Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
August 15, 1995
NRC GENERIC LETTER 95-06: CHANGES IN THE OPERATOR LICENSING PROGRAM
Addressees
All holders of operating licenses (except those licenses that have been
amended to a possession only status) or construction permits for nuclear power
reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to
(1) notify addressees of NRC's intent to change the operator licensing process
so that facility licensees will have the option to prepare draft written
examinations and operating tests used by the NRC to determine the competence
of operator license applicants at power reactor facilities and (2) to solicit
volunteers to participate in a pilot program that will evaluate and refine the
new examination development process.
Background
On March 24, 1995, the staff informed the Commission of its intent to revise
the manner in which the NRC administers the initial operator licensing program
to allow greater participation by facility licensees and the elimination of
contractor assistance in this area. On April 18, 1995, the Commission
consented to the staff's proposal to initiate a transition process to revise
the operator licensing program and directed the staff to carefully consider
experience from the pilot examinations before full implementation.
Description of Circumstances
Part 55, "Operators' Licenses," of Title 10 of the Code of Federal Regulations
(10 CFR Part 55) establishes the Commission's procedures and criteria for
issuing licenses to operators and senior operators. Part 55 states the
minimum training and educational requirements for applying for a license, the
content requirements for licensing examinations, and the process for making a
license application; however, it does not define the specific process for
conducting licensing examinations. Specific guidance in this area is given in
NUREG-1021, "Operator Licensing Examiner Standards," which includes the
procedures that NRC staff examiners and NRC-certified contract examiners use
to prepare and conduct both the written and operating portions of the
licensing examinations. The role of the facility licensees has historically
been limited to reviewing and validating the NRC-prepared examinations before
they are given, and to providing administrative and logistical support to the
NRC and contract examiners while the examinations are in progress.
9508110156. GL 95-06
August 15, 1995
Page 2 of 4
The staff now intends to revise the initial operator licensing program to
permit facility licensees to draft and, in part, conduct initial licensing
examinations with NRC oversight. NRC participation in the examinations will
range from conducting part to all of the examination. This change is expected
to result in significant resource savings because facility employees, who are
more familiar with their plant and its procedures, will be able to develop the
examinations more efficiently than NRC or contract examiners. The change is
part of the NRC's continuing effort to streamline the functions of the Federal
Government consistent with Administration initiatives and to accommodate
anticipated resource reductions. The pilot program described herein will
evaluate and refine the proposed examination process to ensure that acceptable
levels of effectiveness, objectivity, and independence are maintained.
Discussion
The staff has historically determined the level of knowledge and abilities of
applicants for operator licenses at power reactor facilities by conducting
examinations developed fully by the NRC. This approach has been appropriate
to meet the requirement of Section 107 of the Atomic Energy Act of 1954, as
amended, to prescribe uniform conditions for licensing individuals and to
provide an appropriate independent assessment of an applicant's qualifications
to be licensed. During the period from the 1950s to the mid-1980s, the amount
of training provided to license applicants and the facility licensees' focus
on training varied considerably. During the mid- to late-1980s, the
industry's emphasis in the training area increased significantly, and all
power reactor licensees established formal training programs that have been
accredited by the National Academy for Nuclear Training.
In 1987, the NRC amended 10 CFR Part 55 to establish detailed criteria for
implementing licensed operator requalification programs and to require each
licensed operator to pass an NRC-conducted requalification examination as a
condition for license renewal. After conducting requalification examinations
for more than five years, the NRC concluded that the industry had established
a high standard of performance in the requalification area and that the NRC
was largely duplicating the licensees' efforts. Therefore, in 1994, the NRC
amended 10 CFR Part 55 to remove the requirement for every operator to pass an
NRC-conducted requalification examination so the staff could shift its
involvement in the requalification area to one of inspection oversight.
The improvements in operator training and performance that prompted the NRC to
reduce its level of involvement in the requalification program have also been
evident in the initial operator licensing process. That fact, in conjunction
with the aforementioned streamlining initiative, has motivated the NRC to
reconsider its approach to the initial operator licensing examination program.
The NRC now intends to change the guidance in NUREG-1021 to permit facility
licensees to draft the written examinations and operating tests for operator
and senior operator license applicants. The NRC will review and approve the
licensees' proposed examinations and tests and independently conduct the
operating tests. Facility licensees will not conduct any portion of the
operating tests, however, they will conduct the written examinations. The NRC. GL 95-06
August 15, 1995
Page 3 of 4
will review the graded written examinations, grade each applicant's operating
test performance, make the final pass or fail decisions, and issue licenses,
as appropriate.
From October 1995 through March 1996, the staff intends to conduct a voluntary
pilot program to evaluate and refine the proposed examination process; other
potential examination efficiencies may also be evaluated during the pilot
period. The NRC regional offices will be contacting those facility licensees
who have requested initial operator license examinations during the pilot
period to discuss the details of the program and to ascertain the licensees'
willingness to participate. As usual, the regional office will confirm the
examination arrangements in a corporate notification letter.
To maintain uniform standards of examination format, difficulty, and
integrity, the staff will expect participants in the pilot program to prepare
the written examinations and operating tests in accordance with the existing
procedures and guidelines in Revision 7 of NUREG-1021, Revision 5 of
NUREG/BR-0122 ("Examiners' Handbook for Developing Operator Licensing Written
Examinations"), and the supplementary instructions outlined in Attachment 1.
