April 9, 2009 

MEMORANDUM TO: Frederick D. Brown, Director 

Division of Inspection and Regional Support 

Office of Nuclear Reactor Regulation 

FROM: Nancy L. Salgado, Chief /RA/ 

Operator Licensing and Human Performance Branch 

Division of Inspection and Regional Support 

Office of Nuclear Reactor Regulation 

SUBJECT: SUMMARY OF MARCH 19, 2009, MEETING WITH INDUSTRY FOCUS 

GROUP ON OPERATOR LICENSING ISSUES 

On March 19, 2009, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting 

with the Industry Focus Group (FG) on operator licensing to discuss a number of operator 

licensing issues. Enclosure 1 lists the attendees at the meeting. 

This meeting was the latest in a series of meetings intended to promote efficient, effective, and 

consistent preparation and administration of initial operator licensing examinations. The 

discussions addressed issues related to simulator fidelity and testing, implementation of Title 10 

of the Code of Federal Regulations Part 26 (10 CFR 26) Subpart I, consistency in the initial 

licensing process, and other operator licensing issues. Enclosure 2 is the agenda for the 

meeting, and the discussion topics are summarized in Enclosure 3. Enclosure 4 is the Nuclear 

Energy Institute’s (NEI’s) response to NRC comments on their simulator scenario based testing 

white paper. 

Representatives of the NRC and the industry agreed that this meeting was useful for the 

exchange of information and agreed to continue the periodic meetings. 

Enclosures: As stated 

CONTACT: David Muller, NRR/DIRS 

 (301) 415-1412 
 

April 9, 2009 

MEMORANDUM TO: Frederick D. Brown, Director 

Division of Inspection and Regional Support 

Office of Nuclear Reactor Regulation 

FROM: Nancy L. Salgado, Chief /RA/ 

Operator Licensing and Human Performance Branch 

Division of Inspection and Regional Support 

Office of Nuclear Reactor Regulation 

SUBJECT: SUMMARY OF MARCH 19, 2009, MEETING WITH INDUSTRY FOCUS 

GROUP ON OPERATOR LICENSING ISSUES 

On March 19, 2009, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting 

with the Industry Focus Group (FG) on operator licensing to discuss a number of operator 

licensing issues. Enclosure 1 lists the attendees at the meeting. 

This meeting was the latest in a series of meetings intended to promote efficient, effective, and 

consistent preparation and administration of initial operator licensing examinations. The 

discussions addressed issues related to simulator fidelity and testing, implementation of Title 10 

of the Code of Federal Regulations Part 26 (10 CFR 26) Subpart I, consistency in the initial 

licensing process, and other operator licensing issues. Enclosure 2 is the agenda for the 

meeting, and the discussion topics are summarized in Enclosure 3. Enclosure 4 is the Nuclear 

Energy Institute’s (NEI’s) response to NRC comments on their simulator scenario based testing 

white paper. 

Representatives of the NRC and the industry agreed that this meeting was useful for the 

exchange of information and agreed to continue the periodic meetings. 

Enclosures: As stated 

CONTACT: David Muller, NRR/DIRS 

 (301) 415-1412 

DISTRIBUTION: PUBLIC IOLB/NEI & Public Meetings Folders 

BBoger FBrown MCheok NSalgado 

TMensah JMunro RPelton MWidmann 

SGuenther LVick SHansell MJunge 

HPeterson RLantz SCurrie RSmith (ras@nei.org) 

PMcCullough (mcculloughpn@inpo.org) 

RMeyer (robert.meyer@exeloncorp.com) 

ADAMS Accession No. ML090980469 

OFFICE IOLB IOLB/BC 

NAME DMuller NSalgado 

DATE 

04/09/09 04/09/09 

 OFFICIAL RECORD COPY
 

List of Attendees - NRC / Industry Focus Group Meeting on Operator Licensing 

March 19, 2009 

Name Organization 

Nancy Salgado NRC / HQ 

Lawrence Vick NRC / HQ 

Michael Cheok NRC / HQ 

Jim Kellum NRC / HQ 

David Muller NRC / HQ 

John Munro NRC / HQ 

Siegfried Guenther NRC / HQ 

Sean Currie NRC / HQ 

Sam Hansell NRC / RI 

Malcolm Widmann NRC / RII 

Hironori Peterson NRC / RIII 

Ryan Lantz NRC / RIV 

Russell Smith Nuclear Energy Institute (NEI) 

John Butler NEI 

Chuck Sizemore Florida Power and Light 

Gregg Ludlam Exelon 

Michael Petersen XCEL Energy 

Timothy Dennis ANS 3.5 Standards Committee 

Mark Carey Constellation Energy 

Joseph Arsenault Western Technical Services 

Tom Mayfield Entergy 

Robert Meyer (via telephone) Professional Reactor Operator Society (PROS) 

Deann Raleigh (via telephone) Curtiss-Wright Corp. 

