NEI New Plant Training Task Force 

1 

Operator Licensing Process Position Paper 

Introduction

The existing fleet of commercial nuclear plants in the United States was constructed by 

numerous vendors with little standardization. With many site-specific differences, plants 

developed their own training programs with relatively little standard training content. 

Currently, operator license candidates are selected by each nuclear site to participate in 

site-specific or unit specific (for sites that have multiple designs) operator training 

programs developed by the site to meet the requirements of their accredited training 

program and 10 CFR Part 55, Operators’ Licenses. License candidates are granted an 

NRC nuclear plant Reactor Operator or Senior Reactor Operator license upon 

successful completion of the site program and the requirements specified in 10 CFR Part 

55. The operator licensing process is designed for implementation by existing nuclear 

facilities that are operating at power and possess plant reference simulators. The 

license examination process includes written examinations and operating tests. The 

written examinations are administered in two sections, a generic fundamentals 

examination (GFE) section and a site-specific examination. The operating test includes 

performance tests using the plant reference simulator and walk-throughs in the plant. 

The site-specific written examination and the operating test are normally conducted 

during the same week, but may occur with up to a 30 day separation from each other. 

NUREG 1021 implements the requirements of 10 CFR 55 and describes specific 

methods for license examinations. 

There are currently many combined license applications under review by the NRC. 

Planning for the staffing and training of licensed operators is in progress. In order to 

assure sufficient numbers of licensed operators are available when required to support 

operation of these facilities, training must commence several years before start-up 

activities begin. Several facilities are scheduled to begin operation within one or two 

years of each other; therefore, the demand for operator license examinations is 

expected to begin as early as 2013 and peak in the 2015 – 2017 time frame. Anticipated 

delays in the availability of plant reference simulators will tend to exacerbate the peak 

demand for licensed operator examinations. Consequently, the nuclear industry is 

recommending alternatives to the operator licensing process. Proposed alternatives 

include flexibility in the sequencing of written and operating exams and the 

administration of exams for multiple facilities on a common date. In addition, this paper 

discusses potential regulatory issues, and identifies needed changes to regulatory 

guidance documents to support the proposed exam process changes. Rulemaking is 

not expected to be required to support this process. 

Problem Statement

Expectations are for 45 licensed operators to adequately staff an operating unit (75 for 

two units) require utilities to train and qualify license operator candidates over several 

years. As a result, there is an anticipated “surge” in new reactor operator license 

applicants in the next few years because of building new reactors. Current projections 

suggest 36 applicants in 2013, 156 applicants in 2014, 275 applicants in 2015, 89 

applicants in 2016, and 120 applicants in 2017. In addition, existing operating plants are 
NEI New Plant Training Task Force 

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expected to experience a surge in license applications to replace retirements. For 

reasons described below, it may not be possible to conduct operating exams for licensed 

operator candidates before the scheduled fuel load. Also, the work load for NRC 

operator license examiners may exceed capacity during the expected surge of operator 

license candidates. Consequently, staffing of new nuclear power plants with licensed 

operators may be delayed due to the current practice of administering operating exams 

within 30 days of the written exam. A delay in the staffing of licensed operators would 

result in the delay of fuel load. 

As discussed in NEI 06-13A, plant reference simulators lag the completion of plant 

design, and operator training may be conducted for the first plants using limited scope 

simulators. In addition, in order to have knowledgeable operators participate in plant 

construction and testing, operator training must be conducted much earlier and most of it 

completed substantially before the plant reference simulator is available. As a result the 

typical training sequence may be altered due to the unavailability of a plant reference 

simulator early in the training program. In addition, the delay in the availability of the 

plant referenced simulator may cause operating exams for a facility to be conducted 

within one year of fuel load. Also, instructor resources may be inadequate to effectively 

develop examinations and prepare license candidates for NRC exams. Consequently, 

the current practice of conducting the site-specific written examination during the same 

week (maximum 30 days) as the operating test may be difficult to execute. 

