Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
January 31, 1997
NRC GENERIC LETTER 95-06, SUPPLEMENT 1: CHANGES IN THE OPERATOR LICENSING
PROGRAM
Addressees
All holders of operating licenses (except those licensees of permanently
shutdown reactors who are no longer required to utilize licensed reactor
operators) for nuclear power reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter
(GL) supplement to (1) inform addressees of the results of the pilot program
described in GL 95-06 and (2) to notify addressees of NRC's decision to change
the operator licensing process so that facility licensees may voluntarily
prepare the operating tests and prepare, administer, and grade the written
examinations that the NRC will review, approve, and use to determine the
competence of operator license applicants at power reactor facilities. This
change is being implemented on an interim basis pending the completion of
rulemaking that will require power reactor facility licensees to participate
in the examination development process.
Background
On March 24, 1995, the staff informed the Commission of its intent to revise
the initial operator licensing program to allow greater participation by
facility licensees and eliminate contractor assistance in this area. The
staff did not plan to revise Part 55 of Title 10 of the Code of Federal
Regulations (10 CFR Part 55) because the rule does not specify who will
prepare, administer, and grade the examinations. 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 pilot examinations before full implementation. On
August 15, 1995, GL 95-06 outlined the revised examination development process
and solicited volunteers to participate in pilot examinations to evaluate and
refine the methodology.
Description of Circumstances
Between October 1, 1995, and April 5, 1996, the NRC reviewed, approved, and
administered 22 initial operator licensing examinations that had been drafted
by facility licensees in accordance with the pilot examination guidance in GL
95-06. These examinations were used to test 146 operator and senior operator
applicants.
9701310141. GL 95-06, Supplement 1
January 31, 1997
Page 2 of 4
The staff documented the results of the pilot examinations in SECY-96-123,
"Proposed Changes to the NRC Operator Licensing Program," and briefed the
Commission on June 18, 1996. Although the staff had originally considered
rulemaking unnecessary, resource and scheduling considerations, combined with
the fact that the NRC had traditionally developed the examinations itself or
through the use of contract examiners, prompted the staff to seek the
Commission's approval to commence rulemaking that would require all power
reactor facility licensees to prepare the initial operator licensing
examinations. In a staff requirements memorandum (SRM) dated July 23, 1996,
the Commission posed a number of additional questions regarding the revised
examination process and directed the staff to prepare a detailed rulemaking
plan that would amend 10 CFR Part 55 to require power reactor facility
licensees to prepare the initial licensing examinations. The staff
subsequently issued SECY-96-206, "Rulemaking Plan for Amendments to 10 CFR
Part 55 to Change Licensed Operator Examination Requirements," on September
25, 1996. The Commission approved the rulemaking plan and continued interim
voluntary implementation of the new examination methodology in an SRM dated
December 17, 1996.
Lessons learned during the pilot examinations and industry concerns were
addressed in Revision 8 of NUREG-1021, which has been retitled "Operator
Licensing Examination Standards for Power Reactors." A draft copy of the
revision was placed in the NRC's Public Document Room on February 16, 1996,
and a Federal Register notice (FRN) requesting industry and public comments
was published on February 22, 1996 (61 FR 6869). The staff considered the
industry's comments and met with representatives from the Nuclear Energy
Institute (NEI) and a number of utilities to discuss their concerns during a
public meeting on April 18, 1996. The staff is now in the process of issuing
Interim Revision 8, for use until 10 CFR Part 55 is amended to require all
power reactor facility licensees to prepare the initial operator licensing
examinations.
Discussion
Under the voluntary pilot examination program, facility licensees prepared the
initial operator licensing examinations based on the guidance in GL 95-06 and
Revision 7 of NUREG-1021 and submitted the examinations to the NRC for review
and approval. Once the examinations were approved, the facility licensees
administered and graded the written examinations in accordance with NRC
procedures, and NRC examiners independently administered and graded the
operating tests. The NRC reviewed and approved the written examination
grading results, including any changes to the answer keys and deletions of
questions recommended by the facility licensees. The NRC continued to make
the final licensing decisions and administer the appeal process for applicants
who had been denied a license because they failed to pass the examination.