Mitch Taggart (via telephone) Ameren Energy 

 

ENCLOSURE 1
ENCLOSURE 2

AGENDA FOR THE CATEGORY 2 PUBLIC MEETING WITH THE 

 INDUSTRY FOCUS GROUP (FG) ON OPERATOR LICENSING ISSUES 

 March 19, 2009; 10:00 a.m. - 3:00 p.m. 

 U. S. Nuclear Regulatory Commission 

 One White Flint North, Room 13G4 

 11555 Rockville Pike, Rockville, MD 20852-2738 

TOPIC LEAD

Introductions and Opening Remarks NRC/FG 

Public Input Public 

Generic Issues NRC/FG 

- Simulator fidelity and testing 

 - NRC Form 398 OMB clearance 

- New FAQs posted on the OL feedback page 

 - Operator medical issues 

 - Part 26 Subpart I update 

 - New reactor licensing update 

 

Public Questions and Answers Public 

Initial Licensing Issues NRC/FG 

 - Exam projections 

 - SRO-only question guidance update 

 - Examination consistency and level of difficulty 

 - License eligibility (ANS-3.1 and ACAD 09-001) 

 - Other 

Public Questions and Answers Public 

Requalification Issues NRC/FG 

 - IP-71111.11 changes 

Focus Group Issues 

 - Promoting consistency between Regions FG 

Public Questions and Answers Public 

Summary / Conclusion / Action Item Review NRC/FG 
ENCLOSURE 3 

DISCUSSION SUMMARY

GENERIC ISSUES 

Simulator Scenario Based Testing (SBT) Methodology

The NRC staff acknowledged receiving the Nuclear Energy Institute’s (NEI’s) response to NRC 

comments on their September 18, 2008, White Paper entitled “Nuclear Power Plant-Referenced 

Simulator Scenario Based Testing Methodology” (Enclosure 4). Consensus was reached 

between the staff and NEI regarding all outstanding technical details, and the staff 

recommended that NEI issue a formal numbered document. NEI indicated it could issue a 

document by April 30, 2009. Options were discussed regarding future actions, including 

schedules for issuance of new revisions to ANSI/ANS-3.5, “Nuclear Power Plant Simulators for 

Use in Operator Training and Examination,” and Regulatory Guide 1.149, “Nuclear Power Plant 

Simulation Facilities for Use in Operator Licensing Examinations.” 

NRC Form 398 Office of Management and Budget (OMB) Clearance Pubic Comments

The NRC staff informed the attendees that the triennial renewal of the OMB information 

collection clearance is in progress for NRC Form 398, “Personal Qualification Statement – 

Licensee,” and that the public comment period will close in November, 2009. Anyone interested 

in reviewing and making comments on NRC Form 398 should refer to the Documents for 

Comment page on the NRC’s website. In addition, the NRC will be requesting from facility 

licensee’s a time burden estimate for filling out the form. 

Two New Frequently Asked Questions (FAQs) Posted on the OL Feedback Page

The NRC staff discussed with the attendees two new questions and answers on the Operator 

Licensing Feedback page and briefly summarized the issues, which included: a clarification to 

the instructions for NRC Form 398 waivers, and guidance for the use of open reference 

questions on written initial licensing examinations. The FG presented concerns regarding 

limiting the available reference material during initial examinations for senior reactor operators 

(SROs), and setting an apparent maximum number of SRO-only open reference questions that 

can appear on an examination. The staff responded to these concerns by informing the FG that: 

(1) the FAQ provides only clarification of existing guidance, (2) problems can occur if an 

excessive number of open reference questions are used without additional judgment, and (3) the 

allowable range for the number of open reference questions presented in the FAQ was not 

intended to be an absolute limit, but was instead intended to further clarify what is meant by the 

“sparing and judicious” use of open reference questions on initial licensing examinations, 

consistent with the NRC goal to ensure that applicants master the body of knowledge required 

by 10 CFR 55.41 and 55.43. 

