December 30, 2009 

MEMORANDUM TO: Michael Junge, Chief 

Operator Licensing and Human Performance Branch 

Division of Construction and Operational Programs 

Office of New Reactors 

FROM: Richard Pelton /RA/ 

Operator Licensing and Human Performance Branch 

Division of Construction and Operational Programs 

Office of New Reactors 

SUBJECT: SUMMARY OF DECEMBER 2, 2009, MEETING WITH THE 

INDUSTRY FOCUS GROUP ON NEW REACTOR OPERATOR 

LICENSING 

On December 2, 2009, the U.S. Nuclear Regulatory Commission (NRC) staff held a public 

meeting with the Industry Focus Group on New Reactor Operator Licensing to discuss potential 

changes to the licensed operator examination process. Enclosure 1 lists the attendees at the 

meeting. Enclosure 2 is the meeting agenda. This meeting was the latest in a series intended 

to promote efficient, effective, and consistent preparation and administration of new reactor 

operator licensing examinations. 

The NRC representatives stated that NRC concerns focused on the fact that the potential exists 

that license candidates will not maintain their level of readiness after taking the written 

examination. It was further stated that the proposal is a temporary measure designed to bridge 

any potential gaps resulting from the unavailability of plant referenced simulators. In addition, 

the NRC stated that any changes form the current process would be used for limited period of 

and with limited number of candidates using the system. 

Enclosure 3, “Comments on Operator Licensing Process Position Paper” (ML093510901), 

identifies NRC questions and comments based on the review of the “Operator Licensing 

Process Position Paper, Revision C” (ML092440070). Areas within the position paper where 

NRC staff had questions or comments are identified by number. Enclosure 4 contains the 

industry responses to those comments that were discussed during the public meeting. 

No final positions were taken during the meeting. The staff did agree to consider the need for 

clarifications and additions to NUREG-1021 or other regulatory documents to implement the 

modified operator licensing guidance. The industry agreed to consider the staff’s comments and 

will submit a revision to the Operator Licensing Process Position Paper prior to the next meeting. 

Enclosures: As stated 

CONTACT: Rick Pelton, NRO/DCIP 

 (301) 415-1028 
MEMORANDUM TO: Michael Junge, Chief 

Operator Licensing and Human Performance Branch 

Division of Construction and Operational Programs 

Office of New Reactors 

FROM: Richard Pelton /RA/ 

Operator Licensing and Human Performance Branch 

Division of Construction and Operational Programs 

Office of New Reactors 

SUBJECT: SUMMARY OF DECEMBER 2, 2009, MEETING WITH THE 

INDUSTRY FOCUS GROUP ON NEW REACTOR OPERATOR 

LICENSING 

On December 2, 2009, the U.S. Nuclear Regulatory Commission (NRC) staff held a public 

meeting with the Industry Focus Group on New Reactor Operator Licensing to discuss potential 

changes to the licensed operator examination process. Enclosure 1 lists the attendees at the 

meeting. Enclosure 2 is the meeting agenda. This meeting was the latest in a series intended 

to promote efficient, effective, and consistent preparation and administration of new reactor 

operator licensing examinations. 

The NRC representatives stated that NRC concerns focused on the fact that the potential exists 

that license candidates will not maintain their level of readiness after taking the written 

examination. It was further stated that the proposal is a temporary measure designed to bridge 

any potential gaps resulting from the unavailability of plant referenced simulators. In addition, 

the NRC stated that any changes form the current process would be used for limited period of 

and with limited number of candidates using the system. 

Enclosure 3, “Comments on Operator Licensing Process Position Paper” (ML093510901), 

identifies NRC questions and comments based on the review of the “Operator Licensing 

Process Position Paper, Revision C” (ML092440070). Areas within the position paper where 

NRC staff had questions or comments are identified by number. Enclosure 4 contains the 

industry responses to those comments that were discussed during the public meeting. 

No final positions were taken during the meeting. The staff did agree to consider the need for 

clarifications and additions to NUREG-1021 or other regulatory documents to implement the 

modified operator licensing guidance. The industry agreed to consider the staff’s comments and 

will submit a revision to the Operator Licensing Process Position Paper prior to the next meeting. 

