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IN RESPONSE, PLEASE
REFER TO: M010928A

I. SECY-01-0125 - Final Rulemaking to Amend 10 CFR Part 55, "Operators' Licenses," Regarding Operator License Eligibility and the Use of Simulation Facilities in Operator Licensing; and Revision 3 of Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in Operator Training and License Examinations"

The Commission approved a final rule which amends 10 CFR Part 55 to allow the use of simulation facilities by applicants for operator and senior operator licenses to fulfill a portion of the required experience prerequisites as an alternative to manipulation of the controls of the actual plant.

Following incorporation of the changes in the attachment, the Federal Register notice should be reviewed by the Rules Review and Directives Branch in the Office of Administration and forwarded to the Office of the Secretary for signature and publication.

The staff should reassess the draft press release and Congressional letters pertaining to the final rule to ensure these documents clearly convey the NRC's basis for the rule change and adequately discuss the rule change within the context of the NRC's extensive operator training and licensing requirements. The documents should adequately reflect the significant improvements that have occurred in simulator technology since 1987.

Attachment: Changes to the Federal Register notice in SECY-01-0125

Attachment

1. On page 3, paragraph 1, revise line 1 to read ' ... the Commission's regulatory position was that ....'

2. On page 3, last paragraph, revise line 1 to read 'Since After 1987, simulation technology has allowed advances in increased the simulators' ....' Revise line 4 to read ' ... plant. Additionally, s Simulator testing has ....' Revise line 5 to read ' ... initiated a new, improved ....' Revise line 7 to read ' ... and Examination," which that employs a ....'

3. On page 4, revise lines 5 through 8 from the top to read ' ... performance test failures, with a schedule for corrections, are unnecessarily burdensome for licensees. As an alternate approach, the and can be replaced by NRC can review of plant-referenced simulators for acceptability and of performance test results of simulation facilities before the simulator facility is used for operating ....'

4. On page 5, paragraph 2, revise line 2 to read ' ... technology and 14 13 years of ....'

5. On page 5, last paragraph, revise line 4 to read ' ... commenters stated recommended that the ....' Revise line 5 to read ' ... test" be deleted because this could ....' Revise line 6 to read ' ... reactivity manipulations to a short time just before the operating test.' Revise line 7 to read ' ... stated that the proposed language would create this would be a problem if a ....'

6. On page 6, revise line 1 from the top to read ' ... acknowledges the NEI's concern ....' Revise line 3 from the top to read ' ... reactivity manipulations to a short time just before the operating test.' Revise line 8 from the top to read ' ... sought," while deleting without the words ....' Revise line 10 from the top to read ' ...outage, "most recent" means the core just ....'

7. On page 6, paragraph 1, revise lines 4 and 5 to read ' ... submitted quadrennially. Currently licensed power reactor facilities have There are licensee-certified, plant-referenced simulators and now at all currently licensed power reactor facilities. The the NRC staff's experience ....'

8. On page 6, last paragraph, revise line 5 to read ' ... requiringements for licensees to ....' Revise line 8 to read ' ... failures available for NRC review, onsite, and ....'

9. On page 7, 1^st full paragraph, revise line 4 to read ' ... national industry standard specifies ....' Revise line 6 to read ' ... simulators as-tested during initial ....' Revise the last line to read ' ... testing and quality-control ....'

10. On page 8, paragraph 2, revise line 2 to read ' ... relocate the substance provision of that sentence -- a "plant-referenced ....' Revise line 4 to read ' ... has been designed to respond" -- to new ....'

11. On page 10, revise line 1 from the top to read ' ... under "Principal Reactor Regulatory Programs" under "Operating Licensing Program." Additionally ....'

12. On page 10, last paragraph, revise line 9 to read ' ... any requested. Hhowever, the general ....' Revise lines 10 and 11 to read ' ... http://www.nrc.gov/NRC/rule.html, under " NRC Rulemaking Web Site," at "News, Information ....'

13. On page 26, insert the following as the 3^rd paragraph in Section 55.31: 'Additionally, acceptable simulator training scenarios involving control manipulations that affect reactivity are identified in Section 55.31(a)(5) for clarity by reference to current control manipulations and training scenarios described in paragraph 55.59. Consistent with previously issued regulatory guidance, the list provides examples of acceptable control manipulations, which are a subset of evolutions in 55.59(c)(3)(i), and affect reactivity in a controlled manner and exclude those items on the list that are major transients and accidents.'

14. On page 28, 2^nd full paragraph, revise the last 2 lines to read ' ... a refueling outage, "most recent" means the core just ....'

15. On page 30, revise line 3 and 4 from the top to read ' ... requirements for simulators. Which are not addressed in any industry consensus standards. With respect to certification of a simulator, the The ....' Revise lines 7 through 9 to read ' ... training and Examination" is prescriptive rather than performance-based and is more appropriate for endorsement as one acceptable means for complying with specific parts of the requirements of ....' Revise lines 10 and 11 to read ' ... endorses the ANSI/ANS-3.5-1998 as an acceptable method by which facility licensees might implement specific parts of this rule and endorses the ANSI/ANS-3.5-1998.'

16. On page 32, paragraph 3, revise line 1 to read ' ... discussed above below, the Commission ....'

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