Operator Medical Issues

The NRC staff reported that some Regions have noted an increase in the incidence of medical 

conditions that are not properly reported to the NRC as required by the regulations. The staff 

noted that the last generic communication on this subject (Information Notice (IN) 2004-20) was 

issued in 2004, and the staff is planning to update this generic communication in the near future. 

The staff also communicated that guidance regarding medical conditions is available in the FAQ 

section on the public website. The attendees welcomed any future NRC communication on 
2 

operator medical issues. The PROS representative also stated that he could initiate actions via 

PROS to inform their members of medical issues. 

Part 26 Subpart I Update

The staff provided an update of NRC activities associated with the recently published rule 

contained in 10 CFR 26 Subpart I, “Managing Fatigue.” The activities discussed included future 

NRC staff training, further meetings, inspection activities, and inspection procedure 

development. The staff also discussed the plan for publication of the final version of Regulatory 

Guide 5.73, “Fatigue Management for Nuclear Power Plant Personnel.” 

New Reactor Licensing Update

A representative from the Office of New Reactors (NRO) provided a brief update of their 

significant operator licensing activities since the last meeting. Those activities included the 

endorsement of NEI’s approach to cold licensing of operators at new reactors, beginning the 

process for revising the knowledge and abilities catalogs for nuclear power plant operators, 

making scheduling considerations for how initial examinations will be administered, and starting 

to examine what potential simulator resources the NRC will obtain for examiner and inspector 

training. 

INITIAL LICENSING ISSUES 

Exam Projections

The NRC staff emphasized to the attendees the importance of submitting realistic examination 

scheduling needs in response to NRC’s annual operator licensing regulatory information 

summary (RIS). The staff stated that if the RIS responses are not realistic, it makes it very 

difficult to schedule and allocate NRC examiner resources. Also, the nuclear industry needs to 

account for the impact of new reactors on examination needs. The Region II representative 

indicated that dramatic changes have occurred regarding examination scheduling needs, and 

further discussed how that impacts the Region. The Region I representative also noted similar 

scheduling changes. The attendees acknowledged the information presented by the staff, and 

acknowledged the importance of their RIS responses in regard to NRC’s scheduling and 

planning of examinations. 

SRO-only Question Guidance Update

The NRC staff provided a brief update on the trial implementation of SRO-only written 

examination question guidance developed by Region II. The NRC Regions are still using, 

evaluating, and providing feedback on the guidance. The attendees acknowledged that they are 

also still gathering information regarding the use of the SRO-only question guidance. 

Examination Consistency and Level of Difficulty

A FG representative informed the staff that efforts were underway to examine the consistency of 

written examination level of difficulty and distracter plausibility. The FG representative further 

discussed: (1) the use of bank questions and their review by the NRC, (2) the fact that Region II 

is the only Region that prepares written examination outlines for facility-prepared examinations, 

and (3) a concern that the NRC examination outline software used by Region II may result in 
3 

administrative errors regarding the wording of knowledge/ability statements. The NRC staff 

acknowledged the information, further stated that this was the first time the NRC staff had heard 

about any potential problems with Region II examination outlines, and that examination outline 

software problems have also been observed by the NRC for outlines prepared by facility 

licensees. The FG representative agreed to discuss the details of any outline errors with the 

Region II representative following the public meeting. (Following the meeting, discussions 

between the FG and Region II representatives determined that the outline errors were 

administrative in nature, have been corrected, and that there was never any technical errors with 

the software.) Further discussions occurred regarding NRC Region II’s practice of preparing 

examination outlines, and it was concluded that this practice was within the scope of NUREG1021, “Operator Licensing Examination Standards for Power Reactors.” However, no firm 

conclusion was reached by the staff or the attendees as to whether this was a “best” practice. 

NRC headquarters staff, when questioned about regional consistency, responded that 

consistency is evaluated against NUREG-1021, and that in regard to examination outlines, 

Region II is operating within the guidance contained in the NUREG. 

