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. 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 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. 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. |