ML20212M734

Resolution of Public Comments - Reg Guides 1.134,1.149 & 1.8

ML20212M734
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Issue date:	03/10/1987
From:	NRC
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ML20212M636	List: ML20212M632 ML20212M720 ML20212M734 ML20212M767 ML20212M773 ML20212M788
References
FRN-49FR46428, RTR-REGGD-01.008, RTR-REGGD-01.134, RTR-REGGD-01.149, RTR-REGGD-1.008, RTR-REGGD-1.134, RTR-REGGD-1.149, RULE-PR-50, RULE-PR-55 AA88-2-4, NUDOCS 8703120158
Download: ML20212M734 (65)

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-RESOLUTION OF PUBLIC COMMENTS - )

REGULATORY GUIDES 1.134, 1.149, AND 1.8 l I

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. p7J31g158870310 PDR a SS 49FR46428

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h 4 I. LIST OF COPMENTERS 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 4 5 N. S. Elliot, American Nuclear Society L. Roberts, Indian. Point, NY 6

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, Los 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 46 D. Musolf, Northern States Power Company '

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Letter Number Commenter 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 1 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 95 L. L. Weckbaugh, Dunkirk, MD 2

1 Letter Number. Commenter 96' ' L. ~ L. Weckbaugh, Dunkirk,L 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 i

.J. A. Tiernan, Baltimore Gas and Electric 106 107 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 8. 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. Mitt 1, Public Service Electric and Gas Company l 133 C. W. Fay, Wisconsin Electric Power Company l 134 M. O. Medford, Southern California Edison Company 135 W. D. Harrington, Boston Edison Company l'

I Coments 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, coment 2-1 refers to the first coment in letter 2. In Sec-tion II, III, and IV of this report coments are grouped in general categor-

, fes followed by the resolution to that series of coments. An index of

specific coments can be found in Section V.

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II. RESOLUTION OF'PUBLIC COMENTS ON THREE REGULATORY GUIDES-- ASSOCIATED WITH. .

. OPERATORS'1 LICENSES.

A. Regulatory Guide'1'.134, " MEDICAL EVALUATION OF NUCLEAR FACILITY PERSONNEL

' REQUIRING OPERATOR LICENSES"

- 1. Several comments support the~ revisions to RG 1.134.

a. . Comment 117-1 agrees with the concept.of giving medical examinations utilizing qualified personnel with abnormalities when discovered, evaluated by a licensed medical practitioner (MD).

b. -Comment 93-1 agrees with the requirement to have a potentially dis-qualifying condition (mental) evaluated by a psychologist or psychiatrist.

Further, the facility management should initiate these evaluations follow-ing their initial behavioral observations.

Resolution: Noted.

2. Many comments were received in regard to the application of RG 1.134 to operators at test and research reactors. Comments 38-1, 40-2, 70-1, 83-2, 86-2, 86-3, 86-7, 88-2, 102-1, and 130-l' dispute the applicability of the new extensive medical requirements to research, test and training reactor facilities. Comments 38-3 and 102-1 recommend the retention of present regulations for these reactor types. Coment 83-3 states that the current system is adequate to determine operator fitness for test, re-search and training reactors, and should be maintained until the recom-mendations of the ANS 15.4 Standards Committee are known. Comments 20 and 25-2 disagree with the "no solo" restrictions for these reactors.

Resolution: The intention for research, test and training reactors is to maintain the status quo with respect to medical requirements until the ANS 15.4 Standards Comittee recommends changes.

3. Coments 96-4 and 105-4 request a more concise definition of the term

" disabled" which is used throughout the regulatory guide.

Resolution: RG 1.134 endorses ANSI /ANS 3.4-1983 without exception.

4. Several coments express concern with the qualifications of the persons who would judge the medical condition of operators,

a. Comment 86-6 expresses concern with Subpart C whereby facility man-agement is asked to make subjective judgments in regard to medical suit-ability of their operators that are now made by an NRC-appointed physi-cian. Coments 96-5 and 105-5 address the concern over removing authority 4

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from the licenseei s medical practitioner and giving increased authority to the NRC;" medical ~ examiners." Both.commenters agree that the final deter-mination of.an applicant's medical condition should remain with the medical

' practitioner. -

~ b. . Comment 32-29 suggests that the burden of assuming medical welltbeing should-rest with the utility, not the NRC. Some documentation required by the NRC should be deleted.

c. . Comment 38-2 questions the requirement to have identified mental con-ditions followed up by professionally trained individuals.

d. Comment.117-2 questions the_use of behavioral data in medical evalua-tion of operators.

, Resolution: The criteria of ANSI /ANS 3.4-1983 provides-the basis for a physician to evaluate and make recommendations to the facility's management about the medical condition of an operator. The facility's management-is responsible for certifying the suitability of the appli-i' cant for a license. NRC has the responsibility for making an assess- '

i ment of the applicant for a license including the applicant's medical 4- fitness. Neither the facility nor the NRC staff will make medical 1-judgments. When a conditional license is requested, the NRC will 3

use a qualified medical expert to review the medical evidence to -

j make its determination.

) 5. Comments _ 31-59, 45-59,.46-59, 62-59, 96-3, and 105-3 disagree with provid-i ing_the qualifications of individuals in the " team environment" when a j operator receives a "no solo" restriction on his license. The burden of t responsibility for ensuring that two or more conditional licensees do not

! operate together should be left up to facility management. This will allow L

greater flexibility in shift assignments.

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, Resolution: Agree. RG 1.134 endorses ANSI /ANS 3.4-1983 without l exception.

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6. Comments 108-1 and 108-2 discuss the potentially disqualifying conditions outlined in Sections 5.3.8 and 5.4.15 of ANSI /ANS 3.4, and the subsequent j evaluation by a licensed psychologist, psychiatrist or physician. Concern i is raised over the' fact that no provision is made for the operator to ob-i tain his own evaluation which would carry equal weight in a competency hearing.

! Resolution: This is unnecessary. The operator as an applicant has the same appeal rights in this area as in any other area under 10 CFR 2.103(b)(2).

7. Comment 117-3 lists the location of medical information at this multi-unit j utility and states that requests for information should be directed to the Medical Service Advisor.

! i Resolution: Noted. This is an internal consideration for the facility j licensee, not the NRC.

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8. Comments 96-2.and 105-2 indicate concern over retaining medical informa-tion and facility notification to the NRC within 30 days of individual mental or physical problems which could affect job performance. Concern

is. expressed on the effects this reporting will have on in place alcohol /

drug abuse. programs. All medical information sent to the NRC should be-subject to the Privacy Act.

Resolution: Agree. All medical or other personally identifiable in-formation is subject to the Privacy Act. Moreover, alcohol and drug abuse programs are covered by a separate Fitness for Duty Policy Statement-(51 FR 27921) published August 4,:1986, by the Commission.

9. Comment 32-27 requests consistent guidance for all medical examinations, 1

citing the biennial medical examination and the annual respiratory pro-tection program physicals.

Resolution: . Although it is agreed that consistent guidance should be-provided, the purposes of the two types of examinations are different.

As a result, the guidance for these medical examinations-is different.

The facility may coordinate the examinations to eliminate overlapping cost.

10. Comment 32-28 does not' agree with the requirement to submit a completed

' Form NRC-396 for license renewals. The fact that license renewal is requested should indicate that the medical evaluation is up to date and satisfactory.

• Resolution: Revised Form NRC-396 is consistent with the commenter's intent in that, for routine renewals, considerably less detail is re-quired to be submitted than is the case with the current Form NRC-396.

'11. Comment 93-1 disagrees with a mandatory requirement to forward a formal report to a physician addressing absenteeism and other behavioral inci-dents. Further, the NRC should place the responsibility on facility man-agement to determine when and if behavioral data should be forwarded.

Resolution: Noted. The requirement in ANSI /ANS 3.4-1983 to submit a report to the physician ensures that potentially important informa-tion is made available to the medical practitioner, rather than hav-ing the information provided on an exception basis, where the indivi-i duals making the decision are not trained to recognize whether be-

! havioral information is important or not.

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( 12. Comments 85-5 and 86-4 want a better reporting form for medical records.

4 L Resolution: The NRC does not intend to create another reporting form

] beyond the proposed revisions to Form NRC-396.

i l 13. Comment 100-3 suggests moving the last line of RG 1.134, Section B, deal-

! log with clarification on reading habits, political or religious beliefs,

and social, economic, and political issues, to RG 1.134, Section C to establish the Commission's position on these matters.

[ Resolution: Noted. These issues are addressed in current statutes.

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14. Comments 110-1 and 110-2 request a provision to allow for temporary removal of an operator because of illness or injury and.further recommend the removal of the requirements to report these instances in the interest of paperwork reduction.

Resolution: Agree. The rule has been revised and does not require notification to the NRC.

15. Comments 31-58, 45-58, 46-58, and 62-58 suggest that those utilities that have a medical department should have the option of retaining detailed records in the medical department. This option is contrary to the words in the regulatory guide that state-the facility licensee should receive and maintain records.

Resolution: " Facility licensee" in the rule is intended to include any part of the. facility licensee organization including the medical department.

16. Comment 131-9 suggests extension of the timing of physical examinations to 5 years to coincide with the proposed 5 year license cycle.

Resolution: The license cycle has been changed to every 6 years end the physical examination cycle will remain every 2 years.