License Eligibility (ANS-3.1 and ACAD 09-001)

The NRC staff and the attendees briefly discussed a closed meeting previously held on March 

17, 2009, with representatives of the Institute of Nuclear Power Operations (INPO) regarding 

license eligibility. INPO has proposed to replace ACAD 00-003 with ACAD 09-001 (both 

ACADs are titled “Guidelines for Initial Training and Qualification of Licensed Operators”), and 

the proposed replacement ACAD contains several changes with respect to license eligibility, 

including changes to/combining eligibility flowcharts, and certain revisions for crediting academic 

experience. In addition to briefly discussing the ACAD changes, the NRC and the FG discussed 

whether to credit new employee site familiarization activities as on-site experience or as training. 

 However, properly crediting site familiarization activities was not resolved during the meeting, 

and the staff agreed to continue working with INPO and the FG to address eligibility issues. 

Other Issues

One of the attendees questioned the staff if the NRC could delay making initial licensing 

examinations publically available. By delaying the public availability, the attendee stated that the 

last NRC examination administered at a facility could be used as an audit examination for the 

next initial licensing class, thus saving valuable resources associated with preparing audit 

examinations. The NRC staff agreed to further investigate this issue. 

REQUALIFICATION ISSUES 

IP-71111.11 Changes

The NRC staff updated attendees on the status of a proposed revision to IP-71111.11, 

“Licensed Operator Requalification Program.” Although a revision to IP-71111.11 has been 

actively worked on since the last public meeting, efforts have currently been suspended due to 

other higher priority activities. The NRC staff informed the attendees that a revision may be 

completed in 2010, at which time the attendees will have the opportunity to review the new 

revision consistent with current NRC practices for communicating reactor oversight process 

issues. 
4 

FOCUS GROUP ISSUES 

Promoting Consistency Between Regions

A representative from NEI informed the staff that an Executive Group consisting of chief nuclear 

officers has been established to examine the overall operator licensing process. The NEI 

representative stated that the Executive Group will be reviewing items of interest, including: 

(1) the consistency and predictability of the licensing examination process, (2) the resources 

required to train license applicants and develop NRC examinations, and (3) success rates for 

licensing individuals who enter a licensing class (i.e., “throughput”). 

PUBLIC QUESTIONS AND ANSWERS 

The ANS 3.5 Standards Committee representative informed the attendees that efforts have 

begun to consider revisions to ANSI/ANS-3.1, “Selection, Qualification, and Training of 

Personnel for Nuclear Power Plants,” and ANSI/ANS-3.4, “Medical Certification and Monitoring 

of Personnel Requiring Operator Licenses for Nuclear Power Plants.” 

The Western Technical Services representative informed the attendees of the availability of 

examination outline development software that has been certified by the boiling water reactor 

owner’s group. 

The PROS representative discussed taking action with regard to licensed operator medical 

issues, and emphasized the importance of maintaining an appropriate number of properly 

qualified training instructors for operating nuclear reactors, especially considering the potential 

impact of new reactors on training instructor resources. 

SUMMARY / CONCLUSION / ACTION ITEM REVIEW 

In summary, the NRC staff and attendees agreed that the meeting was useful, and that 

communications between the staff and the FG are good, but with room for improvement. A 

future meeting date for July/August 2009 was discussed. 

Action Items

1. NEI will submit a numbered document regarding simulator scenario based testing. 

2. The NRC staff will review the FAQ on the use of open reference questions on initial licensing 

 examinations. 

3. An operator licensing feedback question will be submitted by the FG regarding delaying 

 the public release of NRC examinations. 

4. The NRC staff will provide INPO comments on license eligibility and ACAD 09-001. 

5. A FG representative will provide Region II examples of examination outline errors. 

 
 Page 1 of 5 

Response to NRC Comments on SBT White Paper 

Rev. 0, 3/18/09 

Summary

ADAMS Accession No. ML083290481 dated December 30, 2008 documents the NRC’s 

comments and recommendations regarding the SBT Methodology White Paper of September 16, 

2008. This document provides the NEI Licensed Operator Focus Group (LOFG) response to the 

comments. Formatting below includes the original NRC comment number and comment, 

followed by the LOFG response in italics. 

