- About NRC           - The Commission
      - Statutory Authority
      - Strategic Plan
      - Budget &  Performance
      - Organization & Functions
      - Locations
      - History
      - Values
      - Policymaking
      - Radiation Protection
      - Fire Protection
      - How We Regulate
      - Grants
      - Civil Rights
      -     
    - NuclearReactors           - Operating Reactor Locations
      - Reactor Quick Links
      - Power Reactors
      - Research and Test Reactors
      - Operating Reactors
      - Operator Licensing
      - New Reactors
      - Operator Licensing for New Reactors
      - Reactor Safety Research
      - Advisory Comm (ACRS)
      - Decommissioning of Nuclear Facilities
      -     
    - NuclearMaterials           - Fuel Cycle Facility Locations
      - Uranium Recovery Locations
      - Materials Quick Links
      - Special Nuclear Material
      - Source Material
      - Byproduct Material
      - Med, Academic & Ind Uses
      - Source Materials Facilities
      - Uranium Recovery
      - Fuel Cycle Facilities
      - Materials Transportation
      - Materials Research
      - Advisory Comm (ACMUI)
      - Decommissioning of Nuclear Facilities
      - Materials Environmental Reviews
      -     
    - RadioactiveWaste           - Waste Quick Links
      - Low-Level Waste
      - Waste Incidental to Reprocessing
      - Incidental Waste Criteria
      - High-Level Waste
      - Uranium Mill Tailings
      - LLW Disposal
      - HLW Disposal
      - Spent Fuel Storage
      - Spent Fuel Transport
      - Waste Research
      -     
    - NuclearSecurity           - Security Spotlight
      - NRC Responsibilities
      - Domestic Safeguards
      - Radioactive Material Security
      - Facility Protection
      - Nuclear Material Control
      - International Safeguards
      - Information Security
      - Emergency Preparedness
      - &;   
    - Public Meetings& Involvement           - Public Meeting Schedule
      - Commission	    Schedule
      - Conferences & Symposia
      - Documents for Comment
      - Brochures & Fact Sheets
      - Involving Stakeholders
      - Info Quality Guidelines
      - Rulemaking Process
      - Licensing
      - Enforcement
      - Hearing Process
      - Hearing Applications
      -     

**UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-0001**

October 1, 1998

**Addresses**

All holders of operating licenses for nuclear power reactors, except those who have permanently ceased operations andhave certified that fuel has been permanently removed from the reactor vessel.

**Purpose**

The U. S. Nuclear Regulatory Commission (NRC) is issuing this information notice to remind addressees that theeligibility requirements for applying for an operator license have not changed since 10 CFR Part 55 was amended in 1987.Recently, the NRC staff denied some applications for senior reactor operator licenses because the applicants did not havethe necessary responsible nuclear power plant experience at the plant for which the applicant was seeking a license. It isexpected that recipients will review the information in this notice to avoid similar problems. However, suggestions made inthis information notice are not NRC requirements; therefore, no specific action or written response is required.

**Background**

10 CFR 55.31(a)(4), requires that (1) operator license applicants submit evidence that they have successfully completed afacility licensee's requirements to be licensed as an operator and (2) an authorized representative of the facility licenseecertify successful completion of the requirements on NRC Form 398, "Personal Qualification Statement  Licensee." Inlieu of this evidence, 10 CFR 55.31(a)(4) provides that the Commission may accept certification that the applicant hassuccessfully completed a Commission-approved training program that is based on a systems approach to training (SAT)and that uses a simulation facility acceptable to the Commission.

The NRC discussed revised applicant eligibility criteria in a March 28, 1980 letter from Harold Denton to all nuclear powerplant licensees. In that letter, licensees were informed of the revised criteria that the NRC staff would use in evaluatingreactor operator training and licensing. These criteria included classroom training and simulator training and that acandidate spend a specified amount of time on shift under instruction and to have, in the case of a senior operator, previousresponsible power plant experience, a portion of which must be at the plant for which the license is sought, and a four-yearcollege degree or one year as a reactor operator. On October 31, 1980, the March 28, 1980 letter was reproduced inNUREG-0737 "Clarification of TMI Action Plan Requirements," as Section I.A.2.1, "Immediate Upgrading of ReactorOperator and Senior Reactor Operator Training and Qualifications." Section I.A.2.1 restated the criteria that a seniorreactor operator applicant must have been licensed as a reactor operator for a minimum of one year before obtaining asenior operator license. Section I.A.2.1 further stated that applicants for a senior license were expected to have a minimumof four years of "responsible power plant experience" and defined responsible power plant experience as "that obtained as acontrol room operator (fossil or nuclear) or as a power plant staff engineer involved in the day-to-day activities of thefacility, commencing with the final year of construction."