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B. Regulatory Guide -1.149, " NUCLEAR POWER PLANT SIMULATION FACILITIES FOR USE IN OPERATOR LICENSING EXAMINATIONS" 1.' Several comments either interpret RG 1.149 as if it is a regulatory docu-ment,_or suggest that it become one.

a. Comments 19-10 and 39-10 state that the ANSI 3.5 standard cannot be used as a threshold for regulatory compliance relative to the routine use of a simulator. Comment 32-30 questions whether RG 1.149 was oriented to examinations or training.

Resolution: The endorsement of ANS 3.5 by RG 1.149 is intended to provide regulatory guidance, not compliance, for the specification of a simulator to use in the partial conduct of operating tests.

b. Comments 30-6 and 131-10 state that RG 1.149 should be rewritten to focus on the minimum requirements for a plant-specific simulator.

Resolution: A regulatory guide does not contain requirements. Rather it provides guidance as to one acceptable method for meeting require-ments established by the Commission. The regulatory guide, in its endorsement of ANS 3.5, indicates that the requirements set forth in that document are acceptable for meeting the Commission's requirements set forth in 10 CFR 55.

c. Comment 109-5 indicates that RG 1.149 should not endorse ANS 3.5.

The NRC should develop specific standards for training simulators.

d. Comment 30-9 states that RG 1.149 is.too involved for approval cri-teria. There are very few, if any, simulators which can extensively meet these requirements.

e. Comments 19-3 and 39-3 indicate that simulation facilities should be regulated by the requirements that are necessary to train and evaluate an individual's abilities to safely operate a licensed facility, not by RG 1.149 or ANS 3.5.

f. Comment 28-26 suggests deletion of approval of the simulation facility by the NRC.

g. Comments 13-33, 67-26, 75-1, 77-13, 81-9, and 107-15 state that it is not necessary to implement regulations that are mote restrictive than the present industry standards in relation to simulators.

Resolution: Proposed requirements for simulation facilities are con-tained in that section of the regulations (10 CFR 55.45) that relates to the operating test for license candidates. RG 1.149 contains no requirements, but instead provides guidance that can be used by the utilities to meet the requirements. ANS 3.5 is an industry consensus standard with which NRC is in basic agreement.

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The standard! applies to simulators for use in training, whereas the regulations and regulatory guidance apply to simulators for use in examinationc. The-standard includes appendices that~ provide guid-L ance for documenting simulator performance and for conducting simula--

tor operability tests. These appendices are not a part of the stan--

dard itself. Because performance documentation and operability test-ing are:necessary to ensure _the. adequacy:of a simulator.for.use in the conduct of examinations, the NRC;has accepted these appendices to the standard as a viable approach,-rather.than developing its own,

.possibly different and more restrictive' requirements.

2. -Numerous comments' address'the endorsement, in'RG 1.149, of,AN'SI/ANS 3.5, 1981. These comments properly belong in a discussion of the regulatory guide, but several such comments were directed at 6 55.45 as well.

-a. Comments 5-9c and-5-91 recommend deletion of reference to ANS stan-dards, and "the version of the standard the guides endorse."

Resolution: ' Agreed. Regulatory Position C4 has been changed to indicate that the applicability of ANSI /ANS 3.1 should be determined by referring specifically to Revision 2 to Regulatory Guide 1.8.

b. Comment'5-9b suggests th'at position C3 be deleted or modified to state "only. appropriate requirements of ANS 3.5 standards must be met."

Resolution: Agree. Position C3 has been modified to refer to

" applicable"~ requirements of the standard.

c. Comments 31-60, 45-60, 46-60, 62-60, and 104-1 state that the Com-mission has expanded the scope of ANSI /ANS 3.5. These comments express concern that the Commission is attempting to weave into the guide who may .

be trained or requalified using a simulator. The subject of who may be trained on a particular plant-referenced simulator is outside the scope of the guide. The guide should be limited to plant-referenced simulators.

Resolution: The regulatory guide does not address the use of simula-tors for training, and there is no intent on the part of the Commis-sion to do so,

d. Comments 75-1 and 131-10 state that the revision to RG 1.149 should be held in abeyance until ANSI /ANS 3.5 is revised.

Resolution: The revision to RG 1.149 was developed in response to requirements set forth in Public Law 97-425. Since the time when RG 1.149 was issued for public comment, the revised version of ANSI /

ANS 3.5 has been published, and the regulatory guide has been modified to reflect this,

e. Comments 5-9h, 13-35 and 109-6 state that consideration should be given to the latest ANS 3.5 draft revision which proposes an initial per-formance test conducted during simulator acquisition and an annual oper-ability test conducted each year.

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f. Comment 5-8 refers to Appendix B of the proposed revisions of ANS 3.5.  ;

g. Comment 81-8 indicates that consideration should be given to and refer-ences provided for the latest draft revision to ANS 3.5.

h. Comment 5-9f suggests simulator performance testing (1) on initial simulator construction and (2) if simulator design changes result in sig-nificant configuration or performance' variations when a limited design change is made, specific performance tests on the affected systems and components should be performed.

i. Comments 5-9g and 81-11 suggest an operability test annually in lieu of full performance tests every 4 years.

j. Comment 36-4 indicates that Appendix B of the August 1984 draft revi-sion of ANS 3.5 provides reasonable criteria for simulator certification.

The commenter recommends that the NRC continue to follow the practice of

( endorsing / amplifying industry standards rather than including specific criteria in regulations. Comments 81-11 and 87-7 also recommend that the draft (August 1984) ANS 3.5 be used.

Resolution: RG 1.149 has been modified in response to public comments and to reflect the recent publication of ANSI /ANS 3.5-1985. However, certain exceptions aro taken to the newly issued standard, one of which concerns the staff's belief that periodic performance testing of a simulation facility is necessary.

k. Comments 13-36, 67-32, and 81-12 state that item C-12 (endorsement of the Appendix to ANS 3.5 as a part of the standard) should be deleted.

1. Comment 5-9j recommends that wording of Regulatory Position 12 be changed to adapt other acceptable methods of demonstrating an adequate documentation approach.

m. Comments 13-34, 51-13, 51-15, 67-30, 81-10, 107-16, 109-4, and 131-12 request removal of reference to ANS 3.5 appendices, as they are intended to be used as a guide, and not a standard.

Resolution: Disagree. The appendices to ANS 3.5 identify how simu-lator performance may be documented, and how simulator operability may be verified. Because such documentation and verification is necessary to ensure the adequacy of a simulator for use in the partial conduct of operating tests, the NRC has accepted the appendices to the standard as a viable approach, rather than developing its own, possibly different and more restrictive requirements.

3. Several comments addressed the burdensome application and reporting re-quirements for simulation facility approval. Although these are addressed t

in detail in the section on resolution of comments to 6 55.45, they are summarized here.

a. Comments 28-5, 36-7 and 57-1 suggest that the NRC rethink the require-ments outlined with much less prescriptive rulemaking and closer atten-i tion and cooperation with the consensus standard ANSI /ANS 3.5.

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g - b. -Comment ^109-71 indicates that'the regulatory guide imposed an unrea-1; .sonable requirement for certification'of a simulation facility.

c. Comments 19-2, 20-2, 39-2, 95-2, 98-2, 106-2, 111-2, 112-2, 118-2, 128-2, and 131-11 indicate that the simulator reporting requirements are' excessive.

d. Comments 31-12, 45-12,'46-12, 62-12,.69-26, 78-15,-and 91-14 indicate that the guidance is clear,-but not reasonable.

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Further, the requirements are unnecessary and impose a paperwork burden. In addition, the require-ments are beyond the scope and capability of the computer hardware / software.

e. Comments. 19-3, 20-3, 39-3, 95-3, 98-3, 111-3, 112-3, 118-3, and 128-1 agree with the endorsement of ANSI /ANS 3.5-1981; however, applications to the NRC with respect to plant-specific simulators should be a simple com-mitment to comply with the regulatory guide. No annual reports or renewal applications should be required.

f. Comment 109-3 indicates that NRC should specify what performance tests and reports would be required for non plant-referenced simulators.

Resolution: For facility licensees which. utilize a simulation facil-

.ity consisting soley of a plant-referenced simulator as defined in E 55.4, and which meet 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 utility's application will be required.

4. Several comments address the clarity and the intent of Comission review and approval of simulation facilities.

a. Comment 32-7 states that the guidance in RG 1.149 is not clear. Spe-cific reference is made to the determination of quality of a " simulation facility," which excludes a plant-specific and non plant-specific simulator.

b. Coment 13-20 requests clarification of the regulatory guide, page 6, with reference to "whatever supporting documentation and analysis of simu-lation may be deemed necessary."

c. Coments 5-9a and 56-5 indicate that the regulatory guide is not clear in its application to simulators other than full-scope simulators.

Resolution: It is the Comission's intent that a plant-referenced simulator that meets requirements of ANS 3.5, as modified by RG 1.149, will be acceptable for use in the partial conduct of operating tests based on a certification submitted by the facility licensee. Detailed guidance, including approval criteria, is being developed by the Com-mission and will be made available to all facility licensees before the time when simulation facility audits will be conducted. Such guid-ance 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, with certain exceptions, by NRC. Endorsement of 11 L .

this: standard is more efficient and less burdensome'than NRC develop-ment of.its own independent guidance.

5. .Three comments' address the benefits of a configuration management system.

a. Comment 46-96 makes a statement on the configuration management system / controls instituted by some utilities.

b. Comments 31-66, 45-66, 46-66, an'd 62-66 suggest deletion of Regula-tory Position 8 and the substitution of a configuration management system.

.to ensure that the simulator is updated.

c. Comments 31-70, 45-70, 46-70, and 62-70 request revision to section D,

.whereby a~ licensee should be required to submit an application that com-mits to following the guidance in RG 1.149 and should develop a configura-tion' management system.