Enclosures: As stated 

CONTACT: Rick Pelton, NRO/DCIP 

 (301) 415-1028 

Meeting Notice Accession Number: ML093220430 

Meeting Summary Accession Number: ML093630831 

ADAMS Package Accession Number: ML093631326 NRC-001 

OFFICE DCIP/COLP DCIP/COLP:BC 

NAME RPelton MJunge 

DATE 12/30/09 12/30/09 

 OFFICIAL RECORD COPY 
ENCLOSURE 1 

Meeting with the Industry Focus Group on 

New Reactor Operator Licensing 

December 2, 2009 

Meeting Attendees 

Name Organization 

Mike Junge NRC / NRO 

Rick Pelton NRC / NRO 

Fred Guenther NRC / NRR 

Jack McHale NRC / NRR 

Malcolm Widmann NRC / RII via telephonic bridge 

Hironori Peterson NRC/RIII via telephonic bridge 

Rick Hons Progress Energy 

Tom Kuhar Westinghouse 

Julia Longfellow GE - Hitachi 

Walt Shura Dominion 

Wes Sparkman Southern Nuclear Company 

John Butler NEI 

Glenn MacDonald STPNOC 

Charles Sawyer Duke

Al Koon SCANA 

Michael Llewellyn INPO 

William Wagner DTE Energy 

Chris Paulsen GTTSI 

Leonard Kabana MNES 

Ted Amundson Southern Nuclear Company 
ENCLOSURE 2

AGENDA FOR THE CATEGORY 2 PUBLIC MEETING WITH THE 

INDUSTRY FOCUS GROUP ON NEW REACTOR OPERATOR LICENSING ISSUES 

December 2, 2009 

9:00 a.m. – 2:00 p.m. 

Nuclear Regulatory Commission 

One White Flint North 

11555 Rockville Pike -- Room O 7 B4 

Rockville, MD 20852 

TOPIC LEAD

Introductions and Opening Remarks NRC/Focus Group 

Public Input Public 

Changes to the operator licensing process Focus Group 

Public Questions and Answers Public 

Summary / Conclusion / Action Item Review NRC/ Focus Group 
ENCLOSURE 4

COMMENTS ON OPERATOR LICENSING PROCESS POSITION PAPER 

For comment 1, refer to page 1 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

1. The argument seems to be that demand for exams will go up and simulators won’t 

be available in time, so the process needs to change. Has the industry explored 

other options besides a change in the process, e.g. addressing the delay in 

simulators or hiring more instructors and exam developers and having them in 

place in time for the anticipated demand? 

Yes, the industry has been working on changes to the operator licensing process for more than 

three years. 

The first step in the process was to estimate instructor and licensed operator resource 

requirements. During this step, it was discovered that simulator availability would be a problem. 

 It was determined that certifying that the simulator was plant referenced coupled with the 

number of operators to be licensed; two simulators would be required at each site. 

The second step in the process was to determine the qualifications and experience of potential 

candidates. The result of this review was NEI 06-13A, revision 2, “Licensed Operator Training 

Cold Licensing Plan Template” (ML090910554). 

The third step was to determine the size of the staff necessary to train the projected number of 

candidates. The result of this review was the determination that additional training staff is 

needed. 

The industry is determining the process to safely and efficiently hire additional training staff. The 

instructors are expected to commence training with Westinghouse in 2010. 

For comment 2, refer to page 2 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

2. What is the significance of the operating test being conducted within one year of 

fuel load? 

The objective of conducting the operating test within one year of fuel load is to provide the 

operators with additional plant experience. 

For comment 3, refer to page 2 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

3. If it is anticipated that existing instructor resources may be inadequate to develop 

examinations and conduct training, it would seem logical to increase the number 

of instructors now in anticipation of the future workload rather than or in addition 

to recommending a change to the examination process. If the licensee ensures 

that sufficient resources are in place (by 1Q2013), then the current practice of 
2

4. conducting the written exam and operating test within approximately 30 days 

would not be as difficult to achieve. 

Refer to the response to comment 1 above. It is desirable to have new processes in place early 

to allow changes to improve the processes as necessary. 

For comment 4, refer to page 2 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

5. What is the basis for 24 months (vs. 90 days, 6 months, 12 months, etc.)? What 

licensee training resource assumptions are associated with 24 months? 

The 24 months is a worst case scenario. The actual time between the written exam and 

operating test should be no more than 12 months. Factors that could influence the time 

between exam and test include instructor availability, training schedules, and plant construction 

and start up activities. 

