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SECY-00-0059

March 6, 2000

• PURPOSE:
• BACKGROUND:
• DISCUSSION:
• NRC Requalification Program and Inspection Summary for Fiscal Year 1999
• New Reactor Oversight Inspection Process
• Summary of Initial Examination Results
• Operator Licensing Program Initiatives
• CONCLUSION:

PURPOSE:

To inform the Commission of the status of the NRC's licensed operator requalification program and the results of NRC's initial licensing examinations for reactor operator (RO) and senior reactor operator (SRO) applicants.

BACKGROUND:

The staff has submitted periodic reports to the Commission since August 1989 on the status of NRC's licensed operator requalification program oversight activities. These reports also contained results of initial RO and SRO licensing examinations. The most recent of these reports was SECY-99-056 (dated February 22, 1999).

DISCUSSION:

NRC Requalification Program and Inspection Summary for Fiscal Year 1999

During fiscal year (FY) 1999, the staff continued to monitor the licensees' licensed operator requalification training and examination programs. The staff inspected the licensed operator requalification programs at 39 power reactor facilities during FY 1999. The inspections were to (1) confirm that the licensee's requalification program ensured safe power plant operation by adequately evaluating how well the individual operators and crews have mastered training objectives; (2) determine the licensee's effectiveness in evaluating and revising the requalification program for licensed operators based on their operational performance, including requalification examinations; (3) determine the effectiveness in ensuring that the individuals who are licensed to operate the facility satisfy the conditions of their licenses as specified in 10 CFR 55.53; and (4) provide regional management with the information it needs to assess the performance of the facility licensee's licensed operator requalification program and to determine the need for additional inspections or NRC-conducted examinations. Each of the programs was evaluated using the process described in NRC Inspection Procedure (IP) 71001, "Licensed Operator Requalification Program Evaluation," or draft inspection procedure (IP-71111.11, "Reactor Safety," Attachment 11, "Licensed Operator Requalification Program") that incorporated the new reactor oversight inspection process as discussed in SECY-99-007, "Recommendations for Reactor Oversight Process Improvements," dated January 8, 1999. The staff conducts the requalification program inspection at least every 24-months which is consistent with each licensee's requalification examination cycle. During FY 1999, the staff did not conduct any requalification examinations. The staff may, as needed, conduct requalification examinations when the NRC loses confidence in a licensee's ability to conduct its own examinations or when the NRC believes that the inspection process will not produce the necessary insights into the quality of the licensee's program.

The staff believes that the performance level of licensed operator training programs as a whole at power reactor facilities is being sustained. Additionally, the licensees have continued to demonstrate their ability to develop and administer licensed operator requalification examinations with very little oversight or with minimum intervention from the NRC. The attachment contains the individual results of the requalification program inspections at each facility inspected during FY 1999. A SAT (satisfactory) rating for a requalification program inspection indicates that the licensee's requalification program exhibited no major program failure adverse to safety. The following table summarizes the results of requalification program inspections.

The next table shows the requalification program inspection results since FY 1993.

New Reactor Oversight Inspection Process

The Licensed Operator Requalification Program Evaluation inspection procedure (IP-71001) has been revised to reflect the NRC's new reactor oversight baseline inspection process. The inspection procedure has been designated as IP-71111.11, "Reactor Safety," Attachment 11, "Licensed Operator Requalification Program." In addition to maintaining the objectives of the previous procedure, the procedure provides insights on the following key attributes: (1) human performance (pre- and post-event human error) in the Initiating Event cornerstone as well as the Mitigating Systems and Barrier Integrity cornerstones; (2) procedure quality issues (post-event operating procedures), in the event licensed operator performance issues are identified in the Initiating Events and Mitigating Systems cornerstone areas; and (3) limited emergency response organization performance (self-assessment, severe-accident management guidelines implementation and actual response) regarding initial and subsequent interactions by licensed operators (emergency action levels and protective action recommendations) in the Emergency Preparedness cornerstone area.