Comments and Response

Comment 1 – The staff generally agrees with the Attachment 1 “checklist” concept but 

recommends that the checklist be limited to simulator performance-related items. The 

performance testing of a plant-referenced simulator is a separate technical matter not to be 

confused with the qualitative and quantitative scenario attributes required in Appendix D, 

“Simulator Testing Guidelines,” of NUREG-1021, “Operator Licensing Examination Standards 

for Power Reactors.” The staff recommends that the WP Attachment 1 be replaced with 

“Recommended Revised Attachment 1” found at the end of these comments since it resolves 

many of the technical concerns related to implementation of SBT as simulator performance test. 

LOFG Response: LOFG agrees with the NRC comment and will adopt their proposed checklist. 

Wording of appropriate paragraphs within the white paper will be revised as necessary to 

ensure alignment with the new checklist. 

Comment 2 – Section 2.0, page 2, second paragraph, next to the last sentence: The staff 

recommends this sentence be deleted or modified to reflect that proper conduct of SBT is 

intended to alleviate the need for post-scenario evaluation since the performance of the simulator 

is being evaluated (compared to actual or predicted reference plant performance) during the 

conduct of the SBT. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. The LOFG intent that validation and SBT are parallel activities that do not 

require post-scenario evaluation is still maintained intact and is therefore acceptable to the 

LOFG. 

ENCLOSURE 4 
 Page 2 of 5 

Comment 3 – Section 2.0, page 2, second paragraph, the last sentence: The staff recommends 

that this sentence be deleted since it is highly speculative in nature. It remains to be seen whether 

or not the SBT methodology will actually identify and correct more problems than any other 

form of simulator performance testing. To date, the proposed SBT methodology has only been 

demonstrated on one plant-referenced simulator (i.e., Robinson, in July 2006). The staff 

acknowledges that the methodology holds the potential to uncover simulator fidelity issues 

otherwise undetected since an integrated plant response is being evaluated rather than a specific 

response in a stand-alone testing scheme. 

LOFG Response: LOFG concurs with the scope and comment and revise this sentence to be less 

speculative in nature.. 

Comment 4 – Section 3.2.3, page 4: The staff recommends that the language make clear that 

simulator scenarios used for performing control manipulations that affect reactivity to establish 

eligibility for an operator’s license are those associated with 10 CFR 55.31(a)(5). For example: 

“Scenarios used to satisfy the reactivity control manipulation requirement in 10 CFR 

55.31(a)(5).” 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation.

Comment 5 – Section 3.3, page 4, the first sentence: The staff is concerned that exclusive use of 

unlicensed test personnel (e.g., SRO certified instructors only with no licensed operators) during 

the conduct of SBT could result in less than adequate validation and confirmation of the 

simulator’s fidelity. The staff recommends that the wording be changed from “and/or” to “and” 

to ensure that licensed operators participate in the conduct of SBT. 

LOFG Response: LOFG strongly disagrees with this comment. Instructors responsible for the 

training of licensed personnel, as noted in ANSI 3.1-1993 for example, “...shall hold or shall have held 

a Senior Operator's license for a similar unit or shall have been certified for equivalent senior operator 

knowledge” (i.e. be SRO Certified). INPO NANT guidelines provide structure and content for 

instructor training which, along with instructor performance, is evaluated during accreditation 

team visits. Finally, licensed individuals’ primary responsibility and focus is the safe and 

reliable operation of the power plant and as such are often a difficult commodity to obtain for 

non-plant tasks, which would severely restrict the ability to conduct SBT in a timely manner. It 

is therefore unnecessary to require licensed SROs to conduct SBT. The current wording of this 

section is acceptable and follows current industry practice as well as the practice utilized during 

the NRC-attended SBT pilot at Robinson in July of 2006 with no expressed issues or concerns. 
 Page 3 of 5 

Comment 6 – Section 3.4, page 4, the first sentence: The staff recommends that “key 

parameters” be defined in the WP as: “Key parameters are the parameters necessary for a full 

understanding or explanation of the expected plant response to which the simulator has been 

designed to respond.” Although ANSI/ANS-3.5-1998, Appendix B, “Guidelines for the Conduct 

of Simulator Operability Testing,” provides examples of parameters to be recorded, the actual 

number of key parameters to be recorded during the conduct of SBT is predetermined by the 

nature of the event(s). 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 

Comment 7 – Section 3.5, page 4, the first sentence: The 1998 standard requires, in paragraph 

3.1.1 (Real Time and Repeatability), the simulator to operate in real time while conducting any of 

the evolutions required by the standard. This applies to SBT evolutions as well. The simulator 

scenario must be run in real time until the scenario termination point is reached. The staff 

recommends that the sentence be modified to reflect that the simulator must run in real time 

during the conduct of simulator SBT since time-based relationships, durations, rates, and 

dynamic performance are important for demonstrating fidelity. The staff does not object to using 

the simulator’s “freeze” feature to stop the simulation to evaluate parameters and performance, as 

long as the simulator continues to support the SBT in a continuous manner, without any 

mathematical model or initial condition changes. Bear in mind that subsequent test results from 

performance of the same SBT without using “freeze” must be repeatable. 

