October 30, 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 OCTOBER 8, 2008, MEETING WITH INDUSTRY 

FOCUS GROUP ON OPERATOR LICENSING ISSUES 

On October 8, 2008, 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, 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: Fred Guenther, NRR/DIRS 

 (301) 415-1056 
 

 October 30, 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 OCTOBER 8, 2008, MEETING WITH INDUSTRY 

FOCUS GROUP ON OPERATOR LICENSING ISSUES 

On October 8, 2008, 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, 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: Fred Guenther, NRR/DIRS 

 (301) 415-1056 

DISTRIBUTION: PUBLIC IOLB/NEI & Public Meetings Folders 

BBoger FBrown MCheok NSalgado 

TMensah JMunro RPelton MWidmann 

DMuller LVick SHansell MJunge 

HPeterson RLantz SCurrie GUsova 

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

RMeyer (robert.meyer@exeloncorp.com) 

ADAMS Accession No. ML082960036 

OFFICE IOLB IOLB/BC 

NAME SGuenther NSalgado 

DATE 10/22/08 10/30/08 

 OFFICIAL RECORD COPY 
 

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

October 8, 2008 

Name Organization 

Nancy Salgado (via telephone) NRC / HQ 

Lawrence Vick NRC / HQ 

George Usova NRC / HQ 

Richard Pelton NRC / HQ 

David Muller NRC / HQ 

John Munro NRC / HQ 

Siegfried Guenther NRC / HQ 

Sean Currie NRC / HQ 

Sam Hansell NRC / RI 

Malcolm Widmann NRC / RII 

Hironori Peterson (via telephone) NRC / RIII 

Ryan Lantz (via telephone) NRC / RIV 

Jack Roe Nuclear Energy Institute (NEI) 

Russell Smith NEI 

Chuck Sizemore Florida Power and Light (FPL) – Point Beach 

Gregg Ludlam Exelon – Oyster Creek 

John Steely Duke Energy 

Timothy Dennis ANS 3.5 Standards Committee 

Kerry Wright FPL - Seabrook 

Steve Dennis Western Technical Services 

Tom Mayfield Entergy 

Robert Meyer (via telephone) Professional Reactor Operator Society 

 

ENCLOSURE 1
ENCLOSURE 2

AGENDA FOR THE CATEGORY 2 PUBLIC MEETING WITH THE 

 INDUSTRY FOCUS GROUP (FG) ON OPERATOR LICENSING ISSUES 

 October 8, 2008; 9:00 a.m. - 2:00 p.m. 

 U. S. Nuclear Regulatory Commission 

 One White Flint North, Room 3B4 

 11555 Rockville Pike, Rockville, MD 20852-2738 

Conference Bridge: 888-456-0285; Pass Code 22975 

TOPIC LEAD

Introductions and Opening Remarks NRC/FG 

Public Input Public 

Generic Issues NRC/FG 

- Simulator fidelity and testing 

 - NRC Form 396 OMB Clearance pubic comment closes 10/15 

- Three new FAQs posted on the OL Feedback page 

 - Storing medications on-site 

 - New reactor licensing update 

 - 2007 Training Report issued 

 - Reporting medical conditions 

Public Questions and Answers Public 

Initial Licensing Issues NRC/FG 

 - RIS-2008-16 Exam projections 

 - Examination results (including Generic Fundamentals) 

 - License eligibility (ACAD 00-003) 

 - Other 

Public Questions and Answers Public 

Requalification Issues NRC/FG 

- IP-71111.11 changes 

- NRC staff questions 

Focus Group Issues 

 - Promoting consistency between Regions FG 

Public Questions and Answers Public 

Summary / Conclusion / Action Item Review NRC/FG 
 

DISCUSSION SUMMARY

GENERIC ISSUES 

Simulator Scenario Based Testing (SBT) Methodology

The NRC staff acknowledged receiving the Nuclear Energy Institute’s (NEI’s) September 18, 

2008, White Paper entitled “Nuclear Power Plant-Referenced Simulator Scenario Based Testing 

Methodology” for review and comment. Although the staff did share some preliminary 

observations regarding the paper, it informed the attendees that it will take some time to review 

the details and solicit input from its Regional examiners. The staff noted its general agreement 

with the “checklist” concept, but recommended that it might be better to limit the checklist to 

simulator performance items rather than mix them up with operating test validity criteria from 

NUREG-1021, “Operator Licensing Examination Standards for Power Reactors.” The staff also 

reiterated its position that the proposed SBT Methodology does not relieve, relax, nor circumvent 

the functional, fidelity, and physical requirements of ANSI/ANS-3.5-1998, that was previously 

endorsed by the NRC. The staff’s goal is to provide detailed technical comments, suggestions, 

and recommendations to NEI by November 30, 2008. Assuming that any technical issues are 

adequately resolved, the staff expects that it will be able to incorporate or endorse the SBT 

methodology with its pending revision of Regulatory Guide 1.149, “Nuclear Power Plant 

Simulation Facilities for Use in Operator Licensing Examinations,” currently planned for 2009. 