The pilot program demonstrated that examinations prepared by facility
licensees in accordance with NRC guidelines, and subject to review, revision
where appropriate, and approval by NRC staff examiners, were generally
consistent with examinations prepared by NRC or contract examiners. The
examinations also appeared to be equally effective at identifying applicants
who had not mastered the job requirements well enough to become licensed
reactor operators or senior operators. Although some of the pilot
examinations . GL 95-06, Supplement 1
January 31, 1997
Page 3 of 4
required significant rework to bring them up to NRC standards, the staff
expects that the quality of the draft examinations will improve as facility
licensees gain experience and become more familiar with the NRC's requirements
and expectations.
The lack of familiarity with NRC examination requirements was also reflected
in the fact that several pilot program volunteers required more time to write
the examinations than is usually required by experienced NRC examiners or
contractors. However, the fact that some pilot facilities were able to draft
quality examinations requiring few NRC changes, using their own employees or
contractors, in equal or less time than is normally required by the NRC,
illustrates the viability of the pilot process. It is expected that
efficiency will improve once facility licensees gain experience with writing
the examinations because facility employees have more detailed knowledge of
their facility and easier access to the reference materials required to
prepare the examinations.
The fact that no NRC contractors were used to prepare the pilot examinations
significantly reduced the fees that the NRC charged for examination services
pursuant to 10 CFR 170.12(i). The staff expects that additional fee
reductions may be realized as facility licensees gain experience with the NRC
examination requirements and as the quality of the draft examinations
improves. The revised process gives facility licensees more control over the
cost of licensing their operators and should result in a net resource savings
to the industry.
Since completing the pilot program, the NRC has revised the guidance in
NUREG-1021 to integrate the pilot examination criteria given in Attachment 1
to GL 95-06, incorporate lessons learned during the pilot examinations, and
assimilate public and industry comments submitted in response to the FRN of
February 22, 1996. The significant changes from Revision 7 of the NUREG are
noted in the Executive Summary of Interim Revision 8.
As noted under "Description of Circumstances," the Commission has approved the
voluntary implementation of Revision 8 of NUREG-1021 pending an amendment to
10 CFR Part 55 that will require all power reactor facility licensees to
prepare the initial operator licensing examinations. Facility licensees that
volunteered to prepare their examinations before the date of the FRN
announcing the publication of Interim Revision 8 may prepare the examinations
based on the guidance in the Interim Revision or the pilot examination
guidance in Generic Letter 95-06, as arranged with their NRC Regional Office.
Facility licensees that volunteer after the date of the FRN are expected to
prepare the examinations based on the guidance in Interim Revision 8. For
examinations prepared by the NRC, Interim Revision 8 will become effective 60
days after the date of the FRN. The corporate notification letters issued
after the effective date will give facility licensees at least 120 days of
advance notice that the examinations will be administered based on the
guidance in the revised procedures.
A copy of Interim Revision 8 of NUREG-1021 will be mailed to each facility
licensee. The NRC intends to solicit comments on the interim revision in
conjunction with the rulemaking process and to issue Revision 8 when the
rulemaking is complete.. GL 95-06, Supplement 1
January 31, 1997
Page 4 of 4
Voluntary Response Requested
Those addressees who are scheduled for initial operator licensing examinations
and are interested in preparing the examinations as 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. An
addressee's decision to participate in the revised examination process is
strictly voluntary. Therefore, the staff did not perform a backfit analysis.
The rulemaking that will require all power reactor facility licensees to
prepare the initial operator licensing examinations will include a backfit
analysis.
Federal Register Notification
A notice of opportunity for public comment was not published in the Federal
Register because an earlier notice (61 FR 6869) had solicited public comments
on a draft revision of NUREG-1021, which addresses the same policy issue.
However, 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.
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.
original signed by
Thomas T. Martin, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: Stuart Richards, NRR Melvyn Leach, RIII
(301) 415-1031 (630) 829-9705
E-mail: sar@nrc.gov E-mail: mnl@nrc.gov
Glenn Meyer, RI John Pellet, RIV
(610) 337-5211 (817) 860-8159
E-mail: gwm@nrc.gov E-mail: jlp@nrc.gov
Thomas Peebles, RII
(404) 331-5541
E-mail: tap@nrc.gov