Proposed Process Changes

To ensure sufficient numbers of licensed operators are available to support fuel load, the 

NEI New Plant Training Task Force proposes the following changes to the administration 

of the operator licensing process for next generation reactors: 

1. Allow variable sequencing and separation between the site specific examination 

and the operating test portions of the examination. Allow the separation to be 

increased from 30 days to 24 months. 

2. Allow site specific written examinations to be developed, approved, and 

administered to license candidates for all similar reactor types on the same day. 

The existing operator licensing and training process is shown on Attachment A, and the 

proposed operator licensing and training process is shown on Attachment B. 

Process Change Benefits

1. Allow variable sequencing and separation between the site specific examination 

and the operating test portions of the examination. Allow the separation to be 

increased from 30 days to 24 months. 

• Site specific written exam would maintain high quality while minimizing 

resource constraints on both the NRC and facility licensees. 
NEI New Plant Training Task Force 

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• Eliminates need for the NRC to develop approval process for use of a 

limited scope simulator for operating exam 

• Site specific written exams could be provided at predictable intervals, 

such as biannual thus allowing NRC resources to be leveled 

• Allows instructor teams to remain intact throughout the program and 

allows student ratios to be maintained at an optimum level throughout the 

program thus improving training effectiveness 

• Allows candidates to be tested in sequence with the training program thus 

reducing candidate stress 

2. Allow site specific written examinations to be developed, approved, and 

administered to license candidates for all similar reactor types on the same day. 

• Increases the number of examined candidates to NRC resource ratio 

• Enhances the ‘Uniform Condition’ clause of the Atomic Energy Act 

• Fewer exams to develop, approve, proctor, thus easing exam security 

concerns 

• Reduces licensee resources devoted to development of site-specific 

written examination 

• Provides opportunities to develop a ‘closed’ exam bank 

 

Process Change Risks and Mitigating Strategies

1. Allow variable sequencing and separation between the site specific examination 

and the operating test portions of the examination. Allow the separation to be 

increased from 30 days to 24 months. 

• May decrease comprehensive examination validity 

• Currently, the FAA allows up to 2 years between the written examination 

for a pilot rating and the operational examination.Increases difficulty of 

maintaining examination section content overlap within acceptable limits 

3⁄4 Examination development procedures would be reviewed and 

updated as necessary to ensure exam developers reviewed all 

applicable exams to maintain overlap within acceptable limits 

• May increase difficulty of maintaining examination security 

3⁄4 Examination security procedures would be reviewed and 

updated as necessary to account for the revised process 

• Reduced opportunity for license candidates to appeal results of the 

written examination 

3⁄4 Under this proposal, license candidates would take the sitespecific written examination before formally applying for a 
NEI New Plant Training Task Force 

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license, thus the need for appeals would be eliminated. If a 

candidate failed the exam the candidate could retake an exam 

after remediation. 

• Increased training burden on utilities from earlier placement of licensed 

operator candidates in a continuing training program 

3⁄4 License candidates would begin an operator license continuing 

training program within 90 days of taking the site-specific written 

exam. Utilities already plan to initiate a continuing training 

program early in the licensed operator training program. 

2. Allow site specific written examinations to be developed, approved, and 

administered to license candidates for all similar reactor types on the same day. 

• May increase difficulty of maintaining examination security 

3⁄4 Examination security procedures would be reviewed and 

updated as necessary to account for the revised process 

• Utility commitment to standardized examination reference material 

3⁄4 Utilities are committed to standardization as evidenced through 

the formation of the Design Centered Working Group (DCWG) 

and the Advanced Passive Owners Group (APOG) 

Implementation

Some utility training implementation schedules anticipate the need for a written 

examination as early as the second quarter of 2013. To support this need, the industry 

would work with the NRC to revise the process with the following proposed milestone 

schedule: 

2009 – NRC and industry agree in principle with process change (approve 

 position paper) 

2010 – NRC and industry develop revisions to NUREG 1021 and NRC Form 398 

2011 – Public comment on changes to NUREG 1021 and NRC Form 398 

2012 (First Quarter) – NRC publishes revision to NREG 1021 and NRC Form 

 398 

Compensatory Actions for Process Change Risks

The following table addresses potential process change risks and concerns raised 

during preliminary discussions held with the NRC staff in public meetings. 
NEI New Plant Training Task Force 

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Potential Risk/Concern Regulatory Basis Action 

2 year gap is too long The Atomic Energy Act of 

1954 requires the NRC to 

provide for uniform 

conditions for the licensing 

of operators. 10 CFR 55 is 

silent on the time allowed 

between a written exam 

and the operating exam. 