The current waiver process should work. The industry had questions regarding the waiver 

process: 

● how should the waivers be submitted, 

● what information needs to be included in the waiver, 

● what needs to be included in the package to demonstrate to the NRC that candidate 

knowledge will not deteriorate 

For comment 5, refer to page 2 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

6. How will any required site-specific knowledge be tested? 

Site specific knowledge and abilities will be tested using methods currently being used in the 

operator licensing examination process, job performance measures and site-specific questions 

on the written examination. 

For comment 6, refer to page 2 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

7. This seems to imply that quality will suffer if the proposed process change is not 

adopted. What licensee training resource assumptions are associated with 24 

months? What other mechanisms to ensure qualities were examined besides a 

process change? 

Not discussed during the meeting. 

For comment 7, refer to page 2 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901).
3

8. Has the NRC agreed that it has resource constraints that warrant a process 

change? If not, then the benefit is irrelevant. 

Not discussed during the meeting. 

For comment 8, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

9. Why is this a benefit? Do the benefits resulting from not approving a limited scope 

simulator outweigh those of changing the process as described? 

NRC has the authority to allow the use of a limited scope simulator (Part 55) for the license 

exam. A limited scope simulator can be used for training without NRC approval. It has not been 

discussed in detail as to what would be needed to allow the use of a limited scope simulator for 

the licensing exam. At a minimum, most plant systems would have to be operational on the 

simulator in much the same manner that the reactor vendors use a complete control room 

simulation for human factors engineering (HFE) testing. Any decision on the use of a limited 

scope simulator for the licensing exam would have to be after successful completion of HFE 

testing. 

For comment 8a, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

8a. This could also be achieved by hiring more instructors. If maintaining teams intact 

and maintaining student ratios is a problem, what other options, besides a 

process change, has industry explored? 

To be discussed at a future meeting. 

For comment 9, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

10. Is applicant stress really still an issue? Is this another way of saying that applicant 

stress is lower (and pass rate is higher) when examinations are not cumulative 

(applicants don’t have to pass a written exam and operating test within the same 

30 day period)? 

Several industry representatives felt that increasing the time between the written exam and the 

operating test would reduce the stress levels of candidates. Other industry representatives 

weren’t sure what the impact would be on candidates. It was said that maintaining candidates at 

the peak of their knowledge and ability would be a hardship, a stressor, and the period of time 

candidates are maintained at this peak needs to be reduced/modified. 

Any continuing training after the written exam would have to be conducted in a program and 

manner similar to the existing licensed operator requalification training programs. 

If the length of time between the written exam and the operating test is significant, for whatever 
4

reason, it may be possible to use a process for waiving a retake of the written examination prior 

to administration of the operating test in a manner similar to that used for the generic 

fundamentals examination. 

For comment 10, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

11. Is this a metric important to the NRC? 

Not discussed during the meeting. 

For comment 11, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

12. The current problem with ‘Uniform Conditions’ is in the area of requalification 

examinations, not initial licensing examinations. This does not appear to be a 

substantial benefit. 

Not discussed during the meeting. 

For comment 12, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

13. Although examination security is important, it does not appear to be a problem 

under the current process. This does not appear to be a substantial benefit. 

Not discussed during the meeting. 

For comment 13, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

14. This appears to be a policy decision that has yet to be made. What value does this 

option have, for whom, and under what circumstances? The GFE is largely ‘open’ 

with a portion of new questions on each examination. 

Licensing exams are currently entered into ADAMS as a publicly available document. The 

industry would need to identify something in or about the exam that would allow the exam to be 

withheld. However, even if the exam is withheld, a freedom of information act request could 

result in the release of exam questions. The question of a closed exam bank is also being 

discussed in the Operating Reactor Operator Licensing Focus Group; OGC is looking at the 

issue including how long the exam could be kept out of ADAMS. The current GFE guidance is 

that a GFE exam can include 80% previously used questions. Analysis of GFE exam data 

reveals that candidate performance is better on those questions that are repeated. 

For comment 13a, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 
5

Position Paper” (ML093510901). 

13a. The organization of this section is confusing. Which items are risks and which are 

mitigating actions? 

Not discussed during the meeting. 

For comment 14, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

15. What is the potential impact of a decrease in exam validity? How does this 

translate to risk? 