Resolution: Noted. Although the Commission recognizes the benefits of an effective configuration management system, its responsibility is~to ensure that simulation facilities are appropriate for the par-tial conduct of operating tests and not to dictate the manner in which a utility develops the capability to provide.that assurance.

6. Several comments address the need to limit and define the types, numbers, and categories of malfunctions that a simulation facility be required to demonstrate,

a. Comments 13-37, 31-67, 32-34, 45-67, 46-67,46-96a, 62-67, 67-33, 81-13, and 131-13 recommend that a standard list of malfunctions be estab-lished requiring routine testing to demonstrate acceptable simulator operability. Testing all malfunctions is not' reasonable.

b. Comments46-96a and 132-2 suggest amendment of Regulatory Position 13 to reference simulated malt nctions "as they apply to safety related systems."

c. Comment 5-9k recommends deletion of Regulatory Position 13.

i l d. Comment 46-96a raises concern with Regulatory Position 13 in that it

, could be used improperly in the regulation of simulators. The commentor i

provides recommended procedures for a testing program.

. Resolution: RG 1.149 has been rewritten to endorse, for periodic

performance testing, the list of malfunctions specified in ANS 3.5, 1985.

7. Several comments indicate that the scope of the regulatory guide should

be expanded.

! a. Comment 58-1 suggests revision to RG 1.149 to address the scope of i

simulator examinations and the impact that the subsequent criteria would l have on " pass-fail" decisions.

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1 Resolution: . NUREG-1021, " Operator Licensing Examiner Standards," .

addresses the scope of simulator examinations. Additional work tak-ing place in' examination development also addresses this subject.

.It is-not appropriate _for inclusion in the regulatory guide.

b. Comment 100-4' suggests expansion of RG 1.149 to cover.the details

'specified-in the proposed changes to 10 CFR 55.45.

Resolution: The purpose of the regulatory guide is'to provide one acceptable _ method to satisfy the regulations adopted by the Commis-sion. An expansion of the regulatory guide would do nothing'to fur-therl achieve this goal.

c. Comments'32-20 and 32-31 recommend that the NRC expand the guidance.

to include.the operator perspective and improve the examiners' skills.

With greater examiner experience the non plant referenced simulator versus the plant-referenced simulator controversy is of less consequence.

Resolution: Noted. This comment is outside the scope of the present regulation and regulatory guidance,

d. Comment 109-2. states that the discussion portion of the regulatory guide should point out that many tasks can be evaluated on other than plant-referenced simulators.-

Resciution: Noted. The regulatory guide clearly' indicates that there are justifiable reasons for using other than plant-referenced simulators.

e. Comments 19-11'and 39-11 suggest that the NRC look to developing cri-teria that will ensure operators can perform licensed duties in a safe manner rather than. write regulations for simulators.

Resolution: Noted. This comment is outside the scope of the present regulation and regulatory guidance.

8. Several comments question the applicability of RG 1.149 to " simulation facilities." Some believe that the regulatory guide should be restricted to plant-referenced' simulators, whereas others criticize it because they believe that it is restricted to plant-referenced simulators. Still other comments seek to restrict the applicability of the rules and guidance in special cases of multiunit plants.

a. Comment 53-3 is against mandatory plant-referenced simulators. The commenter indicates that the examiner is the key. His ability, prepara-tion,' and knowledge are the most important factors.

Resolution: Agree. These regulations and guidance have been writ-ten so at to not mandate plant-referenced simulators,

b. Comment 21-15 states that the regulations that deal with simulators should be deleted. A replacement policy statement should be issued that states "no operator licenses will be issued unless the operating test is performed on a simulator which the Commission feels is plant specific."

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o Resolution: _ Disagree. The NRC, in its regulations and guidance, has

.specifically' attempted to permit the use of simulators which are other-than plant specific. Additionally, the term "which the Commission l feels is ' plant specific" is too vague for use as a regulation or as

' policy.. :i

c. Comments 31-60,'45-60, 46-60, 62-60, and 104-1 state that the regula-tory guide and ANSI /ANS 3.5 guidance should only apply to plant .

-referenced simulators.

.d. Comments 31-63, 31-64,'45-63, 45-64, 46-63, 46-64, 62-63, and 62-64 request clarification of the terms " simulation facility" and " simulator" and suggest.that " plant-reference simulator" is an appropriate substitute.

.e.- Comment 5-9 states that the reference to " approval of simulation facility"_is confusing. 4 Resolution: Although it is true that ANS 3.5 is directed only at

" full scope simulator (s)," _it is the intent'of the regulatory guide, a in its endorsement of ANS 3.5, that the standard be assumed to epply- ,

to other types of simulation facilities, as applicable.

f. Comments 19-8,L31-62, 32-32, 39-8, 45-62, 46-62, and 62-62' recommend removal of "special senior operators" and "the plant" from the footnote on-page 1 of the proposed revision of RG 1.149.

Resolution: The term "special-senior operators" will be deleted.

The designation of the plant as a simulation device was envisioned as a possible approach that a facility licensee might propose to use in conjunction with another simulation device or devices in lieu of a plant-referenced simulator. This approach might be especially suit-able for older plants _without plant-referenced simulators where mani-pulations of the plant'(to the extent consistent with plant' conditions) might be used to demonstrate familiarity with the plant for which thi candidate would be licensed.

g. Comment 109-8 states that the demonstration criteria specified in the regulatory guide eliminate the use of a non plant-referenced simulator for operator evaluation.

Resolution: This comment misinterprets this section of the regula-l tory guide, which applies specifically to the use of one simulation

facility for more than one nuclear power plant unit.

[ h. Comment-109-10 requests that for dual plants with mirror image con-trol rooms, a simulator referenced to either unit should be satisfactory for operating examinations and, therefore, should be so specified in the regulatory guide,

~

f- 1. Comment'32-35 states, for a facility that wants to use a simulation

facility for more than one unit, the burden of proof of "significant dif-

i. ference" is the responsibility of the utility. The commenter indicates j that for cases where the facility has already demonstrated that these 14

N differences are small and the NRC has issued a multiunit license, addi-tional justification should not be required.

Resolution: Not every multiunit plant has each unit of the same ven--

dor _and/or vintage. Specific guidance is provided in RG 1.149 for those utilities 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. The guidance.provided in the regulatory guide on this. issue is essentially the same as that provided for the issuance of multiunit operator licenses.

9. Miscellaneous comments to RG 1.149 are listed below.

a. Comment.5-9e recommends deletion of " abnormal conditions" and "ab-

. norma 1 ' evolutions" from position C-7. ,

Resolution: This regulatory position has been deleted in its entirety.

i' b. Comment 67-29 suggests that review of the simulator against the refer-enced plant be on an as-needed basis.

Resolution: Disagree. 'The need for an annual review was recognized by its inclusion as a requirement of ANS 3.5. The Commission has endorsed ANS.3.5, including this requirement.

c. Comment.5-9d recommends no changes to position C5.

' Resolution: Noted. Although position C5 has been deleted, the intent remains the same, since each unit of a multi-unit plant _has a speci-fic docket number.

d. Comment 28-27 suggests deletion of the last sentence of Regulatory Position 8.

Resolution: Regulatory Position C8 has been rewritten. It is now y

Position C4. This statement is made specifically to provide a time-base against which the annual review should be performed, and there-fore has not been deleted. The timing for the annual reviews has-been changed, however, to indicate that they need not begin until after a certification on an application for approval of a simulation facility has been submitted.

e. Comments 31-70, 45-70, 46-70, and 62-70 request a modification to permit flexibility in the use of simulators after initial approval of the ,

simulator.

f. Comments 31-69, 45-69, 46-69, and 62-69 suggest a change to state that the simulation facility should be in general (vice full) compliance with the requirements of ANSI /ANS 3.5. This change will allow flexibility

, to use the simulator until recent changes to the plant that have not been t-installed in the simulator can be accommodated.

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g.

Resolution: It is.the Commission's1 intent to allow' flexibility while establishing a uniform requirement applicable to all.. The preamble to the rule has been written to reflect this~ position.

g. ' Comments 28-28, 51-14, 67-31, and 132-1 state the annual 25% per .

formance retest would not provide meaningful information. Verification

.of modification and overall performance would be more significant.

Resolution: .-The ' Commission' 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 list of malfunction tests specified in ANS 3.5, to the extent applicable

.to the facility. The Commission 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' simulation facility remains acceptable;over time.

E

h. Comment 86-8 questions whether research reactor operators will be required to meet the 4 year performance test outlined in RG 1.149.

$- i. Coment 130-1 states that the guidance provided in the regulatory

guide is not appropriate for non power reactor facilities.

! Resolution: It is_not the intention of these regulations or regu-2 latory guidance to change the way in which test and research reac-4 tors are regulated. The appropriate clarifications has been made.

.j. Comment 131-14 states that the schedule requirements are clearly unrealistic and the section should be deleted.

k. -Comments 31-68, 45-68, 46-68, 62-68, 100-5, and 104-4, request a change from 3 to 4 years as a time requirement from which the non plant walkthrough portion of the operating test will not be administered on

'l other than an approved simulat'on facility.

, _1. Coment 32-33 requests an extension of time for simulation facility approval. Thre'e years is the generally accepted lead time for plant-specific simulators and would not allow sufficient time for delivery and NRC approval.

Resolution: The rule has been changed to permit 4 years, rather than 3, and the applicable sections of the regulatory guide have been changed accordingly.

m. Coments 21-5 and 27-5 are restatements of question 5 in the proposed rule with no responses provided by the comenter.

i Resolution: Noted.