NUREG 1021 specifies that 

to exceed 30 days, NRR 

must be involved 

The NRC has the authority to 

set uniform conditions that 

would allow a gap of up to two 

years between the written 

examination and the operating 

test. Current NRC guidance 

allows two years to elapse 

between the Generic 

Fundamentals Exam and the 

final site specific exam which 

may be extended beyond two 

years by the NRC on a case by 

case basis. Note: Currently, the 

FAA allows up to 2 years 

between the written examination 

for a pilot rating and the 

operational examination. 

Gap allows training to 

be narrowly focused – 

may be better for 

training but not for 

evaluation 

Not directly addressed by 

regulation or regulatory 

guidance 

The industry agrees that this is a 

better process from a training 

perspective. The industry does 

not believe separating the 

written examination from the 

operating test diminishes the 

validity of the qualification 

process. 

Examination must be 

comprehensive 

Content of the written 

examination is specified by 

10 CFR 55.41 and 10 CFR 

55.43 

The degree of standardization 

for new generation plants is 

expected to be extensive, the 

written exam would continue to 

be comprehensive in that all 

requirements of 55.41 and 55.43 

would be met 

Having a bulk exam 

makes security difficult 

Examination Integrity 

requirements are specified 

in 10 CFR 55.49. 10 CFR 

55.49 requirements are 

implemented throughout 

NUREG 1021 

The industry believes that 

common exam security issues 

would be readily handled with 

existing procedures and policies 

Would have to 

consider overlap with 

operational exam 

differently 

The issue of overlap is not 

covered in 10 CFR 55, but 

is discussed in several 

sections of NUREG 1021. 

These discussions are in 

the form of verification that 

overlap between 

examination sections is 

within acceptable limits 

The operating exam developer 

and reviewer would have to 

have access to the candidates 

written exam to ensure overlap 

was not an issue, and exam 

development procedures would 

be upgraded to ensure overlap 

is not an issue 
NEI New Plant Training Task Force 

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Potential Risk/Concern Regulatory Basis Action 

The uniform conditions 

requirement of the 

Atomic Energy Act 

would need to be 

explored. The longer 

gap allow could 

provide candidates the 

ability to appeal if their 

utility chose not to 

allow the full 2 year 

gap while another 

utility chose to allow 

the full 2 year gap. 

10 CFR 55.33 and 10 CFR 

55.35 provide the regulation 

regarding license 

applications and reapplications. 10 CFR 

55.35(a) provides time 

frames for re-applying if an 

application is denied. 10 

CFR 55.35(b) provides 

permission to retake only 

those parts of the 

examination that were 

failed, but does not provide 

a limit on time. 10 CFR 

2.103(b)(2) provides that an 

applicant may appeal a 

denial within 20 days of 

denial. NUREG 1021 

Section 202 implements the 

regulation, but further 

defines a time limit of two 

years for allowing a waiver 

for retake of passed 

sections of the exam 

The industry is proposing that 

the written examination be 

administered before a candidate 

applies for a license. The 

processes would be analogous 

to the GFE. The facility would 

certify that the candidate is 

enrolled in an operator license 

training program. A candidate 

would have the option of 

retaking a written exam after 

remediation, but would not have 

rights of appeal since no denial 

letter would have been issued. 

The concept is that the process 

for the GFE would be expanded 

to the entire written exam. 

How would an 

examination failure be 

remediated? 

See above See above 

The NRC had a 

comment or 

suggestion to consider 

a license good below 

5% power and then 

take a comprehensive 

examination prior to 

exceeding 5%. 

N/A Would require rulemaking and 

rulemaking is outside the scope 

of this position paper 

The application form 

would need revision to 

match the white paper 

process. 

