
C: II:
62-8 Elb 62-40 Gla 62-9 Ela 62-41 61f 62-10 Ella 62-42 62 62-11 E10e 62-43 G2 62-12 B3d 62-44 E14b, 62 62-13 A3n 62-45 C4 62-14 F1d 62-46 C8 62-15 A3t 62-47 C1, C2 62-16 A3b,A3j 62-48 C11 62-17 A3b, A3n 62-49 C20a 62-18 B6 62-50 C12 62-19 B3 62-51 C19 62-20 F2c 62-52 C20a, C20c 62-21 D1 62-53 C22 62-22 D1 62-54 C23 62-23 D13 62-55 C24 62-24 Flc 62-56 C26 62-25 D1 62-57 C28b E2-26 D10a 62-58 A15 62-27 E13a 62-59 A5 62-28 Elb 62-60 B2c,B8c,89s 62-29 E8c 62-61 89n 62-30 E6b 62-62 88f 62-31 E14b 62-63 B8d 62-32 F2d 62-64 B8d 62-33 D17 62-65 89o 62-34 F1b, F2d 62-66 B5h 62-35 F6 62-67 B6a 62-36 F7 62-68 89k 62-37 Fil 62-69 89f 62-38 G3 62-70 B5c, B9e 62-39 F7 63-1 H5
Resolved By' Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Coment B: II:
C: II:
Coment B: II:
1;JJi 64-1 A1 67-13 E12d 64-2 F2a, H8 67-14 D16a, D16c 64-3 A31 67-15 D15 64-4 D4 67-16 F13 65-1 D1 67-17 F2b 65-2 D1 67-18 G6 65-3 Elb, E15a 67-19 G2 65-4 Elb 67-20 C2 65-5 E6b 67-21 C18 65-6 B3 67-22 C19 65-7 F3 67-23 C23, C28b 65-8 F12 67-24 C28b 65-9 F12 67-25 83 65-10 G2 67-26 Big 65-11 G2 67-27 A3v 65-12 F2b 67-28 A3r 66-1 D1 67-29 89b 65-2 C6 67-30 82m 66-3 15 67-31 89g 66-4 D17 67-32 82k 67-1 D1 67-33 86a 67-2 13 68-1 G10 67-3 F1d 68-2 610 67-4 B3 69-1 F1b 67-5 C2, F2b 69-2 Elb, 13 67-6 Not Used 69-3 F2d 67-7 Not Used 69-4 A3u 67-8 D1 69-5 H8 67-9 E13a 69-6 D9 67-10 Elg 69-7 D9 67-11 E13a 69-8 D9 67-12 E14a 69-9 D9
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Coments B: II:
C: II:
Coment 9: II:
C: II:
69-10 D10a 71-15 D10a 69-11 D10b 71-16 D10b 69-12 G4 71-17 D16b, D16c 69-13 G2 71-18 F8 69-14 82 71-19 F7 69-15 F7, 13 71-20 Gla 69-16 C20a 71-21 Gla 69-17 C12 71-22 Gla 69-18 C20c 71-23 G4 69-19 C26 71-24 13 69-20 C28c 72-1 Flc, F1b, F2d 69-21 C28b 72-2 E8e 69-22 E15 72-3 F2d 69-23 Elb 72-4 F2c 69-24 Ella 72-5 F2b 69-25 E10e 72-6 Flc 69-26 83d 72-7 F2d i
69-27 A3n 72-8 F2b 70-1 A2 72-9 E8e 71-1 F2d 72-10 F2b 71-2 F1d 72-11 F2d 71-3 A3t 72-12 F9 71-4 F2d 72-13 F2d 71-5 83 72-14 F2d 71-6 H8 72-15 F2d 71-7 D1 73-1 F1d, F2d 71-8 D1 73-2 F1d 71-9 D13 73-3 A3t 71-10 D1 73-4 F2d 71-11 D1 73-5 83 71-12 D9 73-6 H8 71-13 D9 73-7 D1 71-14 D9 73-8 D1 N.