NRC Form 396 Office of Management and Budget (OMB) Clearance Pubic Comments

The NRC staff informed attendees that the triennial renewal of the OMB information collection 

clearance is in progress and that the public comment period will close on October 15, 2008. 

Anyone interested in reviewing the burden estimates and making comments should refer to the 

Documents for Comment page on the NRC’s website. 

Three New Frequently Asked Questions (FAQs) Posted on the OL Feedback Page

The NRC staff informed attendees that it recently posted three new questions and answers on 

the Operator Licensing Feedback page and briefly summarized the issues, which included the 

following: a clarification that the emergency plan topic on the administrative section of the initial 

licensing operating test does not include emergency operating procedures; guidance related to 

the rehiring and license retention (or relicensing) of retired operators; and guidance related to 

license conditions for operators suffering from sleep apnea. 

Storing Medications On-site

The NRC staff informed attendees that it had recently received an inquiry regarding its policy 

with respect to operators keeping a supply of required medications on-site in case they are 

unable to return home for an extended period of time. The staff noted that it does not have an 

official policy but that it was planning to develop a new FAQ to alert facility licensees and 

operators to the issue. 

ENCLOSURE 3 
 

New Reactor Licensing Update

A representative from the Office of New Reactors (NRO) provided a brief update of their 

significant operator licensing activities since the last meeting. Those activities included a visit to 

the Mitsubishi Heavy Industries digital control room simulator in Mars, PA, to assist the staff in 

planning its simulator training needs for license examiners and visits to Japan and Taiwan to 

gain insights into training and testing operators in digital control rooms. The staff also noted that 

the ANSI 3.1 working group is being reconstituted (see additional discussion below under 

license eligibility). 

2007 Training Report Issued

The NRC staff informed attendees that it had recently issued its “Annual Report on the 

Effectiveness of Training in the Nuclear Industry for Calendar Year 2007” and that the report is 

available via a link from the NRC’s Operator Licensing Webpage. The staff provided a brief 

synopsis of the report, noting that the Human Factors Information System (HFIS) database for 

calendar year 2007 shows 255 fewer errors than in 2006 and that the human performance errors 

attributable to training constituted only a small fraction of the total. When the representative 

from the Professional Reactor Operator Society (PROS) noted that the data in HFIS appears to 

be dated, the staff acknowledged that its new contractor was working to catch up on the backlog 

since the previous contract expired. The staff also offered to make a presentation on HFIS 

during a future meeting to familiarize the FG with the system’s capabilities. 

Reporting Medical Conditions

The NRC staff reported that some Regions have noted an increase in the incidence of medical 

conditions that are not properly reported to the NRC as required by the regulations. The staff 

noted that the last generic communication on this subject (Information Notice (IN) 2004-20) was 

not mailed directly to licensed operators but it did remind facility licensees that operators need to 

be familiar with their medical requirements so they can keep their employer informed of 

reportable changes in medical status. The NEI and PROS representatives suggested that the 

NRC explore other means of communicating directly with operators, but the FG noted that there 

are plenty of communications tools already available. The staff agreed to consider NEI’s 

suggestion and further noted that it has attended two contractor-sponsored medical workshops 

and would support the industry if it undertook a similar event. 

INITIAL LICENSING ISSUES 

RIS-2008-16 Exam Projections

The NRC staff reported that most facility licensees, including one new reactor licensee, had 

responded to the subject RIS with their examination projections for the next four years. The 

Region II representative indicated that its number of examinations and applicants per exam are 

increasing dramatically and that near term changes in exam dates and class sizes are impacting 

its ability to schedule its limited resources. The staff noted that the Mid-Atlantic Nuclear Training 

Group (MANTG) has taken an active role in helping Region I prioritize its examination schedule 

and suggested that the Southern States Nuclear Training Association (SSNTA) perform a similar 

service for Region II. 

2 
 

Examination Results

The NRC staff reported that it has been compiling the examination results for fiscal year 2008 

and that the preliminary data shows no obvious adverse trends. The staff noted that it will 

update the graphs on the Operator Licensing Webpage when all the examination results are 

final (i.e., after any pending appeals are resolved). An NEI representative expressed concern 

that the RO written examination pass rate had declined significantly from 2003 through 2007, as 

evidenced by the graphs on the NRC’s website, and suggested that the industry perform a root 

cause analysis of this adverse trend. The staff noted that the preliminary 2008 data appears to 

have reversed the trend and opined that the average written examination grades, which 

remained almost constant over that same period, are a better indicator of examination difficulty. 