Application forms are 398 

and 396 which are 

referenced throughout 10 

CFR 55 

398 needs to be revised to 

incorporate NEI 06-13A 

provisions and would potentially 

need additional modification for 

the proposed revisions 

regarding the written exam. 
NEI New Plant Training Task Force 

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Potential Risk/Concern Regulatory Basis Action 

The white paper needs 

to consider and 

address the risk 

associated with a 

common examination 

and a 2 year gap 

extension. As written it 

only acknowledges 

benefits. 

10 CFR 55 NUREG 1021 

references Chapter 11 of 

the 1985 version of the 

Standards for Educational 

and Psychological Testing 

The proposed process does not 

conflict with 10 CFR 55. The 

risk is that the evaluation 

process would reduce the 

evaluation validity. There is no 

evidence that segmenting the 

qualification process reduces 

the validity of the process 

What will be the 

appeal rights of the 

applicant in bulk 

examinations? 

Considering the 

examination could 

impact several utilities. 

10 CFR 55 and 10 CFR 

2.103(b)(2) 

The process would be 

analogous to the GFE process 

and since the written exam 

would be administered before 

an application was made, no 

appeal process would exist 

The white paper needs 

to consider the makeup of the examination. 

10 CFR 55.41 and 10 CFR 

55.43 provide regulations 

regarding written exam 

content. NUREG 1021 

Sections 401, 402, and 403 

implement the requirements 

of 10 CFR 55.41 and 10 

CFR 55.43 

The degree of standardization 

within the new plant vendor 

design is expected to be high. 

The examination would continue 

to contain all elements of the 

existing exams and be in 

compliance with the regulations. 

Will the use of a 

common examination 

require a rule change? 

The NRC prefers to 

avoid rule changes for 

the common 

examination. 

10 CFR 55 The industry proposals will not 

require a rule change 

When would this 

common examination 

process become 

effective and when 

would it be retired? 

NA The industry proposes that this 

process become effective in 

2013 and be treated as a pilot 

process for permanent revision 

to the process. 

Who would write the 

examination? The 

white paper does not 

address how the 

examination would be 

developed and 

approved. 

10 CFR 55.40(b) allows the 

facility to prepare, 

administer, and grade the 

written examination. 

NUREG 1021 Section 401, 

402, and 403 implement the 

requirements of 10 CFR 

55.40(b) 

The industry proposes to write, 

administer, and grade the 

written exam. 
NEI New Plant Training Task Force 

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Regulatory Analysis

1954 Atomic Energy Act 

Section 107, Operators’ Licenses, of the 1954 Atomic Energy Act states: 

The Commission shall: 

a. prescribe uniform conditions for licensing individuals as operators of any of the 

various classes of production and utilization facilities licensed in this Act; 

b. determine the qualifications of such individuals; 

c. issue licenses to such individuals in such form as the commission may prescribe; 

and 

d. suspend such licenses for violations of any provision of this Act or any rule or 

regulation issued thereunder whenever the Commission deems such action 

desirable. 

Section 202 of 1974 Energy Reorganization Act extends the NRC’s authority regarding 

operator licensing activities to additional nuclear facilities such as demonstration liquid 

metal fast breeder reactors and facilities used for the storage of high-level radioactive 

waste. 

10 CFR 55: 

10 CFR 55 implements the requirements of Section 107 of the 1954 Atomic Energy Act, 

which specifies that the NRC will provide for uniform conditions for licensing operators of 

nuclear power plants, determine their qualifications, issue licenses, and suspend 

licenses for cause as necessary. 

All paragraphs of 10 CFR 55 will not be discussed here. Paragraphs of 10 CFR 55 that 

have implications for developing and administering the written exam are addressed in 

this paper 

 

Paragraphs of 10 CFR 55 related to written examinations include Paragraph 55.33 which 

requires written and operating tests be administered. 

Section 55.40(a) requires the NRC to use the revision of NUREG 1021 in effect 6 

months prior to scheduled exam to prepare written and operating exams and evaluate 

the results of the exams. Section 55.40(b) allows the licensee to prepare, proctor, and 

grade the written exam. Section 55.40(c) allows the facility to have the NRC develop, 

proctor and grade the written examination and allows the NRC to reject an applicant’s 

request to preparing the written or operating examination. 