LOFG Response: LOFG agrees with this comment so long as the use of freeze is still allowed to 

the extent necessary to validate simulator performance. LOFG understands and agrees with the 

need to ensure real-time performance of the simulator and the need for repeatability. Wording 

of this section will be revised appropriately to capture these points as well as the NRC’s 

comments.

Comment 8 – Section 3.7, page 5, the third sentence: The staff recommends that the sentence be 

modified, for simulator SBT purposes, to state that test personnel, as a minimum, (1) must verify 

parameters, alarms, and automatic actions directly related to a scenario event, a malfunction, and 

or an operator input, and (2) are not expected to verify non-relevant alarms and automatic 

actions, unless they are unexpected. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 
 Page 4 of 5 

Comment 9 – Section 3.9, page 5: The staff recommends that the sentence be modified to reflect 

that the response of the simulator resulting from operator action, no operator action, improper 

operator action, automatic reference unit controls, and inherent operating characteristics shall be 

realistic and shall not violate the physical laws of nature, such as conservation of mass, 

momentum, and energy, within the limits of the verification, validation, and performance testing 

criteria of the standard. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 

Comment 10 – Section 3.10, page 5: To prevent any confusion, the staff recommends that the 

sentence be modified to reflect paragraph 4.4.3.2, “Simulator Scenario-Based Testing,” of the 

1998 standard. The standard does not include the term “tasks.” The inclusion of the term “tasks” 

could be misconstrued to be more limiting than that allowed on the referenced plant since there 

may be more than one predetermined way for an operator to perform a given task. Furthermore, 

the regulation speaks to the performance of significant control manipulations being completed 

without procedural exceptions rather than tasks being completed without exceptions. During the 

conduct of SBT, it is the simulator’s fidelity and scope, rather than the operator’s performance 

and ability, being assessed as sufficient and adequate for use. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 

Comment 11 – Section 3.12, page 5, the first sentence: The staff recommends that the sentence 

be modified to state that test personnel must verbally communicate expected plant response, 

trends, parameter/set point values, and primary alarms they observe throughout each event of the 

scenario. This is a critical implementation element of the SBT methodology since clear and 

deliberate verbal communications at all times ensures that expected test results are observed and 

validated. The staff observed strong communications among simulator test personnel during the 

conduct of the Robinson SBT demonstration. The staff recommends this expectation be carried 

forward as guidance in the SBT methodology. 

LOFG Response: LOFG requests clarification for the Staff’s request to substitute the term 

“articulate” with “verbalize”. During the Robinson SBT demonstration, instructors used both 

verbal and non-verbal cuing to validate simulator performance, which is why the term 

“articulate” was used in this section. 
 Page 5 of 5 

Comment 12 – Section 3.15, page 6: The staff recommends that the terminology be changed to 

“SBT Test Results Package” since the documentation must be retained for four years after the 

completion of each performance test or until superseded by updated test results. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 

Comment 13 – Section 3.16, page 6: The staff recommends the sentence be modified to reflect 

that an electronic copy of the “SBT Test Results Package” is acceptable for record retention 

purposes. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 

Comment 14 – Section 3.19, page 7, the first sentence: The staff recommends the sentence be 

modified to state that test personnel must document discrepancies in accordance with site 

simulator configuration management procedures. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation. 

Comment 15 – Section 4.0, page 7: The staff recommends updating the WP references once 

NRC staff comments have been resolved. One minor editorial comment for Item 4.4 – the term 

“Use” needs to be capitalized in the standard’s title. Also, regarding item 4.5, the correct 

ADAMS number is ML073240964. 

LOFG Response: LOFG agrees with the comment and will revise this sentence per the NRC 

recommendation.