During FY 1999, the NRC piloted the revised requalification program inspection procedure at two sites (Cooper and Salem). These results indicate that the licensees' licensed operator requalification programs had acceptable performance levels, with cornerstone objectives being met with no significant deviation from expected performance. The staff is confident that the new reactor oversight inspection process will continue to determine whether licensed operators are trained and capable of safely operating their facilities.

Summary of Initial Examination Results

The staff is continuing to administer initial licensing examinations to applicants for RO and SRO licenses at power and non-power reactor facilities. The following table gives results of the power reactor initial operator licensing examination over a period of 5 years from FY 1995 through FY 1999. During FY 1999, the staff administered 58 site-specific initial licensing examinations to RO and SRO applicants at power reactor facilities. This number includes 53 site-specific licensing examinations that had been prepared by facility licensees in accordance with the NRC's revised examination guidance. The table separates NRC-prepared and facility-prepared examination results for FYs 1996, 1997, 1998, and 1999. In addition, the staff administered 263 generic fundamentals examinations during FY 1999 to prospective license applicants at power reactor facilities.

*Only a limited number of examinations were NRC- prepared.

Operator license applicants who are denied a license because they failed a written examination or operating test are notified of their denials in writing. The proposed denial letters describe the nature of the deficiencies noted and inform the applicants of their available response options.

The applicants may (1) reapply pursuant to the provisions of 10 CFR 55.35, (2) request an informal NRC staff review of the examination's grading, and/or (3) request a hearing pursuant to 10 CFR 2.103(b)(2).

The following table indicates the total number of applicants who requested NRC review of their examination results including the review outcomes from FY 1995 through FY 1999. The data indicates that there has been an increase in the number of applicants who requested review of their examination failures since revising the operator licensing program on October 1, 1995, to allow for facility-prepared examinations. The staff believes that the recently implemented change to Revision 8 of NUREG-1021 that encourages facility licensees to solicit and consider comments from the license applicants during the written examination review and grading processes may have contributed to the relative decrease in the number of requested reviews between FY 1998-1999. The staff anticipates that the number of applicant-requested reviews should continue to decrease as the facility licensees become more familiar with NUREG-1021 and its quality review checks for proposed examination test items.

The following table gives the results of the non-power reactor initial operator licensing examinations over a period of 5 years from FY 1995 through FY 1999. During FY 1999, the staff administered 17 site-specific initial licensing examinations to RO and SRO applicants at non-power reactor facilities in accordance with the current examination guidance in NUREG-1478, "Non-Power Reactor Operator Licensing Examiner Standards."

Operator Licensing Program Initiatives

During FYs 1999 and 2000 to date, the staff continued efforts to improve the NRC's oversight of the operator licensing program and responded to stakeholder concerns. Examples of the staff's initiatives include the following:

CONCLUSION:

The NRC's licensed operator requalification inspection program effectively and efficiently ensures that ROs and SROs who are licensed by the NRC to operate or supervise the reactor controls are maintaining the required level of competence to safely perform their licensed duties. In addition, the NRC's initial operator licensing examination program is providing realistic assurance that only those applicants who have mastered the knowledge, skills, and abilities required to safely operate and/or supervise the nuclear reactor controls are being licensed to do so. Ongoing operator licensing program initiatives are directed at reducing unnecessary burden and improving consistency in the administration of the operator licensing programs.

ATTACHMENT

STATUS REPORT ON THE NRC REQUALIFICATION PROGRAM
FISCAL YEAR 1999

1. A program rating of SAT (satisfactory) indicates that the licensee's requalification program complied with the requirements of 10 CFR 55.53 and 55.59 for the areas inspected and that the NRC staff did not elect to conduct NRC-administered requalification examinations for cause as a result of any weaknesses that may have been noted.

2. Limited SRO (LSRO) program evaluation.

3. Limited SRO (LSRO) program evaluation.