Paragraphs 55.41 and 55.43 provide requirements related to the content of written 

exams. 

Paragraph 55.47 allows the NRC to waive requirements related to written and operating 

examinations, but the conditions of the paragraph may preclude its use for new plants. 
NEI New Plant Training Task Force 

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Examination requirements may be waived only on a case by case basis and only if the 

applicant has extensive actual experience at a comparable facility. 

Paragraph 55.49 provides requirements related to exam integrity. Note: There does not 

appear to be any regulatory barrier to allowing for common reactor type written exams 

and allowing the site specific written exam to be administered more than 30 days prior to 

the operating exam. 

Other paragraphs of 10 CFR 55 that may have implications for operator licensing 

include: 

 55.45 requires that a plant walkthrough be part of the operating exam. 

Subsection 55.46(c)(2)(i) requires the core model to replicate the most recent core load. 

Section 55.53(e) provides requirements for maintaining an active license 

Regulatory Guidance Analysis

Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants, 

provides guidance that is acceptable to the NRC staff regarding qualifications and 

training for nuclear power plant personnel. RG 1.8 endorses ANSI/ANS-3.1-1993, 

Selection, Qualification, and Training of Personnel for Nuclear Power Plants, with certain 

clarifications, additions, and exceptions. RG 1.8 notes that Subpart D, "Applications," of 

10 CFR Part 55, Operators' Licenses, requires that operator license applications include 

information concerning an individual's education and experience and other related 

matters. However, RG 1.8 does not provide guidance directly related to written 

examinations and thus does not impact this position paper. 

Regulatory Guide 1.149, Nuclear Power Plant Simulation Facilities for Use in Operator 

Training and License Examinations, describes methods acceptable to the NRC staff for 

complying with those portions of the NRC's regulations associated with approval or 

acceptance of a simulation facility for use in reactor operator and senior reactor operator 

training and NRC license examinations. 

In 10 CFR Part 55, "Operators' Licenses," Paragraphs 55.45(a) and 55.45(b) require that 

an applicant for an operator or senior operator license demonstrate both an 

understanding of and the ability to perform certain essential job tasks. The operating test 

would be administered in a plant walk-through and on a simulation facility or on the 

actual plant if approved by the Commission. 

A simulation facility as defined in 10 CFR 55.4 means one or more of the following 

components, alone or in combination, used for the partial conduct of operating tests for 

operators, senior operators, and license applicants or to establish on-the-job training 

experience prerequisites for operator license eligibility: (1) a plant-referenced simulator, 

(2) a Commission-approved simulator in accordance with 10 CFR 55.46(b), or (3) 

another simulation device, including part-task and limited scope simulation devices 

approved under 10 CFR 55.46(b). 

The requirements for the use of a simulation facility for the administration of the operator 

licensing operating test are in 10 CFR 55.46, as are the requirements for the use of a 
NEI New Plant Training Task Force 

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plant-referenced simulator for fulfilling a portion of the experience requirements for 

applicants for operator and senior operator licenses. The requirements for the licensed 

operator requalification programs, including evaluation, are in 10 CFR 55.59(c)(3) and 

(4). 

Although RG 1.149 is not directly applicable to the written portion of an operator license 

examination, it is a key RG for the operating portion of the operator license examination. 

Regulatory Guide 1.134, Medical Evaluation of Licensed Personnel at Nuclear Power 

Plants, describes a method acceptable to the NRC staff for providing the information 

needed by the staff for its evaluation of the medical qualifications of applicants for initial 

or renewal of operator or senior operator licenses for nuclear power plants and for 

providing notification to the NRC of an incapacitating disability or illness. RG 1.134 does 

not apply to the written portion of the operator license examination process. 

NUREG-1122, Knowledge and Abilities Catalog for Nuclear Power Plant Operators, 

Pressurized Water Reactors, provides the basis for the development of content-valid 

licensing examinations for reactor operators (ROs) and senior reactor operators (SROs). 

