NRC QUESTIONS AND COMMENTS ON OPERATOR LICENSING 

PROCESS POSITION PAPER 
NEI New Plant Training Task Force

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 simul ' erbate the peak

demand for licensed operator examinations. Consequently, the nuclear In us ry IS '11:(

recommendin alternatIves a e operator licensing process. Proposed altern s

rncu e exibility in the sequ n en an rating 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 "surqe" 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

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NEI New Plant Training Task Force

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 trainin ro ram. In addition the delay in the availabili 0

plant referenced simulator ay cause 0 erating exams for a aC1 1 to e conducted

ithin one year ail so, instructor resources may be inadequa 0 e c Ive y

deve 0 exam, Ions an re are license candidates for N C exams. Consequen ,

e 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:

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 sHe specific examination

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

increased from 30 days to 24 months. -b

• Site s eciflc written aintai&h q~ ile minimizing

resource constraints on both the NRC nd facility licensees.

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NEI New Plant Training Task Force

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

limited scope simulator for operatin 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 tact throughout the program and

allows tudent ratios to be maintained an optimum level throughout the

program t us Improving raining e Iveness .Jk.

Hows candidates to be tested in sequence with the training program thu 8

educing candidate stress "'if::-

2. Allow s.ft.e specific written examinations to be developed, approved, and /'

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

•

•

•

nhances the 'Uniform Condition' clause of the Atomic Energy Act

Fewer exams to develo

concerns

• Reduces licensee resources devoted to "development of 5ite-specific

written examination

• Provides opportunities to develop a 'closed' exam bank

--!:o \5

Proce ss Change Risks and Mitigating Strategies --F\ A1. 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. -.lb.

• May decrease comprehensive examination va li l4

• urr the FAA allows p to 2 years between the written examination

a pilot ratin and the operational examination.Increases difficulty of

mam ination section content overlap within acceptable limits

_____ );;> nation development procedure§> would be reviewed and

".-- up aled as necessary to ensure exam developers reviewed all

applicable exams to maintain overlap within acceptable limits

• May increase difficulty of maintaining examinaJion $.ecurity

Examination security procedure would be reviewed and

up s necessary 0 account for the revised process

• Reduced opportunity for license candidates to appeal results of the

written examination

);;> Under this proposal, license candidates would take the sitespecific written examination before formally applying for a

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•

NEI New Plant Training Task Force

_ Ii--

license, thusG;::e:-::n=e=e:d-:f:o=-r-:a::p::p::e:::a:ls:-::w:::o::U:;ld;-;b::e:-::e"li=m"in"'a"t"e"dj If a

candidate failed the exam the candidate could retake an exam

after remediation.

Increase training burden on utilities from earlier placement ofJicensed

operator can In a c tinuing training program _ -tt-(8 ,. License candidates w Id be in an 0 erator license continuin

trainin ro ram within a days of taking the site-speci IC written

exam. y ptan 0 rm ra e con mumq rammq

p am 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

,. Examination security procedures would be reviewed and

- --__'>.-':u~p~d:at~e:d~asnecessary to account for the revised process

standardized examination reference material

,. 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.

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NEI New Plant Training Task Force

Potential Risk/Concern Rezulatorv Basis Action

The uniform conditions 10 CFR 55.33 and 10 CFR The industry is proposing that

requirement of the 55.35 provide the regulation the written examination be

Atomic Energy Act regarding license administered before a candidate

would need to be applications and re- applies for a license. The

explored. The longer applications. 10 CFR processes would be ana logous

gap allow could 55.35(a) provides time to the GFE. The faci lity would

provide candidates the frames for re-applying if an certify that the candidate is

ability to appeal if their application is denied. 10 enrolled in an operator license

utility chose not to CFR 55.35(b) provides training program . A candidate

allow the full 2 year permission to retake only would have the option of

gap while another those parts of the retaking a written exam after

utility chose to allow examina tion that were remediation, but would not have

the full 2 year gap. failed, but does not provide rights of appeal since no denial

a limit on time . 10 CFR letter would have been issued.

2.103(b)(2) provides that an The concept is that the process

applicant may appeal a for the GFE would be expanded

denial within 20 days of to the entire written exam .

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

How would an See above See above

examination fai lure be

remedia ted? <,

The NRC had a N/A ( Would require rulemaking and

commen t or rulemaking is outside the scope

suggestion to consider of this position paper / a license good below

5% power and then

take a comprehensive

examination prior to

exceeding 5%.

The application form Application forms are 398 398 needs to be revised to

would need revision to and 396 which are incorporate NEI 06-13A

match the white paper referenced through out 10 provisions and would potentially

process. CFR 55 need additional modification for

the proposed revisions

reoardino the written exam.

