ML092520457 

UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

OFFICE OF NUCLEAR REACTOR REGULATION 

WASHINGTON, DC 20555-0001 

September 30, 2009 

NRC INFORMATION NOTICE 2009-21 INCOMPLETE MEDICAL TESTING FOR 

LICENSED OPERATORS 

ADDRESSEES 

All holders of operating licenses for nuclear power reactors and research and test reactors, 

except those who have permanently ceased operations and have certified that fuel has been 

permanently removed from the reactor vessel. 

PURPOSE 

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform 

addressees of recent examples where facility licensees did not meet NRC medical requirements 

for applicants and holders of reactor operator and senior operator licenses (referred to 

collectively as licensed operators from here forward). The NRC expects that recipients will 

review the information for applicability to their facilities and consider actions, as appropriate, to 

avoid similar problems. Suggestions contained in this IN are not NRC requirements; therefore, 

no specific action or written response is required. 

DESCRIPTION OF CIRCUMSTANCES 

Several recent examples have occurred where licensed operators did not meet NRC medical 

requirements because the facility licensee failed to adequately perform the required medical 

testing specified in American National Standards Institute (ANSI)/American Nuclear Society 

(ANS)-3.4, “Medical Certification and Monitoring of Personnel Requiring Operator Licenses for 

Nuclear Power Plants.” The examples are as follows: 

• In August 2009, a power reactor facility licensee identified that it had not completed the 

olfactory sensitivity and neurological testing specified in ANSI/ANS-3.4 for its licensed 

operators. Specifically, the olfactory sensitivity testing verifies the ability to detect the odor 

of combustion products and of tracer or marker gases; the neurological testing verifies that 

tactile discrimination is sufficient to distinguish among various shapes of control room knobs 

and handles by touch. The facility licensee implemented immediate corrective action by 

testing its operators before they were allowed back on shift. 

• In July 2009, at a second power reactor facility, an NRC inspector identified that the facility 

licensee had not performed tactile discrimination testing on all licensed operators. The 

facility licensee took action to ensure that its licensed operators were adequately tested and 

the site physician reviewed and documented all results. All licensed operators were 

satisfactorily tested with no failures. 
IN 2009-21 

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• In August 2008, at a third power reactor facility, NRC inspectors identified that some 

licensed operators had not received an electrocardiogram (ECG) test as part of their 

biennial medical examination. After a thorough review, the facility licensee identified several 

additional licensed operators who had not received an ECG during their last physical 

examination. The facility licensee promptly scheduled the required tests and verified that 

licensed operators for the oncoming shift had received complete biennial medical 

examinations. 

BACKGROUND 

Related NRC Generic Communications

• NRC IN 2004-20, “Recent Issues Associated with NRC Medical Requirements for Licensed 

Operators,” dated November 24, 2004, Agencywide Documents Access and Management 

System (ADAMS) Accession No. ML042510509). 

• NRC IN 1994-14, “Failure to Implement Requirements for Biennial Medical Examinations 

and Notification to the NRC of Changes in Licensed Operator Medical Conditions,” dated 

February 24, 1994 (ADAMS Accession No. ML031060622), and Supplement 1 dated April 

14, 1997 (ADAMS Accession No. ML031060468). 

• NRC IN 1991-08, “Medical Examinations for Licensed Operators,” dated February 5, 1991 

(ADAMS Accession No. ML031190668). 

DISCUSSION 

The regulations in Title 10 of the Code of Federal Regulations (10 CFR) Section 55.21, “Medical 

examination,” require every NRC-licensed operator to be examined by a physician every 

2 years. The purpose of this examination is to determine if the individual meets the 

requirements of 10 CFR 55.33(a)(1), “Health,” which states that the operator’s (or applicant’s) 

medical condition and general health will not adversely affect the performance of assigned 

operator duties or cause operational errors that could endanger public health and safety. 

Furthermore, 10 CFR 55.23, “Certification,” specifies that an authorized representative of the 

facility licensee shall complete and sign NRC Form 396, “Certification of Medical Examination 

by Facility Licensee,” to certify the licensed operator’s medical fitness every time he or she 

submits a license application (i.e., for a new license under 10 CFR 55.31, “How to apply,” or to 

renew an existing license under 10 CFR 55.57, “Renewal of licenses”). By signing NRC Form 

396, the facility licensee certifies that (1) the guidance in ANSI/ANS-3.4 was followed in 

determining the medical fitness of an operator for power reactors, or (2) the guidance in 

ANSI/ANS-15.4, “American National Standard for the Selection and Training of Personnel for 

Research Reactors,” was followed in determining the medical fitness of an operator for nonpower reactors. If the guidance in these documents was not used, a facility licensee may certify 

that an alternative method was used, and the NRC will consider the acceptability of that method. 