(

n. Coments 31-61, 45-61, 46-61, 62-61, and 104-3 discuss the inappro-priate use of the term " requirements" and recommend replacement with l i

"in conformance with."

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- , . c.._ .,.,,_ _ _.___ _ ._._._ _.____._.--__._ _ _ ___ _. _ _ _ ,__ -.

_ . . _ __ 4 _ . _

~

Resol'ution: -Disagree.

o. Comments 31-65, 45-65, 46-65, and 62-65 suggest that Regulatory Posi- >

tion-3 be-deleted in its entirety.

Resolution: Regulatory Position 3 has been. rewritten, and is now Position 2. It has been_ changed to indicate that all_ simulation facilities as defined in SS 55.4 should meet'the applicable require-ments of the standard.

l. p. Comment 109-1 states that it should be recognized that the most'im -

portant use of ' simulators is to promote analytical ability, particularly under abnormal conditions, and not to encourage rote response to particular .i alarms.

Resolution: Noted.

q. Comment 109-9 states that parts of the regulatory guide reiterate portions of 10 CFR 55.45.

Resolution: These restatements have been deleted.

r. Comment 104-5 states that it is difficult to believe that it is the Commission's aim to prevent safe, efficient operation of a nuclear power plant because a training device is inoperable or does not meet all of the NRC-imposed requirements. This statement is made in relation to item 3 of section D. The item should be modified as it is unduly restrictive.

Comment 46-89 also requests modification of 10 CFR 55.59(c)(4)(iv) on the

, same basis.

-Resolution: Item 3 of Section D has been deleted.

It is the Commis-sion's intent that every facility licensee have available a simulation facility that meets the Commission's regulations, and-that, once avail-able, the simulation facility be maintained 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 unac-

! ceptable for the conduct of operating tests. It is the Commission's intent to address such situations on a case-by-case basis.

s. Comments 7-1, 31-60, 45-60, 46-60, 62-60, and 104-2 question the validity of the findings of the staff in reference to information gathered

- on non plant referenced simulators. The commenter questioned whether training programs have been approved that do not conform to acceptable practice.

2 Resolution: The Commission supports the staff's findings of the re-sults of examinations given on non plant-referenced simulators, as

, discussed in the regulatory guide. The second comment is outside the scope of the present regulations and regulatory guidance.

I t. Comment 118-4 believes that normal simulator audits should be con-

ducted by the same NRC licensing examiners that conduct operator testing at the facility.

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_ . _ , _ , , _ _ ,~.___ _ _ - . . _ . , . . _ . _ _ _ . _ . _ _ _ - . - ~ - _ - - - _ _ _ _ . _ _ _ . -

Resolution: Noted. The review or audit of a. sophisticated simulator requires expertise in several disciplines. -A study is being conduc-ted for the NRC, one purpose of which is to define the expertise needed by members of a simulation facility evaluation ~ team. It is

, likely that the discipline of licensing examiner will be recommended

for inclusion.

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C. _' Regulatory Guide 1.8,:" PERSONNEL QUALIFICATIONS AND TRAINING FOR NUCLEAR POWER PLANTS"

1. Comments 4-3, 4-4', 31-47,345-47, 46-47, 62-47, 119-2,1120-2, 131-2, and

, 134-2. request clarification of what positions will be covered by RG 1.8.

Comments 33-2, 43-2, and 90-4 also indicate a need for clarification.

Resolution: The introduction to'RG 1.8 has been expanded to include

reference to the " Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel" (50 FR 11147). As. stated in this poli-

.cy statement, the industry has commTEted to obtaining INPO accredita-tion of training programs for nuclear power plant personnel and the NRC has endorsed this process. Through this approach, both the indus-try and NRC have agreed that nuclear power plant personnel should have qualification requirements commensurate with the performance requirements of their jobs. Reference is also made to the commission

" Policy Statement on Engineering Expertise in Shift" (50 FR 43621).

This policy statement describes the qualifications of a diial role SR0/STA and defines the responsibilities of the STA.

Following publication of these policy statements and receipt of public comments on RG 1.8, the NRC decided that this revision to RG 1.8 will endorse Sections 4.3.1.1, " Shift Supervisor"; 4.3.1.2, " Senior Operator"; 4.5.1.2, " Licensed Operators"; 4.4.2, " Shift Technical Advisor"; and 4.4.4, " Radiation Protection" (including referenced sections)-of' ANSI /ANS 3.1-1981 and that ANSI /ANS N 18.1-1971 will'be endorsed-for all other positions.

2. Comments 31-47, 45-47, 46-47, 62-47, 67-20, 114-11, 119-1, 131-2, and 134-2 state that it appears that license applicants who have completed a training program accredited by INP0 do not need to meet the requirements of RG 1.8. This type of exemption of program requirements should be included in 10 CFR 55.

Resolution: The NRC will continue to approve operator training programs, as required by 10 CFR Parts 50 and 55.

3. Comment 13-22 states that RG 1.8, which endorses ANSI /ANS 3.1.-1981, exceeds the recommendations of NUREG-0737 and ANSI N18.1-1971. The more restrictive regulations make the task of achieving excellence in operator performance more difficult, i Resolution: RG 1.8 does not exceed the recommendations stated in j' NUREG-0737, but incorproates them. The purpose of RG 1.8 is not to produce "more restrictive regulations" but to incorporate existing guidance for operator qualifications in one place.

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4. Comments 31-45, 45-45, 46-45, 62-45, 95-1, 98-1, 106-1, 111-1, 112-1, 114-9, 118-1, 128-1, and 134-1 recommend that the NRC delay issuing RG 1.8 until the latest version of ANSI /ANS 3.1 is published. It makes little

! sense to endorse a 1981 standard which will soon be superseded. In the in-i terim, presently published guidance regarding training and qualifications l should be used.

19

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Resolution: A new version of ANSI /ANS 3.1 has not yet been published.

The experience requirements'are not significantly different in the

. proposed draft standard from those in the 1981 standard. The training requirements of the' draft standard clearly states that a ~ systematic

, approach to training shall be instituted, which .is the current indus-try commitment. Thus, RG 1.8 is consistent with the~ proposed version of ANSI /ANS 3.1.

. 5. ' Comment 94-1 states that the NRC should approve-INP0's training program rather than wait 2'or more years.

Resolution: The Commissioners directed the staff to withhold a rule on training for at least 2 years; in the interim, the NRC has endorsed INP0's accreditation program. At the end of 2-years, the staff will provide the Commissioners with an overall evaluation of the effects of accreditation on training in the industry.

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6. Comments 101-1 and 130-1 take exception to the application of RG 1.8 to nonpower reactor personnel. A request for a disclaimer exempting nonpower reactor personnel-is suggested.

I

~ Resolution: RG 1.8 endorses ANSI /ANS 3.1-1981, which applies only to nuclear power plants. Test, training, research, and mobile reac-tors are excluded. RG 1.8 has been revised to include a statement-

specifically excluding nonpower reactors.

7. Comment 133-1 suggests that the INPO accreditation process be addressed

as an acceptable program for determining training needs for personnel.

l The regulatory guide should focus on selection and qualification and

leave specific job-related training requirements to be identified by the

[ systematic approach to training.

Resolution: The INP0 accreditation process has been endorsed by NRC

in the policy statement (50 FR 11147) as an acceptable program for training operators for a 2 year evaluation period.

8. Comments 31-46, 45-46, 46-46, 62-46, 113-1, 114-10, 116-1, 122-1, and i 129-1 discuss the requirements in ANSI /ANS 3.1 for shift supervisors to

obtain 60 semester hours of college level education and for senior opera-l tors to obtain 30 semester hours of college level education. RG 1.8 must include an exception to the endorsement of ANSI /ANS 3.1, which deletes the j semester hours requirements.

Resolution: Agree, an exception to these requirements has been added c to the regulatory guide.

9. Comment 127-1 requests that an acceptable method for determining and docu-menting compliance for contractor personnel be included in this regulatory

. guide.

L Resolution: Guidance regarding contractor personnel is no longer in the regulatory guide.

20

10. _ Comment 97-1 points out a problem in item C-1 of the regulatory guide in that it identifies other documents to be included as part of ANSI /ANS Standard 3.1-1981, when, in fact, the standard only mentions ANS standards and does not include them as a part of its guidance.

Resolution: The comment is noted and C-1 has been deleted.

11. Comments 13-23, 31-48, 45-48, 46-48, 62-48,107-1,114-12,127-2, and 134-3 suggest that relevant guidance be spelled out in item C-4 of the regulatory guide rather than referencing three or four separate NUREGs.

The present approach allows for unique interpretation of positions which evolved over several years.

Resolution: Agree, item C-4 has been rewritten to include relevant guidance (C.1.b.).

12. Comments 28-30, 31-50, 45-50, 46-50, 62-50, 80-11, 90-3, 107-2, 114-14, 119-3, 133-3, 134-5, and 135-1 indicate that the present definition of 4 years of responsible power plant experience in item C-6 is confusing and overly restrictive. It is recommended that the sentence "A maximum of two years of responsible power plant experience may be fulfilled by aca-demic or related technical training on a one-for-one basis" be changed to read "A maximum of two years of responsible power plant experience may be fulfilled by academic or related technical training, or nuclear power plant auxiliary operator experience on a one-for-one basis." Comments 6-3, 10-1, 13-25, 15-1, 17-1, 51-10, 69-17, and 99-1 express concern with the substi-tution of a college engineering degree for operator experience in qualify-ing for an SR0 license. There also is concern that this policy will lead to unsafe operating conditions. Comment 61-3 states that NUREG-0737 re-quires 1 year of experience and should be retained instead of the proposed resented in R.G. 1.8. Comment 114-1 requests the addi-experience levels p'as a power plant technical or training staff member tion of the words involved in the support of day-to-day facility operations" to item C-6, line b. Comment 114-2 states that it would be inappropriate for the NRC to not allow utility management the prerogative to license personnel with-out a degree as " instant" SR0s.