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NEI New Plant Training Task Force

Potential Risk/Concern Reeulatorv Basis Action

The white paper needs 10 CFR 55 NUREG 1021 [The proposed process does not

to consider and references Chapter 11 of 'N;onflict with 10 CFR 55,;""

address the risk the 1985 version of the risk IS that tne on"""

associated with a Stan t---. dards for Educational process would reduce the

common examination and Psychological Testing evaluation validitv. T here is n~

and a 2 year gap that segmenting the

extension. As written it qualification process redUCeS)

only acknowledges the validity of the process

benefits.

What will be the 10 CFR 55 and 10 CFR The process would be

appeal rights of the 2.103(b)(2) analogous to the GFE process

applicant in bulk and since the written exam

examinations? would be administered before

Considering the an application was made, no

examination could appeal process would exist

impact several utilities.

The white paper needs 10 CFR 55.41 and 10 CFR The degree of standardi zation

to consider the make- 55.43 provide regulations within the new plant vendor

up of the examination. regarding written exam design is expected to be high.

content. NUREG 1021 The examination would continue

Sections 401, 402, and 403 to contain all elements of the

implement the requirements existing exams and be in

of 10 CFR 55.41 and 10 compliance with the regulations.

CFR 55.43

Will the use of a 10 CFR 55 The industry proposals will not

common examination require a rule change

require a rule change?

The NRC prefers to

avoid rule changes for

the common

examination.

When would this NA The industry proposes that this

common examination process become effective in

process become 2013 and h~ treated as .

effective and when or permanent revision "'+ Iwould it be retired? to the process.

Who would write the 10 CFR 55.40(b) allows the The industry proposes to write,

examination ? The facility to prepare, administer, and grade the

white paper does not administer, and grade the written exam.

address how the written examination.

examination would be NUREG 1021 Section 401,

developed and 402, and 403 implement the

approved . reqU~~b~ nts of 10 CFR

55.40 b

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NEI New Plant Training Task Force

Regulatory An alysi s

1954 Atomic Energy Act

Section 107, Operators' Licenses, of the 1954 Atomic Energy Act states;

TheCommission shall:

a. prescribe uniform conditionsfor licensing individuals as operators of any of the

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

b. determine the qualificationsof such individuals;

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

and

d. suspend suchlicenses for violations of any provisionof thisAct or any rule or

regulation issued thereunder whenever the Commission deemssuchaction

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

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 Ana lysi s

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 ofPersonnel 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, descrioes 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

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NEI New Plant Training Task Force

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 app licable 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, Medica! Evaluation of Ucensed Personnel at Nuclear Power

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

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

or renewal of operator or sen ior operator licenses for nuclear power plants and for

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

not app ly to the written portion of the operator license examination process.

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

Pressurized Water Reaclors , provides the basis for the development of conten t-valid

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

The examinations developed using the PWR Cata log 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 Regula tions , 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 tech nological 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 Reaelors, provides the basis for the development of conten t-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 exam s, 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

person nel for reviewing training programs at nuclear power plants to verify comp liance

with the requirements of 10 CFR 50.120 and 10 CFR 55 as appli cable. 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 exam ination 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 d arification

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NEI New Plant Train ing Task Force

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

information about written exam inations 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 Ucens;ng Exam;naUon Standards For Power Reactors,

establishes the policies, procedures, and practices for examin ing 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 Affected Basis

Required Subsections

List of Possible NA The list should be

abbreviations reviewed after mark-ups of

the NUREG are

completed to determine if

chances are required

ES-101 Purpose And No NA NA

Format

Of Operator

Licensing

Examination

Standards

ES-102 Regulations and Yes 4; xx; yy 4 - For Part 52 licenses

Publications requalification must

Applicable to commence 90 days after

Operator Licensing fuel load. xx and yy -

Need to be updated to

reflect new KA catalogs

for advanced passive light

water reacto rs.

ES-201 Initial Operator Yes C.3.j If the written exam date is

Licensing separated from the

Examination operating test by more

Process than 30 days - NRR

program office must

approve

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NEI New Plant Training Tas k Force

Section Title Revision Affected Basis

Reuuired Subsections

ES-202 Preparing and Yes B; C.1.a ; B Update to reflect cold

Reviewing C.1.b ; D.4 license process; C.1.a -

Operator Licensing 398 to be used - propose

Applications 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 add ress

written exam failure retake

process - medical exam

now or later? C.1.brevise to provide tha t

applying for a written

exam within 24 months of

GFE satisfies this section;

0 .4 - Cold license

eligibility should reference

NEI 06-13A

ES-204 Processing No NA NA Waivers app ly to

Waivers Req uested individual candidates and

By Reactor not to the process itself.