The NRC relies upon the facility licensee’s certification against an accepted medical standard to 

make a finding that a licensed operator's medical condition and general health will not adversely 
IN 2009-21 

Page 3 of 3 

affect performance of assigned operator duties or cause operational errors that may endanger 

public health and safety. 

The 1983 and 1996 versions of ANSI/ANS-3.4, which the NRC endorsed with Revisions 2 and 3 

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

Plants,” describe a number of specific operator health requirements and disqualifying 

conditions. In addition, these ANSI/ANS standards delineate specific minimum capacities 

required for medical qualification. The ANSI/ANS standards also specify medical tests and 

evaluations required to appropriately determine the medical fitness of licensed operators. If an 

operator license applicant’s health does not meet the minimum standards, the facility licensee 

may still certify that the individual’s health is satisfactory for licensing if it is possible to 

compensate for the individual’s medical condition. However, in such cases, the facility licensee 

must request a conditional license in accordance with 10 CFR 55.23(b) and submit the 

appropriate medical evidence for evaluation with NRC Form 396. Following 10 CFR 55.33(b), 

“Conditional license,” and 10 CFR 55.57(b), “Renewal of licenses,” as applicable, the NRC will 

review the license application based on the facility licensee’s certification and include any 

conditions on the license that might be necessary based on the facility licensee’s 

recommendation and the supporting medical evidence. 

CONTACTS 

Please direct any questions about this matter to the technical contacts listed below. 

 /RA/ 

Timothy J. McGinty, Director 

Division of Policy and Rulemaking 

Office of Nuclear Reactor Regulation 

Technical Contacts: Sam Hansell, RI Malcolm Widmann, RII 

 610-337-5046 404-562-4550 

 E-mail: sam.hansell@nrc.gov E-mail: malcolm.widmann@nrc.gov 

 Hironori Peterson, RIII Ryan Lantz, RIV 

 630-829-9707 817-860-8159 

 E-mail: hironori.peterson@nrc.gov E-mail: ryan.lantz@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, 

http://www.nrc.gov, under Electronic Reading Room/Document Collections. 
IN 2009-21 

Page 3 of 3 

affect performance of assigned operator duties or cause operational errors that may endanger 

public health and safety. 

The 1983 and 1996 versions of ANSI/ANS-3.4, which the NRC endorsed with Revisions 2 and 3 

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

Plants,” describe a number of specific operator health requirements and disqualifying 

conditions. In addition, these ANSI/ANS standards delineate specific minimum capacities 

required for medical qualification. The ANSI/ANS standards also specify medical tests and 

evaluations required to appropriately determine the medical fitness of licensed operators. If an 

operator license applicant’s health does not meet the minimum standards, the facility licensee 

may still certify that the individual’s health is satisfactory for licensing if it is possible to 

compensate for the individual’s medical condition. However, in such cases, the facility licensee 

must request a conditional license in accordance with 10 CFR 55.23(b) and submit the 

appropriate medical evidence for evaluation with NRC Form 396. Following 10 CFR 55.33(b), 

“Conditional license,” and 10 CFR 55.57(b), “Renewal of licenses,” as applicable, the NRC will 

review the license application based on the facility licensee’s certification and include any 

conditions on the license that might be necessary based on the facility licensee’s 

recommendation and the supporting medical evidence. 

CONTACTS 

Please direct any questions about this matter to the technical contacts listed. 

 /RA/

Timothy J. McGinty, Director 

Division of Policy and Rulemaking 

Office of Nuclear Reactor Regulation 

Technical Contacts: Sam Hansell, RI Malcolm Widmann, RII 

 610-337-5046 404-562-4550 

 E-mail: sam.hansell@nrc.gov E-mail: malcolm.widmann@nrc.gov 

 Hironori Peterson, RIII Ryan Lantz, RIV 

 630-829-9707 817-860-8159 

 E-mail: hironori.peterson@nrc.gov E-mail: ryan.lantz@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site, 

http://www.nrc.gov, under Electronic Reading Room/Document Collections. 

ADAMS Accession Number: ML092520457 

OFFICE IOLB TECH EDITOR BC:IOLB:DIRS D:DIRS 

NAME SGuenther CHsu JMcHale FBrown 

DATE 9/16/09 9/11/09 by e-mail 9/16/09 9/17/09 

OFFICE PGCB:DPR PGCB:DPR BC:PGCB:DPR D:DPR 

NAME DBeaulieu CHawes MMurphy TMcGinty 

DATE 9/29/09 9/30/09 9/30/09 9/30/09 

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