Not discussed during the meeting. 

For comment 15, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

16. Specifically, what is the point of the analogy? How are pilots, and pilot training 

programs, similar to and different from, nuclear plant operators and nuclear 

plants? Were other analogous situations explored that might indicate that a 

process change is not warranted? 

The industry is trying to show that separation of written and practical examinations is used in 

other highly regulated industries. The industry feels this is a reasonable analogy. 

For comment 16, refer to page 3 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

17. Whose procedures? Who approves the procedures? 

Not discussed during the meeting. 

For comment 71, refer to page 4 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

18. This appears to be a policy decision. Do we want to eliminate a stakeholder’s 

ability to appeal the outcome of a new process with no track record? 

To allow candidates to appeal the results of their examination, an NRC Form 398 will be 

submitted. 

For comment 18, refer to page 4 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 
6

19. Interesting language that labels continuing license training a burden. What will be 

the training content without a simulator? 

Not discussed during the meeting. 

For comment 19, refer to page 4 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

20. What is the nature of the commitment, how will it be enforced, and for how long? 

How much deviation is too much and then what? 

It is recognized that under existing 1021, common exams are possible. A common exam would 

require increased cooperation between both utilities and the NRC. The first few exams will use 

a common licensing basis for exam development. After using the process for the first several 

exams, an evaluation would be conducted to ensure the industry level of cooperation is being 

maintained and the plants remain standardized. An incentive to maintain standardization and to 

continue to cooperate is the plan to store training materials on a common server. Maintaining 

common materials should make the exam approval faster. 

For comment 20, refer to page 5 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

21. What do impartial educational psychologists know about this? 

The industry agreed to contact educational psychologists/specialists from outside the nuclear 

industry to determine the impact on a candidate of a time separated examination. 

For comment 21, refer to page 6 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

22. What are the benefits/costs of a ‘5% license’ vs. the proposed process change? 

Why would this require rulemaking? 

Not discussed during the meeting. 

For comment 22, refer to page 7 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

23. The action doesn’t directly address the potential risk/concern. Although the 

proposed process may not conflict with 10CFR55, it may not be a change that is in 

the best interests of all stakeholders. What is the basis for the assertion that 

segmenting does not reduce validity? Since the proposal to segment is a new 

process, would there be any evidence based on historical data? 

The industry does not have data available at this time. It is possible that the educational 

psychologists/specialists from outside the nuclear industry may have data of this sort, especially 
7

the FAA. At a minimum, continuing training during the time between the written exam and the 

operating test would be necessary. 

For comment 23, refer to page 7 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

24. Which process would be permanently revised? New reactors only or new and 

existing (10CFR50) reactors? 

This new process would be only for new reactors. The industry is proposing adding the process 

to a new reactor section of NUREG 1021. The process would be in effect as long as the 

common design is common and divergence is minimized. Ending use of a common examination 

would be dependent upon the gap between the standard design and the actual design. Major 

differences would probably be noticed first in training. 

For comment 24, refer to page 13 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

25. Why should retake necessarily occur before denial? 

By submitting NRC Form 398, retakes will only occur after denial. 

For comment 25, refer to page 14 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

26. One option would be to define “active” differently before and after fuel load (e.g. 

for less than 5% and above 5%). 

This will be discussed internally. 

For comment 26, refer to page 14 of Enclosure 3, “Comments on Operator Licensing Process 

Position Paper” (ML093510901). 

27. Is written examination quality criteria part of the revised process? Written 

examination quality guidelines would not appear to be applicable to the proposal 

to extend the time between the written exam and operating tests to 24 months, i.e. 

outside the scope of this position paper. 

Written examination quality criteria would continue to be part of the exam development process. 
8

DISTRIBUTION: Summary of December 2, 2009, Meeting with the Industry Focus Group on 

New Reactor Operator Licensing 

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Mr. Anthony Pietrangelo, Senior Director 

Risk Regulation 

Nuclear Energy Institute 

1776 I Street, NW, Suite 400 

Washington, DC 20006-3708 

Mr. H. A. Sepp, Manager 

Regulatory and Licensing Engineering 

Westinghouse Electric Company 

P. O. Box 355 

Pittsburgh, PA 15230-0355 

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Nuclear Energy Institute 

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Washington, DC 20006-3708 

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Washington Operations 

ABB-Combustion Engineering, Inc. 

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