The examinations developed using the PWR Catalog along with the Operator Licensing 

Examination Standards for Power Reactors (NUREG-1021, Rev. 9, Supplement 1) will 

sample the topics listed under Title 10, Code of Federal Regulations, Part 55 (10 CFR 

55). NUREG-1122 is a pertinent regulatory guidance document related to written 

operator license exams, but will be re-written for advanced passive light water reactors 

and will be revised to reflect technological advances used in other advanced PWR 

designs. These changes will be accomplished under a separate NEI sponsored project. 

Thus NUREG-1122 does not have a direct impact on this position paper. 

NUREG-1123, Knowledge and Abilities Catalog for Nuclear Power Plant Operators, 

Boiling Water Reactors, provides the basis for the development of content-valid licensing 

examinations for reactor operators (ROs) and senior reactor operators (SROs). The 

examinations developed using the BWR Catalog along with the Operator Licensing 

Examination Standards for Power Reactors (NUREG-1021, Rev. 9, Supplement 1) will 

sample the topics listed under Title 10, Code of Federal Regulations, Part 55 (10 CFR 

55). NUREG-1123 is a pertinent regulatory guidance document related to written 

operator license exams, but will be re-written for advanced passive light water reactors 

and will be revised to reflect technological advances used in other advanced BWR 

designs. These changes will be accomplished under a separate NEI sponsored project. 

Thus, NUREG-1123 does not have a direct impact on this position paper. 

NUREG-1220, Training Review Criteria and Procedures, provides direction to NRC 

personnel for reviewing training programs at nuclear power plants to verify compliance 

with the requirements of 10 CFR 50.120 and 10 CFR 55 as applicable. It describes the 

process for evaluating the effectiveness of training programs, provides aids for collection 

of information during interviews and observations, and provides criteria for evaluating the 

implementation of a systems approach to training. NUREG-1220 is not directly pertinent 

to the operator licensing written examination process. 

NUREG-1262, Answers to Questions at Public Meetings Regarding Implementation of 

Title 10, Code of Federal Regulations, Part 55 on Operators’ Licenses, provides 

historical information about the public meetings that were held in 1987 when revisions of 

the subject regulations were implemented. Although NUREG-1262 provides clarification 
NEI New Plant Training Task Force 

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of the regulations for issuing licenses to operators and senior operators, including 

information about written examinations and operating tests, requirements for a plant 

reference simulator, and the form and content for operator license applications; the 

information is dated and NUREG-1262 does not have a direct impact on this position 

paper. 

NUREG-1021, Operator Licensing Examination Standards For Power Reactors, 

establishes the policies, procedures, and practices for examining licensees and 

applicants for reactor operator and senior reactor operator licenses at power reactor 

facilities pursuant to Title 10, Part 55, of the Code of Federal Regulations (10 CFR 55). 

NUREG-1021 is the principal document that establishes NRC policies and processes 

related operator license examinations and thus would require revision to implement the 

recommendations of this position paper regarding written operator license examinations. 

A detailed sectional analysis of NUREG 1021 follows: 

Section Title Revision 

Required

Affected 

Subsections

Basis 

 List of 

abbreviations 

Possible NA The list should be 

reviewed after mark-ups of 

the NUREG are 

completed to determine if 

changes are required 

ES-101 Purpose And 

Format 

Of Operator 

Licensing 

Examination 

Standards 

No NA NA 

ES-102 Regulations and 

Publications 

Applicable to 

Operator Licensing 

Yes 4; xx; yy 4 - For Part 52 licenses 

requalification must 

commence 90 days after 

fuel load. xx and yy – 

Need to be updated to 

reflect new KA catalogs 

for advanced passive light 

water reactors. 