1 Resolved By Resolved By Resolved By Resolved By
~
Enclosure Enclosure Enclosure Enclosure Coment B: II:
C: II:
Coment 8: II:
C: II:
~
73-9 D13 74-18 F7 73-10 D1 74-19 Fil 73-11 D1 74-20 F13 73-12 D9 74-21 F15 73-13 D9 75-1 81g, B2d 73-14 D9 76-1 83 73-15 D10a 76-2 D1 73-16 D10b 76-3 D10a 73-17 D16b, D16c 76-4 EL 73-18 F8 76-5 Ella 73-19 F7 76-6 Elg 73-20 Gla 76-7 E6c 73-21 Gla 76-8 D17 73-22 Gla 76-9 F2b 73-23 G4 76-10 FIS 73-24 13 76-11 62 74-1 D4 76-12 C14 74-2 Fla 76-13 C20a 74-3 EK 76-14 C23 74-4 F1d 76-15 C28b 74-5 A3b 76-16 A3c,A3e 74-6 A4, A5 77-1 Elb
.74-7 85 77-2 D1 74-8 F2c 77-3 D10b 74-9 D1 77-4 Elb 74-10 D9 77-5 E12a 74-11 D9 77-6 D17 74-12 D9 77-7 F6 74-13 D1 77-8 63 i
74-14 D10a 77-9 13 74-15 D10b 77-10 C20a, C19 74-16 D16b 77-11 C26 74-17 D17 77-12 C28b i
Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Encicsure Comment B: II:
C: II:
Consent B: II:
C: II:
77-13 81g 81-4 D17 78-1 Resolved by the Resolution of 81-5 F2d Comments 78-2 through 78-16.
81-6 F6 78-2 A31 81-7 Gla 78-3 Elb 81-8 82g 78-4 A3m 81-9 Big 78-5 F2d 81-10 82m 78-6 F2d 81-11 B21,B2j 78-7 F2b 81-12 82k 78-8 F1b, F2d 81-13 86a 78-9 F2d 81-14 C20a 78-10 81-15 C26 78-11 Elb, E13a 81-16 C28b 78-12 E10b, Elb 82-1 D9 78-13 E10b 82-2 E8f 78-14 E10h 82-3 D9 78-15 B3d 82-4 E8b 78-16 43p 82-5 Elb 79-1 F2d 82-6 F3 l
80-1 H2 82-7 F7 l
80-2 D1 82-8 F12 80-3 E12b 82-9 Gla 80-4 D17 C28b 82-10 G2 80-5 C28b 82-11 A8 80-6 F10 83-1 88 80-7 F13 83-2 A2 80-8 Gla 83-3 A2 80-9 Gla 84-1 D1 80-10 Gla 84-2 D10b, E16f 80-11 Gla C12 84-3 Elb, E15a 81-1 D10a 84-4 Elb, E6b l
81-2 E13a 84-5 B3 81-3 Elc 84-6 B3, F3
I Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Qomment B: II:
C II:
Comment B: II:
C II:
84-7 F3. F12 85-29 D17 84-8 F12 85-30 F6 84-9 62 85-31 G1g, G2 84-10 62 85-32 Gil 84-11 F2b 85-33 12 85-1 86-1 B8 85-2 HS 86-2 A2 85-3 A2 86-3 A2 85-4 F2d 86-4 A12 85-5 A12 86-5 89 85-6 810 86-6 A4a, C28b 85-7 B3 86-7 A2 85-8 C1 86-8 89h 85-9 D1 87-1 F2d 85-10 D13 87-2 F2d 85-11 D9, D15a 87-3 B6, Elg 85-12 59 87-4 B6 85-13 D9 87-5 D1 85-14 D9 87-6 D9 85-15 D10a 87-7 Ellb B2j l
85-16 D10b 87-8 D1 85-17 Elb 87-9 D10a 85-18 E12e 87-10 E13a 85-19 E13a 87-11 E2 85-20 E13a, E14b 87-12 Elg, E9 85-21 Elb 87-13 Elf i
85-22 Elc 87-14 F12
(
85-23 E8f 87-15 G10 85-24 E12e 88-1 88 85-25 Elb 88-2 A2 l
85-26 E7 89-1 B8 85-27 E6d 90-1 Elb 85-28 EK 90-2 F1b t
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ar,__-.-,-__.--..,_,.-..,.--,_.,...-------,---.,,,,_-n-n-
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.l Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Connent 8: II:
C: II:
Comment B: II:
C: II:
i 90-3 C12 96-5 A4a 90-4 D1 C1, C20a 97-1 C10 90-5 C28b 97-2 C26 91-1 D1 97-3 C28b 91-2 D10d 97-4 G16 91-3 B6 98-1 C4 91-4 Fla 98-2 B3c 91-5 C28b 98-3 B3e 91-6 F7 98-4 E15a 91-7 F12 99-1 C12 91-8 G1c 100-1 62 91-9 G3 100-2 C25 91-10 Elb 200-3 A13 91-11 Elb 200-4 B7b 91-12 E10a 100-5 B9k 91-13 E81 101-1 C6, C23 91-14 B3d 102-1 A2 91-15 A3p 103 Endorsed letter #3 without 92-1 Al additional comment 92-2 D9 D12 104-1 B8c 93-1 Alb, All 104-2 B9s 94-1 C5 104-3 89n l
94-2 H8 104-4 89k 94-3 C16 104-5 89r 94-4 C28b 105-1 83 95-1 C4 105-2 82 A8 95-2 83c 105-3 A5 95-3 83e 105-4 A3 95-4 E15a 105-5 A4a 96-1 B3 106-1 C4 96-2 A8 106-2 B3c 96-3 A5 107-1 C11 96-4 A3 107-2 C12
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.-,,r,,-
l Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure M
B: II:
C: II:
Coment B: II:
C: II:
107-3
'C28a 112-2 83c' 107-4 C17 112-3 B3e 107-5 C18 112-4 E15a 107-6 C19 113-1 C8 107-7 C20a 113-2 C20a 107-8 C20c 113-3 C20c 107-9 C23 113-4 C23 107-10 C26 113-5 C28b 107-11 C28b 114-1 C12 107-12 C28e 114-2 C12 107-13 H8 114-3 C19 107-14 C28b 114-4 C23 107-15 Big 114-5 C25 107-16 B2m 114-6 C28b 108-1 A6 114-7 C28b 108-2 A6 114-8 C28b 109-1 89p 114-9 C4 109 B7d 114-10 C8 109-3 B3f 114-11 C2 109-4 B2m 114-12 C11 109-5 B1c 114-13 C20a 109-6 B2e 114-14 C12 109-7 B3b 114-15 C19 109-8 88g 114-16 C20c 109-9 89q 114-17 C22 109-10 B8h 114-18 C23 110-1 A14 114-19 C24 110-2 A14 114-20 C26 111-1 C4' 114-21 C28b 111-2 B3c 115-1 Endorsed Letter #31 with-111-3 B3e out additional Comments 111-4 E15a 116-1 C8 112-1 C4 116-2 C20a l
Resolved By Resolved By Resolved By Reisived By Enclosure Enclosure Enclosure Enclosure Comment B: II:
C: II:
Comment B: II:
C II:
115-3 C23 124 Endorsed letter #31 without 116-4 C28b additional Comments.
117-1 Ala 125-1 C23 117-2 A4d 126-1 C19 117-3 A7 126-2 C22 118-1 C4 126-3 C23 118-2 B3c 127-1 C9 118-3 B3e 127-2 C11 118-4 E15a 89t 127-3 C13 119-1 C2 127-4 C19 119-2 C1 127-5 C20c 119-3 C12 127-6 C28b 119-4 C19 127-7 C28f 119-5 C20c 128-1 C4 119-6 C23 128-2 B3c 119-7 C28b 128-3 B3e 120-1 A2 128-4 E15a 120-2 C1 129-1 C8 120-3 C19 129-2 C20a 120-4 C20c 129-3 C23 l
120-5 C24 129-4 C28b 120-6 C28b 130-1 A2, B91, C6 121-1 C28b 130-2 88 122-1 C8, C23 131-1 H3 j'
122-2 C20a 131-2 C1, C2 122-3 C23 131-3 C20b 122-4 C28b 131-4 F2d C19 123-1 C28a 131-5 C20c 123-2 C20a 131-6 C21 123-3 C22 131-7 C28b 123-4 C23 131-8 C28b 123-5 C25 131-9 A16 123-6 C28b
Resolved By Resolved By Enclosure Enclosure Comment B II:
C: II:
131-10 B1b, B2d 131-11 83c 131-12 B2m 131-13 86a 131-14 89j 132-1 B99 132-2 B6b 133-1 C7 133-2 C20a 133-3 C12 133-4 C19 133-5 C28b 134-1 C4 134-2 C1, C2 134-3 C11 134-4 C20a 134-5 C12 134-6 C19 134-7 C20s, C20c 134-8 C22 134-9 C23 134-10 C24 134-11 C26 134-12 C28b 135-1 C12 135-2 C23 s
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