[Note that, during the August 2007 meeting (see ML072630592 for a summary), the staff 

enumerated a number of factors, other than examination difficulty, that could be affecting 

operator performance: e.g., more difficulty in recruiting qualified applicants; trying to reduce cost 

by training more operators with fewer instructors; the retirement of experienced trainers; oldschool training techniques may be less effective with the current generation of trainees; and less 

rigorous pre-exam screening criteria. The NRC staff found no basis to conclude that the 

examinations were getting more difficult, and the FG agreed with the staff’s conclusion that a 

host of other factors are likely responsible for any changes in operator performance.] 

The staff also briefly reviewed the results of the September 2008 generic fundamentals 

examination (GFE), noting that while the failure rate on the PWR examination was higher than 

normal, the average grades were consistent with past results, leading the staff to conclude that 

the examination was within the normal range of difficulty. The staff also reminded the FG 

attendees that they have the option of reviewing the GFE before it is administered, as described 

in Section c.4 of ES-205 of NUREG-1021. 

License Eligibility (ACAD 00-003)

The NRC staff informed the attendees that it is aware of two potential changes that the Institute 

of Nuclear Power Operations (INPO), which was not represented at the meeting, is considering 

for ACAD 00-003. The first would clarify, at the staff’s request, what type of activities would 

satisfy the requirement for 6 months of on-site experience for SRO applicants per Figure 2-3 of 

the ACAD, and the second would extend the academic-equivalence provisions of Figure 2-3 to 

Figure 2-4, as well. The staff also reviewed some recent eligibility waiver requests and 

encouraged facility licensees to resolve any eligibility questions before the applicants enter the 

training program rather than wait until the training is (almost) complete. The staff noted that 

reconstitution of the ANSI 3.1 working group, noted above, provides an opportunity to reconcile 

some of the differences between the industry standard and the ACAD. The chairman of the 

ANSI 3.1 working group, who happened to be representing NEI at the meeting, indicated that the 

Standard was definitely outdated; students are different today, and it needs to recognize INPO 

accreditation, state of the art simulators, and other technological advances and changes in our 

educational system. The staff agreed to continue working with INPO and the FG to address 

eligibility issues during future meetings. 

3 
 

REQUALIFICATION ISSUES 

IP-71111.11 Changes

The NRC staff updated attendees on the status of a proposed revision to IP-71111.11, 

“Licensed Operator Requalification Program,” that was first reported during the August 2007 FG 

meeting. The staff noted that it is working with a group of Regional examiners in an effort to 

resolve comments submitted with respect to the existing procedure. The staff does not intend to 

change the frequency of the inspections or the areas inspected, and no firm timeline has been 

established for its completion. The NEI and FG representatives expressed concerns that the 

staff not regulate through inspection or inspect against INPO ACAD guidelines, and the staff 

provided assurance that the new procedure would be reviewed to ensure compliance with the 

Backfit Rule. 

NRC Staff Questions

The NRC staff sought feedback from the FG attendees regarding two questions that had 

recently come up with regard to requalification program management. Although the staff was 

aware that accredited programs often suspend their routine training cycles during plant outages, 

it sought clarification regarding the allowable frequency and duration of such breaks. The FG 

attendees explained that the breaks could last up to 90 days, but that plants are required to 

complete 5 to 6 training cycles per year (with each cycle lasting about 5 to 6 weeks) and a 

required minimum number of classroom and simulator training hours, and that INPO would issue 

a warning flag if a facility’s breaks are too long or too frequent. The staff also sought clarification 

on the industry practice regarding make-up training if an operator missed part of a requalification 

training cycle, and the FG indicated that most facilities require their operators to make up any 

missed training by the end of the next training cycle. 

FOCUS GROUP ISSUES 

Promoting Consistency Between Regions

The FG members questioned the NRC staff regarding a draft guidance document that Region II 

had developed to help examiners screen SRO-only written examination questions and 

expressed concern that it was contributing to inconsistency between the Regions. The staff 

indicated that it was aware of the document and has been working with the other Regions to 

reach internal consensus on the guidance before presenting it to the FG for review and formal 

implementation. The staff noted that it currently plans to have each Region use the draft 

guidance for 6 months to a year and provide feedback to Region II to refine the guidance. The 

guidance is intended to clarify existing policy in NUREG-1021, so any question changes required 

as a result of the new screening tool will have to be justified using existing NUREG criteria. The 

staff committed to share the results of the trial examinations and the updated guidance with the 

FG during the next meeting. If the staff and FG determine that the new guidance adds value to 

the process, it will be formally implemented and incorporated in the next revision of 

NUREG-1021. 

4