ES-201 Initial Operator 

Licensing 

Examination 

Process 

Yes C.3.j If the written exam date is 

separated from the 

operating test by more 

than 30 days – NRR 

program office must 

approve 
NEI New Plant Training Task Force 

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Section Title Revision 

Required

Affected 

Subsections

Basis 

ES-202 Preparing and 

Reviewing 

Operator Licensing 

Applications 

Yes B; C.1.a; 

C.1.b; D.4 

B – Update to reflect cold 

license process; C.1.a – 

398 to be used – propose 

a new process that would 

not require completion of 

all training and 

qualification before taking 

the written examination – 

supplement to 398 

perhaps – certify 

completion of applicable 

classroom training 

(courses) before applying 

for the written exam. Will 

also need to address 

written exam failure retake 

process – medical exam 

now or later? C.1.b – 

revise to provide that 

applying for a written 

exam within 24 months of 

GFE satisfies this section; 

D.4 – Cold license 

eligibility should reference 

NEI 06-13A 

ES-204 Processing 

Waivers Requested 

By Reactor 

Operator and 

Senior Reactor 

Operator 

Applicants 

No NA NA – Waivers apply to 

individual candidates and 

not to the process itself. 

ES-205 Procedures for 

Administering the 

Generic 

Fundamentals 

Examination 

Program 

No NA NA – may want to use this 

section as a model for 

administering generic 

vendor related written 

examinations 

ES-301 Preparing Initial 

Operating Tests 

Yes D.1.g D.1.g – suggests the 

operating test should be 

conducted on both units of 

a multi-unit site – difficult 

to do as second unit may 

be several years behind 

initial unit – should not be 

an issue due to level of 

standardization 
NEI New Plant Training Task Force 

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Section Title Revision 

Required

Affected 

Subsections

Basis 

ES-302 Administering 

Operating Tests to 

Initial License 

Applicants 

No NA NA 

ES-303 Documenting and 

Grading Operating 

Tests 

No NA NA 

ES-401 Preparing Initial 

Site-Specific 

Written 

Examinations 

Yes B; C.2.b B – Background suggests 

the written exam is given 

in two sections – GFE and 

site specific. We may be 

adding a third – generic 

vendor type written. C.2.b 

– only allows 30 day 

margin between written 

and operating exams 

ES- 403 Grading Initial SiteSpecific Written 

Examinations 

No NA NA 

ES-501 Initial PostExamination 

Activities 

Yes B B – Goal of the NRC is to 

complete licensing or 

denial within 30 days of 

grading exam. This 

section should be modified 

to meet the provisions of 

NEI 06-13A which 

provides for the NRC to 

issue the license well after 

the examination process. 

This section would require 

a general re-write to 

reflect a revised process 

ES-502 Processing 

Requests for 

Administrative 

Reviews and 

Hearings after 

Initial License 

Denial 

Yes B B – General re-write 

because review and/or retake of the written exam 

should occur before 

license denial 

ES-601 Conducting NRC 

Requalification 

Examinations 

No NA NA 

ES-602 Requalification 

Written 

Examinations 

No NA NA 

ES-603 Requalification 

Walk-Through 

Examinations 

No NA NA 
NEI New Plant Training Task Force 

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Section Title Revision 

Required

Affected 

Subsections

Basis 

ES-604 Dynamic Simulator 

Requalification 

Examinations 

No NA NA 

ES-605 License 

Maintenance, 

License Renewal 

Applications, and 

Requests for 

Administrative 

Reviews and 

Hearings 

Yes C.2 C.2 – It is not clear how 

operators will maintain 

active licenses before fuel 

load. This section should 

be clarified for cold 

licenses. 

