January 3, 2008 

MEMORANDUM TO: Frederick D. Brown, Director 

 Division of Inspection and Regional Support 

 Office of Nuclear Reactor Regulation 

FROM: Nancy L. Salgado, Chief /RA/

 Operator Licensing and Human Performance Branch 

 Division of Inspection and Regional Support 

 Office of Nuclear Reactor Regulation 

SUBJECT: SUMMARY OF DECEMBER 11, 2007, MEETING WITH INDUSTRY 

 FOCUS GROUP ON OPERATOR LICENSING ISSUES 

On December 11, 2007, the U.S. Nuclear Regulatory Commission (NRC) staff held a public 

meeting with the industry focus group on operator licensing to discuss a number of operator 

licensing issues. Enclosure 1 lists the attendees at the meeting; no members of the general 

public were present. 

This meeting was the latest in a series of meetings intended to promote efficient, effective, and 

consistent preparation and administration of initial operator licensing examinations. The 

discussions addressed issues related to simulator fidelity and testing, new reactor licensing, 

implementation of the fatigue rule (Subpart I of 10 CFR Part 26), and other operator licensing 

issues. Enclosure 2 is the agenda for the meeting, and the discussion topics are summarized in 

Enclosure 3. 

Representatives of the NRC and the industry agreed that this meeting was useful for the 

exchange of information and agreed to continue the periodic meetings. 

Enclosures: As stated 

CONTACT: David Muller, NRR/DIRS 

 (301) 415-1412 
 

 January 3, 2008 

MEMORANDUM TO: Frederick D. Brown, Director 

 Division of Inspection and Regional Support 

 Office of Nuclear Reactor Regulation 

FROM: Nancy L. Salgado, Chief /RA/

 Operator Licensing and Human Performance Branch 

 Division of Inspection and Regional Support 

 Office of Nuclear Reactor Regulation 

SUBJECT: SUMMARY OF DECEMBER 11, 2007, MEETING WITH INDUSTRY 

 FOCUS GROUP ON OPERATOR LICENSING ISSUES 

On December 11, 2007, the U.S. Nuclear Regulatory Commission (NRC) staff held a public 

meeting with the industry focus group on operator licensing to discuss a number of operator 

licensing issues. Enclosure 1 lists the attendees at the meeting; no members of the general 

public were present. 

This meeting was the latest in a series of meetings intended to promote efficient, effective, and 

consistent preparation and administration of initial operator licensing examinations. The 

discussions addressed issues related to simulator fidelity and testing, new reactor licensing, 

implementation of the fatigue rule (Subpart I of 10 CFR Part 26), and other operator licensing 

issues. Enclosure 2 is the agenda for the meeting, and the discussion topics are summarized in 

Enclosure 3. 

Representatives of the NRC and the industry agreed that this meeting was useful for the 

exchange of information and agreed to continue the periodic meetings. 

Enclosures: As stated 

CONTACT: David Muller, NRR/DIRS 

 (301) 415-1412 

DISTRIBUTION: PUBLIC IOLB/NEI & Public Meetings Folders 

BBoger FBrown SRichards NSalgado 

TMensah JMunro RPelton MWidmann 

DMuller LVick MSykes MJunge 

HPeterson RLantz SHansell 

JRoe (jwr@nei.org) PMcCullough (mcculloughpn@inpo.org) 

ADAMS Accession No. ML073511714 

OFFICE IOLB IOLB/BC 

NAME DMuller NSalgado 

DATE 12/20/07 01/03/08 

 OFFICIAL RECORD COPY 
 

List of Attendees - NRC / Industry Focus Group Meeting on Operator Licensing 

December 11, 2007 

Name Organization 

Stuart Richards Nuclear Regulatory Commission (NRC) / HQ 

Nancy Salgado NRC / HQ 

Lawrence Vick NRC / HQ 

George Usova NRC / HQ 

Richard Pelton NRC / HQ 

David Muller NRC / HQ 

John Munro NRC / HQ 

Mike Junge NRC / HQ 

Marvin Sykes NRC / RI 

Sam Hansell NRC / RI 

Peter Presby NRC / RI 

Mark Bates (via telephone) NRC / RII 

Craig Kontz (via telephone) NRC / RII 

Gerry Laska (via telephone) NRC / RII 

Hironori Peterson (via telephone) NRC / RIII 

Jack Roe Nuclear Energy Institute (NEI) 

Chris Earls NEI 

Chuck Sizemore Florida Power and Light (FPL) 

Gregg Ludlam Exelon 

John Steely Duke Energy 

Michael Petersen XCEL 

Timothy Dennis ANS Standards Committee Chairman 

Kerry Wright FPL 

Ed Momm FPL 

Tom Mayfield Entergy 

Russell Smith NEI 

Robert Meyer Professional Reactor Operator Society 

Keith Welchel Duke Energy, ANS 3.5 Secretary 

Chuck Hess Pennsylvania Power and Light (PPL) 

ENCLOSURE 1
ENCLOSURE 2

FINAL AGENDA FOR THE CATEGORY 2 PUBLIC MEETING WITH THE 

 INDUSTRY FOCUS GROUP (FG) ON OPERATOR LICENSING ISSUES 

December 11, 2007; 9:00 a.m. – 12:00 p.m. 