Resolution: The words in C-6 (now C.1.e.) are the same as those used in the March 28, 1980 letter to all licensees from Harold R.

Denton concerning " Qualifications of Reactor Operators," as published in NUREG-0737. Waivers to the guidance may be obtained from the NRC Operator Licensing Branch. It is not the purpose of RG 1.8 to change existing guidance, but only to incorporate all existing guidance on operator qualifications.

13. Comment 127-3 recommends C-6 be rewritten to reference NUREG-1021 as the definitive listing of acceptable experience.

Resolution: NUREGs are not referenced in the regulatory guide because NUREGs may be revised without the benefit of public comment.

14. Comment 13-26 states that much success has been achieved with previous fossil plant or Navy nuclear control room operators as instant SR0s.

Why then does the NUREG limit " instant" senior reactor operators to 21

engineers with degrees? Comment 76-12 requ'ests appropriate experience allowance for U.S. Navy Machinist Mates who were watch-standees outside the control room.

Resolution: RG 1.8 is not changing existing guidance on eligibility requirements for control room operators.

15. Comment 12-1 requests a special restricted SR0 license requiring a pre-determined number of hours in the control room as an R0 before the SR0 license becomes valid.

Resolution: The NRC does not give probationary licenses.

16. Comment 94-3 states that the Commission is wasting the taxpayers' money in licensing engineers who, in fact, have no intention of operating the plant.

Resolution: The need for an R0 or SR0 license for an employee is determined by the facility. The management of each facility is given the prerogative to staff the facility in a way deemed appropriate to the facility, as long as minimum NRC staffing requirements are met.

17. Comment 107-4 is seeking guidelines for satisfying the requirement for 6 months of operating experience at the nuclear power plant for which the applicant seeks a license and requests that time in training counts toward the 6 months.

Resolution: It is the intent of this requirement that the applicant has been at that nuclear site for 6 months, therefore, training time counts.

18. Comments 67-21 and 107-5 request provisions for a special SRO to upgrade to a full SR0 license after 1 year of experience as a simulator instructor or after completion of an INP0-accredited training program.

Resolution: In recognition of the industry commitment to INPO accredi-tation of training programs, which includes review of instructor quali-fications and in keeping with the intent of the " Policy Statement on Training and Qualifications of Nuclear Power Plant Personnel" (50 FR 11147), the NRC is deferring the implementation of special senioF licenses. Industry efforts in implementing instructor qualifi-cation programs will be monitored as directed by the policy statement.

19. Comments 13-27, 28-31, 31-51, 45-51, 46-51, 51-11, 62-51, 67-22, 77-10, 107-6, 114-3, 114-15, 119-4, 120-3, 126-1, 127-4, 131-4, 133-4, and 134-6 refer to item C-7 and the statement that instructors who teach systems, integrated responses, and the like, are required to complete a senior reactor operator or special senior reactor operator certification examination.

22

' Resolution: 'In' recognition of industry commitment to INPO accredita-tion of. training programs, which includes instructor training, quali-fication and evaluation, and in keeping with the intent of the " Policy Statement on Training and Qualifications of Nuclear Power Plant Per-sonnel" (50 FR 11147), the NRC is deferring the implementation of special senioF licenses for instructors and fuel handlers. Industry efforts in implementing instructor qualification programs will be monitored as directed by the policy statement. Therefore, C-7 has been deleted.

20. Several comments (as listed in a through d below) concerned the position

~of shift technical advisor (STA).

(a) Comments- 13-24, 31-49, 31-52, 43-2, 45-49, 45-52, 46-49, 46-52, 51-9, 62-49, 62-52, 69-16, 77-10, 81-14, 90-4, 114-13, 123-2, 133-2, 134-4, and 134-7 state that. items-C-5 and C-8 should be rewritten to reflect the Commission's forthcoming policy statement on engineering expertise on shift for all matters relating to the requirements for STAS.

Comments 76-13, 107-7,'113-2, 116-2, 122-2, and 129-2 request a definition of " acceptable alternative" with respect to STA education requirements.

Resolution: Concerning the STA, C-5 and C-8 have been rewritten (c.1.J.) to reflect the " Policy Statement on Engineering Expertise on. Shift (50 F_R 43621)

(b) Comment 131-3 points out inconsistency in wording between items C-6 and C-8, " engineering or equivalent" and recommends the words be changed to " engineering or acceptable alternative." Comment 61-4 recommends that the regulatory requirement be consistent with the "NRC Policy Statement on Engineering Expertise on Shift." Comment 76-13 indicates that ANSI /-

ANS 3.1 educational requirements for STAS should be identified as an acceptable alternative to a bachelors degree in R.P. C-8.

Resolution: C-8 has been rewritten (C.1.j.) in accordance with the final Policy Statement on Engineering Expertise on Shift (50 F_R 43621).

(c) Comments 31-52, 45-52, 46-52, 62-52, 69-18, 107-8, 113-3, 114-16, 120-4, 127-5, and 134-7 refer to C-8 and request clarification of the meaning of " performing the STA functions." Several commenters disagree with the 30-day requirement and suggest alternative time requirements.

One commenter also requests that the requalification training needed for an STA to resume duties be specified. Comment 119-5 recommended that -

the STA requirements be the same as for licensed operators.

Resolution: Actively performing STA functions means performing at least three shifts per quarter as the STA. If an STA has not actively performed, then the STA should receive training sufficient to ensure that the STA is cognizant of facility and procedure changes that occurred during the absence. The RG 1.8 has been revised accord-ingly and the sentence concerning requalification training has been deleted.

(d) Comment 8-6 recommends that item C-8 be revised to require persons serving as an STA to pass an NRC-administered examination equivalent to 23

that for senior reactor operators. This will enhance the credibility of '

this position.

Resolution: The Commission may consider such an examination in the future. No new rulemaking will be undertaken until after the accreditation program relative to the STA has been fully evaluated.

21. Comment 131-6 recommends that the third line of item C-9 be changed to read ". . . include training in the use of installed plant systems for the control and/or mitigation of an accident in which the core is severely damaged."

Resolution: C-9 has been reworded (c.1.f.).

22. Comments 13-28, 31-53, 45-53, 46-53, 62-53, 114-17, and 123-3, 134-8 suggest item C-10 should be applied to hot license applicants onl Coment 123-3 requests a definition of "an extra person on shift"y.as applied in C-10. Comments 126-2 and 6-4 suggest deletion of all refer-ences to length of time in C-10 because they believe there is no justi-fication to require 3 months of on-shift training.

Resolution: Existing guidance on operator qualifications in NUREG-0737 applies (C.1.g.).

23. Comments 6-4, 31-54, 45-54, 46-54, 62-54, 67-23, 76-14, 101-1, 107-9, 113-4, 114-4, 114-18, 116-3, 119-6, 122-1, 122-3, 123-4, 125-1, 126-3, 129-3, 134-2, and 135-2, concern reactivity manipulations. Several com-menters requested the term "significant" in relation to reactivity change manipulation be defined in C-11. Further, several of the commenters in-dicated that these manipulations should be acceptable, if performed on a plant-referenced simulator.

Resolution: Examples of significant control manipulations include:

startups, shutdowns, large load changes and changes in rod programming are some examples and could be accomplished by manually using systems such as rod control, chemical shim control, or recirculation flow.

Reactivity control manipulations are intended to be performed at the plant for the purpose of gaining actual operating experience (c.1.h.).

These issues are also addressed in revisions to 10 CFR 55.33(a)(5).

24. Comments 31-55, 45-55, 46-55, 62-55, 114-19, and 134-10 request that item C-12 clearly states that the 6-month period of practical work assignments can be conducted concurrently with other duties or training. Comment 120-5 states the 6-month program of minimum work assignments, in addition to the approved cold license program, does not contribute meaningfully and should not be imposed.

Resolution: Participation in 6 months of practical work assignments is current guidance for cold license applicants. These assignments are intended to be an experience requirement and, therefore, should not be part of training. NRC's position is that cold license appli-cants shall have a 6 month experience requirement in addition to an NRC-approved training program. This requirement provides the applicant with hands-on plant experience.

24

25. Comments 13-29, 100-2, 114-5, and 123-5 suggest removal of item C-13 in its entirety.

Resolution: C-13 has been deleted.

26. Comments 13-30, 107-10, 77-11, 81-15, 69-19 and 97-2 recommend that C-14 only apply to " individuals performing fuel handling activities," and comments 31-56, 45-56, 46-56, 62-56, 114-20, and 134-11 recommend that C-14 be deleted.

Resolution: C-14 has been deleted.

27. Comment 11-1 agrees with the proposal in item C-15.

Resolution: The comment has been noted.

28. Actively performing: Numerous comments (as listed in a through f below) were made on the topic of actively performing the functions of a reactor operator or senior reactor operator.

(a) Comments 107-3 and 123-1 seek a definition of the terminology

" actively performing."

Resolution: A definition of actively performing the functions of a reactor operator or senior reactor operator has been added to 10 CFR 55.4.