Operato r and

Senior Reactor

Operato r

Aoolicants

ES-20S Procedures for No NA NA may want to use this

Administering the secti on as a model for

Generic administering gen eric

Fundamentals vendor related written

Examination examinations

Proaram

ES-3 01 Preparing Initial Yes D.1.g D.1.g suggests the

Operating Tests operating test should be

conducted on both units of

a multi-urnt site - difficult

to do as second unit may

be several years behind

initial unit - should not be

an issue due to leve l of

standardization

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NEI New Plant Training Task Force

Section Title Revision Affected Basis

Reoulred Subsections

ES-302 Administering No NA NA

Operating Tests to

Initial License

Aoolicants

ES-303 Documenting and No NA NA

Grading Operating

Tests

ES-401 Preparing Initial Yes B; C.2.b B Background suggests

Site-Specific the written exam is given

Written in two sections - GFE and

Examinations site specific. We may be

adding a third - generic

vendor type written. C.2.b

- only allows 30 day

margin between written

and ooeratina exams

ES- 403 Grading Initial Site- No NA NA

Specific Written

Examinations

ES-501 Initial Post- Yes B 8 - Goal of the NRC is to

Examination complete licensing or

Activities denial within 30 daysof

grading exam. This

section should be modified

to meet the provisions of

NEI06-13Awhich

provides forthe 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 Yes B B - General re-write

Requests for voecause review and/or reAdministrative take 01 theWB/

Reviews and should occur before

Hearings after denial

Initial License

Denial

ES-601 Conducting NRC No NA NA

Requalification

Examinations

ES-602 Requalification No NA NA

Written

Examinations

ES-603 Requalification No NA NA

Walk-Through

Examinations

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NEI New Plant Training Task Force

Section Title Revision Affected Basis

Recuired Subsections

ES-604 Dynamic Simulator No NA NA

Requalification

Examinations

ES-605 License Yes C.2 C.2 It is not clear how

Maintenance, o ·11 maintain

License Renewal c active Ii n s ·uel

Applications, and IVGlU . • ..;::, section should

Requests for be clarified for cold

Administrative licenses.

Reviews and

Hearinqs

ES-701 Administration of No NA NA

Initial Examinations

for Senior

Operators Limited

to Fuel Handline

ES-702 Administration of No NA NA

Requalification

Examinations for

Senior Reactor

Operators Limited

to Fuel Hanonnc

Appendix A Overview of Yes All Some of the concepts in

Generic this section contribute to

Examination the differences between

Concepts the NRC and the industry

regarding the difficulty

level of written

examinations.)This

~ctlon should receive a

comprehensive and cross

disciplinary review and

comments should be

l orovided to the NRC )

Appendix B Written Yes All I sorne UI In

Examination this section contribute to

Guidelines the differences betwee n

the NRC and the industry

regarding the difficulty

level of written

examinationsflhis

V'§ection should receive a :tl

comprehensive and cross

disciplinary review and

comments should be

l nrovided to the NRC ./

<,

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NEI New Plant Training Task Force

Industry Standards AnalysIs

Section Title Revision Affected Basis

Required Subsections

Appendix C Job Performance No NA NA

Measure

Guidelines

Appendix D Simulator Testing No NA NA

Guidelines

Appendix E Policies and No NA NA

Guidelines for

Taking NRC

Examinations ..

Glossary Possible NA The list should be

reviewed after mark-ups of

the NUREG are : cOmpleted to determine if

chances are required

-. . :~ y

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, operatorss and technicians). RG 1.8,

Revision 3 (May 2000) endorses ther, 1993 version of tli is standard, with additions,

exceptions, and clarifications thereto. 'ANS 3.tis currentfY:/ being revised under the

sponsorship of NEI and the proposed chanqes.would notimpact issues discussed in this

position paper. . :: " "",;/

ANSI/ANS 3.4-1 996;: Medical rtifica Monitoring of Personnel Requiring

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

health and disquali fying -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 issuesd iscussed in this position paper.

ANSIIANS 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 ctarlflcatlonss ANS 3.5 is currently under revision but is not expected to

impact issues discussed in this position paper.

Training GuidancelAccreditation 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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NEI New Plant Training Task Force

• 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 typesonjne same day.

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

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

requirements of 10 CFR 55.wO'-!td be met for-the portion of the examination

process completed. ' .

The existing operator licensing and training process Is Attachment A and the

proposed operator Iice si ga~d 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 'N RC to address NRC concerns, draft revrsrons of

guidance documents, and support any eQ public comment and review. -. "," , "

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

16
Attachment A

NEI New Plant Training Task Force

Existing License Training and Exarrihlation Process

Fundamentals

Training

Classroom. OJT.

Simulator, and

ReviewTraining

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.

I I 'c' , . c I I ".;' , .... __ . ' f.

5 months 18 months 30 days

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17
Attachment B

NEI New Plant Training Task Force

Proposed License Training and Exam~nation Process

I 5moo~, I 24~"~. I

Fund~mentals

Training

OJT, Simulator,

Plant Experience, I .. C

and Review

Training

Classroomand

Umlted Simulator

Tmlnlng and Plant

experience

>----wPlant Experience If

Necessary

'. I I I I Up 1024moo~ montns I

'IL - -.--- - - - - - - , .;...'

Continuing Training

18