Departure from the stated guidelines may result in examination delays if the
NRC has to rewrite the examinations.
Lessons learned during the pilot examinations will be incorporated in
Revision 8 of NUREG-1021. The staff will make a draft copy of the revised
report available for industry and public comment before it is implemented on a
generic basis. The NRC intends to formally implement the facility-developed
examination option in October 1996, contingent upon successful pilot
examination experience and Commission approval.
Voluntary Response Requested
Those addressees who are scheduled for initial operator licensing examinations
during the pilot period (October 1995 through March 1996) and are interested
in participating in the program described herein should contact their NRC
Regional Office to make the necessary arrangements.
Backfit Discussion
This generic letter requires no specific action or written response. The
addressee's decision to participate in the pilot program is strictly
voluntary. Therefore, the staff has not performed a backfit analysis. Formal
implementation of the revised examination process may require a backfit
analysis.
Federal Register Notification
A notice of opportunity for public comment was not published in the Federal
Register because of the voluntary nature of the pilot program. However,
. GL 95-06
August 15, 1995
Page 4 of 4
comments on the issues addressed by this generic letter may be sent to the
U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington,
D.C. 20555-0001.
The staff intends to publish a notice of opportunity for public comment before
issuing the revised examination procedures in Revision 8 of NUREG-1021.
If you have any questions about this matter, please contact one of the
technical contacts listed below or the appropriate Office of Nuclear Reactor
Regulation (NRR) project manager.
/S/'D BY BKGRIMES/FOR
Dennis M. Crutchfield, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: Stuart Richards, NRR Thomas Burdick, RIII
(301) 415-1031 (708) 829-9703
Glenn Meyer, RI John Pellet, RIV
(610) 337-5211 (817) 860-8159
Thomas Peebles, RII
(404) 331-5541
Attachments:
1. Pilot Examination Guidelines
2. List of Recently Issued NRC Generic Letters. Attachment 1
GL 95-06
August 15, 1995
Page 1 of 2
PILOT EXAMINATION GUIDELINES
Facility licensees will prepare the written examinations and operating tests
(dynamic simulator and walkthrough) in accordance with the instructions in
Revision 7 of NUREG-1021 ("Operator Licensing Examiner Standards") and
Revision 5 of NUREG/BR-0122 ("Examiners' Handbook for Developing Operator
Licensing Written Examinations"), subject to the following additional
criteria:
(1) The facility licensee will prepare an integrated examination outline
(written and operating test) and submit it to the NRC regional office
for review, comment, and approval at least 60 days before the scheduled
examination date. The NRC chief examiner will work with the facility
licensee to resolve any problems and to avoid unnecessary revision of
the final examination products.
(2) Facility employees who are involved with developing the examinations and
tests will sign a standard security agreement (Form ES-201-2) before
they gain specific knowledge of the examinations and tests. Facility
employees who played a substantial role in training the license
applicants will generally not be involved in developing the license
examinations or tests. If the facility licensee considers such
employees necessary for developing the examinations or tests, it will
define the process it will use to ensure that the integrity of the
examinations is not compromised and discuss the process with the NRC
chief examiner.
(3) The written examinations and operating tests will satisfy the following
specific criteria:
þ A maximum of 50 percent of the written examination questions may
be taken directly from the facility question bank; up to an
additional 40 percent of the questions may be taken from the
facility bank but must be significantly modified; and a minimum of
10 percent of the questions will be newly developed. As discussed
in NUREG/BR-0122, new questions should emphasize the applicants'
understanding at the comprehension or application levels of
knowledge because they have the greatest operational and
discriminatory validity.
þ No more than 25 percent of the questions on the examination may be
repeated from examinations, quizzes, or tests administered to the
license applicants during their license training class, or from
the past two NRC license examinations at the facility. No
questions may be drawn directly from the applicants' audit
examination or similar testing vehicle given at the end of the
license training class.
. Attachment 1
GL 95-06
August 15, 1995
Page 2 of 2
þ Each walkthrough test will include at least two job performance
measures (JPMs) that are either new or significantly altered, and
each simulator scenario set will include at least one new or
significantly altered scenario. Other scenarios used may be drawn
directly from the facility scenario bank; however, they will be
altered to the degree needed to prevent the applicants from
immediately recognizing the scenarios based on initial conditions
or other cues.
þ A significant modification, for purposes of the written questions,
means a change to the conditions in the stem and at least one
distractor significantly changed. Similarly, JPMs and simulator
scenarios will have at least one substantive event or condition
change that alters the course of action in the JPM or scenario.
(4) The facility licensee will submit the final written examinations and
operating tests to the NRC regional office at least 30 days before the
scheduled examination date. In its submittal, the facility licensee
will include a history (e.g., bank, revised, new, and date last used) of
each test item used on the written and operating tests.
(5) The NRC regional office will assign a chief examiner to coordinate the
review, revision (as determined necessary by the NRC), and validation of
the written examinations and operating tests with the facility licensee.
Additional NRC staff examiners will be assigned as necessary (typically
one or two, depending on the number of applicants) to assist the chief
examiner with administering and grading the operating tests in
accordance with existing procedures. The facility licensee will
administer and grade the written examinations; NRC examiners will review
and approve the licensee's grading.