Nuclear Energy Institute 

1776 I Street, NW, Washington, DC 

TOPIC LEAD

Introductions and Opening Remarks NRC/FG 

Public Input Public 

Generic Issues NRC/FG 

- Simulator fidelity and testing 

- New reactor licensing update 

- 10 CFR Part 26 (Fatigue Rule update) 

- IN-2007-31, FDA Announcement on Sleep Disorder Drugs 

Public Questions and Answers Public 

Initial Licensing Issues NRC/FG 

- RIS-2007-17 exam projections 

- Contractor-prepared initial exams 

- Other 

Public Questions and Answers Public 

Requalification Issues NRC/FG 

- RIS on license proficiency watches 

Focus Group Issues FG 

- Instant SRO eligibility requirements for engineers and NLOs 

Public Questions and Answers Public 

Summary / Conclusion / Action Item Review NRC/FG 
ENCLOSURE 3

DISCUSSION SUMMARY

GENERIC ISSUES 

Simulator Scenario Based Testing (SBT) Methodology

The NRC staff acknowledged the Nuclear Energy Institute’s (NEI) letter of November 20, 2007, 

to the NRC on simulator Scenario-Based Testing (SBT) methodology and agreed in principle to 

the letter’s four recommendations as listed below: 

1. Accept and endorse the Robinson Nuclear Plant simulator SBT testing methodology 

demonstrated to the staff. 

2. Accept and endorse the Robinson Nuclear Plant simulator SBT documentation 

methodology. 

3. Limit the scope of simulator SBT scenarios that fall under the 1998 version of ANSI/ANS3.5, “Nuclear Power Plant Simulators for Use in Operator Training and Examination,” to: 

a. NRC initial license examination scenarios, 

b. NRC annual re-qualification examination scenarios, and 

c. Facility licensee scenarios utilized for license candidate reactivity control 

manipulation credit. 

4. Demonstrate that testing of the malfunctions listed in section 3.1.4 of ANSI/ANS-3.5-

1998 has been performed at least once in the lifetime of the simulator and that the 

documentation will include the completed test results. 

Each of the recommendations was discussed. The NEI operator licensing (OL) focus group 

(FG) agreed to avoid use of the terms “validation” and “simulator design data” in the context of 

these recommendations because of the potential for misunderstanding given that these terms 

have specific meanings in ANSI/ANS-3.5. The NRC reiterated that simulator core performance 

testing must be conducted independent of SBT. Industry representatives agreed that bounding 

the scenarios used for SBT was not intended to cover simulator core performance testing and 

that facility licensees would still be expected to perform steady-state, normal operations, and 

transient tests. Malfunction testing would be the only periodic testing affected by the 

recommendations, as stated in Recommendation #4. 

The FG agreed to develop a more detailed standards implementation document regarding the 

aforementioned SBT recommendations. The implementation document will also clarify that 

facility licensees must, as a minimum, conduct the SBT methodology on all scenarios described 

in Recommendation #3. The FG also agreed to forward a draft implementation document to the 

Office of Nuclear Reactor Regulation (NRR) and the Office of New Reactor Operations (NRO) 

Operator Licensing Program Offices for NRC staff review. 

The American Nuclear Society (ANS) Standards 21 Committee Chairman discussed the status 

of the “200X” revision of ANSI/ANS-3.5. He reported that the proposed revision to ANSI/ANS3.5 is currently out for public comment and that the public comment period ends January 29, 

2008. He further indicated that the ANS standards committee will provide written responses to 

all comment submitters and requested that comments should state the problem, provide 

justification and analysis, and suggest a solution. The Chairman finally noted that the Nuclear 

Facilities Standards Committee (NFSC) will conduct balloting on January 15, 2008, to determine 

whether or not to publish a revised standard. 
 

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The NRC stated that staff representatives will attend the industry’s Utility Simulator Users Group 

(USUG) conference in February 2008 and participate in a forum to discuss the simulator SBT 

recommendations with industry representatives. 

New Reactor Licensing

NRC staff from the NRO provided an update on new plant licensing submittal processing. The 

staff indicated that they had met with NEI and industry representatives in September 2007 to 

discuss a NEI draft “white paper” regarding cold licensing of operators. A consensus was 

reached that more detail was needed on the subjects covered in the draft “white paper” and NEI 

agreed to submit a revised version in late December 2007. A follow-up meeting is planned for 

January 2008. NRC staff indicated that it has developed a time line to identify the tasks required 

to complete its review of issues listed in the draft “white paper.” The staff further noted that there 

are tasks that will require several years to accomplish which are captured in the time line. 

The NRC staff indicated that the agency has received three combined operating license (COL) 

applications for new reactors. The applicants for the new reactors at the South Texas Project, 

Bellefonte, and North Anna sites have endorsed NEI 06-13, “Template for an Industry Training 

Program Description,” with an addendum to include what will be developed in final “white 

papers.” 