(b) Comments 4-2, 8-2, 28-32, 31-57, 45-57, 46-57, 62-57, 69-21, 51-12, 67-24, 76-15, 77-12, 80-4, 80-5, 86-6, 90-5, 91-5, 94-4, 97-3, 107-11, 113-5, 114-6, 107-14, 114-8, 114-21, 116-4, 123-6, 119-7, 120-6, 121-1, 122-4,127-6,129-4,131-7,131-8,133-5, and 134-12 object to the require-ment of C-15 to have licensees " actively performing" as an operator. The requirements would essentially remove licenses from anyone who is not in the operations organization. Several alternative lengths of time of per-formance are suggested. Comments 76-15 and 120-6 request that the 8-hour per month of license duty performance to maintain active status be allowed to be performed on a plant-referenced simulation facility. Comments 67-23, 80-5, 81-16, 90-5, 94-5, 114-7, 123-6, 131-8, 133-5, and 134-12 state that the current options to allow the facility licensee to certify that satisfactory knowledge and understanding exist before to resuming duties is sufficient and that the Commission should not be involved in the determination.

Resolution: 10 CFR 655.4 has been modified as follows: " Actively performing the functions of an operator or senior operator means that an individual takes responsibility for and carries out a position on the shift crew which requires the subject license as defined in the facility's technical specifications." S55.53(e) indicates that for a license to remain active, the licensee must actively perform the functions of an operator or senior operator for a minimum of seven 8-hour shifts or five twelve-hour shifts per quarter.

C-15 has been deleted.

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(c) Comment 69-20 suggests that C-15 should clearly state that " actively performing functions of an operator" should apply both to " conditions of licenses" and " renewal of licenses." Comment 13-31 suggests that C-15 should only apply to " conditions for licenses" and not to " renewal of licenses."

Resolution: C-15 has been deleted. The requirement is in 10 CFR 55.

(d) Comment 97-4 states that the requirement for all departments to pro-vide input to operator retraining is overly restrictive and burdent,ome.

Familiarization with new procedures, plant modifications, and other current events specified by the training department should be adequate for operator requalification.

Resolution: C-15 has been deleted.

(e) Comment 107-12 requests the following phrase be added to the end of C-15: "or functioned in a position that normally requires the licensed individual to maintain current knowledge of actual plant conditions and participate in overall plant operations on a periodic basis to a depth consistent with that required of licensed operators or senior operators on-shift."

Resolution: C-15 has been deleted.

(f) Comment 127-7 recommends that the " update" training referred to in C-15 should be clearly identified as performance-based training.

Resolution: C-15 has been deleted.

29. Comment 120-1 states that comments were generated under the assumption that positions indicating an action "should be accomplished" were specifi-cations of requirements as opposed to a discretionary, justified action.

Resolution: This assumption is correct.

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l 26 l

m_. _ . . , _ m _ .4 _ ___ .._; . - _ . _ .-

!!!. INOtX OF SPECIFIC COMMENT 5 Resolved By Resolved By Resolved By Resolved By Enclosure inclosure Enclosure Enclosure Sammini R2 I12 t E.L.11.L 1emaal h llt AL.JI.t .

1-1 F2a. 813. N8 5 9j B21 2-1 A1 5 9k 88c tot 01 5 10 A3q 2-3 F2d 5-11, Elb. E2 24 64 5 12 Resolved 8y 25 84 Resolution of Comments 2-6 44 5 ta. 5 9c. 5 lh and 5 9k 27 D7 6-1 F12 i 28 Elec 82 A3o .

29 11 63 04 C12 31 18d 64 D4 C22. C23 4-1 A3d 7-1 89s j 4-2 C28b 7-2 Ele 43 C1 7-3 E181 44 C1 74 Elij 5-1 Elb 75 MS 52 Ellb 78 D4 l 53 Elg 81 A1

! 54 tid 82 C28b 55 E13a 83 F7 54 tif. Elsa 84 F7 57 E11b 85 F8 58 82f 86 C20d 5-9 88e 87 F3 5 94 A3b 94c 51 A3w '

5 9b 52b 91 F2a 5 9c B2a 93 B2

)

5 9d BSc 94 H7 ,

5 9e 89a 95 H7 i

l 5 9f 82h 98 82 1 5 9g 821 9-7 C4 5 lh 32e 98 H7 ,

5 91 S2a 99 09

t Resolved By Resolved By Resolved By Resolved By inclosure Enclosure Enclosure inclosure j Cannant 31.lh M tammant 11.111 C1_111

, 9 10 09 13 16 E13a 9 11 D9 13 17 Elf 8-12 D9 13 18 E4 9 13 E18b. N7 13 19 E10f 9-14 D9

' 13-20 -

84b 9 15 F2d 13 21 ,

• A3p 9-14 M7 13-22 C3 9 17 83 13 23 C11

! 9 18 42 13-24 C20s j 9 19 42 13 25 C12 9 20 82 13 28 C14 >

9 21 42 13 27

- C19 9 22 42 13 28 -

C22

9 23 82 13 29 C25 i 10 1 C12 13 30 C26

{ 11-1 C27 t

13 31 C28c 11 2 D156 13 32 F8

! 12 1 C15 13 33

. Big 13 1 13 13 34 B2m 13 2 F2d 13 35 Sto i

13 3 D4 13 38 B2k 13 4 83 13 37 844 13 5 D1 14 1 810 13 6 D1 14 2 81 i 13 7 D10s 14 3 F13 13 8 Elb 14 4 01 13 9 017 14 5 01

) 13 10 F2b 14 8 01 i 13 11 F6 14 7 010d I 13 12 Fil 14 8 010e j 13 13 83 14 9 Of .

j 13 14 810 14 10 09. 015b

) 13 15 82 j

14 11 Of i

i______ -

. _ _ _ . _ _ _ . . . _ . _ _ _ _ u. .

e e Resolved By Resolved By Resolved By Resolved By Enclosure inclosure inclosure inclosure Cannant RL lh tt 11 Cm ment R1_111 M ~

14 12 F2d I

19-16 F1b '

14 13 A3u, 83 19-17 F1b

14 14 48 19-14 F1b 14 15 82 19-19 A3u, A4, Al 14 16 11 19 20 A3j l 14 17 12 19 21 F1b i 14 18 13 19-22 F2d 14 19 13 19-23 F1b 15 1 C12 19 24 F1b 16 1 D6 19 25 83 16 2 N8 19 24 F2c 16 3 F3 19 27 C1, C2, C3, F2b 18 4 F11 19 28 HC l 17 1 C12 19-29 F1b (

17 2 F3 19-30 C1 18 1 M8 19 31 02 i 18A 1 E8e 19 32 013 14A 2 813. He 19 33 02 i

i 19 1 010d 19 34 F1b 19 2 04 83c 19 35 D2 19 3 Ble, 83e 19 34 09 19 4 Ella 19-37 09 19 5 112b 19 34 09

^

! 19 4 112b 19 39 09 19 7 A3e 19 40 010d 19 8 88f 19 41 0104, 010b 19 9 Elle

• 19 42 A3b  :

19 10 '

Bla 19 43 E13a ,

l 19 11 87e 19 44 Ela t 19 12 H5 19 45 017 l 19 13 H6 19 46 F2b ,

l 19 14 81a 19 47 F11 l 19 15 F2b F2d 19 48 F13 l

l

s Resolved By Sesolved By Resolved By Resolved By inclosure inclosure inclosure inclosure SGRE80.1 82 II2 S.L.lh 111h Cam 8nt 1.L.lh

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19 49 F2b 22 1 F2c 19 50 F2h 22 3 F2b 19 51 81a 22 4 D1 '

19-52 81a 22 5 F2h 19 53 81a 22 6 F3

, 19 54 81a 23 1 13 19 55 84 23 2 F1b 19 56 82 23 3 F13 19 57 82 23 4 B3 19 58 82 23 5 01 19 59 M7 23 8 011 19 60 13 23 7 015 20 1 H4. 14 23 8 D10a 20 2 F2b B3c 23 9 D9, 113a 20 3 A2, B3e 23 10 E14b 21-1 12 23 11 Elb 21 2 13 23 12 017 21 3, B7 23 13 F6 21 4 C4 23 14 13 21 5 C7 59m 23 15 81e 21 6 C4 24 1 Al 21 7 Fla 24 2 F7 21 8 014 25 1 H4 21 9 014 25 2 A2 21 10 A3v 26 1 01 21 11 El6 f, 015b 26 2 01 21 12 Elid 26 3 Elif D15b 21 13 81d 26 4 Elb 21 14 82 26 5 Ella 21 15 Bab 26 6 E6b 21 16 E16d, F1b 26 7 83 21 17 H4 26 8 F3 .