ES-701 Administration of 

Initial Examinations 

for Senior 

Operators Limited 

to Fuel Handling 

No NA NA 

ES-702 Administration of 

Requalification 

Examinations for 

Senior Reactor 

Operators Limited 

to Fuel Handling 

No NA NA 

Appendix A Overview of 

Generic 

Examination 

Concepts 

Yes All Some of the concepts in 

this section contribute to 

the differences between 

the NRC and the industry 

regarding the difficulty 

level of written 

examinations. This 

section should receive a 

comprehensive and cross 

disciplinary review and 

comments should be 

provided to the NRC 

Appendix B Written 

Examination 

Guidelines 

Yes All Some of the concepts in 

this section contribute to 

the differences between 

the NRC and the industry 

regarding the difficulty 

level of written 

examinations. This 

section should receive a 

comprehensive and cross 

disciplinary review and 

comments should be 

provided to the NRC 
NEI New Plant Training Task Force 

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Section Title Revision 

Required

Affected 

Subsections

Basis 

Appendix C Job Performance 

Measure 

Guidelines 

No NA NA 

Appendix D Simulator Testing 

Guidelines 

No NA NA 

Appendix E Policies and 

Guidelines for 

Taking NRC 

Examinations 

No NA NA 

 Glossary Possible NA The list should be 

reviewed after mark-ups of 

the NUREG are 

completed to determine if 

changes are required 

Industry Standards Analysis

ANSI/ANS 3.1, American National Standard for Selection, Qualification, and Training of 

Personnel for Nuclear Power Plants, provides criteria for selecting and training nuclear 

power plant employees who perform a variety of functions at various levels of 

responsibility (e.g., managers, supervisors, operators, and technicians). RG 1.8, 

Revision 3 (May 2000) endorses the 1993 version of this standard, with additions, 

exceptions, and clarifications thereto. ANS 3.1 is currently being revised under the 

sponsorship of NEI and the proposed changes would not impact issues discussed in this 

position paper. 

ANSI/ANS 3.4-1996, Medical Certification and Monitoring of Personnel Requiring 

Operator Licenses for Nuclear Power Plants, is the basic document covering the general 

health and disqualifying conditions applicable to license applicants and licensed 

personnel. Revision 3 of RG 1.134 currently endorses this standard, with exceptions. 

ANS 3.4 does not impact issues discussed in this position paper. 

ANSI/ANS 3.5-1998, Nuclear Power Plant Simulators for Use in Operator Training, 

establishes the minimum functional requirements and capabilities for nuclear power 

plant simulators for use in operator training. Revision 3 of RG 1.149 endorses this 

standard, with clarifications. ANS 3.5 is currently under revision but is not expected to 

impact issues discussed in this position paper. 

Training Guidance/Accreditation Analysis

ACAD 09-001, Guidelines for Initial Training and Qualification of Licensed Operators, 

when used in conjunction with plant-specific job and task analyses, provides the 

framework for a training and qualification program for reactor operators and senior 

reactor operators at nuclear power plants. 

The guideline addresses the following: 

• the licensing of reactor operators and senior reactor operators for operating 

existing nuclear power plants 
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• the licensing of reactor operators and senior reactor operators for initial startup 

and operation of newly constructed nuclear power plants (cold licensing) 

With the exception of a brief discussion related to license exam preparation, ACAD 09-

001 does not affect the issues discussed in this position paper. 

Summary 

To alleviate an expected surge in the demand for operator licensing exams, the industry 

is proposing revisions to the operator licensing examination process. The proposed 

changes include: 

1. Allow site specific written examinations to be developed, approved, and 

administered to license candidates for all similar reactor types on the same day. 

2. Allow the separation between the plant-design written examination, the sitedesign written examination, and the operating test portions of the examination to 

be increased from 30 days to 24 months to support earlier training on designbased topics and then experience during construction. The requalification 

requirements of 10 CFR 55 would be met for the portion of the examination 

process completed. 

The existing operator licensing and training process is shown on Attachment A and the 

proposed operator licensing and training process is shown on Attachment B. The 

proposed changes can be made without rulemaking. The proposed changes would 

require a revision to NUREG 1021 and NRC Form 398. 

The industry will work with the NRC to address NRC concerns, draft revisions of 

guidance documents, and support any required public comment and review. 

The industry needs the revised process to be in place by the second quarter of 2013.
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Attachment A 

Existing License Training and Examination Process 
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Attachment B 

Proposed License Training and Examination Process 

Enroll in License 

Training

Fundamentals 

Training GFES Exam

Classroom and 

Limited Simulator 

Training and Plant 

Experience

Written Audit 

Exam

NR

NR

Up to 24 months 30 days

OJT, Simulator, 

Plant Experience, 

and Review 

Training

NRC Operating 

Exam

Operating Audit 

Exam

5 months Up to 24 months

Plant Experience if 

Necessary

Up to 6 

months

Licensed Operator Candidate 

Continuing Training