The NRC staff indicated that it had met with the Institute of Nuclear Power Operations (INPO) 

last week and INPO provided the NRC a time line for its accreditation of new reactor training 

programs. 

The NRC staff finally indicated that a Regulatory Issue Summary (RIS) will be issued in 2008 

similar in content to RIS 07-17 to gather information for preparation and scheduling of operator 

licensing examinations, for both existing and new reactors. The staff further noted that the RIS 

will be issued a little earlier than last year due to NRC’s budget and planning process starting 

earlier in 2008. 

10 CFR Part 26 (Fatigue Rule and Fitness for Duty (FFD))

The NRC staff provided a brief update on the status of Subpart I, regarding the fatigue 

management provisions of the pending 10 CFR Part 26 rule change. The NRC staff noted that it 

is continuing the dialog with stakeholders and that another meeting is scheduled for January 

2008. NEI’s staff commented about concerns from industry that work hour changes would be 

implemented faster than previously expected as a result of recent industry issues. NEI also 

noted that the recent Peach Bottom augmented inspection team for inattentive security officers 

identified no nexus between inattentive personnel and work hours and cautioned against 

accelerating the implementation schedules because of the time required to change labor 

agreements. An NRC/NEI workshop is planned for early April 2008. 

NRC staff informed the FG regarding a recent NRC Information Notice IN-2007-31, “US FDA 

Announcement Related to Certain Sleep Disorder Drugs.” The notice alerts licensees to the 

potentially serious side effects of these drugs and recommends licensees review the IN for 

applicability to fitness-for duty, behavioral observation, and employee assistance programs. 
 

3 

OTHER ISSUES RELATED TO OPERATOR LICENSING 

Potential Examination Integrity Issue Relating to Contractor-Prepared License Exams

The NRC staff provided background information on a concern arising from a recent NRC 

examination that some contractor-developed written examination content could be predictable. 

The NRC noted that the examination contained a high percentage of questions that were 

essentially the same as questions used on recent NRC examinations at other similar facilities in 

the same region. The examinations at these facilities were all developed by the same contract 

exam developer, apparently using a question bank maintained by the developer. The NRC 

noted that while these examinations did not exceed thresholds for repeat questions on any 

particular facility’s previous two examinations, the potential existed for examination predictability 

due to use of similar questions from the other facility examinations. NUREG-1021, “Operator 

Licensing Examination Standards for Power Reactors,” provides guidance that applicants should 

not be able to predict specific examination content and requires random selection of bank 

questions relating to the selected knowledge and abilities in the examination outline. The FG 

indicated that it understood the staff’s concern and noted that the facility licensees are 

responsible for examination development and content as it relates to this concern. 

Unsatisfactory Submittals of Licensee-Developed Initial License Examinations

A facility licensee representative described a potential concern with the high number of 

unsatisfactory examination submittals in one particular NRC region. He pointed out that eight 

examinations in the recent past were considered unsatisfactory by NRC reviewers from this 

region. However, he also indicated that, at this time, the concern is based on preliminary survey 

data. Therefore, the NEI FG will conduct additional reviews regarding the concern, including 

looking at root cause findings regarding the unsatisfactory examination submittals and the 

statistics regarding facility examination submittals in other regions. Depending on the results of 

these reviews, the FG will be prepared to discuss the concern at the next NRC/NEI OL FG 

meeting. 

License Class “Throughput”

The Professional Reactor Operator Society (PROS) representative stated the view that initial 

licensed operator applicant “throughput” – the number of final license applicants as a percentage 

of the number of students that begin training for a license – is unacceptably low. He opined that 

the low “throughput” is potentially due to a high difficulty level for NRC license examinations and 

proposed that the NRC consider changing initial license written examinations to allow for 

increased numbers of open-reference questions, similar to that employed for facility licenseedeveloped licensed operator requalification examinations. He also expressed the view that 

many examination question topics have low safety significance. 

Changes to License Applicant Eligibility Requirements

A facility licensee representative proposed that the FG continue a dialogue to consider 

enhancements to current licensed operator eligibility requirements. He noted apparent 

inconsistencies in that credit given for responsible power plant experience for certain US Navy 

nuclear submarine shift positions was not also recognized for analogous shift positions on US 

Navy surface vessels. He stated that the NRC staff frequently approves waiver requests for 

these types of situations and suggested it would reduce unnecessary effort if additional flexibility 

was introduced into the process. A NEI representative stated that this was a subject in an NEI 
 

4 

white paper currently in draft. The NRC staff stated that much of the problem resulted from 

facility licensee commitments to 5 or 6 overlapping standards and that all INPO accredited 

facilities should use INPO ACAD-00-003 to determine eligibility. The staff further noted that the 

NRC is reluctant to waive requirements for minimum time on site. The NEI representative stated 

that chief nuclear officers are asking if it is time to rethink the approach and whether the 

apprenticeship approach is outdated.