22 1 A3b 26 9 F12

Aesolved By Resolved By Resolved By Resolved 8y Enclosure Enclosure Enclosure Enclosure 19M8D.1 SL11.L S.L111 1928D1 at Iff fdfl1 26-10 F12 28 22 Sla 26-11 42 28 23 Sla 26-12 82 28-24 82 ,

26 13 F2h 28-25 82 27-1 Elb 28 26 81f

. 27 2 Elb 28 27 B9d 27-3 Ella 28 28 09g 27-4 E10e 28-29 F7 27 5 59m 28-30 C12 27 6 A3p 28 31 C19 27-7 017 28 32 C28b 27 8 F2d 29 1 B4 28 1 Elb 30 1 H5 28 2 Elb, F2b, Sla 30 2

• F2d 28 3 E8g 30 3 F2d 24 4 E8h 30 4 F2d

28-5 83a 30 5 012

, 28 6 Fla 30 8 A3s, E8s 51b 28 7 F1b 30 7 El 28 8 F1d ,

30 8 E81 28 9 56 30 9 B1d 28 10 83 30 10 A3b Fla 28 11 33 30 11 A8 28 12 01 30 12 F2c 28 13 F1b 30-13 H7 1 28 14 01 30 14 08 28 15 010d 30 15 D1 l

28 16 D10s 30 16 01 ,

28 17 Elb 30 17 010s, 010b f

! 28 18 Ol6c 30 18 A3g 28 19 D17 30 19 F2b 28 20 F2h 30 20 F7 28 21 F7 30 21 82

Resolved By Resolved By Resolved By Resol.ved 8y Enclosure inclosure Enclosure

, Enclosure 195801 21,.111 11.111 Comment 31.,111 CLil;

.~

i 30-22 F7 31 33 D17 31-1 HS 31-34

' F1b, F2d 31 2 Fla F1b,Flc 31-35 F6 31-3 D1 31 36 F7 31 4 Ela, Illa 31-37 Fil 31-5 Fla,'F2d 31-38 83 i 31 6 D1 31-39 F7 i 31-7 Elb 31-40 Gla 31-8 Elb 31-41 i 81f l 31 9 Ela 31-42 42

31-10 Ella 31-43 82 31-11 Il0e 31-44 E14b 82 '

{ 31-12 83d 31-45 -

C4 l 31-13 A3n 31 46 C8 1

31-14 F1d 31-47 C1, C2 1

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, C20c 31 20 F2e 31-53 C22 i 31-21 D1 31-54 C23 31-22 D1 31-55 C24 1

31-23 013 31 54 C26 31-24 Flc 31 57 C28b j 31 25 D1 31 58 l All 31 26 D10a 31 59 A5

31 27 113a 31 60 82c 88c 89s i

31 28 Elb 31 61 89n 31 29 Esc 31 62 Saf 31 30 16b 31 63 88d 31-31 114b 31 64 i

88d ,

31-32 F2d 31 65 890 t

l l

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment Bt 11: c: II: Comment B II: c II:

31-66 B5b 32-29 A4b 31-67 B6a 32-30 Bla 31-68 89k 32-31 B7c 31-69 B9f 32-32 B8f 31-70 B5c. 59e 32-33 891 32-1 Al 32-34 B6a 32-2 Elb 32-35 881 32-3 810 33-1 Al 32-4 09. 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 82 32-12 D9, D11 33-10 82 32-13 09 34-1 F3 32-14 D9 34-2 F2d 32-15 D9 34-3 A3g 32-16 010d 35-1 D2 32-17 D10a 35-2 D2 32-18 D15 35-3 D1 32-19 Elb 35-4 D1 32-20 E14b B7c 35 5 09 32-21 F13 35-6 010d 32-22 A3u 35-7 A3v 32-23 Gla 35-8 E13a 32-24 F2b 35-9 Elf 32-25 82 35-10 E10c 32-26 12 35-11 017 32-27 A9 35-12 F2b 32-28 A10 35-13 -

F2d

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment Br II: $1_11 Comment B II: Cr II:

35-14 F2d 36-26 A3e 35-15 F4 37-1 Elb, F2d 35-16 F6 37-2 Fla, Fic 35-17 Fil 37-3 D1 35-18 11 37-4 Elb i 35-19 F13 37-5 F1d 35-20 A3u 37-6 D1 35-21 A3u 37-7 01  !

36-1 D10d, H7 37-8 F2b 36-2 HS 37-9 F2b 36-3 E13a 37-10 M7 l 36-4 52j 37-11 D1 36-5 Ella 37-12 010d 36-6 E10e 37-13 E16g 36-7 B3a 37-14 Ele l 36-8 A3p 37-15 Ella

36-9 F2d 37-16 E6d 36-10 A6 37-17 F7 36-11 810 37-18 Fil l 36-12 F2c 37-19 81a

! 36-13 F2b 34-1 A2

! 36-14 F2c 38-2 A4c

! 36-15 D1 38-3 A2 I

36-16 D13 39-1 010d

! 36-17 D1. E16h, F2b, 39-2 D4 B3c l 36-18 D10d 39-3 ble, B3e ,

36-19 D10d 39 4 E13a 36-20 E13a . 39-5 E12b l 36-21 E8e 39-6 E12b 36-22 F13 39 7 A3e 36-23 Gla 39-8 88f j 36-24 Gla 39-9 E16e 36-25 82 39-10 Bla

1 Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment, er IIr cr II: Comment er 11: ct IIr 2 .

39-11 B7e 39-44 Ela 39-12 H5 39-45 017 39-13 N6 39-46 F2b l 39-14 Sta 39-47 Fil l 39-15 F2b. F2d 39-48 F13 39-16 F1b 39-49 F2b i

39-17 F1b 39-50 F2b l 39-18 F1b 39-31 Gla, I i 39-19 A3u, A4, A5 39-52 81a

, 39-20 A3j 39 53 81a -

4 39-21 F1b 39-54 81a

) 39 22 F2d 39 55 64 39-23 F1b 39-54 82 f l

39 24 F1b 39-57 42 .

j 39 25 B3 39-54 62

39-26 F2c 39-59 H7  ;

! 39-27 C1, C2, C3, F2b 39-60 13 l 39-28 He 40 1 88  ;

l 39-29 F1b 40-2 A2  !

39 30 C1 40 3 015a  !

l 39 31 02 40-4 85 l j 39-32 013 40-5 B8 39 33 D2 41-1 13 l l

l 39-34 F1b 41 2 Flc, F2d  ;

I 39 35 02 41-3 E13a l l 39 36 09 41-4 Elb i

! 39 37 D9 41-5 E8b,E8j i 39 38 09 41 6 F6 l

l 39 39 09 41-7 F11 i 39-40 010d 41 8 03 l 39 41 010a, D10b 42 1 D1 -  !

l 39 42 A3b 42 2 D1 l 39 43 E13a 42 3 F2b  !

1 l i

....__.m....,__, ---__..m.,_.,..,_,.-.._ ._, , . _ _ . . . . _ _

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure M Br II Cr II: Co u nt Br II: Cr Ilt 42-4 010c 45-16 A3b,A3j 42-5 010c 45-17 A3b, A3n 42-6 A3k 45-18 B6 42-7 Fla, H7 45-19 B3 42-8 F2d 45-20 F2c 43-1 Flc 45-21 D1 43-2 C1, C20s 45-22 D1 43 3 13 45 23 D13 43-4 F1b 45-24 Flc 43-5 D15 45-25 01 43 6 D10a 45 26 'D10a 43-7 A3a, Elc, E13a 45 27 E13a 43 8 017 45-28 Elb 43-9 B3 45 29 E8c 43-10 F7 45 30 E6b 43-11 83 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 01 45-36 F7 45-4 Ela, Ella 45-37 F11 45-5 Fla, F2d 45-34 83 45 8 01 45 39 F7 45 7 Elb 45 40 Gla 45 8 Elb 45-41 81f 45 9 Ela 45 42 82 45 10 Ella 45 43 82 45 11 E10e 45 44 E14b, 82

) 45 12 B3d 45 45 C4 45 13 A3n 45-46 C8 j 45 14 F1d 45 47 C1, C2 45 15 A3t 45 48 C11

Resolved By Resolved By Resolves By Resolved By Enclosure Enclosure Enclosure Enclosure Co u nt R: II: Cr II: Conment Bt II Cr IIt 45-49 C20a 46-12 B3d 45-50 C12 46-13 A3n 45-51 C19 46-14 F1d 45-52 C20s, 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 53 45-57 C28b 46-20 F2c 45 58 A15 46-21 D1 45-59 A5 46-22 'D1 45-60 B2c, B8c, B9 46-23s D13 45-61 89n 46 24 Flc 45-62 88f 46-25 D1 45-63 88d 46-26 D10a 45-64 88d 46-27 E13a 45-65 89o 46-28 Elb 45-66 55b 46-29 E8c 45 67 B6a 46-30 E6b 45 68 B9k 46-31 E14b 45-69 89f 46 32 F2d 45 70 B5c, B9e 46-33 D17

, 46 1 H5 46 34 F1b, F2d i 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 83 46-6 D1 46 39 F7 I 46-7 Elb 46-40 Gla

46-8 Elb 46-41 G1f l 46 9 Ela 46-42 G2 46 10 Ella 46 43 G2 46 11 E10e 46 44 E14b, G2

4 Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment St_lh cr II: Comment Br II: c II:

46-45 C4 46-78 D9 46-46 C8 46-79 F2b 46-47 C1, C2 46-80 D10a 46-48 C11 46-81 E14b 46-49 C20s 46-82 F2b 46-50 C12 46-83 F14 46-51 C19 46-84 F2b 46-52 C20s, C20c 46-85 F2b 46-53 C22 46-86 H8 46-54 C23 46-87 82 46-55 C24 46-B4 ' 811 46-56 C26 46-89 89r 46-57 C28b 46-90 82 46-58 A15 46-91 H11 46-59 A5 46-92 11 46-60 B2c, 88c, B9s 46-93 46-61 89n 46-94 14 46-62 Bef 46-95 46-63 B8d 46-96 B5a 46-64 B8d 46 96a 56a, 86b, 86d 46-65 B90 47-1 H3 46-66 B5b 47-2 F2d 46 67 56a 47-3 F1b, F1d 46 68 B9k 47-4 53 46-69 B9f 47-5 01, H7 46-70 B5c, 39e 47-6 D9 46 71 C5, H7 47-7 09 46-72 H7 47 8 09 46 73 09 47 9 09 46-74 09 47 10 010a, D10d 46 75 09 47-11 010b 46 76 04 47-12 A3e 46-77 09. D11 47-13 E13a