On February 7, 1985, the Commission published a policy statement on training and qualification, which endorsed theindustry-wide accreditation process while affirming the NRC's responsibility for evaluating licensees' training efforts. Theaccreditation process was endorsed by the Commission based on the strength of the SAT process in maintaining thetraining program content and because the accreditation guidance for licensed operator training programs establishedrecommended qualifications, including experience, for licensed control room operators, senior control room operators, andshift supervisors that were consistent with the experience requirements contained in the 1980 Denton letter.

In 1987, 10 CFR Part 55, was amended to codify the Commission's policy related to operator training. Concurrent withpublication of the Part 55 rule change, the staff published Revision 2 to Regulatory Guide 1.8, "Personnel Selection andTraining," and endorsed ANSI/ANS-3.1-1981, with exceptions. Regulatory Guide 1.8 defined a method acceptable to theNRC for compliance with regulations regarding training and qualification of nuclear power plant personnel. Theendorsement and exceptions reiterated the NRC's position on the experience needed by operator and senior reactor operatorapplicants, previously stated in the 1980 Denton letter and in NUREG-0737.

**Description of Circumstances**

Recently the NRC staff denied some applications for senior reactor operator licenses because the applicants did not havethe necessary responsible power plant experience. These applicants had completed the licensee's training program but didnot have six months of responsible nuclear power plant experience at the plants for which the applicants were seeking alicense.

**Discussion**

The 1987 amendment to 10 CFR Part 55 provided that applicants would no longer need to provide details of their trainingand experience on the application if they certified that they had completed a Commission-approved training program thatused a simulation facility acceptable to the NRC under 55.45(b). Additionally, the Statement of Considerations (SOC)accompanying the rule change stated that a facility licensee's training program would be approved by being accredited bythe National Nuclear Accrediting Board. At the time of the publication of the Part 55 rule change, the experiencerecommendations in the industry's accredited licensed operator training program guidelines were considered to beequivalent to the experience criteria of Regulatory Guide 1.8, Revision 2. Therefore, when 10 CFR 55.31(a)(4) waspromulgated, an accredited training program, based on an SAT process, together with the specific experience criteriacontained in the training program accreditation guidelines at that time, was an acceptable alternative method for complyingwith the Commission's regulations on training and qualification of nuclear power plant workers. The SOC accompanyingthe 1987 revision also informed licensees that their training programs and experience criteria must conform to theCommission-approved baseline as these were reflected in the industry's accreditation standards at the time of the revision.

While the Commission-approved experience baseline for licensed operators has not changed since the 1980 Denton letter,the National Academy for Nuclear Training modified its accredited licensed operator training program guidelines in 1991by removing certain criteria integral to the NRC's endorsement of that accreditation as an acceptable means of meeting therequirements in 10 CFR Part 55. Some facility licensees interpreted the removal of these criteria from the industryguidelines as NRC approval to reduce the training and experience requirements for operator license applicants andmodified their training programs and procedures accordingly. To rectify the unintended interpretation by many facilitylicensees as a result of the modified industry guidelines, the National Academy for Nuclear Training developed interimguidance which reinstates the industry guidance that was removed in 1991. This interim guidance was sent to itsmembership on July 8, 1998.

Many licensees are in the process of upgrading (amending) their facility licensing basis documents, including the technicalspecifications, prior to submitting them to the NRC staff for approval. The NRC staff will review submittals which containreferences to licensed operator eligibility requirements against the Commission-approved experience baseline referenced inthis information notice; however, licensees may propose means other than those specified in the baseline criteria formeeting applicable regulations.

This information notice requires no specific action or written response. If you have any questions about the information inthis notice, please contact one of the technical contacts listed below or the appropriate Office of Nuclear ReactorRegulation (NRR) project manager.

Attachment:  List of Recently Issued NRC Information Notices

----