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure

] Co m ts B II: C II: Co u nt B: II: C: II:

, 47-14 Elb 51-3 E13a 47-15 D16c 51-4 Elb 47-16 D17

• 51-5 E8b,E8j 47-17 F5 51-6 F6 l

47-18 Fil 51-7 Fil 47-19 FIS 51-8 G3 47-20 Gla 51-9 C20a l 47-21 Gla 51-10 C12 i 47-22 Gla 51-11 C19 47-23 Gla 51-12 C28b 47-24 64 51-13 B2m i 48-1 At 51-14 89g 48-2 F2d 51-15 B2m 48-3 B10 52-1 A1, F1d 48-4 D12 52-2 A3j i

48-5 D9 52-3 A3t 48-6 D9 52-4 F1b l 48-7 D10d 52-5 56.1 44-8 D10c 52-6 89 H7 l

48-9 81f 52-7 B4

! 49-1 D1, D14 52-8 83

! 49-2 D1 52-9 F2c ,

i 49-3 Elb, E15a 52-10 D3 I

49-4 Elb 52-11 D1 i 49-5 E6b 52-12 01 1

l 49-6 53 52 13 D3 49-7 F3 52-14 D1

[

l 49-8 F12 52-15 D3 49-9 F12 52-16 D1 h i 49-10 82 52 17 D10a l

50-1 05 52 18 A3e i 51-1 13 52 19 E13a 51-2 Flc, F2d 52-20 E13a l.

e"M-*' - - - -'emesw+wmWeeys-+en--*--v----e _ w %yyp.ng s w wimum-waw- -yw 7-- w , Fw- w ery' e-w M-g- C-*-

Resolved By Resolved By Resolved By Resolved By 4

Enclosure Enclosure Enclosure Enclosure

,Co m nt B II: C: II: Comment B: II: C: II:

t 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 B3 52-26 F2d 59-7 F3

! 52-27 F7 59-8 F12 52-28 G1b 59-9 F12

! 52-29 G7 59-10 G2 52-30 67 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 89 60-4 Elb 53-6 A3f 60-5 E6b

53-7 A3h 60-6 B3 l 53-8 E10d 60-7 F3 53-9 E10e 60-8 F12 j 54-1 D12 60-9 F12

) 54-2 F13 60-10 G2 55-1 H8 60-11 G2

55-2 89 60-12 F2b j 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 57-1 83a 62-4 Ela, E15a

! 58-1 B7a 62-5 Fla, F2d l 59-1 DI CZ 6 D1 62-7 Elb

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B: II: C II: Coment Bd C: II:

62-8 Elb 62-40 Gla

- 62-9 Ela 62-41 61f 62-10 Ella 62-42 G2 62-11 E10e 62-43 62 62-12 B3d 62-44 E14b, G2 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 62-50 86 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 62-26 D10a 62-58 A15 62-27 E13a 62-59 A5 62-28 Elb 62-60 82c 88c,89s 62-29 E8c 62-61 89n 62-30 E6b 62-62 B8f 62-31 E14b 62-63 88d 62-32 F2d 62-64 88d 62-33 D17 62-65 890 62-34 F1b, F2d 62-66 B5b 62-35 F6 62-67 B6a 62-36 F7 62-68 B9k 62-37 Fil 62-69 89f 62-38 63 62-70 B5c, B9e 62-39 F7 63-1 H5

4 i

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Consent B: II: C: II: Comment B: II: C,tlh

' ~

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 62 l

65-4 Elb 67-20 C2 65-5 E6b 67-21 C18 4 65-6 83 67-22 C19 65-7 F3 67-23 C23, C28b 65-8 F12 67-24 C28b 65-9 F12 67-25 B3 65-10 62 67-26 Big 65-11 62 67-27 A3v -

65-12 F2h 67-28 A3r 66-1 D1 67-29 89b 66-2 C6 67-30 B2m 66-3 15 67-31 B9g 66-4 D17 67-32 B2k 67-1 D1 67-33 B6a 67-2 13 68-1 G10 l

67-3 F1d 68-2 G10 67-4 83 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 l 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

4 Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comments .B: II: C: II: Comment B 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 G2 71-19 F7 69-15 F7, 13 71-20 Gla 69-16 C20a 71-21 Gla i

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 Elb 72-3 F2d 69-23 Elb 72-4 F2c 69-24 Ellt 72-5 F2b i 69-25 E10e 72-6 Flc 69-26 B3d 72-7 F2d 69-27 A3n 72-8 F2b 70-1 A2 72-9 E8e i 71-1 F2d 72-10 F2b 71-2 F1d 72-11 F2d

71-3 A3t 72-12 F9 l 71-4 F2d 72-13 F2d 71-5 B3 72-14 F2d 71-6 H8 72-15 F2d

, 71-7 D1 73-1 F1d, F2d i

71-8 D1 73-2 F1d 71-9 D13 73-3 A3t 71-10 D1 73-4 F2d 71-11 D1 73-5 B3 71-12 D9 73-6 H8 71-13 D9 73-7 D1 71-14 D9 73-8 . D1

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B: II: C: II: Connent B: II: C: II:

73-9 D13 74-18 F7 73-10 D1 74-19 F11 73-11 D1 74-20 F13 l 73-12 D9 74-21 F15 73-13 D9 75-1 B1g, B2d 73-14 D9 76-1 B3 73-15 D10a 76-2 D1 73-16 D10b 76-3 D10a 73-17 D16b, D16c 76-4 EL 4

73-18 F8 76-5 Ella 73-19 F7 76-6 Elg .

73-20 Gla 76-7 E6e 73-21 Gla 76-8 D17 73-22 Gla 76-9 F2b-73-23 64 76-10 F13 73-24 13 76-11 G2 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 l 74-13 D1 77-8 G3 74-14 D10a 77-9 13 1 74-15 D10b 77-10 C20a, C'9 74-16 D16b 77-11 C26 l 74-17 D17 77-12 C28b l

l

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B: II: C: II: Comment B: II: C: II:

~

77-13 Big 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 B2g 78-4 A3m 81-9 Big 78-5 F2d 81-10 B2m 78-6 F2d 81-11 B21 B2j 78-7 F2b 81-12 B2k 78-8 F1b, F2d 81-13 B6a 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 A3p 82-5 Elb 79-1 F2d 82-6 F3 80-1 H2 82-7 F7 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 81-2 E13a 84-5 B3 81-3 Elc 84-6 B3, F3

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B II: C: II: CQEntnt 8: II: C: II:

84-7 F3. F12 85-29 D17 84-8 F12 85-30 F6 84-9 62 85-31 G1g, G2 10 G2 85-32 G11 84-11 F2b 85-33 I2 85-1 86-1 88 85-2 H5 86-2 A2 85-3 A2 86-3 A2 85-4 F2d 86-4 A12 85-5 A12 86-5 89 85-6 B10 86-0 A4a, C28b .

85-7 B3 86-7 A2 85-8 C1 86-8 B9h 85-9 D1 87-1 F2d 85-10 D13 87-2 F2d 85-11 D9, D15a 87-3 B6, Elg 85-12 D9 87-4 B6 85-13 D9 87-5 D1 85-14 D9 87-6 D9 85-15 D10a 87-7 Ellb B2j 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 85-22 Elc 87-14 F12 85-23 E8f 87-15 G10 85-24 E12c 88-1 88 85-25 Elb 88-2 A2 85-26 E7 89-1 88 85-27 E6d 90-1 Elb 85-28 EK 90-2 F1b

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B II: C: II: Comment B: II: C: II:

90-3 C12 96-5 A4a 90-4 DI C1, C20a 97-1 CIO 90-5 C28b 97-2 C26 91-1 D1 97-3 C28b 91-2 D10d 97-4 616 91-3 86 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 61c 100-1 62 .

91-9 63 100-2 C25 91-10 Elb 100-3 A13 91-11 Elb 100-4 B7b 91-12 E10a 100-5 89k 91-13 E81 101-1 C6, C23 91-14 83d 102-1 A2 91-15 A3p 103 Endorsed letter #3 without 92-1 Al additional comment 92-2 D9, D12 104-1 88c 93-1 Alb All 104-2 B9s 94-1 C5 104-3 89n 94-2 H8 104-4 B9k 94-3 C16 104-5 89r 94-4 C28b 105-1 B3 95-1 C4 105-2 82 A8 95-2 B3c 105-3 A5 95-3 B3e 105-4 A3 95-4 E15a 105-5 A4a 96-1 83 106-1 C4 96-2 A8 106-2 B3c 96-3 A5 107-1 C11 96-4 A3 107-2 C12

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment 8: II: C: II: Comment B: II: C: II:

107-3 'C28a 112-2 53c 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 j 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 i

108-2 A6 114-8 C28b 109-1 B9p 114-9 C4 109 87d 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 B9q 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

u . _ _ _ _ __ ~ _ ._._.- __ . _ -

Resolved By Resolved By Resolved By Resolved By Enclosure Enclosure Enclosure Enclosure Comment B II: C: II: Comment B: II: C II:

116-3 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 B9t 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 122-2 C20a 131-2 C1, C2 122-3 C23 131-3 C20b I

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

v Resolved By Resolved By Enclosure Enclosure Comment B: II: C: II:

131-10 B1b, B2d -

131-11 83c 131-12 B2m 131-13 B6a 131-14 89j 132-1 B9g 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 C20a, C20c 134-8 C22 134-9 C23 134-10 C24 134-11 C26 134-12 C28b 135-1 C12 135-2 C23 l

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